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PRIVACY NOTICE FOR HEALTHCARE PROFESSIONALS AND CONGRESS CONTACTS

Last updated: 10/2026

This Privacy Notice explains how Actial Farmaceutica Srl, with registered office at Via Shakespeare 47, 00144, Rome, Italy (“we”, “us” or the “Company”), collects and processes personal data relating to healthcare professionals and other professional contacts, including individuals who interact with us at congresses, conferences, exhibitions and other professional events.

1. Data Controller
The data controller is:
Actial Farmaceutica Srl,
Via Shakespeare 47, 00144, Rome, Italy
Email: info@vsl3pharma.com
For any questions regarding this Privacy Notice or the processing of your personal data, you may contact us at the email address above.

2. Personal Data We Collect
We may collect personal data that you provide to us directly, including when your congress badge or contact details are scanned at our exhibition stand.Such data may include:

- first name and last name;
- professional title and role;
- healthcare institution or organisation;
country;
- professional email address;
- professional telephone number;
- professional field or specialty;
- information contained in your congress badge or - registration profile;information concerning your professional interests in our products or services.

3. Purposes of Processing
Where you have provided your consent, we may process your personal data for marketing and professional communication purposes, including:
contacting you regarding our products and services;
- providing scientific, educational, commercial or promotional information relating to our products;
- following up on your interaction with us at congresses, conferences or other professional events;
- inviting you to relevant professional events, meetings or presentations;
- sharing your contact details with our authorised distributor responsible for your country so that the distributor may contact you for the same marketing and professional communication purposes.

4. Legal Basis
The legal basis for the processing described above is your consent, pursuant to Article 6(1)(a) of Regulation (EU) 2016/679 (“GDPR”).
Where required under applicable electronic marketing laws, your consent will also constitute the legal basis for receiving marketing communications by email or other electronic means. Providing consent is voluntary. Refusal to provide consent will not affect your ability to visit our stand, receive information requested by you at the event, or otherwise interact with us.You may withdraw your consent at any time.Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.

5. Sharing of Personal Data with Local Distributors
In order to ensure that marketing and professional communications are handled by the appropriate local commercial organisation, we may share your personal data with the authorised distributor responsible for your country or territory.Our current distribution partners include:

Country Distributor
Poland: Adexilis, Medezin
United Kingdom: Nordic Pharma Limited
Czech Republic, Slovakia, Hungary, Romania, Bulgaria, Croatia, Serbia, Slovenia: Adexilis 

The relevant distributor may use your personal data for the marketing and professional communication purposes described in this Privacy Notice.Depending on the contractual and operational arrangements applicable in the relevant territory, the distributor may process personal data either on behalf of Actial Farmaceutica Srl or as an independent data controller. Where a distributor acts as an independent data controller, its processing activities will also be governed by its own privacy notice and applicable data protection laws.For further information regarding the distributor applicable to your country, you may contact us at info@vsl3pharma.com.

6. International Transfers
Some of our distributors or service providers may be located outside the European Economic Area (“EEA”) or may process personal data from countries outside the EEA. Where personal data is transferred outside the EEA, we will ensure that the transfer is carried out in accordance with applicable data protection legislation and, where required, appropriate safeguards are implemented, such as an adequacy decision of the European Commission or the European Commission Standard Contractual Clauses.Further information regarding applicable safeguards may be requested by contacting info@vsl3pharma.com

7. Data Retention
We will retain your personal data for as long as reasonably necessary for the marketing purposes described above and while your consent remains valid.Unless a shorter period is required by applicable law or our internal policies, marketing contact information will be periodically reviewed and deleted or anonymised when it is no longer required. If you withdraw your consent, we will stop processing your personal data for the relevant marketing purposes and will retain only the information necessary to document your withdrawal and comply with applicable legal obligations.

8. Your Rights
Subject to the conditions provided by applicable data protection legislation, you may have the right to:
- request access to your personal data;
- request correction of inaccurate or incomplete personal data;
- request deletion of your personal data;
- request restriction of processing;
- receive your personal data in a structured, commonly used and machine-readable format where the right to data portability applies;
- withdraw your consent at any time;
- object to processing where applicable;lodge a complaint with the competent data protection supervisory authority.

To exercise any of these rights or withdraw your consent, please contact: info@vsl3pharma.com

9. Marketing Communications
You may stop receiving marketing communications at any time by:using the unsubscribe mechanism included in our electronic communications, where available; orcontacting us at info@vsl3pharma.com. Where your personal data has been shared with an authorised distributor, we will take appropriate steps to ensure that your withdrawal request is communicated to the relevant distributor where necessary.You may also exercise your rights directly with the distributor where that distributor acts as an independent data controller.

10. Security
We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.Access to personal data is limited to persons and organisations that require such access for the purposes described in this Privacy Notice.

11. Updates to this Privacy Notice
We may update this Privacy Notice from time to time, including to reflect changes to our distribution network, processing activities or applicable legal requirements.The most recent version will be available on our website and will indicate the date on which it was last updated.

12. Contact
For questions, requests or withdrawal of marketing consent, please contact:
Actial Farmaceutica Srl
Via Shakespeare 47, 00144, Rome, Italy
Email: info@vsl3pharma.com