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GEPHA (“us”, “we”, “APP”) is committed to protecting YOUR privacy and personal data. This Privacy Policy is

published in compliance with the law of Georgia on the “Personal Data Protection” and explains how we collect,

process, share and protect personal data and special categories of data of our registered users (“User”, “YOU”,

“YOUR”). It also describes YOUR choices regarding the use, access, correction, and deletion of YOUR personal

information.

If YOU do not agree with the data practices described in this Privacy Policy, YOU should not use Pharmadepot or

any other Services of GEPHA.

🞐 BY USING THIS APPLICATION (APP), YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD, AND

AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE

BOUND BY THE PRIVACY POLICY.

🞐 AFTER READING THIS DOCUMENT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING,

AND DISCLOSURE OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY.

🞐 IF YOU USE THE APPLICATION ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) YOU

REPRESENT THAT YOU ARE AUTHORISED TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH

INDIVIDUAL’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL TO OUR COLLECTION,

USE AND DISCLOSURE OF SUCH INDIVIDUAL’S INFORMATION AS DESCRIBED IN THIS PRIVACY

POLICY.

1. COLLECTION AND PROCESSING OF PERSONAL INFORMATION

GEPHA collects and processes personal data that is necessary to provide YOU with services and best meet YOUR

needs, health services or other providers, also only in aggregated or anonymized form for statistical analysis and

business intelligence purposes.

We respect YOUR privacy and therefore, Personal data undergoing processing is:

A. processed lawfully, fairly, and in a transparent manner;

B. collected for explicit, specified, and legitimate purposes and not processed in a way incompatible with those

purposes;

C. adequate, relevant, and not excessive in relation to the purposes for which they are processed;

D. accurate and, where necessary, kept up to date;

E. preserved in a form that permits identification of data subjects for no longer than is necessary for the purposes

for which those data are processed.

YOU hereby consent to the collection and processing of such information for the above-mentioned purposes by

GEPHA. Information collected and processed by us from YOU may include the following:

● YOUR first name and last name;

● Device that YOU use for APP;

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● YOUR residential address (Country, city and other details of address);

● Contact data (such as email address and phone number);

● Demographic data (such as YOUR gender and date of birth);

● YOUR ID number or number of any other identification document, issuing country;

● Information about a person for whom you decided to order at-home lab tests (first name, last name, personal

ID, citizenship, date of birth, sex and e-mail).

● Insurance data (such as YOUR insurance company, insurance policy data, insurance plea data, letter of

guarantee, insurance plan and insurance project);

● Information about pharmacy loyalty or reward cards;

● Health data – such as prescriptions, medications, appointments with doctor, etc.;

● First 6 or/and last 4 digits of Debit/credit card number, name and last name of card holder and unique code of

transaction;

● Medicine purchase history acquired via Pharmadepot;

● Payments transactions for services/products purchased via Pharmadepot;

● Other information that YOU voluntarily choose to provide to us (such as photo, height, weight, allergies, blood

group etc.).

2. PRIVACY STATEMENTS

2.1. YOU are responsible for maintaining the accuracy of the information YOU submit to us, such as YOUR

contact information provided as part of the account registration. If YOUR personal information changes, YOU may

correct, delete inaccuracies, or amend the information. We will make good faith efforts to make requested changes in

our then-active databases as soon as reasonably practicable. If YOU provide any information that is untrue, inaccurate,

out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or Pharmadepot has reasonable

grounds to suspect that the information provided by YOU is untrue, inaccurate, out of date or incomplete, We may

discontinue the provision of the Services to YOU according to the Georgian legislation.

2.2. If YOU wish to deactivate or cancel YOUR account or request that we no longer use YOUR information to

provide YOU Services, contact us through support@pharmadepot.ge. We may retain YOUR information for as long

as YOUR account with the Services is active and as needed to provide YOU the Services. We shall not retain such

information for longer than is required for the purposes for which the information may lawfully be used or is otherwise

required under law for the time being in force. YOUR data may be anonymized and aggregated, and then may be held

by us if necessary, for us to provide our services effectively, but our use of anonymized data will be solely for

analytic/statistical purposes. Please note that YOUR withdrawal of consent, or cancellation of account may result in

GEPHA being unable to provide YOU with its services or to terminate any existing relationship GEPHA may have

with YOU.

2.3. If YOU wish to opt-out of receiving non-essential communications such as promotional and marketing-related

information regarding the Services, please send us an email support@pharmadepot.ge

2.4. If YOU pay with a debit/credit card for medical services or healthcare products, we will collect such User’s

credit card number and/or other financial institution information such as bank account numbers and will use that

information for the billing and payment processes, including but not limited to the use and disclosure of such credit

card number and information to third parties as necessary to complete such billing operation. Verification of credit

information, however, is accomplished solely by the User through the authentication process. User’s credit-card/debit

card details are transacted upon secure sites of approved payment gateways which are digitally under encryption,

thereby providing the highest possible degree of care as per current technology.

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2.5. A User may have limited access to the service (e.g. searching medications) without providing ID number and

other personal data necessary to make appointments with the doctors, receiving prescriptions, discounts or letter of

guarantees from insurance companies. In order to have access to all the features and benefits on our APP, a User must

provide ID number and other relevant data that will be exchanged with our partner organizations/PROVIDERS for

verification.

2.6. This privacy policy applies to APP, software, products and services owned and controlled by Pharmadepot,

the owner of GEPHA (legal entity established and operating pursuant to the Georgian legislation, with Company #

201991229). YOUR use of and access to the Services is subject to this Privacy Policy, our terms and conditions as

well as other policies (If any). GEPHA does not exercise control over the sites displayed as search results or links from

within its Services. These other sites may place their own cookies or other files on the Users’ devices, collect data or

solicit personal information from the Users, for which GEPHA is not responsible or liable. Accordingly, GEPHA does

not make any representations concerning the privacy practices, nor do we guarantee the accuracy, integrity, or quality

of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on

such websites. If YOU decide to visit a third-party website linked, YOU do this entirely at YOUR own risk. GEPHA

encourages the User to read the privacy policies of third parties.

2.7. GEPHA implements reasonable security practices and procedures to protect the personal data that it has under

its control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction

or accidental loss. However, for any data loss or theft due to unauthorized access to the User’s electronic devices

through which the User avails the Services, GEPHA not be held liable for any loss whatsoever incurred by the User.

2.8. GEPHA implements reasonable security practices and procedures and has a comprehensive documented

information security program and information security policies that contain managerial, technical, operational and

physical security control measures that are commensurate with respect to the information being collected and the nature

of our business.

2.9. We take YOUR right to privacy and personal data protection very seriously and other than as specifically

stated in this Privacy Policy, will only disclose YOUR Personal Information in the event it is required to do so by law,

supervisory body or law enforcement agency or when GEPHA, in its sole discretion, deems it necessary in order to

protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to

enforce or apply the Terms of Use.

2.10. To the extent necessary to provide Users with the Services, GEPHA may provide Information to third-party

contractors who work on behalf of or with GEPHA to maintain the APP. In such circumstances, YOU consent to us

disclosing YOUR Personal Information to contractors, solely for the intended purposes only.

2.11. We make all User information accessible to its employees, agents or partners, and third parties only on a need-

to-know basis and bind our employees to strict confidentiality obligations.

2.12. YOU hereby agree, that medical institutions, insurance companies, and other PROVIDERS of GEPHA

(referred as – PROVIDERS) that you will choose to get service by Pharmadepot application, will process and share to

GEPHA your personal data, the processing/sharing of which is necessary in order to provide YOU with the Services.

The processing of the above-mentioned data will be made within the range and capacity, that is necessary to provide

YOU with proper Services considered by Pharmadepot.

2.13. Notwithstanding the above, GEPHA is not responsible for the confidentiality, security or distribution of YOUR

Personal Information by our partners and third parties outside the scope of our agreement with such

partners/PROVIDERS and third parties. Further, GEPHA shall not be responsible for any breach of security or for any

actions of any third parties or events that are beyond the reasonable control of GEPHA including but not limited to,

acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes,

breach of security and encryption, poor quality of Internet service or telephone service of the User etc.

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3. CHANGE TO PRIVACY POLICY

We may update this Privacy Policy at any time. In the event there are significant changes in the way we treat User’s

personally identifiable information, or in the Privacy Policy itself, we will display a notice on APP, so that YOU may

review the changed terms prior to continuing to use the Services. As always, if YOU object to any of the changes to

our terms, and YOU no longer wish to use the Services, YOU may contact support@pharmadepo.ge to deactivate

YOUR account. Unless stated otherwise, our current Privacy Policy applies to all information that GEPHA has about

YOU and YOUR account.

4. CONSENT TO THIS POLICY

YOU acknowledge that this Privacy Policy is a part of the Terms of Use of the APP and the Services, and YOU

unconditionally agree that becoming a User of the APP and its Services signifies YOUR (i) assent to this Privacy

Policy, and (ii) consent to GEPHA using, collecting, processing and/or disclosing YOUR Personal Information in the

manner and for the purposes set out in this Privacy Policy and the Terms of Use.

5. ADDRESS FOR PRIVACY QUESTIONS AND YOUR DATA PROTECTION RIGHTS

Should YOU have questions about this Privacy Policy or our information collection, use and disclosure practices, YOU

may contact us via our email support@pharmadepo.ge. We will use reasonable efforts to respond promptly to any

requests, questions or concerns, which YOU may have regarding our use of YOUR personal information.

In certain circumstances, YOU have the following data protection rights:

● The right to access, update or to delete the information we have on YOU. Whenever made possible, YOU can

access, update or request deletion of YOUR Personal Data directly within YOUR account settings section. If

YOU are unable to perform these actions yourself, please contact us to assist YOU.

● The right of rectification. YOU have the right to have YOUR information rectified if that information is

inaccurate or incomplete.

● The right to withdraw consent. YOU also have the right to withdraw YOUR consent at any time where GEPHA

relied on YOUR consent to process YOUR personal information. In case YOU no longer wish EKIMO to

process YOUR personal information, YOU can contact us on support@pharmadepo.ge. Such withdrawal of

the consent will trigger termination of YOUR Pharmadepot account.

Please note that we may ask YOU to verify YOUR identity before responding to such requests.