Privacy Policy

This privacy policy (the “Privacy Policy”) was last modified on 15 April 2021.


Pharmatrade Sal (“Pharmatrade”, “us”, “we”, “our”) has obtained the necessary authorizations from the Lebanese Ministry of Public Health (MoPH) to import and distribute the Sputnik V vaccine (the “Vaccine”) in Lebanon, in compliance with the applicable laws and regulations, namely Law no. 211 of 16/01/2021 on Regulating the Emerging Use of Medical Products to Combat the COVID-19 Pandemic.


Pharmatrade operates the web application https://vaccine.pharmaline.com.lb (the “Application”), and may recourse to the services of a web platform operated by NEXtCARE Lebanon SAL for vaccination appointments scheduling purposes (the “Scheduling Platform”) (the Application and the Scheduling Platform shall together be referred to as the “Platforms”).


This Privacy Policy sets out the policies adopted by Pharmatrade Sal in compliance with Law no. 81 dated 18/10/2018 regarding the collection, storage, processing, use and sharing of information provided to it in connection with the purchase and/or use of the Vaccine.


By using the Platforms, reaching out to Pharmatrade by phone or email regarding the purchase of the Vaccine or vaccination appointments, and/or signing the Individual Vaccine Consent Form related to the administration of the Vaccine, you (“you”) agree to the collection, storage, processing, use and sharing of information in accordance with this Privacy Policy. If you use the Platforms on behalf of another person, you acknowledge that you are authorized to accept this Privacy Policy on their behalf.


The Privacy Policy does not extend to any other website or application that you may access through the Platforms, each of which may have their own privacy policy. The information provided by individuals on the web platform IMPACT (https://covax.moph.gov.lb) is subject to said application’s own privacy policy.


DATA COLLECTION


We collect information:


  1. when you visit and use the Platforms;
  2. when you provide information by completing the application forms on the Platform;
  3. from legal entities that fill information on behalf of their staff members;
  4. when you sign and provide the Individual Vaccine Consent Form related to the administration of the Vaccine;
  5. when you send us an email or contact us by any other means; and
  6. through website analytics services and other technologies.

We will collect and process personally identifiable information, namely as detailed below:



The entry of data on the Platforms is optional and if you choose to provide the information, such information shall be registered. In some instances, choosing not to provide certain information will affect usage of the Platforms and limit access to some of the services.


DATA USE


We will use the personal information provided to us for the below purposes:


  1. To analyze the provided information and classify registered legal entities and individuals into groups and determine the modalities and timing of Vaccine distribution and administration;
  2. To organize the distribution of the Vaccine in Lebanon and the administration of the Vaccine in the vaccination centers located across Lebanon;
  3. To respond to questions and communications in the ordinary course of business;
  4. For analytical purposes, and to assist us in improving our processes, services, and products;
  5. To contact users and applicants as needed;
  6. To comply with our legal obligations; and
  7. For any other purpose described in this Privacy Policy.

DATA PROCESSING AND DISCLOSURE


We will ensure that your personal data is processed in a manner that is compatible with the purposes indicated in this Privacy Policy.


For the purposes indicated in this Privacy Policy, your personal data may be disclosed to the following parties:

  1. The Ministry of Public Health if requested by it in compliance with applicable laws;
  2. NEXtCARE Lebanon SAL for appointment scheduling purposes;
  3. The vaccination centers who will be administering the Vaccine.

Certain staff members of Pharmatrade and companies affiliated to Pharmatrade, namely Malia Trust Sal and Pharmaline Sal, have access to the data on a strict need-to-know basis for purposes of ensuring the smooth operation of the Platforms. They are subject by contract to non-disclosure obligations and are legally bound to use the data they have access to only in line with applicable laws.


Your personal data will be processed by us subject to the confidentiality and security obligations by which we are legally bound and in compliance with applicable laws. Personally identifiable information will only be shared as set out in this Privacy Policy.


DATA PROTECTION AND SECURITY


The data is hosted on servers outside Lebanon. We have taken the necessary measures to protect the collected data on the servers, and have established the required procedures in compliance with applicable laws and industry practices to ensure the security of the data.


While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.


DATA RETENTION


We shall retain the personal data for as long necessary to ensure the proper distribution of the Vaccine and the scheduling of the appointments for the administration of the Vaccine at the vaccination centers.


We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Platform, or when legally obligated to retain this data for longer time periods.


ACCESS AND MODIFICATION OF INFORMATION


You, and any of your heirs, may access the collected data which you provided, and may request the data protection officer indicated below to (1) inform you of (i) whether and how your personal data is being processed, (ii) the purpose, type, source, subject and nature of the data processing, (iii) the type and identity of the persons to whom the personal data is disclosed or those who can access the same, as well as the timing and purposes of such disclosure and access, and (2) to provide you with a legible copy of your personal data.


You, or any of your heirs, may request the data protection officer to correct, complete, update and/or erase your personal data which is incorrect, incomplete, ambiguous, expired or incompatible with the purposes of processing, or which is not to be processed, collected, used, saved or transferred.


You, and any of your heirs, will be required to present sufficient documentation to verify your identity in order to access and modify your personal data.


We will notify any third-party that has access to your personal data of the amendments made at your request or that of any of your heirs.


COOKIES


Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.


Like many online platforms, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the Platforms.


CONTACT US


If you have any questions about this Privacy Policy, please contact our data protection officer at vaccine@maliagroup.com.


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