PRIVACY POLICY

EKIMO (“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 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 EKIMO or any of its Services.

■ 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 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.

1.1EKIMO collects and processes personal data that is necessary to provide YOU with services and best meet YOUR needs, for obtaining feedback in relation to the doctors and health service 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 which 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 above mentioned purposes by EKIMO. Information collected and processed by us from YOU may include the following:

•YOUR first name and last name;

•Device that YOU use for APP;

•City and country of YOUR residence;

•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;

•Fingerprint and Face ID;

•First name, last name, phone number and status of relationship with the person who might be contacted in an emergency situation;

•Data regarding YOUR usage of the services and history of the appointments made by or with YOU through the use of Services;

•Insurance data (such as YOUR insurance company, insurance policy information, letter of guarantee, insurance plan);

•Information about pharmacy loyalty or reward cards;

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

•First 6 and last 4 digits of Debit/credit card number, name and last name of card holder and unique code of transaction;

•Payments transactions for services / products purchased via EKIMO;

•Other information that YOU voluntarily choose to provide to us (such as photo, height, weight, allergies, blood group etc.).

2.1YOU 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 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 EKIMO 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.

2.2If 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@ekimo.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 EKIMO being unable to provide YOU with its services and/or to terminate any existing relationship EKIMO may have with YOU.

2.3If 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@ekimo.ge

2.4If 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.

2.5A 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 for verification.

2.6This privacy policy applies to APP, software, products and services owned and controlled by JSC VABACO, the owner of EKIMO (legal entity established and operating pursuant to the Georgian legislation, with Company # 406102275). YOUR use of and access to the Services is subject to this Privacy Policy, our terms and conditions as well as other policies. EKIMO 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’ device, collect data or solicit personal information from the Users, for which EKIMO is not responsible or liable. Accordingly, EKIMO does not make any representations concerning the privacy practices, nor does 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. EKIMO encourages the User to read/examine the privacy policies of third parties.

2.7EKIMO 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, EKIMO not be held liable for any loss whatsoever incurred by the User.

2.8EKIMO 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.

2.9We 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 EKIMO, 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.

2.10To the extent necessary to provide Users with the Services, EKIMO may provide Information to third party contractors who work on behalf of or with EKIMO to maintain the APP. In such circumstances, YOU consent to us disclosing YOUR Personal Information to contractors, solely for the intended purposes only.

2.11We 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.

2.12Notwithstanding the above, EKIMO 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 and third parties. Further, EKIMO 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 EKIMO 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.

3.1We 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@ekimo.ge to deactivate YOUR account. Unless stated otherwise, our current Privacy Policy applies to all information that EKIMO has about YOU and YOUR account.

4.1YOU 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 EKIMO 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.

Should YOU have questions about this Privacy Policy or our information collection, use and disclosure practices, YOU may contact us via our email support@ekimo.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 EKIMO 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@ekimo.ge. Such withdrawal of the consent will trigger termination of YOUR EKIMO account.

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

YOU have the right to complain to a Data Protection Authority about our collection and use of YOUR Personal Data. For more information, please contact State Inspector’s Office via https://personaldata.ge