CHAPTER 1

GENERAL PROVISIONS

1.1. The Privacy Policy of AmantisMed LLC (hereinafter the “Policy”) defines the main principles, purposes, conditions and methods of processing personal data, the lists of subjects and personal data that is processed by AmantisMed LLC, the functions of AmantisMed LLC when processing personal data, the rights of data subjects, as well as the personal data protection requirements in place at AmantisMed LLC.

1.2. The Policy has been developed taking into account the requirements of the Constitution of the Republic of Belarus, statutory and other regulations of the Republic of Belarus in the area of personal data.

CHAPTER 2

STATUTORY AND OTHER REGULATIONS OF THE REPUBLIC OF BELARUS ACCORDING TO WHICH THE PRIVACY POLICY IS DETERMINED AT AMANTISMED LLC

2.1. The Policy of AmantisMed LLC is determined in accordance with the following laws and regulations:

The Constitution of the Republic of Belarus;

Law of the Republic of Belarus No. 99-З “On Personal Data Protection” dated 07/05/2021 (hereinafter the “Personal Data Protection Law”);

Law of the Republic of Belarus No. 455-З “On information, informatisation and information protection” dated 10/11/2008;

Other regulations of the Republic of Belarus and regulatory documents of the competent public authorities.

CHAPTER 3

KEY TERMS AND DEFINITIONS USED IN THE POLICY

3.1. Website means a set of graphic and information content, programs and databases ensuring their availability on the Internet at the network address amantismed.by, including its subpages.

3.2. Website Administration means authorised employees who manage the Website, acting on behalf of AmantisMed LLC and organising and/or processing personal data.

3.3. Website User means any visitor of the Website.

3.4. Personal Data means any information related to an identified or identifiable natural person.

3.5. Data Subject means an individual whose personal data is processed.

3.6. Processing of Personal Data means any operation or set of operations performed on personal data, including collection, systematisation, storage, alteration, usage, anonymisation, blocking, distribution, provision, erasure of personal data.

3.7. Erasure of Personal Data means actions as a result of which it becomes impossible to restore personal data in information resources (systems) containing personal data and/or as a result of which physical storage media with personal data are destroyed.

3.8. Blocking of Personal Data means restriction of access to personal data without its erasure.

3.9. Anonymisation of Personal Data means actions as a result of which it becomes impossible to attribute the personal data to a specific data subject without the use of additional information.

3.10. Publicly Available Personal Data means personal data disclosed by the data subject on their own or with their consent or disclosed in accordance with the legal requirements.

3.11. Special Categories of Personal Data means personal data related to racial or ethnic origin, political opinions, trade union membership, religious or other beliefs, health or sex life, administrative or criminal prosecution, as well as biometric and genetic personal data.

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

3.13. Automated Processing of Personal Data means processing of personal data using computers.

CHAPTER 4

PRINCIPLES AND PURPOSES OF PERSONAL DATA PROCESSING

4.1. AmantisMed LLC, being the operator of personal data, processes personal data of any Users.

4.2. Processing of personal data at AmantisMed LLC shall be carried out taking into account the need to ensure protection of rights and freedoms of data subjects, including protection of the right to privacy, personal and family secrets, based on the following principles:

Personal data shall be processed fairly and lawfully;

Processing of personal data shall be proportional to the stated purposes of its processing and shall ensure fair balance of interests of all stakeholders at all stages of such processing;

Personal data shall be processed with the consent of the data subject, except in cases provided for by statutory regulations;

Processing of personal data shall be restricted to achievement of specific lawful purposes stated in advance. Processing of personal data in a manner that is incompatible with the initially stated purposes of its processing is not allowed;

The content and scope of the personal data that is processed shall correspond to the stated purposes of its processing. The personal data being processed shall not be redundant in relation to the stated purposes of its processing;

Processing of personal data shall be transparent. The relevant information related to personal data processing may be provided to the data subject;

The operator shall take measures to ensure accuracy of the personal data processed by it and update it if necessary;

Personal data shall be kept in a form which permits identification of a data subject for no longer than is necessary for the stated purposes for which the personal data is processed.

4.3. Personal data shall be processed at AmantisMed LLC for the purposes of:

- performing functions, powers and responsibilities entrusted to AmantisMed LLC by the legislation of the Republic of Belarus in the area of pharmacovigilance, including those related to provision of personal data to public authorities, to the Ministry of Health of the Republic of Belarus, as well as other state authorities;

- interacting with the Users regarding the activities of AmantisMed LLC, inquiries of the Users, including electronic inquiries, the posting of data for open vacancies;

- collection of information about the User activity on the Website, improvement of the Website quality and content;

- for other lawful purposes.

CHAPTER 5

LIST OF SUBJECTS WHOSE PERSONAL DATA IS PROCESSED AT AMANTISMED LLC

5.1. At AmantisMed LLC, we process personal data of the Website Users only if it is filled in and/or sent by the User on his/her own via special forms and/or by sending your personal data to the Website Administration, the User agrees with this Policy.

5.2. The Website Administration shall process anonymised data of the Users if it is allowed in User’s browser settings.

CHAPTER 6

LIST OF PERSONAL DATA PROCESSED AT AMANTISMED LLC

6.1. The list of personal data that is processed by AmantisMed LLC shall be determined in accordance with the legislation of the Republic of Belarus and local regulations of AmantisMed LLC with consideration of the purposes for personal data processing specified in Chapter 4 of the Policy.

6.2. Special categories of personal data shall not be processed at AmantisMed LLC.

CHAPTER 7

FUNCTIONS OF AMANTISMED LLC WHEN PROCESSING PERSONAL DATA

7.1. When processing personal data, AmantisMed LLC:

Shall take measures necessary and sufficient to ensure compliance with the legislation of the Republic of Belarus and local regulations of AmantisMed LLC in the area of personal data;

Shall take legal, organisational and technical measures to protect personal data from unauthorised or accidental access to it, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other illegal actions in relation to personal data;

Shall assign a structural division or a person responsible for internal control over personal data processing;

Shall publish or otherwise provide unrestricted access to this Policy;

Shall cease processing and destroy personal data in cases provided for by the legislation of the Republic of Belarus in the area of personal data;

Shall perform other actions provided for by the legislation of the Republic of Belarus in the area of personal data.

CHAPTER 8

CONDITIONS OF PERSONAL DATA PROCESSING AT AMANTISMED LLC

8.1. At AmantisMed LLC, personal data shall be processed with the consent of the data subject given to process his/her personal data unless otherwise provided for by the legislation of the Republic of Belarus in the area of personal data.

8.2. AmantisMed LLC shall not disclose and distribute personal data to third parties without the consent of the data subject unless otherwise provided for by the legislation of the Republic of Belarus.

CHAPTER 9

LIST OF PERSONAL DATA OPERATIONS AND METHODS OF ITS PROCESSING

9.1. AmantisMed LLC shall carry out personal data processing (any operation or set of operations performed on personal data, including collection, systematisation, storage, alteration, usage, anonymisation, blocking, distribution, provision, erasure of personal data).

9.2. At AmantisMed LLC, personal data shall be processed using the following methods:

By automated means;

Without automated means if there is search for personal data and/or access to it based on certain criteria.

CHAPTER 10

RIGHTS OF DATA SUBJECTS

10.1. Data subjects shall have the right to:

Withdraw the consent of the data subject;

Receive information regarding personal data processing and change personal data;

Demand termination of personal data processing and/or its erasure;

Appeal against the operator’s actions (omissions) and decisions related to personal data processing.

CHAPTER 11

FINAL PROVISIONS

11.1. The User can receive any explanations concerning the issues related to processing of its personal data by contacting the Website Administration via office@amantismed.by.

11.2. The Policy shall remain in force indefinitely until it is replaced by a new version.