Service usage policies

THESE TERMS AND CONDITIONS OF USE OF THIS AGREEMENT SHOULD BE READ CAREFULLY BEFORE USING THE WEBSITE

By accepting this Agreement (the or this “Agreement”), you (the “User”) conclude the agreement between you and the Company on the terms and conditions set forth below. The text of the Agreement is available at: https://findhospital.com/service-usage-policies/

Parties:

LECHU GROUP DWC-LLC (UAE), a limited liability company, organized and existing under the laws of the United Arab Emirates, license number 11452813, address: Dubai South Business Centre, Building C – 3rd Floor, Dubai Logistic City, PO Box 390667, Dubai, U.A.E. (the “Company”), and the User (hereinafter the User and the Company may be separately referred to as a “Party” and jointly as the “Parties”).

This Agreement incorporates and is subject to the privacy and data protection policy (the “Policy”) in its version applicable to you as the User (Sections 6.2 or 6.3) and being an integral part of this Agreement.

Services

The Company provides:
1. Information and Consultancy Services: the Website (Section 16.1.13) allows the User to obtain the information about the Clinics (Section 16.1.1); to place queries for the selection of the Clinic for Medical Treatment (Section 16.1.1); the User may consult with the Company by phone, messengers, email or otherwise.
  The Company determines the scope of the Information and Consultancy Services available to the User at its sole discretion and may modify the scope at any time without any notice to the User (Section 7).
2. Organizational Services: organizing the User’s trip to the Clinic, including visa consultancy support, tickets purchase, booking of accommodation, and other similar services at the expense of the User. The Parties shall agree upon the Organizational Services separately.
Services FeeS
1. The Company provides the Information and Consultancy Services free of charge.
2. The Parties shall agree upon the Fee for the Organizational Services separately; these Services shall be paid for by the User separately against the Company’s invoice.
Agreement conclusion and termination
1. With regard to the Information and Consultancy Services, the Agreement shall be deemed accepted by the User and concluded by one of the following:
  1. contacting the Company by phone, messenger or email;
  2. completing and sending of the Website online form for feedback.
2. With regard to the Organizational Services the User will conclude a separate contract (the “Contract”) with the Company by paying the Company’s invoice setting out the terms and conditions of the Organizational Services.
3. The User may terminate the Agreement in respect of Information and Consultancy Services (Section 1.1) anytime by ceasing to use the Website and informing the Company of his/her refusal to receive the information earlier requested (if such query took place).
4. As for the Organizational Services (Section 1.2), the User may terminate the Contract with the Company by a notice to the Company, provided the User fully paid to the Company for the Organizational Services delivered, and reimbursed the Company for the expenses incurred in connection with the Organizational Services. The User may not terminate the Contract with regard to the Organizational Services which the Company has already commenced.
5. As to the Information and Consultancy Services, the Company may at any time unilaterally, by notice to the User:
  1. terminate the Agreement and deny the User’s access to the Website if the Company has reasons to believe that the User breaks the terms of use of the Website (Section 5) or uses the information received from the Company for purposes not connected with the Medical Treatment for himself/herself or his/her family members;
  2. terminate the Agreement if the Company thinks that the further consultancy or services requested by the User will cause the unreasonable expenditure of funds or time for the Company.
6. As to the Organizational Services, the Company may unilaterally terminate the Contract on the terms set out in the Contract.
Сompany’s representations
1. Under no circumstances will the Company:
  1. provide medical care or medical services;
  2. act as the Clinic’s or User’s agent or give to the User warranties or representations regarding the Clinic selected by the User, the opportunity to receive the Medical Treatment as set forth in this Agreement, reaching the outcomes desired by the User, feasibility to travel to the Clinic including the granting by the competent authorities of the states of location of the User or the Clinic of exit or entry visas or other permissions.
Website Use restrictions
The User shall not act or try to act as follows:
1. interfere, modify or turn off any functions, functionality or the software safety control tools;
2. destroy, bypass, delete, deactivate or otherwise bypass any software or data protection mechanisms;
3. re-engineer, decompile, disassemble or extract the software source code, as well as any underlying ideas, algorithms, structure or organizational form;
4. use the Website’s software or Content, as well as the written or oral information received from the Company’s representatives, for other purposes (except for obtaining information of the Clinics, organization of the trip to a Clinic, and for the Medical Treatment of the User or his/her family members) including: revise, distribute, publish, give access to or transfer to third parties the right to use any of the Website components.
Personal data
1. The Company processes the Users’ personal data in accordance with the Company’s Policy.
2. If the User’s permanent residency is in any of the EU states or the UK the User’s personal data shall be processed in accordance with the Company’s Policy available at: https://findhospital.com/en/service-usage-policies/
3. If the User’s permanent residency is in any state except for those specified in Section 6.2, the User’s personal data shall be processed in accordance with the Company’s Policy available at: https://findhospital.com/service-usage-policies/
4. The personal data the User transfers to the Company which are to be further forwarded to any of the Clinics may be also processed in accordance with the rules and procedures adopted by such Clinic. The link to the Clinic’s policy is available in the Clinic’s profile on the Website.
Access AND Changes
1. The User is responsible for making all necessary arrangements to have access to the Website.
2. The User is also responsible for ensuring that all persons who access the Website through the User’s device are aware of this Agreement and other applicable terms and conditions that may apply, and that such persons agree and comply with all such terms and conditions.
3. The Company may update the Website from time to time and may change the content on the Website at any time and without notice. If any of the content on the Website is out of date at any given time, the Company is under no obligation to update it. Although the Company makes reasonable efforts to update the information on the Website, the Company makes no representations, warranties or guarantees, whether expressed or implied, that the content on the Website is accurate, complete or up-to-date.
Warranties
1. Each Party hereby warrants to the other Party that it has the full power and authority to enter into and perform this Agreement.
2. The Company hereby represents and warrants to the User that it is the sole owner of the Website, and it has the right to license the Website to any third party and/or render the Information and Consultancy Services as contemplated in this Agreement.
3. The User undertakes to perform this Agreement at all times in strict compliance to applicable laws and regulations. The User further undertakes not to do anything whether by act or omission which may bring the reputation of the Company into disrepute.
4. The User accepts responsibility for the selection of the Website to achieve its intended results and acknowledges that the Website has not been developed to meet the individual requirements of the User.
5. The Information and Consultancy Services under this Agreement are provided on an "as is" and "as available" basis without warranties of any kind, whether expressed or implied.
6. The Company does not warrant that the Information and Consultancy Services on the Website will be uninterrupted, timely, reliable, secure or error-free, and the Company expressly disclaims any warranties as to the information contained therein or services and/or Medical Treatment offered by the Clinics.
7. The Company provides no guarantee of any kind; the Company shall have no liability for any misuse of the Website, Medical Treatment of the Clinics, the Information and Consultancy Services as well as for incomplete or wrong data provided by the User or Clinic.
8. The Company is not liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect the User’s devices, programs, data or other Confidential Information due to the User’s use of the Website or downloading of any content on it, or on any Website linked to it.
REPRESENTATIONS OF THE USER
1. By using the Website, the User confirms and agrees that all the personal data he/she provided or provides in the future, are accurate, true, current, and complete.
2. By using the Website, the User confirms that he/she is legally able to consent to receive the Organization Services and/or Information and Consultancy Services or has the consent of a parent or guardian, and that the parent or guardian is legally able to give such consent.
Indemnity & Limitation of Liability
1. The User hereby agrees to indemnify, defend and hold harmless – the Company, and the Company’s present and future officers, directors, shareholders, employees, members, volunteers, contractors, clients, representatives, parents, owners, affiliates, agents, successors, heirs, assigns and other Company related parties –
  from and against any and all claims and proceedings asserted against such indemnitees and losses, liabilities, for any special, indirect, incidental or consequential damages, costs and expenses (including legal fees and disbursements in connection therewith and interest chargeable thereon) incurred by such indemnitees, –
  resulting from the use of the Organization Services, Information and Consultancy Services or Medical Treatment provided by the Clinics, or the Website, including, without limitation, any act, omission, opinion, response, advice, suggestion, information and/or service of any Clinic and/or any other content or information accessible through the Website.
2. The User agrees, by accepting this Agreement:
  1. that either he/she did not rely on any representations (whether written or oral) of any kind or of any person other than those expressly set out in this Agreement; or
  2. if he/she did rely on any representations, whether written or oral, not expressly set out in this Agreement – that it shall have no remedy in respect of such representations and (in either case) the Company shall have no liability in any circumstances otherwise than in accordance with the express terms of this Agreement.
3. The limitation and exclusion of liability of the Company set out in this Agreement shall not be construed as limiting or excluding the liability of the Company which cannot, under the applicable laws and regulations, be limited or excluded, such as liability for death or personal injury resulting from gross negligence or wilful misconduct.
Ownership & Intellectual Property Rights
1. The User acknowledges that all intellectual property rights (the “Intellectual Property Rights”) related to the Website and the Company exclusively belong and shall belong to the Company, and the User shall have no Intellectual Property Rights or other rights in or to the Website other than the right to use the Website in accordance with this Agreement.
2. The User agrees not to disclose, provide, or otherwise make available such Intellectual Property Rights or other rights of the Company in any form to any third party beyond the scope of this Agreement without the prior written consent of the Company. The User agrees to implement reasonable security measures to protect such Intellectual Property Rights or other rights of the Company.
Confidentiality
1. Each Party shall treat as confidential (as set forth in the Agreement) all and any information received from the other Party of a confidential nature disclosed (whether before or after the date of this Agreement) by or on behalf of one Party and all information, including, without limitation, regarding services of the Company; personal data, medical or service records or reports (the “Confidential Information”).
2. Each Party shall not use the Confidential Information except as contemplated in the Agreement.
3. Each Party shall implement reasonable procedures to prohibit the unauthorized disclosure or misuse of the Confidential Information and shall not disclose the Confidential Information to any third party except for the purposes of this Agreement, and subject to the third party accepting the confidentiality obligations similar to those set forth herein.
4. Each Party shall use at least the same procedures and degree of care that it uses to prevent disclosure of its own confidential information of like importance to prevent disclosure of the Confidential Information disclosed to it by the other Party under this Agreement, but in no event less than reasonable care.
5. Notwithstanding the above, neither Party shall have liability to the other with regard to any Confidential Information which:
  1. was publicly available at the time it was disclosed or becomes publicly available through no fault of the Party receiving the Confidential Information (the “Receiving Party”);
  2. was known to the Receiving Party, without similar confidentiality restriction, at the time of disclosure;
  3. is disclosed with the prior written approval of the Party which transfers the Confidential Information to the Receiving Party (the “Disclosing Party”);
  4. becomes known to the Receiving Party without similar confidentiality restriction from a source other than the Disclosing Party without breach of the Agreement by the Receiving Party.
6. In addition, each Party shall be entitled to disclose the Confidential Information to the extent required by any order or requirement of a court, administrative agency, or other governmental body, provided that the Receiving Party shall give a prompt advance notice thereof to enable the Disclosing Party to seek a protective order or otherwise prevent such disclosure.
Notices
1. Any notice given to the Company under or in connection with this Agreement shall be in writing and shall be:
Governing Law. Dispute resolution
1. This Agreement and all the documents referred to in it which are not expressed to be governed by another law, and all non-contractual obligations arising in any way whatsoever out of or in connection with this Agreement or any such documents, shall be governed by, construed and take effect in accordance with the laws of the United Arab Emirates. This Section shall not be construed as depriving the User of the rights and remedies available to him/her in accordance with consumer protection laws of the User’s place of residence, if, according to the applicable laws and regulations, such rights and remedies shall be available to the User regardless of the choice of law applicable to this Agreement.
2. The Parties shall resolve any dispute arising out of or relating to this Agreement through negotiations. If the matter is not resolved by negotiations within 30 calendar days from receipt of a written notice, the Parties agree that the matter shall be referred to and finally resolved by arbitration under the Arbitration Rules of the Dubai International Arbitration Centre (DIAC), which rules are deemed to be incorporated by reference into this Section. The number of arbitrators shall be one.
3. The seat, or legal place, of arbitration shall be the Emirate of Dubai. The language to be used in the arbitration shall be English.
Other provisions
1. Assignment. The User shall not assign to a third party any rights hereunder. The Company may, without the User’s consent, assign any rights hereunder in whole or in part to a third party.
2. Severability. If any provision or part of any provision of this Agreement is or becomes invalid, illegal or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, legal and enforceable. If such modification is not possible, the relevant provision or partial provision shall be deemed deleted. Any modification to or deletion of a provision or part of the provision pursuant to this Section 15.2 shall not affect the validity and enforceability of any other part of this Agreement.
3. No Third-Party Rights. Unless otherwise specifically stipulated in this Agreement, a person who is not a party to this Agreement shall not have any rights under this Agreement.
4. Force Majeure. Neither Party shall be responsible for a failure or delay of performance hereunder solely due to an acts of war, hostility or sabotage, acts of God, governmental acts or restrictions, revolutions, civil disturbances, riots, insurrections, epidemics, or any other events beyond the reasonable control of the obligated Party (the “Force Majeure Event”), provided, however, that such Party (i) has not contributed to such Force Majeure Event; (ii) has exerted reasonable efforts to avoid such Force Majeure Event or to mitigate its effects; and (iii) continues to exert reasonable efforts to comply with this Agreement. The Party prevented from performing the Agreement due to a Force Majeure Event shall promptly notify the other Party of the occurrence of such Force Majeure Event specifying the details and the estimated duration thereof.
  The Parties have agreed to consider the COVID-19 epidemic as a non-Force Majeure Event.
5. Form and Signature. Any document to be executed pursuant to the Agreement may be executed by stamped, facsimile, or electronic signature, including the actual approvals performed via the Website. Such signatures shall have the same validity and effect as a signature affixed by hand (i.e., acknowledged by the Parties as executed in a simple written form). Electronic signature means data in electronic form which is attached to or logically associated with other data in electronic form and which is used by the Party to sign, and includes, but is not limited to, to a simple electronic signature by DocuSign or by any similar service.
DEFINITIONS. INTERPRETATION
1. The following definitions shall apply to the terms set forth below wherever they appear:
  1. Clinic – any organization or institution listed in the Company’s Website (Section 16.1.13) providing services of a medical nature (the “Medical Treatment”) on the basis of the agreement between the Clinic and the User.
  2. Company shall have the meaning defined in the Preamble of the Agreement..
  3. Content shall have the meaning defined in Section 16.1.13.
  4. Confidential Information shall have the meaning defined in Section 12.1.
  5. Contract shall have the meaning defined in Section 3.2.
  6. Disclosing Party shall have the meaning defined in Section 12.5.3.
  7. Intellectual Property Rights shall have the meaning defined in section 11.1.
  8. Force Majeure Event shall have the meaning defined in Section 15.4.
  9. Medical Treatment shall have the meaning defined in Section 16.1.1.
  10. Software shall have the meaning defined in Section 16.1.13.
  11. User shall have the meaning defined in the Preamble of the Agreement.
  12. Receiving Party shall have the meaning defined in Section 12.5.1.
  13. Website means a set of the software belonging to the Company and available at URL (the “Software”), of the databases connected to its functioning, as well as of the texts, graphics, drawings, photos, audio and video materials (the “Content”) facilitating the receipt of the information and selection of the Clinic for the User, including information about the cost of the Medical Treatment and the method of payment, as well as any other information that may be provided by the Company or Clinic to organize the Medical Treatment.
2. The references to the Section and Sections are the references to the Sections and Sections of this Agreement.
3. The terms and conditions contained on the web-pages of the Company’s Website referred to in this Agreement shall be considered an integral part of this Agreement in the edition effective at the given time.
  By accepting this Agreement, the User hereby expressly declares and confirms that the User has read this Agreement and understands the contents of this Agreement in full and agrees to abide by this Agreement as set out herein.

PRIVACY AND DATA PROTECTION POLICY

1	SCOPE. REGULATION	2
2	INFORMATION WE COLLECT	2
3	USE OF DATA	3
4	WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES	4
5	WITH WHOM WE SHARE INFORMATION	5
6	USE OF COOKIES	6
7	TRANSFER OF YOUR INFORMATION	7
8	RETENTION OF YOUR INFORMATION	8
9	MINORS’ PRIVACY	8
10	YOUR DATA PROTECTION RIGHTS	8
11	AUTOMATED DECISION MAKING	9
12	CHANGES TO POLICY	9
13	CONTACT US	9
14	INTERPRETATION	10

Version 1.0

Issued on 1 november 2021

SCOPE. REGULATION
1. This privacy and data protection policy (the “Policy”) governs the privacy terms of our website, located at https://findhospital.com (the “Website”).
2. The Policy is a legal statement, which explains how FindHospital (UAE), a limited liability company, with License No. 11452813, having its registered address at Dubai South Business Centre, Building C – 3rd Floor, Dubai Logistic City, PO Box 390667, Dubai, UAE (the “Company” or “we” or “us”), collects, retains, processes, and transfers the information about you (the “Customer” or “you”) which we receive when you access or use the Website (the “Personal Data”).
3. You accept the Policy by using any of the Services (as defined in Section ‎14.2.10).
4. Please, read the Policy carefully, as it will help you to make informed decisions about sharing your Personal Data with us.
5. The Policy is incorporated into and is subject to the Terms and Conditions of Use (the “Agreement”) being integral part of this Policy.

INFORMATION WE COLLECT

We collect two types of the Personal Data for various purposes to provide you with the Services and to improve them. These types are the information you give us directly when you use the Website, Services, and interact with the Company by, for example, using the Website, and the second type is when are you contacting the Company for support during which the Personal Data is collected.

Information you give us. You give it to us in two ways:
1. via special communication channels denoted on the Website: email, messengers (Telegram, WhatsApp, Viber) etc.; or
2. (1) you use the Website, and your browser settings allow saving cookie files and using JavaScript, and (2) you have not blocked the automatic data transmission.
In this case we process only the data specified in Section ‎2.1.3.
The information you give us may include the following Submitted Data:

Type of information	Information we collect
2.1.2.1. Personal and Contact Details	full name, email address, phone number, logins to messengers and other information in your messenger (statuses, etc.).
2.1.2.2. Identity Data	copies of identification documents such as passport, ID card, other data which may be requested by the embassy (consulate) of the state of the Clinic’s (as defined in Section ‎14.2.2) location.
2.1.2.3. Personal Health Data	clinical record, medical card, diagnosis, results of medical examinations, your other personal health details necessary to find the Clinic.
2.1.2.4. Family and Dependents’ Health Data	clinical record, medical card, diagnosis, results of medical examinations, other details of the health of your family member or dependent necessary to find the Clinic.
2.1.2.5. Parent (Guardian) Status Data	information about your family relations or the status of the legal guardian if we process the data specified in Section ‎2.1.2.4.

Information automatically collected. We automatically collect certain information when you visit, use or navigate the Website (the “Usage Data”). The Usage Data is your IP-address, the information about the software (browser, etc.), regional and language settings, and the devices you use; the search queries when you use search tools on the Website; date, time and URL addresses of the web pages you access and other similar data; your anonymized data (including the cookie files) which we collect via the internet statistics services such as Google Analytics, YandexMetrika etc.

USE OF DATA

We use the Personal Data we collect for the following purposes:
1. as it is necessary for our legitimate business interests; and/or
2. to enter into or perform a contract with you; and/or
3. as you have given consent, so that we process the information; and/or
4. to comply with our legal obligations.
Please find the description of how we use your Personal Data, legal bases on which we rely, what are our legitimate interests (where appropriate):

Type of data we use	Purpose and/or activity and legal basis
3.2.1. Personal and Contact Details, Identity Data	We use it to: (1) verify your identity; and (2) execute, at your initiative, an agreement between you and us. The subject matter of this Policy is using the Website, delivery of the Information and Consultancy Services (as defined in the Agreement at https://findhospital.com/en/service-usage-policies/; and (3) fulfill our obligations under the Agreement, namely provide the Services to you.
3.2.2. Personal Health Data. Family and Dependents Health Data	We use it to perform the Agreement with you and based on your written consent to process this data. The data is used to select the Clinic matching your needs, including the preliminary consultation with the Clinic’s medical personnel; to determine the program of the services of medical nature (the “Medical Treatment”) and their price.
3.2.3. The Usage Data	We use it for our legitimate interests, namely to: (1) analyze how you use the Website, your behavior on the Website to improve our Services; (2) determine the country of your location and suggest to you a comfortable language version of the Website, Agreement and to select the Privacy Policy applicable to you; (3) detect, prevent and address technical issues of our Website; (3) administer our Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; (4) ensure that we present the content of our Website to you in the most effective manner; (5) keep our Website safe and secure.
3.2.4. Contact Details	We use it for our legitimate interest which is direct marketing. If you agree we will provide you with news, information about changes to the Services, special offers and general information about other services we offer, similar to those that you have already purchased or enquired about. We use it to perform the Agreement as well: it is impossible to provide you with the Services without communicating with you.
3.2.5. the Submitted Data, the Usage Data	We use it to comply with our legal obligations, namely to: (1) respond in the course of legal, regulatory, arbitration procedures; (2) respond to requests for information, which are issued by public authorities or other third parties; (3) prevent harm as legally required. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

We process some of the Personal Data based on your consent: clinical record, medical card, diagnosis, results of medical examinations, your other personal health details and/or the same health details of your family members and dependents necessary to find the Clinic.
You should give your consent for processing the Family and Dependents’ Health Data if the family member is under the age of 16 (unless lower age threshold is prescribed by the applicable law), or if the dependent is legally incapable. In other cases, the family members or dependents shall give their own consent.

WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES
1. We only share the information:
  1. to comply with laws;
  2. to protect your rights;
  3. to fulfill the business obligations (for example, if it is necessary to engage a third party to provide you with the Services);
  4. if you granted us your consent to do so.
2. By accepting the Policy, you agree that we may disclose the information about you only:
  1. To comply with laws. We may disclose your information where we are legally required to do so to comply with the applicable law, governmental requests, a judicial proceeding, court order, or legal process. For example, we may disclose the information in response to a court order, a subpoena, public authorities’ requests to meet national security or law enforcement requirements. We may also disclose your information when we conduct or cooperate in investigations of fraud or other illegal activity, to prevent and detect fraud or crime;
  2. To allow third parties to render the services. We may share your data with business partners, service providers, contractors or agents performing the services for us or on our behalf and require access to such information to perform their obligations. The examples of such third-party services are our transportation providers (airlines, taxi, etc.), accommodation providers (hotels, private accommodation, etc.), payment processors, data analysis providers, email services providers. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect the data about how you interact with the Website over time. We may also share the information about you with our Affiliates (the “Affiliates”) which include our parent company and any subsidiaries, joint venture partners or other members of our group of companies. Our affiliates, partners and contractors will be required to meet our standards on processing data and security;
  3. To transfer our business. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We will provide you with the notice before your Personal Data is transferred and become subject to a different privacy policy;
  4. If you agreed. We may disclose your Personal Data for other purposes described in this Section ‎4 if you granted us consent to do so.

WITH WHOM WE SHARE INFORMATION

Clinics
1. We share and disclose your Submitted Data to the Clinics listed on our Website. The Clinics process the Submitted Data as described in their privacy policies available in the Clinic’s profile on the Website.
Storage Providers
We store the data on our secured servers in the Netherlands:

Storage provider	Who operates it	Where can you read the privacy policy
5.2.1. GoDaddy	Go Daddy Netherlands BV, Schiphol Boulevard 3591118BJSchiphol	https://nl.godaddy.com/legal/agreements/archived-privacy-policy

Advertising Websites and Applications The websites we use for advertising allow us to optimize and serve advertising based on your using of the Website. These websites track the Usage Data and use Сookies (as defined in Section 6.1.2)

Advertising Website	Who operates it	Purpose, for which we use it	Who and how stores and processes the data	Where can you read the privacy policy	How can you opt out
5.3.1. Google Ads	“Google”: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA	(1) to track your actions after you have been forwarded to our Website by clicking the Google advertisement; (2) to measure the effectiveness of Google Ads for market research and statistical purposes, in particular, to better understand and deliver ads and make them more relevant to you	Google	https://policies.google.com/privacy	s described at https://policies.google.com/technologies/ads, in the Section How you can control advertising Cookies
5.3.2. Facebook Pixel; Facebook SDK	“Facebook”: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (for EU residents)	(1) to track your actions after you have been forwarded to our Website by clicking a Facebook advertisement; (2) to measure the effectiveness of Facebook ads for market research and statistical purposes, in particular, to better understand and deliver ads and make them more relevant to you	Facebook. The data are anonymous to us. The Facebook may connect this data with your Facebook account and use it for its own advertising purposes	https://www.facebook.com/about/privacy/	(1) for Facebook Pixel – through your Facebook account settings. You can do so both for Facebook Pixel and Cookies; (2) for Facebook SDK – via your device settings

Marketing and Analytics Websites
We share and disclose your Cookies and Usage Data for the web and mobile analytics purposes and to personalize the content on our Website: for example, to offer you not all our Services but the ones in which you might be interested.

Provider	Who operates it	Purpose, for which we use it	Where can you read the privacy policy	How can you opt out transmitting and processing the data generated by Cookies by third party provider
5.4.1. Google Analytics	Google	(1) to track the Website traffic and your behavior at the Website; (2) analyze, how you use the Website to improve its performance and manage advertising placements based on your interests and preferences	https://policies.google.com/privacy	By installing the add-on for your browser: https://tools.google.com/dlpage/gaoptout
5.4.2. Yandex.Metrika	Yandex	(1) to track the Website traffic and your behavior at the Website; (2) analyze, how you use the Website to improve its performance and manage advertising placements based on your interests and preferences	https://yandex.ru/legal/confidential	by installing the add-on for your browser: https://yandex.com/support/metrica/general/opt-out

USE OF COOKIES

How we Use Cookies
1. We use cookies to distinguish you from other users of our Website. This helps us to improve your experience and the Website itself: we store your preferences and analyze how you use the Website.
2. A Сookie is a small amount of data stored in your web browser while you are browsing our Website. Our Website sends cookies to your browser; your device stores them. We assign a different cookie to each device which accesses our Website. Using cookies will not give us access to any data on your device other than the data stored in the cookie. The cookies we collect do not store your Personal Data such as name or your address.
3. The Cookies are stored no longer than 24 months. Anyway, you can easily delete Cookies in the web browser settings. You can learn more about Cookies management in Section ‎6.3.
4. By using the Website, you consent to the use of Cookies as specified in the Policy.
Types of Cookies we Use

Cookies Type	Why do we use them. Other comments
6.2.1. essential cookies	they are necessary to operate our Website. Without the use of these cookies, some parts of our Website would not function
6.2.2. functional cookies	we use them to identify your preferences and customize the Website subject to them. Functional cookies allow us to remember the choices you have made on our Website and store information that you have already provided (e.g. language and other preferences) to enhance your browsing experience. These features help us to improve your visit to the Website
6.2.3. analytical and performance cookies	they: (1) collect the information about how you use our Website, including to which pages you go most often; (2) allow us to see the patterns of how you use the Website; and (3) help us to record any errors appearing during your use of the Website. These cookies do not identify you and all the information is anonymous to us. We use them only to improve functioning and performance of our Website. We may engage third parties to track and analyze how you use our Website as described in the Policy
6.2.4. third party cookies	some of our third party service providers use their own cookies on our Website and we do not control such cookies. Third parties use their cookies for analytical and targeting purposes. Using the information, which third parties collect using their cookies, is governed by their privacy policies. This Policy does not cover the use of cookies by any third party service provider. Please, see section 5 to know, with whom we share the information.

Cookies Management
1. You can customize cookies, delete, or refuse all the cookies any time: just activate the setting of your browser which allows you to refuse the cookies. Please note that this can lead to impossibility to access certain functions of the Website.
2. For more information about the cookies management, including refusal from them, please refer to the settings of the browsers: Chrome, Edge, Firefox, Internet Explorer, Opera, Safari. You can also opt out the cookies which are used by Google or Facebook, as specified in Sections ‎5.3.1 and ‎5.3.2.
The Customer may consent to certain categories of the optional Cookies. The Customer also may adjust choices.
Certain features of the Website depend on the Cookies. If the Customer chooses to block the Cookies, the Customer cannot sign in or use some of those features, and preferences that depend on the Cookies. If the Customer chooses to delete the Cookies, any settings and preferences controlled by the Cookies, including advertising preferences, are deleted and will need to be recreated.

TRANSFER OF YOUR INFORMATION
1. The countries to which we or the third parties we engage transfer your data, may not have the same data protection laws as your jurisdiction. For example: (1) some third parties (Section ‎5) with which we share your Personal Data may be located in the Netherlands, Russia, the United States; (2) the European Commission considers these states as the countries which do not provide the personal data with adequate protection. So, in these cases we take reasonable security measures, which the applicable laws prescribe, to ensure that your data are properly protected when they are transferred outside your jurisdiction.
2. By accepting the Policy and providing us with your Personal Data (except the Personal Health Data and Family and Dependents’ Health Data which is transferred pursuant to the separate consent), you agree to such transfers. If you don’t agree to such transfers you will no longer be able to use the Website or ask us for other Services. If you are a resident in the EEA we may transfer your data outside the EEA to fulfill our contract with you (to provide you with the Services), as we provide an international service. When we make such transfers we: (1) comply with our legal and regulatory obligations; and (2) implement the appropriate safeguards such as executing standard data protection contractual clauses. We will take all the steps to ensure that your data are treated securely and in accordance with the Policy.
3. The Policy applies regardless of the location in which we store or process your Personal Data.

RETENTION OF YOUR INFORMATION

Retention period of your data depends on its category:

User category	Retention period
8.1.1. Сontact and Personal Details	(1) until we have selected the Clinic for you; or (2) until you have completed the Medical Treatment if you requested us to provide you with the Organizational Services (as defined in the Agreement).
8.1.2. Identity Data	until you complete the trip to the Clinic we organized for you.
8.1.3. Personal Health Data	same to Section ‎8.1.1.
8.1.4. Family and Dependents Health Data	(1) until we have selected the Clinic for your Family Member or Dependent; or (2) until your Family Member or Dependent has completed the Medical Treatment if you requested us to provide the Organizational Services.
8.1.5. Parent (Guardian) Status Data	same to Section ‎8.1.1 and ‎8.1.4.
8.1.6. Usage Data:
8.1.6.1. IP-address	until the end of the web session of the user
8.1.6.2. other data	24 months

A longer retention period may be required or permitted by law.
After the retention period ends we will
1. delete your Personal Data; or
2. anonymize it, so that it can no longer be associated with you.
We may use the anonymized data for research or statistical purposes or to improve our Services. We may use them indefinitely without further notice to you.

MINORS’ PRIVACY
1. Our Services are for general audience and can be used by minors. We process their data as Family and Dependents’ Health Data (Sections ‎2.1.2.4, ‎3.2.2, ‎8.1.4). If you are a minor and request for the Services yourself we may require you to provide us with the documents confirming your emancipation or legal consent of your parent or legal guardian.
2. Minors can access the publicly available parts of the Website and its content providing us only with the Usage Data. We collect, process, store and disclose the minors’ Usage Data as described in the Policy.

YOUR DATA PROTECTION RIGHTS

Your data protection rights are:

Right	What you may do	How to execute the right
10.1.1. to access the Personal Data	(1) obtain a confirmation, if we process your Personal Data; (2) access your Personal Data and the information, how we use your Personal Data	please, contact us, as specified in Section ‎13
10.1.2. to rectify inaccurate data	request that any incomplete or inaccurate Personal Data about you are corrected	please, contact us, as specified in Section ‎13
10.1.3. to object to processing	object to processing your Personal Data if we process them based on the legitimate interests (please, see the examples of our legitimate interests in Sections ‎3.2.3, ‎3.2.4), use them for direct marketing or statistical purposes	please, contact us, as specified in Section ‎13
10.1.4. to make us your data portable	request that in certain circumstances we provide you with a copy of your Personal Data in structured, commonly used and machine-readable format	please, contact us, as specified in Section ‎13
10.1.5. to have your data erased	request that we delete your Personal Data in some circumstances – for example, we no longer need them, or you withdraw your consent, which was the basis for processing	please, contact us, as specified in Section ‎13
10.1.6. to withdraw consent to processing the data	withdraw your consent for processing of your Personal Data	please, contact us, as specified in Section ‎13
10.1.7. to restrict the processing	ask to restrict or stop collection, use, processing and/or disclosure of your Personal Data	please, contact us, as specified in Section ‎13
10.1.8. to withdraw consent to electronic marketing	opt out receiving our marketing emails (if any)	please, contact us, as specified in Section ‎13 or click the unsubscribe link in any our marketing email
10.1.9. to be informed about the safeguards, which we arrange the data transfer to a third country or an international organization	ask us about these safeguards	please, contact us, as specified in Section ‎13
10.1.10. to file complaints	to complain to a data protection authority about our collection and use of your Personal Data	please, contact your local data protection authority

Please, note that we may ask you to verify your identity before we respond to the request and, in certain circumstances, charge a fee to cover our costs. Our time limit to respond is one month after we receive the request. If it takes longer to process your request, we will notify you. In any case, we cannot extend the response timeframe for more than two months after the first month for response passes. This Section ‎‎10.2 is not applied to your requests, which are specified in Sections ‎10.1.8, ‎10.1.10.
If you opt out of our marketing emails (Section ‎10.1.8) we may still need to send you Services-related emails; for instance, to inform you of the changes made to this Policy (Section ‎12).

AUTOMATED DECISION MAKING
We don’t apply automated decision making (making user profiles based on the Personal Data, etc.).
CHANGES TO POLICY
We may modify the Policy at any time. If we make material changes to the Policy, we may notify you on our Website or via email. We will also change the version number and issue date at the beginning of the Policy. Any changes we make to the Policy are effective on or after the issue date. Each new version replaces any prior version of the Policy. We encourage you to review the Policy frequently to be informed of how we are protecting your information.
CONTACT US
1. If the Customer has a privacy concern, complaint, or question, please contact the Company via email operation@lechumedical.com.
INTERPRETATION
1. References to Sections mean references to sections of this Policy. Expression “including” and other similar expressions mean including, without limitation.
2. The definitions in the Policy shall have the following meanings:
  1. Affiliates have the meaning specified in Section ‎4.2.2;
  2. Clinic means any organization or institution listed on the Website providing the Medical Treatment on the basis of the agreement between the Clinic and you;
  3. Company has the meaning specified in Section ‎1.2;
  4. Cookie(s) has the meaning specified in Section 6.1.2;
  5. Facebook has the meaning specified in Section ‎5.3.2;
  6. Google has the meaning specified in Section ‎5.3.1;
  7. Medical Treatment has the meaning specified in Section ‎3.2.2;
  8. Personal Data has the meaning specified in Section ‎1.2;
  9. Policy has the meaning specified in Section ‎1.1;
  10. Services mean the Information and Consultancy Services and the Organizational Services provided under the Agreement;
  11. Submitted Data has the meaning specified in Section ‎2.1.2;
  12. Usage Data has the meaning specified in Section ‎2.1.3;
  13. we has the meaning specified in Section ‎1.2;
  14. Website has the meaning specified in Section ‎1.1.

Service usage policies

PRIVACY AND DATA PROTECTION POLICY

Contents

Version 1.0

Issued on 1 november 2021