Privacy Policy
1. Data Controller Information
This Privacy Policy outlines how Incurepharma B.V. ("IncureA arma", "we", "us", or "our") processes, collects, and safeguards personal data when you visit our website, submit inquiries, or engage with our pharmaceutical wholesale distribution services.
Incurepharma B.V. operates as the Data Controller in respect of personal data processed under the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and the Dutch GDPR Implementation Act (Uitvoeringswet Algemene verordening gegevensbescherming - U@Tg).
Corporate Identity & Address:
Incurepharma B.V.
[REGISTERED ADDRESS]
[POSTAL CODE, CITY], Netherlands
Chamber of Commerce (KvK) Number: [NUMBER]
Email: privacy@[companyname].com
2. Categories of Data Collected
We process personal and corporate data collected directly from you or automatically during your interactions with our online portal:
- Contact Form & Inquiries: Full name, professional email address, corporate telephone number, job title, company name, pharmaceutical license number (WDA/Pharmacy/Hospital License), country of operation, and the content of your message.
- Account & Transactional Data: Commercial correspondence, requests for quotes (RFQs), distribution agreement records, billing addresses, and payment history.
- Technical & Usage Data: Internet Protocol (IP) address, browser type and version, operating system, time zone settings, referral URLs, page visit metrics, and system log files.
- Cookies & Telemetry: Essential operational cookies, user preference data, and anonymized website performance analytics.
3. Legal Basis for Processing
Under GDPR Article 6, we process personal data strictly under valid legal bases depending on the nature of the interaction:
| Processing Purpose | Data Category | Legal Basis (GDPR Art. 6) |
|---|---|---|
| Responding to contact form inquiries & RFQs | Contact & Company Info | Art. 6(1)(b) - Contractual necessity / Pre-contractual steps |
| Verifying B2B pharmaceutical license eligibility | Regulatory License Data | Art. 6(1)(c) - Legal obligation (GDP Regulations & EU Directives) |
| Executing supply chain & delivery operations | Transactional & Contact Data | Art. 6(1)(b) - Performance of a contract |
| Technical & IP Logs | Art. 6(1)(f) - Legitimate commercial interest | |
4. Data Retention Periods
Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, or to comply with statutory legal, tax, and pharmaceutical audit requirements:
- Contact Form Inquiries: Retained for a maximum of 24 months after the last active communication unless a business relationship is established.
- Contractual & Transaction Records: Retained for 7 years following the end of the fiscal year in compliance with Dutch commercial code and tax laws.
- Good Distribution Practice (GDP) Records: Product traceability and licensing verification records are stored for 5 to 7 years as mandated by European pharmaceutical laws.
- Analytics & Web Logs: Technical server logs are retained for 90 days; aggregated, anonymized analytics metrics are stored for up to 13 months.
5. Rights of Data Subjects
As a data subject located within the European Economic Area (EEA), you possess specific rights under Articles 15 through 22 of the GDPR:
- Right of Access (Art. 15): Obtain confirmation as to whether your data is being processed and receive a copy of your personal records.
- Right to Rectification (Art. 16): Request immediate correction of inaccurate or incomplete personal data.
- Right to Erasure / Right to be Forgotten (Art. 17): Request deletion of your personal data when it is no longer needed or when processing lacks a legal basis.
- Right to Restriction of Processing (Art. 18): Request temporary restriction of data processing during verification of accuracy or legal disputes.
- Right to Data Portability (Art. 20): Receive your personal data in a structured, commonly used, and machine-readable format for transfer to another controller.
- Right to Object (Art. 21): Object at any time to processing based on legitimate interests or direct marketing activities.
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting prior lawful processing.
To exercise any of these rights, please submit a written request to our Data Protection Officer at privacy@[companyname].com.
6. Data Protection Officer (DPO)
We have appointed a designated Data Protection Officer to monitor regulatory compliance and address all privacy-related inquiries:
DPO Contact Information:
Data Protection Officer
Incurepharma B.V.
Email: dpo@[companyname].com
Address: [DPO Contact Info / Corporate Address], Netherlands
7. Supervisory Authority
If you believe that our processeng of your personal data infringes applicable data protection laws, you have the right to lodge a formal complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):
Autoriteit Persoonsgegevens
PO Box 93374, 2509 AJ DEN HAAG, Netherlands
Telephone: (+31) - (0)70 - 888 85 00
Website: https://autoriteitpersoonsgegevens.nl
8. Data Security & Third-Party Transfers
We enforce robust technical and organizational security measures including TLS encryption, access controls, network firewalls, and pseudonymization to protect data against unauthorized access, loss, or alteration. Third-party cloud service providers and sub-processors operate strictly under Data Protection Agreements (DPAs). Any transfers outside the EEA are governed by standard contractual clauses approved by the European Commission.
Last updated: August 2026