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Personal Data Processing Policy

Revision dated 08 July 2026

1. GENERAL PROVISIONS

1.1.This Personal Data Processing Policy of Lamyra-Pharmacare LLC (hereinafter, the “Controller”) sets out the procedure for processing personal data of users of the https://lphc.by website, the purposes, scope, legal grounds and retention periods for personal data processing, as well as the rights of data subjects and the procedure for exercising those rights.

1.2. The personal data Controller is:

Limited Liability Company “Lamyra-Pharmacare”
Lamyra-Pharmacare LLC
Address: Minsk Region, Smolevichi District, Ozeritsko-Slobodskoy Rural Council, 10B, near the agro-town of Sloboda, Room 55.
Website: https://lphc.by
Email for personal data processing inquiries: info@lphc.by

1.3. This Policy has been developed in accordance with Law of the Republic of Belarus No. 99-Z dated 7 May 2021 “On Personal Data Protection”, as well as other legislative acts of the Republic of Belarus governing the processing and protection of personal data.

1.4. This Policy applies to personal data obtained by the Controller through the https://lphc.by website, including through the following forms:

  1. “Ask a Question”;

  2. “Become a Partner”;

  3. “Pharmacovigilance”;

  4. other Site forms, where they involve the provision of personal data by the user.

1.5. This Policy does not govern the processing of personal data of the Controller's employees, job applicants, counterparties and other persons within the Controller's internal processes where such processing is unrelated to use of the Site. Such processing is governed by separate internal documents of the Controller.

1.6. The terms used in this Policy have the meanings assigned to them by the Law of the Republic of Belarus “On Personal Data Protection”.

1.7. The Controller processes personal data only to the extent necessary to achieve specific, predetermined and lawful processing purposes.

The Controller does not collect personal data unrelated to the purposes of processing and does not require Site users to provide information that is not necessary to consider an inquiry, cooperation proposal or pharmacovigilance report.

1.8. Where personal data is processed on the basis of the data subject's consent, such consent shall be given before personal data processing begins.

When completing electronic forms available on the Site, consent is given by ticking the relevant checkbox before submitting the form.

By checking this box, the data subject confirms that they have read this Policy and consents to the processing of their personal data for the purposes specified for the relevant form.

1.9. Where consent is the required legal basis for personal data processing, the form cannot be submitted unless the relevant checkbox has been selected.

1.10. The Controller does not use personal data provided by users through Site forms to send advertising, marketing or other informational communications without obtaining the data subject's separate consent, where such consent is required by the laws of the Republic of Belarus.

1.11. This Policy is a publicly available document and is published on the https://lphc.by website.

2. TERMS AND ABBREVIATIONS

The following terms and abbreviations are used in this Policy:

Law – Law of the Republic of Belarus No. 99-Z dated 7 May 2021 “On Personal Data Protection”.

Controller – Limited Liability Company “Lamyra-Pharmacare”, which independently determines the purposes, scope, legal grounds and procedure for processing personal data of Site users.

Blocking of Personal Data – suspension of access to personal data without deleting it;

Site – the official website of Lamyra-Pharmacare LLC available on the Internet at: https://lphc.by.

User – an individual who visits the Site, uses its functionality, completes forms available on the Site, or otherwise interacts with Lamyra-Pharmacare LLC through the Site.

Form User – a person who submits an inquiry, question, request or message through a feedback form on the Site.

Data Subject – an individual whose personal data is processed.

Personal Data – any information relating to an identified individual or an individual who can be identified.

Personal Data Processing – any action or set of actions performed with personal data, including collection, systematization, storage, modification, use, depersonalization, blocking, dissemination, provision and deletion of personal data;

Data Subject Consent – a freely given, unambiguous and informed expression of the data subject's will by which they authorize the processing of their personal data.

Checkbox – a field on the Site in which the User independently places a check mark confirming that they have read this Policy and consent to the processing of personal data for the purposes specified for the relevant form.

Authorized Person – a person who, under an agreement with the Controller or on another legal basis, processes personal data on behalf of the Controller or in its interests.

Provision of Personal Data – actions aimed at making personal data available to a specific person or a specific group of persons.

Dissemination of Personal Data – actions aimed at making personal data available to an indefinite group of persons.

Special Personal Data – personal data concerning racial or national origin, political opinions, trade union membership, religious or other beliefs, health or sex life, administrative or criminal liability, as well as biometric and genetic personal data.

Cross-Border Transfer of Personal Data – transfer of personal data to the territory of a foreign state.

Cookies – small text files stored on the User's device when visiting the Site and used to ensure the operation of the Site, save user settings, analyze traffic and for other purposes specified in this Policy and the Cookie Processing Policy (link).

2.2. Other terms used in this Policy have the meanings assigned to them by the laws of the Republic of Belarus on personal data protection.

3. CATEGORIES OF DATA SUBJECTS

3.1. In connection with the operation of the https://lphc.by website, the Controller processes personal data of the following categories of data subjects:

Category of Data Subjects

Description

Website Visitors

Individuals who visit the https://lphc.by website, browse its pages, use its functionality and interact with the cookie banner.

Users of the “Ask a Question” Form

Individuals who submit an inquiry, question, request or message through the feedback form on the Site.

Users of the “Become a Partner” Form

Representatives of legal entities, individual entrepreneurs and organizations, as well as other persons interested in cooperation with Lamyra-Pharmacare LLC.

Users of the Pharmacovigilance Form

Healthcare professionals, consumers of medicinal products, patients, patient representatives and other persons submitting reports of adverse reactions or lack of efficacy of medicinal products.

Special Personal Data of Persons Identified in Pharmacovigilance Reports

Patients or other persons whose details may be included in a report of an adverse reaction or lack of efficacy of a medicinal product.

3.2. The Controller does not request passport details, bank details, information on marital status, information on social status, biometric personal data or other information through the Site that is not required for the operation of the relevant Site form.

3.3. If a user voluntarily provides additional personal data in the text of an inquiry, such data is processed only to the extent necessary to consider the relevant inquiry, cooperation proposal or pharmacovigilance report.

4. PURPOSES, SCOPE, LEGAL GROUNDS AND RETENTION PERIODS FOR PERSONAL DATA PROCESSING

4.1. The Controller processes personal data of Site users only for the purposes specified in this Policy.

The categories of personal data processed depend on the specific processing purpose and the Site form through which such data is provided.

4.2. The purposes, categories of data subjects, list of personal data processed, legal grounds and retention periods are determined as follows:

Purpose of Personal Data Processing

Category of Data Subjects

Personal Data Processed

Legal Basis for Processing

Processing / Retention Period

Ensuring operation of the Site, correct display of pages, security and technical support of the Site

Website Visitors

IP address, browser information, device information, date and time of visit, technical cookies, information on actions performed on the Site

Processing is carried out in cases provided for by the laws of the Republic of Belarus and to the extent necessary for operation of the Site

For the period necessary to ensure operation of the Site or for the retention period of the relevant technical cookies and technical logs

Use of functional and analytics cookies

Website Visitors

Cookie identifiers, information on user actions on the Site, pages viewed, technical information about the browser and device

User consent — where obtaining consent is required by the laws of the Republic of Belarus

For the lifetime of the relevant cookies or until the user changes their cookie settings

Handling an inquiry submitted through the “Ask a Question” form

Users of the “Ask a Question” Form

Name, email address, text of the inquiry and other information voluntarily provided by the user

Data subject consent

Until the inquiry has been reviewed and interaction with the applicant has been completed, unless a longer retention period is required by the laws of the Republic of Belarus

Considering a cooperation proposal submitted through the “Become a Partner” form

Representatives of prospective partners

Name, organization name, position if applicable, phone number, email address, content of the inquiry and other information voluntarily provided by the user

Data subject consent

Until the inquiry has been reviewed and interaction with the applicant has been completed, unless a longer retention period is required by the laws of the Republic of Belarus

Registration, review and follow-up of reports of adverse reactions or lack of efficacy of medicinal products submitted through the “Pharmacovigilance” form

Healthcare professionals, consumers, patients, patient representatives and other reporters

Reporter data; patient data where applicable; information on the medicinal product; information on the adverse reaction or lack of efficacy; other information voluntarily provided by the reporter

Requirements of the laws of the Republic of Belarus and acts of the Eurasian Economic Union governing medicinal product circulation and pharmacovigilance; data subject consent — where required by law

For the periods established by the laws of the Republic of Belarus and applicable pharmacovigilance requirements

Contacting the applicant to clarify information relating to an inquiry, cooperation proposal or pharmacovigilance report

Users of Site forms

Name, phone number, email address, content of the inquiry and information required for clarification

Data subject consent or other grounds provided for by the laws of the Republic of Belarus

Until interaction with the applicant is completed or for the period necessary to achieve the processing purpose

Compliance with the requirements of the laws of the Republic of Belarus and protection of the rights and legitimate interests of Lamyra-Pharmacare LLC

Users of the Site and Site forms

Personal data necessary to fulfill an obligation established by law or to protect the Company's rights and legitimate interests

Laws of the Republic of Belarus

For the periods established by the laws of the Republic of Belarus

4.3. The Controller does not process personal data for purposes incompatible with those specified in this Policy.

4.4. When personal data processing is no longer necessary, the personal data shall be deleted or depersonalized, except where further retention is required under the laws of the Republic of Belarus.

5. PROCESSING PERSONAL DATA THROUGH SITE FORMS

5.1.  General Conditions for Data Processing through Site Forms

The https://lphc.by website contains electronic forms through which a user may submit an inquiry, cooperation proposal or pharmacovigilance report to the Controller.

These forms include:

  • the “Ask a Question” form;

  • the “Become a Partner” form;

  • the “Pharmacovigilance” form.

Personal data provided through Site forms is used only for the purposes for which the relevant form is intended.

The Controller does not use personal data obtained through Site forms for other purposes, including the sending of advertising or marketing information, without obtaining the data subject's separate consent where such consent is required by the laws of the Republic of Belarus.

5.2. Consent to Personal Data Processing when Completing Site Forms

Where personal data processing is based on the data subject's consent, such consent is provided by the user before the form is submitted.

Consent is provided by selecting the relevant checkbox before submitting the form.

Selecting the checkbox means that the user:

  • has read this Policy;

  • understands which personal data is processed;

  • understands the purposes of personal data processing;

  • consents to the processing of personal data for the purposes specified for the relevant form.

Where consent is the required legal basis for personal data processing, the form cannot be submitted unless the relevant checkbox has been selected.

5.3. “Ask a Question” Form

The “Ask a Question” form is intended for users to submit an inquiry, question, request or message to the Controller.

Purpose of Processing

Personal data provided through the “Ask a Question” form is processed for the following purposes:

  • considering the user's inquiry;

  • preparing and sending a response;

  • clarifying information relating to the inquiry where necessary;

  • providing feedback to the user.

List of Personal Data Processed

When the “Ask a Question” form is completed, the Controller processes the following personal data:

Data Category

Data Included

User Contact Details

name, email address

Content of the Inquiry

text of the question, inquiry or message

Additional Information

other information voluntarily provided by the user in the text of the inquiry

The user should not include personal data in the inquiry that is unrelated to the subject matter of the question.

Personal data is processed on the basis of the data subject's consent.

Personal data is processed until the inquiry has been reviewed and interaction with the user has been completed, unless a longer retention period is required under the laws of the Republic of Belarus.

5.4. “Become a Partner” Form

The “Become a Partner” form is intended for submitting cooperation proposals and establishing business relations with the Controller.

Personal data provided through the “Become a Partner” form is processed for the following purposes:

  • considering a cooperation proposal;

  • establishing business contacts;

  • conducting preliminary negotiations;

  • preparing a response to the proposal;

  • clarifying information required to assess the possibility of cooperation.

List of Personal Data Processed:

When the “Become a Partner” form is completed, the Controller processes the following personal data:

Data Category

List of Data

Prospective Partner Representative Details

name, position (if applicable)

Contact Details

phone number, email address

Organization Information

organization name and other information about the organization provided by the user

Content of the Inquiry

text of the question, inquiry or message

Additional Information

other information voluntarily provided by the user in the text of the inquiry

The Controller uses the specified data solely to contact the user regarding potential cooperation.

Personal data is processed on the basis of the data subject's consent.

Personal data is processed until consideration of the cooperation proposal and negotiations are completed or until the processing purpose is achieved.

If contractual or pre-contractual relations arise between the parties following consideration of the proposal, further processing of personal data is carried out in accordance with the laws of the Republic of Belarus and the documents governing the relevant relations.

5.5. “Pharmacovigilance” Form

The “Pharmacovigilance” form is intended for submitting reports of adverse reactions, suspected adverse reactions, lack of efficacy of medicinal products and other information relevant to the Controller's pharmacovigilance obligations.

Personal data processing through the “Pharmacovigilance” form is carried out in accordance with the Good Pharmacovigilance Practice Rules of the Eurasian Economic Union, approved by Decision No. 87 of the Council of the Eurasian Economic Commission dated 3 November 2016 (as amended by Decision No. 81 of the Council of the Eurasian Economic Commission dated 19 May 2022).

Purposes of Processing

Personal data provided through the “Pharmacovigilance” form is processed for the following purposes:

  • registering a report of an adverse reaction or lack of efficacy of a medicinal product;

  • assessing the information received;

  • clarifying information with the reporter where necessary;

  • fulfilling pharmacovigilance obligations;

  • preparing and retaining pharmacovigilance documentation;

  • complying with the laws of the Republic of Belarus and applicable acts of the Eurasian Economic Union.

5.6. Personal Data When a Report Is Submitted by a Healthcare Professional

If a report is submitted through the “Pharmacovigilance” form by a healthcare professional, the Controller may process the following personal data:

Reporter Data — Healthcare Professional

Data Category

List of Data

Identification Data

last name, first name, patronymic

Professional Information

place of work, specialty

Healthcare Organization Information

organization name, organization address (if available)

Contact Details

phone number, email address

Additional Information

other information voluntarily provided by the reporter

Patient Data, if included in the report

Data Category

List of Data

Patient Identification Data 

last name, first name, patronymic (if available)

General Information

sex, age, country of residence

Contact Details

phone number, email address (if available)

Health-Related Information

information on the adverse reaction, the patient's condition, use of the medicinal product and lack of efficacy of the medicinal product

Additional Information

other information voluntarily provided by the user in the text of the inquiry

Medicinal Product Information

Data Category

List of Data

Product Details

trade name of the medicinal product

Manufacturing Details

batch number, if available

Use Information

information on use of the medicinal product, dosage and period of use — if provided by the reporter

Case Description

description of the adverse reaction, suspected adverse reaction or lack of efficacy

5.7. Personal Data When a Report Is Submitted by a Consumer

If a report is submitted through the “Pharmacovigilance” form by a consumer, patient, patient representative or another person, the Controller may process the following personal data:
Reporter Data

Data Category

List of Data

Identification Data

last name, first name, patronymic — if available

General Information

sex, age, country of residence — if provided by the applicant

Contact Details

phone number, email address

Content of the Report

information on the adverse reaction, suspected adverse reaction or lack of efficacy of the medicinal product

Additional Information

other information voluntarily provided by the reporter

Medicinal Product Information

Data Category

List of Data

Product Details

trade name of the medicinal product

Manufacturing Details

batch number, if available

Content of the Report

information on the adverse reaction, suspected adverse reaction or lack of efficacy of the medicinal product

5.8. Specific Aspects of Processing Health Information

Reports submitted through the “Pharmacovigilance” form may contain information relating to the patient's health.

Such information is processed by the Controller only to the extent necessary to register, review, assess and follow up the pharmacovigilance report.

The Controller does not use information about the patient's health for purposes unrelated to pharmacovigilance.

5.9. Contact with the Reporter Regarding Pharmacovigilance Matters

The Controller may use the reporter's contact details provided in the “Pharmacovigilance” form solely to contact the reporter regarding review of the submitted report.

Such contact may be made to:

  • clarify the circumstances of the report;

  • obtain additional information about the medicinal product;

  • obtain additional information about the adverse reaction or lack of efficacy;

  • fulfill pharmacovigilance obligations.

5.10. Limitation of Excessive Data

When completing Site forms, users should not provide personal data that is not required to consider the inquiry, cooperation proposal or pharmacovigilance report.

If the user voluntarily provides additional information, the Controller processes such information only to the extent necessary to achieve the relevant processing purpose.

6. USE OF COOKIES

6.1.The https://lphc.by website uses cookies.

6.2. The following categories of cookies are used on the Site:

Cookie Category

Purpose

Essential / Technical / Functional Cookies

Necessary for operation of the Site, correct display of pages, security and storage of basic Site settings. They allow user preferences to be saved and provide a more convenient Site experience.

Analytics Cookies

Used to analyze Site traffic, assess page performance and improve the Site structure.

Advertising Cookies

Used only if such cookies are actually deployed on the Site and only with the user's consent where such consent is required by the laws of the Republic of Belarus.

6.3. Essential technical/functional cookies are used to ensure operation of the Site and cannot be disabled through the cookie banner where the Site cannot function properly without them.

The user may restrict or block such cookies in their browser settings; however, certain Site functions may not work properly in that case.

6.4. Analytics and marketing cookies are used with the user's consent, by accepting or rejecting them, in accordance with the laws of the Republic of Belarus.

The user may give consent, refuse the use of certain cookie categories or change previously selected settings through the cookie banner, browser settings or the Cookie Processing Policy page.

6.5. The Controller does not use cookies to identify the user unless the user independently provides personal data through Site forms.

6.6. Detailed information about the cookies used on the Site, their processing purposes, retention periods and the procedure for changing settings is provided in the separate Cookie Processing Policy page.

7.  DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

7.1. The Controller does not disseminate personal data of Site users or provide it to third parties without legal grounds provided for by the laws of the Republic of Belarus.

7.2. Personal data may be provided to third parties only to the extent necessary to achieve the processing purposes specified in this Policy.

7.3. Depending on the processing purpose, personal data may be provided to the following categories of recipients:

Category of Recipients

Purpose of Personal Data Disclosure

Data That May Be Disclosed

Organizations providing technical support for the Site, hosting, software maintenance and information systems support

Ensuring operation of the Site, storing inquiries, providing technical support and protecting the Site against unauthorized access

Technical data, cookie data and information submitted through Site forms, to the extent necessary to provide the relevant service

Providers of email services, CRM systems and other inquiry-processing services

Receipt, routing, storage and processing of user inquiries

Name, contact details, content of the inquiry and technical information required to process the inquiry

Government Authorities and Organizations

Fulfillment of obligations established by the laws of the Republic of Belarus

Personal data to the extent required by the relevant request or by law

Organizations and Authorized Persons involved in fulfilling pharmacovigilance obligations

Registration, review, assessment and follow-up of reports of adverse reactions or lack of efficacy of medicinal products

Reporter data, patient data where applicable, information on the medicinal product and information on the adverse reaction or lack of efficacy — to the extent necessary for pharmacovigilance purposes

Other Persons

Only where there is a legal basis provided for by the laws of the Republic of Belarus or the data subject's consent

Personal data to the extent necessary for the relevant processing purpose

7.4. If personal data processing is entrusted to an Authorized Person, the Controller takes measures to ensure that such person processes personal data in accordance with the requirements of the laws of the Republic of Belarus and ensures the confidentiality and security of personal data.

7.5. The Controller does not sell personal data of Site users, transfer it to third parties for their independent marketing use or disseminate it publicly, except in cases expressly provided for by the laws of the Republic of Belarus or agreed to by the data subject.

8. CROSS-BORDER TRANSFER OF PERSONAL DATA


8.1. At the time this Policy is published, the Controller does not carry out cross-border transfers of personal data in connection with operation of the Site. If services involving the transfer of personal data to the territory of a foreign state are subsequently used, such transfer will be carried out only where there is a legal basis and in compliance with the requirements of the laws of the Republic of Belarus.

9. PERSONAL DATA RETENTION PERIODS

9.1. The Controller retains personal data no longer than required for the purposes of personal data processing, unless another retention period is established by the laws of the Republic of Belarus.

9.2. Retention periods for personal data processed through the https://lphc.by website are determined as follows:

Personal Data Category / Processing Purpose

Retention Period

Technical data required for operation of the Site

For the period specified in the settings of the relevant cookies, or until consent is withdrawn / cookie settings are changed by the user

Essential technical cookies

For the lifetime of the relevant cookies or until they are deleted by the user through browser settings

Functional, analytics and marketing cookies

For the period specified in the settings of the relevant cookies, or until consent is withdrawn / cookie settings are changed by the user

Personal data provided through the “Ask a Question” form

Until the inquiry has been reviewed and interaction with the user has been completed, but no longer than 1 year after the response is sent, unless a longer retention period is required by the laws of the Republic of Belarus

Personal data provided through the “Become a Partner” form

Until consideration of the cooperation proposal and negotiations are completed, but no longer than 1 year after the last interaction, unless further processing is required in connection with conclusion of a contract or under the laws of the Republic of Belarus

Personal data provided through the “Pharmacovigilance” form

For the periods established by the laws of the Republic of Belarus and applicable requirements governing medicinal product circulation and pharmacovigilance

Personal data processed to comply with legal requirements or protect the rights and legitimate interests of Lamyra-Pharmacare LLC

For the periods established by the laws of the Republic of Belarus or for the period necessary to protect the Company's rights and legitimate interests

9.3. Once the processing purposes have been achieved, personal data shall be deleted, depersonalized or blocked, unless otherwise provided for by the laws of the Republic of Belarus.

9.4. If the data subject withdraws consent to personal data processing, the Controller stops processing the relevant personal data and deletes it, unless there are other grounds for processing provided for by the laws of the Republic of Belarus.

9.5. If personal data cannot be deleted for technical reasons, the Controller takes measures to prevent further processing of such personal data, including blocking it, in the cases and in the manner provided for by the laws of the Republic of Belarus.

10. RIGHTS OF DATA SUBJECTS

10.1. The data subject has the rights provided for by the laws of the Republic of Belarus on personal data protection. 

10.2. The data subject is entitled to:

Data Subject Right

What This Means

Right to Withdraw Consent

The data subject may withdraw their consent to personal data processing at any time without giving reasons where processing is based on consent.

Right to Obtain Information About Personal Data Processing

The data subject has the right to obtain information on whether their personal data is being processed, what data is processed, for what purpose, on what basis, from what source it was obtained, and other information provided for by law.

Right to Rectification

The data subject has the right to request amendments to personal data if it is incomplete, outdated or inaccurate.

Right to Obtain Information About Disclosure of Personal Data to Third Parties

Once per calendar year, the data subject has the right to obtain, free of charge, information on what personal data relating to them was provided and to whom during the year preceding the date of the application.

Right to Request Cessation of Processing and Deletion of Personal Data

The data subject has the right to request cessation of personal data processing and deletion of the data where there are no grounds for further processing.

Right to Appeal

The data subject has the right to appeal actions, omissions or decisions of Lamyra-Pharmacare LLC relating to personal data processing to the National Personal Data Protection Center of the Republic of Belarus or to a court.

10.3. The exercise of certain rights of the data subject may be restricted in cases provided for by the laws of the Republic of Belarus.

11. PROCEDURE FOR EXERCISING DATA SUBJECT RIGHTS

11.1. To exercise their rights, a data subject may submit an application to the Controller:

  • in writing;

  • in the form of an electronic document;

  • in another form, where such form is provided for by the laws of the Republic of Belarus.

11.2. The data subject's application shall contain the information required by the laws of the Republic of Belarus, including:

  • last name, given name and patronymic, if any;

  • address of residence or temporary stay;

  • date of birth;

  • identification number or, if none, the number of an identity document, where such information was provided by the data subject when giving consent or where processing is carried out without the data subject's consent;

  • the substance of the request;

  • a handwritten signature or electronic digital signature.

11.3. A response to the application is sent to the data subject in a form corresponding to the form in which the application was submitted, unless the application itself specifies otherwise.

11.4. The Controller considers applications from data subjects within the following time limits:

Data Subject Request

Review / Fulfillment Period

Provision of information relating to personal data processing

Within 5 business days after receipt of the application, unless another period is established by legislative acts

Withdrawal of consent to personal data processing

Within fifteen days after receipt of the application or a request submitted in the form through which consent was obtained

Rectification of personal data where it is incomplete, outdated or inaccurate

Within fifteen days after receipt of the application — make the amendments and notify the data subject, or notify the data subject of the reasons for refusal

Provision of information on disclosure of personal data to third parties

Within fifteen days after receipt of the application — provide information on what personal data and to whom it was provided during the year preceding the date of the application, or notify the data subject of the reasons for refusal

Cessation of personal data processing and/or deletion

Within fifteen days after receipt of the application — stop processing and delete the personal data where there are no other grounds for processing, or notify the data subject of the reasons for refusal

11.5. Where the Controller has lawful grounds to continue processing personal data, the Company may refuse the data subject's request to stop processing and/or delete personal data, notifying the data subject of the grounds for such refusal in the manner provided for by the laws of the Republic of Belarus.

11.6. Contact details for submitting applications concerning personal data processing are provided in Section 14 of this Policy.

12. MEASURES TO ENSURE PERSONAL DATA PROTECTION

12.1. The Controller takes the necessary legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, dissemination, provision, and other unlawful actions.

12.2. Personal data protection measures are applied taking into account:

  • the nature of the personal data processed;

  • the purposes of personal data processing;

  • the scope of personal data processed;

  • potential risks to the rights and freedoms of data subjects;

  • the requirements of the laws of the Republic of Belarus.

12.3. To ensure personal data protection, the Controller:

  • restricts access to personal data to persons who require such access to perform their job duties;

  • ensures the confidentiality of personal data;

  • applies organizational and technical information security measures;

  • maintains records of and controls access to personal data;

  • takes measures to prevent unauthorized access to personal data;

  • conducts internal monitoring of compliance with personal data protection requirements;

  • ensures that employees who have access to personal data are familiar with the requirements of the laws of the Republic of Belarus and the Company's internal documents on personal data processing and protection.

12.4. The Controller does not disclose information on specific technical measures used to protect personal data where disclosure could reduce the level of personal data protection or create a threat to the security of the Controller's information systems.

12.5. Persons granted access to personal data shall maintain the confidentiality of such data and may not use it for purposes unrelated to the performance of their duties or the Controller's instructions.

12.6. If a personal data security breach is identified, the Controller takes measures aimed at remedying the breach, minimizing potential adverse consequences and preventing similar breaches in the future.

13. AUTOMATED DECISION-MAKING

13.1. The Controller does not make decisions that produce legal effects for the data subject or otherwise significantly affect their rights and legitimate interests solely on the basis of automated personal data processing.

13.2. Information obtained through cookies and other technical means may be used to analyze Site performance, improve its structure and enhance usability, but is not used to make legally significant decisions concerning a specific user.

14. CONTACT INFORMATION

14.1. For matters relating to personal data processing, exercising data subject rights, withdrawing consent, rectifying data, stopping processing or deleting personal data, the data subject may contact Lamyra-Pharmacare LLC (hereinafter, the “Controller”).

14.2. Controller contact details:

Controller: Limited Liability Company “Lamyra-Pharmacare”
Address: Minsk Region, Smolevichi District, Ozeritsko-Slobodskoy Rural Council, 10B, near the agro-town of Sloboda, Room 55
Website: https://lphc.by
Email for personal data processing inquiries: info@lphc.by

14.3. When submitting an inquiry, the data subject shall provide the information necessary for identification and consideration of the inquiry in accordance with the laws of the Republic of Belarus.

14.4.  If the inquiry relates to a pharmacovigilance report, the Controller may request additional information from the reporter that is necessary for proper review of a report of an adverse reaction or lack of efficacy of a medicinal product.

15. FINAL PROVISIONS

15.1. This Policy enters into force on the date of its latest revision indicated on the https://lphc.by website.

15.2. The Controller may amend this Policy in the event of: 

  • changes to the laws of the Republic of Belarus;

  • changes to the structure or functionality of the Site;

  • changes to the purposes, methods or conditions of personal data processing;

  • changes to the information systems, services or cookies used;

  • the need to clarify provisions of the Policy.

15.3. The current version of the Policy is published on the https://lphc.by website and is publicly available.

15.4. Continued use of the Site after a new version of the Policy is published means that the user has familiarized themselves with the current version of the Policy.

Where personal data processing is based on the data subject's consent, amendment of the Policy itself does not replace the need to obtain new consent in cases where such consent is required by the laws of the Republic of Belarus.

15.5. This Policy applies only to the https://lphc.by website.

The Controller is not responsible for personal data processing practices on third-party websites that may be accessed via links posted on the Company's Site.

15.6. In all matters not governed by this Policy, the Controller is guided by the laws of the Republic of Belarus.

 

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