DATA PRIVACY POLICY

This Data Privacy Policy describes how Biotech Healthcare Holding GmbH and its affiliates under common ownership and control (collectively,“Biotech” or “we” or “our” or “us” )) use and disclose the information Biotech collects from the visitors of our website www.biotechhealthcare.com, eifu.biotechhealthcare.com , www.biotechcalculators.com, order.biotechhealthcare.com,  and other websites owned and managed by Biotech group of companies.

Biotech is operating on a global scale with legally independent companies, business processes, management structures, and technical systems. This Data Privacy Policy (hereinafter referred to as the Privacy Policy) applies to the website www.biotechhealthcare.com, domains, mobile & digital applications, digital services and social media platforms belonging to Biotech (hereinafter referred to as the Website).

When you visit the Website, data may be collected which may, in some cases, be of personal nature. This Privacy Policy is intended at analysing our Website traffic and letting every visitor know different forms of personal data collection at Biotech along with usage, disclosure and the rights of the visitors (henceforth referred to as “you” or “your”).

At Biotech, we are committed to protecting your personal data.

Biotech is, and at all prior times was, in material compliance with all applicable state and federal data privacy and security laws and regulations, and Biotech has taken commercially reasonable actions to prepare to comply with, and since its inception, have been and currently are in compliance with, the European Union General Data Protection Regulation (“GDPR”) (collectively, the “Privacy Laws”). To ensure compliance with the Privacy Laws, Biotech has in place, comply with, and take appropriate steps reasonably designed to ensure compliance in all material respects with their policies and procedures relating to data privacy and security and the collection, storage, use, disclosure, handling, and analysis of Personal Data (the “Policies”). Biotech has at all times made all disclosures to users or customers required by applicable laws and regulatory rules or requirements, and none of such disclosures made or contained in any Policy have, to the knowledge of Biotech, been inaccurate or in violation of any applicable laws and regulatory rules or requirements in any material respect.

Data processing at Biotech (e.g. collection, processing, transfer) is performed in accordance with the applicable laws in force. The personal information needed from you for business transactions is stored by us and transferred to service providers contracted by Biotech to the extent necessary to process the transactions. The privacy of our Website visitors and trust is very important to us, and we are committed to safeguarding it. Please read this Privacy Policy carefully to make sure you understand how any personal information you provide to us will be handled. This Privacy Policy explains how we will use information about you and the steps we take to ensure your information is kept secure, private and confidential. It should be read together with our terms of use. If you use this Website, it will be deemed that you have read and accepted this Privacy Policy and you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. You must not use this Website and/or our Services and/or our Products if you do not accept this Privacy Policy.

Our Privacy Policy is subject to change at any time without notice. To make sure you are aware of any changes, please review our Privacy Policy periodically.

It may be noted that some of the companies forming part of the Biotech Group could have amended versions of this Privacy Policy subject to the applicable local laws. It is recommended that you review the Privacy Policy of the respective Website you visit. In some cases, Biotech Website also contains links to websites of third-party/external companies to which this Privacy Policy does not apply.

Biotech Website

We would like to inform you in this regard, that we may employ third-party companies and individuals for assisting us in the following ways:

• To facilitate our Service / Products;
• To provide the Service or Service related services on our behalf; or
• To assist us in analyzing how our Products are being used.

If you choose to avail our Services / Products, then you agree to the collection and use of information in relation with this Policy. The Personal Information that we collect is used for providing and improving our Products and/or our Services. We will not use or share your information with anyone except in the manner as described in this Privacy Policy.

2. Data Collection and Disclosure:

The personal information we collect when you interact with us via this Website includes:

Information made available by you::

We collect information that you voluntarily provide to us when you use the Website, such as when you register for a Biotech program or service, participate in a survey, provide a testimonial, order a product, participate in an interactive feature or forum (such as chat features), or contact us with a question, comment, or request. The type of information that you provide is based on the specific function of the products/services that you use or the Biotech program or service for which you register, and might include, for instance, your name, address, age, birth date, gender, email address, phone number, photo, social media account ID, zip code, education, professional experience, demographic information, information about your health and/or medical conditions, product usage and preferences.

Information received by us from Third Parties:We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information, joint marketing partners, social media platforms, people with whom you are connected on social media platforms, and other third parties.Information received through the use of cookies::

We could also be in possession of technical information through cookies, such as

• activity data, such as when you completed a form on the Website;
• information from your visits to this Website, including the type of browser and operating system you use, access times, pages viewed, URLs clicked on, your IP address, geographical location, browser type and version, operating system
• pages you visited before and after navigating to this Website including referral source, length of visit, page views, website navigation paths;
• social media tracking pixels that allow platforms such as Facebook, Instagram, LinkedIn, Youtube and Twitter to interact with this Website and give feedback on your actions;
• device information, including the unique device identifier, hardware model, operating system and version and mobile network information;
• information that you have voluntarily entered while creating a profile on our Website—for example, your name, profile pictures, gender, birthday, relationship status, interests and hobbies, educational details, and employment details;
• information relating to anything you purchase, services you use, or transactions you make through our Website, which includes your name, address, telephone number, email address, and credit card details;
• any other personal or sensitive information that you post on our Website or send to us.

Information received through Recording of telephone and chat conversations for the purpose of quality improvement:

Biotech may record telephone or chat conversations (after you have been informed of it during the phone conversation and before the recording commences) for the purpose of improving the quality of its Services/Products.

3. How do we use your personal information?

We may use your personal information to:

Provide you with information and services including:

• online events, such as webcast events;
• our press releases;
• job postings;
• financial results;
• tips, helpful information and marketing communications about our products and services. We will always obtain consent for marketing where required by law.

Contact and interact with you, including to:

• respond to your requests; and
• provide important notices and updates, such as changes to our terms and policies, security alerts and administrative messages.

Operate our business, including to:

• respond to reports you make of a possible side effect associated with one of our products and to monitor the safety of our products.
• comply with applicable laws, regulations and guidance;
• comply with demands or requests made by regulators, governments, courts and law enforcement authorities; and
• investigate and take action against illegal or harmful behaviour of users.

Improve our daily operations, including:

• for internal purposes such as auditing, data analysis and research to help us deliver and improve our digital platforms, content and services;
• to monitor and analyse trends, usage and activities in connection with our products and services to understand which parts of our digital platforms and services are of the most interest and to improve the design and content of our platforms;
• to improve our Products and Services and our communications to you; and
• (wherever applicable) to ensure we have up-to-date contact information for you.

Biotech may invite you to participate in customer surveys. The questionnaires used for these surveys are designed in such a way that the questions can be answered without providing personal information. However, any personal information provided in a questionnaire or survey may be used by Biotech to improve its Products and Services.

4. How long will we keep your personal information?

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.

We will always keep your personal information for the period required under the applicable laws and where we need to do so in connection with legal action or an investigation involving Biotech.

Otherwise, we keep your personal information:

• for as long as needed to provide you with access to services you have requested;
• where you have contacted us with a question or request, for as long as necessary to allow us to respond your question or request.

However, as part of the provision of our services, your information may under certain circumstances be transferred to third parties who we have included in order processing, e.g. business partners or IT service providers. When transferring personal information to these third parties, we restrict ourselves to the information which is necessary for the provision of the service in question and we ensure that this transfer is carried out in compliance with the required data security. Biotech will only transfer your personal information to third parties which have committed themselves to data protection and to the processing of your information in compliance with the applicable laws as in force.

In addition, Biotech may be forced by court or official orders to disclose your data and associated information. Likewise, we reserve the right to use your information for the assertion of or defense against legal claims.

Provided it is clarified that any personal information you submit is treated as confidential and is saved and processed exclusively within the scope of the relationship between you and Biotech.

In the event of a takeover or merger with another company, it may be necessary to disclose or transfer your information to actual or potential buyers. In this case, Biotech shall aspire to the highest possible level of data protection and will comply with all legal stipulations.

5. When and to Whom Do We Disclose Your Information?

The information we collect from and about you may be disclosed:

• to the subsidiaries and affiliates within the Biotech Group of Companies, for the purposes described in this Privacy Policy;
• to third parties that provide services to us, such as those that fulfil requests for information, answer calls,administer programs or projects, assist in research and development, or deliver advertisements or other communications;
• to business partners who offer Products or Services jointly with Biotech;
• to permit a third party business partner to deliver marketing communications or products that may be of interest to you, subject to any choices you have expressed;
• to identify you to any person to whom you send messages through the Website;
• to any person you direct us to contact, such as your designated representative/caregiver(s);
• by you, on message boards, chat, profile pages, blogs, and other services to which you post information and materials. Because any information you post may become public, we urge you to be very careful when deciding to disclose any information on or through the Services;
• to your friends associated with your social media accounts, to other Website users, and to your social media account providers, in connection with your social sharing activity, such as if you connect your social media account to your Website account or log into your Website account from your social media account. By connecting your accounts, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media provider’s own privacy policy;
• as required by applicable laws, such as to law enforcement, to health authorities to report possible adverse events, during government inspections or audits, as ordered or directed by courts or other governmental agencies, or in order to comply with asubpoena or other legal process;
• when we believe in good faith that disclosure is necessary to protect legal rights or the or the safety of others; investigate fraud, a breach of contract, or a violation of law; respond to a government request; or allow us to pursue available remedies or limit the damages that we may sustain; and
• to third parties, advisors, and other entities to the extent reasonably necessary for development of or to proceed with the negotiation or completion of a corporate or commercial transaction, including a reorganization, merger, acquisition, joint venture, sale or other disposition of all or a portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

6. Your Choices

Where you have elected to participate in one of our programs or services or to receive to opt out of receiving those communications in the communication itself. Alternatively, you can contact us to opt out using the contact information found in the “How to Contact Us” section at the end of this Privacy Policy.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across websites or other online services.

7. Accessing and Updating Your Information

If the Information provided by you when you applied for a Product or Service on our Website changes, you may update it whenever you apply for a new Product or Service.

We encourage you to update the personal information you provide to us to help us continue to provide information that best meets your needs. You may be able to access and update this information through the member account section of the Service for which you registered, or you can contact us by using the contact information found in the “How to Contact Us” section at the end of this Privacy Policy. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

Your personal information may be processed by Biotech, its affiliated companies and Biotech’s trusted third party suppliers outside of your home country. Data privacy laws in the countries to which your personal information is transferred may not be equivalent to, or as protective as, the laws in your home country.

We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws.

If you wish to cancel your account or request that we no longer use your information to provide you any kind of Services you can contact us using the contact information found in the “How to Contact Us” section at the end of this Privacy Policy.

8. Data Protection:

Biotech is aware how important it is that the information you provide to us is handled discreetly and is protected. Data security and privacy on our Website is a top priority. We have therefore made great efforts to ensure that our online security measures are effective. Essential data traffic on the Biotech Website is therefore encrypted. Biotech endeavors to update its encryption technology on a continuous basis in line with technical progress, in order to guarantee the confidential handling of the information you send us over the Internet.

In addition, we use a variety of security measures and technologies to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction in line with applicable data protection and privacy laws. For example:

1. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it.
2. We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Biotech accounts and systems from unauthorized access.
3. All electronic financial transactions entered into and/or through our Website will be protected by encryption technology.
4. When you register at our Website, the Website requires a password from you for your privacy and security. The Website transmits information such as your Registration Information securely.
5. Our databases are protected from general employee access both physically and logically.
6. While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of the Website after your sessions. If you have any questions about security on our Website, you can contact us using the contact information found in the “How to Contact Us” section at the end of this Privacy Policy.

9. Websites that we do not own or control

From time to time we may provide links to websites or mobile applications that are not owned or controlled by us. This Privacy Policy does not apply to those websites. If you choose to use those websites, please check the legal and privacy statements posted on each website or mobile application you access to understand their privacy practices.

10. What if you do not want to provide us with your personal information?

Where you are given the option to share your personal information with us, you can always choose not to do so. You can also request the correction of your personal information or restrict or object to the processing of your personal information.

You are also entitled to request information regarding the personal data we process at any time, you may also object to the processing of this information as well as request that the extent to which your personal information is processed be limited, that information be corrected or that information be deleted. Please note that Biotech may only delete your personal information in the event that no legal stipulations exist which require this information to be stored, or in the event that Biotech’s right to store this information does not take precedence over your right to have it deleted. Please also note that once you have requested to have your information deleted, or to have the processing of your information limited, or you have objected to the processing of your information, you may then no longer be able to use Biotech services, in part or in full, which require the use of your personal information.

If your personal information is being used by Biotech because you have agreed to have it used, or because it is required for the fulfilment of a contract you have concluded with Biotech, you may request a copy of the information that you have made available to Biotech. Please send your request using the contact information found in the “How to Contact Us” section at the end of this Privacy Policy. Be sure to include which data or processing activities you are requesting information about, in what format you would like to receive this information, and whether the information should be sent to you or another recipient. Biotech will carefully review your request
and inform you of the best way to fulfil it.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. This could however mean that we may not be able to perform the actions necessary to achieve the purposes as set out in the section ‘How do we use your personal information above or that you are unable to make use of the Services and Products offered by us.

11. Information relating to Children

Biotech does not intentionally collect or process the information of children under the age of 16, or as required by local laws, except on websites intended specifically for children. Biotech adheres to the applicable data protection laws with respect to such websites.

12. Intellectual Property

The Website and the contents contain copyrights, patents and other proprietary materials that are owned by Biotech, its affiliates and/or third parties and are protected by intellectual property laws of the country.

You should assume that all content of the Website is copyrighted unless otherwise noted and may not be – used, copied, reproduced, downloaded, modified, published, distributed, transmitted, or exploited, in whole or in part, in any form or by any means, except as provided herein and not without the express written permission of Biotech or the original creator of the material.

Product names, logos, trademarks, and service marks that are used or displayed on the Website (collectively, the “Trademarks”)are registered or unregistered trademarks and the exclusive property of Biotech or its affiliates. No use of the Trademarks may be made without Biotech’s prior written authorization, except to identify the Products and/or Services of Biotech. Other product names, logos, trademarks, and service marks appearing on the websites that are not owned by Biotech may not be used without express permission from its owner.

Nothing contained herein shall be construed as conferring by implication, estoppel, or otherwise any license or right, either express or implied, under any intellectual property of Biotech or any third party.

13. Modifications and Amendments

We may revise, amend, modify or update this Privacy Policy from time to time to reflect changes to our information practices and/or to ensure that it complies with current legal requirements and covers all of ours Products and/or Services through our Website. If we make any material changes we will notify you by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices and cookie policy.

Your legal rights to information, rectification, blocking, erasure, and objection are not affected by these changes.

14. Contact Us

If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, contact us as under:

The Corporate Data Protection Officer

Biotech Healthcare Group

Address: Biotech Vision Care Pvt. Ltd.1st Floor, Plot No. 555-556-557, Near Shubham Tex-O-Pack, Khatraj-Vadsar Road, Taluka Kalol, District Gandhinagar, Gujarat – 382721, INDIA.

E-mail: dpo@biotechhealthcare.com

Telephone: 02764-662000