Privacy and personal data protection policy of LLC "BIOTECHNOS"

1. General provisions and scope of application

This Privacy Policy (hereinafter referred to as the “Policy”) regulates the procedure for collecting, using, processing, storing, transferring and other actions with personal data carried out by the Limited Liability Company “BIOTECHNOS” (EDRPOU code: 41599490), registered at the address: 08129, Ukraine, Kyiv region, Buchansky district, Petropavlivska Borshchahivka village, Soborna st., building 2v, office 86 (hereinafter referred to as the “Company”, “we”, “us”).

We process personal data of individuals (hereinafter referred to as “Users”, “data subjects”, “you”) who interact with the Company within the framework of professional, informational, commercial, educational or partnership relationships, in particular in the process of:

  • providing relevant professional, scientific, educational or analytical information;
  • participation in questionnaires, surveys, filling out registration or information forms (including consent forms) in paper or electronic form;
  • promotion of medicines, including, but not limited to: carrying out promotional, advertising, information, marketing activities, representing the interests of the Company, participating in specialized events, as well as cooperation with third parties involved in such activities;
  • conducting business correspondence and exchanging information through various communication channels (email, instant messengers, social networks, online forms, etc.).

This Policy applies to all individuals whose personal data we process, including (but not limited to):

  • visitors to the official website biotehnos.in.ua;
  • doctors, pharmacists and other healthcare professionals;
  • users who subscribe to newsletters, complete surveys, or participate in events;
  • representatives of our partner, client, supplier and other organizations.

The company is the controller of personal data within the meaning of the Law of Ukraine "On Personal Data Protection" and ensures their processing in full compliance with the requirements of national legislation, as well as - in cases provided for by Regulation (EU) 2016/679 (GDPR) - in accordance with international standards for the protection of personal information.

The terms used in this Policy should be understood in the meaning defined by the Law of Ukraine "On Personal Data Protection" dated June 1, 2010 No. 2297-VI. In cases not regulated by the national legislation of Ukraine, as well as for the purposes of better understanding, the interpretation of the terms is in accordance with generally recognized international standards and principles in the field of personal data protection, in particular those laid down in the General Data Protection Regulation (GDPR) of the European Union.

Regulation (EU) 2016/679 (GDPR) applies if:

  • we process personal data of individuals located in the European Union or the European Economic Area;
  • such persons are participants in our events, subscribers to newsletters, survey respondents, or recipients of professional information;
  • we carry out marketing, informational or educational activities aimed at persons residing in the EU.

Personal data within the scope of this Policy means any information that directly or indirectly allows the identification of an individual, in particular: name, surname, contact details, place of work, specialization, professional activity, email address, phone numbers, IP addresses, identifiers in messengers and social networks, etc.

2. Composition, content and sources of personal data collection

We, BIOTECHNOS LLC, may process personal data of the following individuals: doctors, pharmacists, representatives of medical institutions, as well as other Users who voluntarily provide us with their data during interaction with the Company.

The personal data that may be processed includes:

  • Identification data: last name, first name, patronymic.
  • Contact information: phone number, email address.
  • Professional data: professional specialization, position, name of the medical institution or institution where the User works.
  • Interaction data: selected communication channel (for example, messengers, social media accounts), results of completed questionnaires or surveys, information about participation in events, registration, as well as data from correspondence.

This list is not exhaustive and may be supplemented depending on the specific purposes of our interaction, always in compliance with the principle of data minimization and subject to your consent.

We collect your personal data from several sources to ensure effective interaction:

  • Directly from you: This happens when you fill out questionnaires, registration or contact forms, communicate with Company representatives in person or remotely, participate in our events, conferences, trainings, or subscribe to our newsletters or communication channels.
  • Through third-party platforms or services: We may receive data when you use services such as Google Forms, SurveyMonkey, or other electronic platforms to interact with us via email or messengers.
  • Through integration with social networks: If you contact us through your social media accounts (e.g. Facebook, LinkedIn, Instagram), or use them to authenticate on our Website, BIOTECHNOS LLC may access a minimum set of publicly available data from your profile (e.g. name, contact information, place of work), if you have allowed this in the settings of the relevant service.

Your responsibility for public information:

You are personally responsible for the accuracy and scope of the information that you publish in public social media profiles or voluntarily provide during your interaction with BIOTECHNOS LLC. It is important to be aware of the potential risks associated with publicly posting contact or geolocation information, so please use your own discretion when deciding to publish such information.

Categories of data that we do not process:

LLC "BIOTECHNOS" categorically does not process special categories of personal data (so-called "sensitive data"). We do not collect or use information related to your racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties or professional associations, information about your criminal past, health, intimate life, as well as biometric or genetic characteristics. We also do not process information that can identify a person based on their physiological or biological characteristics.

3. Purpose, legal basis and time limits for processing personal data

We process your personal data for a number of important purposes, guided by the principles of transparency and lawfulness. One or more of the following purposes may apply at the same time:

Purposes of data processing

  • Fulfillment of contractual and legal obligations: This includes ensuring civil, economic and tax relations, as well as the performance of all functions and obligations assigned to BIOTECHNOS LLC by the current legislation of Ukraine.
  • Identification and effective interaction: We use your data to identify you as a user of the Website, to provide information and consulting services, to process your requests and applications. This also includes creating and managing your personal accounts on the Website for ease of authorization and interaction.
  • Service improvements and analytics: Your data helps us to continuously improve the quality of our services and interactions, conduct research and analytical activities. We analyze your preferences, interests and behavior on the Website to form the most relevant offers, making your interaction with the Company more effective and personalized. This also includes analyzing data on the use of the Website to optimize it and improve its functionality.
  • Marketing and outreach: We send you professional, educational, scientific, analytical and marketing information for newsletters. This includes information about medicines, clinical trials, educational programs and events, as well as materials for promoting the Company's products, services, trademarks and brands. Promotion of medicines includes, but is not limited to: carrying out promotional activities, advertising, informing, marketing activities, representing the interests of the Company, participation in specialized events, as well as cooperation with third parties involved in such activities. Communication can be carried out by mail, e-mail, via phone calls, SMS, as well as via messengers (Viber, WhatsApp, Telegram, Signal and other similar platforms).
  • Handling of adverse event reports: We may use your personal data to receive and process reports of adverse drug reactions, to investigate their causes and minimize their occurrence in the future, and to contact you regarding these issues.
  • Protection of legitimate interests: Data processing is necessary to protect the legitimate interests of BIOTECHNOS LLC or third parties to whom this data may be transferred in accordance with the requirements of the law.

You may opt out of receiving informational and marketing mailings at any time by changing the relevant settings in your personal account on the Website (if such a function is available) or by sending a message to the following email address: info@biotehnos.com.ua with the subject line "Unsubscribe".

Legal basis for data processing

We process your personal data only if at least one of the following legal grounds exists:

  • Contract execution: When processing is necessary for the conclusion or performance of a contract between BIOTECHNOS LLC and you, or to take steps prior to entering into a contract (e.g. processing your request for a consultation or registration for an event).
  • Legislative obligation: If processing is necessary to fulfill an obligation imposed on the Company by the applicable legislation of Ukraine.
  • Protection of legitimate interests: When data processing is necessary to protect the legitimate interests of BIOTECHNOS LLC or third parties, provided that such interests do not conflict with your fundamental rights and freedoms.
  • Your consent: In cases where this is required by the current legislation of Ukraine, we process data based on your unambiguous voluntary consent provided in accordance with this Policy (for example, when registering on the Website, subscribing to newsletters or filling out a consent form).

Data storage and processing periods

Your personal data is processed and stored for no longer than is necessary to achieve the purposes of their processing as defined in this Policy. Unless the current legislation of Ukraine (in particular, in the field of archival and office management) requires a longer storage period, your data will be deleted or depersonalized after the purpose of their processing has been achieved or the relevant storage period has expired.

4. Where your personal data is stored

Your personal data is processed and stored in Ukraine.

5. Access to your personal data

Access to your personal data is provided only to a limited number of persons, solely in case of business necessity and to achieve the purposes set out in this Policy. This includes:

  • Company staff: Employees of BIOTECHNOS LLC who need access to such data to perform their work and functional duties.
  • Affiliates of the Company: Persons or entities related to the Company, if appropriate and necessary to implement the goals set out in this Policy (for example, for joint analytical activities or projects).
  • Counterparties and service providers: Third-party organizations that provide services to BIOTECHNOS LLC. These may include, in particular, IT service providers, marketing agencies, auditors or other partners that perform certain functions on behalf of the Company. In such cases, our counterparties are not entitled to use the personal data received otherwise than to fulfill their obligations to BIOTECHNOS LLC, or to hold joint events (competitions, promotions) with the determination of the winner, if such events are held.
  • Government, regulatory and law enforcement agencies: Access may be granted if it is necessary to achieve the purposes of data processing provided for by law, or if BIOTECHNOS LLC is obliged to fulfill a statutory obligation, or to protect its legitimate interests.

6. Transfer of personal data to third parties

BIOTECHNOS LLC does not sell, transfer or disclose personal data obtained on our Website to third parties without your prior express consent.

Disclosure of personal data occurs exclusively in cases directly defined by the current legislation of Ukraine, as well as in the presence of the following circumstances:

  • Crime prevention and protection of interests: We may disclose information if necessary to prevent criminal activity or avoid harm to the Company or third parties.
  • Technical support and services: Information may be disclosed to third parties who provide us with technical support and ensure the functionality of the services through which you interact with us (for example, form a request, send a message, etc.).
  • Requirements of regulatory and supervisory authorities: We may disclose information upon request or to inform regulatory and/or supervisory authorities, including (but not limited to): State Enterprise "State Expert Center of the Ministry of Health of Ukraine", Ministry of Health of Ukraine, State Service of Ukraine for Medicines and Drug Control, etc.

Your responsibility for third-party data:

You agree not to transfer to the Company the personal data of third parties without their proper consent. By using personal data, you agree to comply with the current legislation of Ukraine on the protection of personal data, in particular, the Law of Ukraine "On the Protection of Personal Data".

In the event that personal data is transferred outside Ukraine to countries that are not recognized as providing an adequate level of protection for personal data, such transfer will occur only if there are appropriate legal grounds (e.g. standard contractual clauses, binding corporate rules) or if you have given your explicit consent to such transfer. You will not need separate consent or additional notification for each such transfer if it is carried out in accordance with the purposes specified in this Policy and on lawful grounds.

7. Your rights as a data subject

Your rights as a subject of personal data are inalienable and inviolable. LLC "BIOTECHNOS" complies with all provisions of Article 8 of the Law of Ukraine "On Personal Data Protection", which provides you with the following rights:

  • Right to information about your data: You can learn about the sources of collection, location and purpose of processing your personal data. You also have the right to know the location or place of residence (stay) of LLC BIOTECHNOS as the data controller or processor, or authorize other persons to receive this information, unless this is contrary to the law.
  • Right to access and transfer information: You can obtain full information about the terms of providing access to your personal data, including information about any third parties to whom this data is transferred.
  • The right to access your data: You have direct access to your personal data stored with us.
  • The right to receive a response to a request: Upon receipt of your request, we will provide a response on whether your personal data is being processed and its content. You will receive this information no later than thirty calendar days from the date of receipt of the request, unless otherwise provided by law.
  • Right to object to processing: You may submit a reasoned request to BIOTECHNOS LLC to object to the processing of your personal data.
  • Right to change or delete data: You have the right to request the modification or complete destruction of your personal data by any controller or processor if these data are processed unlawfully or are inaccurate.
  • Right to protection: We ensure the protection of your personal data against unlawful processing, accidental loss, destruction or damage. This also applies to protection against intentional concealment, failure to provide or untimely provision of information, as well as against the provision of false information that may harm your honor, dignity and business reputation.
  • Right to appeal: You may file complaints regarding the processing of your personal data with the Commissioner for Human Rights of the Verkhovna Rada of Ukraine (hereinafter referred to as the "Commissioner") or directly with the court.
  • The right to legal protection: In the event of a violation of personal data protection legislation, you have the right to exercise all legal remedies provided by law.
  • Right to reservation: When giving consent to data processing, you may make reservations regarding the restriction of such right.
  • Right to withdraw consent: You can withdraw your consent to the processing of personal data at any time.
  • The right to know the mechanism of automatic processing: You have the right to be informed about the mechanism of automatic processing of your personal data.
  • Right to protection against automated decision-making: You have the right to protection against automated decision-making that may have legal consequences for you.

8. Procedure for processing requests for access to personal data

You have the full right to receive any information about yourself from BIOTECHNOS LLC. We provide access to your personal data free of charge.

To submit a request for access to personal data (hereinafter referred to as the "Request") to the Company, please be sure to indicate:

  • Your data: Surname, first name and patronymic, place of residence (or place of stay), as well as details of your identity document.
  • Details of the person being requested (if it is a different person): Surname, first name and patronymic, as well as other information that allows identification of this individual.
  • Subject of the request: Information about the specific personal data you are interested in, or information about the owner or processor of the personal data.
  • List of requested data: A clear list of the personal data you wish to receive.
  • Purpose and basis of the request: The purpose for which you are making the Request and/or the legal basis for submitting it.

Consideration of your Request:

We will review your Request within 10 business days of its receipt to determine whether it can be satisfied. During this period, BIOTECHNOS LLC will notify you of the decision: whether the Request will be satisfied, or whether it will provide a reasoned refusal to provide the relevant personal data, indicating the grounds in accordance with the regulatory legal act.

In case of a positive decision, your Request will be fully satisfied within 30 calendar days from the date of its receipt, unless otherwise provided by the current legislation of Ukraine.

9. Deleting your personal data

You can initiate the deletion of your personal data by taking one of the following actions:

  • Submitting a written request: Send a written request to delete personal data to info@biotehnos.com.ua with the subject line "Personal data".
  • Self-deletion via your personal account: If the Website has a personal account function, you can take steps to delete your data directly through it.

In addition to your request, personal data is also subject to deletion in the following cases:

  • Commissioner's prescription: On the basis of the relevant order of the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or officials designated by him.
  • Court decision: In the event of a court decision to delete or destroy personal data becoming legally effective.

If you independently delete personal data from your personal account on the Website, the destruction of this data from the Company's information systems occurs automatically.

We destroy personal data in a way that completely eliminates the possibility of its further recovery, as well as the identification of the person.

You also have the right to delete your account completely. Deleting your account at your initiative is carried out in accordance with the procedure specified in the User Agreement and the Terms of Use of the Website. This is grounds for immediate termination of the processing and storage of such personal data by BIOTECHNOS LLC.

In case of inactivity in your account for 5 (five) years, BIOTECHNOS LLC reserves the right to delete such account, including all personal data stored in it. This means that you will no longer be able to access and use it. The procedure for deleting personal data from the Company's internal databases is governed by our internal policies.

If you have any questions regarding the grounds, conditions, or procedures for changing or deleting personal data, please contact the email address: info@biotehnos.com.ua with the note "Personal data" in the subject line.

10. Withdrawal of consent to the processing of personal data

You may withdraw your consent to the processing of personal data at any time. To do this, send a request to the email address: info@biotehnos.com.ua with the subject line "Personal data".

After receiving your request, employees of BIOTECHNOS LLC will review it and delete your personal data from the Company's information systems.

Please note that the withdrawal of consent to the processing of personal data does not affect the lawfulness of the processing carried out prior to such withdrawal. It also does not prevent data processing if it is carried out on other lawful grounds provided for by applicable law.

11. Amendments to this Policy

We, BIOTECHNOS LLC, reserve the right to periodically update this Policy unilaterally.

We will notify you of any material additions or changes to this Policy. If you do not agree to such changes, which may be made in the future, you may opt out of receiving newsletters by sending a request. Or, in case of disagreement with other aspects of data processing, you should stop using the Company's services.

We may also make other changes to this Policy without prior personal notice, so we recommend that you regularly check the current version.

The new version of this Policy comes into force from the moment of its posting on the Website, unless otherwise provided by the new version itself. The current version of the Policy is always available on the page at: biotehnos.in.ua/privacy-policy.

Last revision date: 07/23/2025

12. Personal data security measures

We, BIOTECHNOS LLC, take reasonable steps to protect information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.

The Law of Ukraine "On Personal Data Protection" establishes basic requirements for the collection, storage and processing of personal data. Informed consent of the patient involves the collection, transfer, use and storage of the patient's personal data.

INFORMED CONSENT to the processing and transfer of personal data

I consent to the processing of my personal data (i.e., the performance of actions related to the collection, registration, accumulation, storage, adaptation, modification, renewal, updating, use and dissemination (transfer), depersonalization and destruction, as well as the performance of other actions related to the processing of my personal data. The personal data provided by me may be distributed and transferred, including to healthcare institutions of foreign countries, state authorities and local self-government bodies, as well as to other persons determined by the owner/manager independently.
I agree that such transfer of my personal data will not require separate consent or notification to me.