Privacy Policy

1. General provisions

1.1. The Privacy Policy (hereinafter referred to as Privacy Policy) shall define basic principles and policy of managing personal data of customers of NORAMEDA Private Limited Company (Company Reg. No. 140744584, registered address: Meistru Str. 8A, Vilnius c., address for correspondence: Gyneju Str. 16, Vilnius c.; hereinafter referred to as NORAMEDA) using the Internet website at www.gudruciovaistine.lt (hereinafter referred to as GUDRUCIO VAISTINE).

1.2. The Privacy Policy shall make you aware of management of your personal data by NORAMEDA. Personal data is any information, on the basis of which you are or can be identified, such as surname, first name, phone number, e-mail or postal address, information on your purchase (date, item, price, quantity, amount and discount) as well as any other information (hereinafter referred to as Personal Data).

1.3. The Privacy Policy shall be available for reading on GUDRUCIO VAISTINE website any time.

1.4. Your Personal Data shall be managed by NORAMEDA.

1.5. Collection, management and storage of your personal data shall be governed by the Privacy Policy, the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania and the General Data Protection Regulation No. 2016/679 (hereinafter referred to as GDPR).

1.6. Your usage of GUDRUCIO VAISTINE website shall mean you accept the Privacy Policy and confirm you are aware of the fact that your Personal Data is owned and managed by NORAMEDA by the means, for the purposes and in the manner intended in the Privacy Policy hereto.

2. Principles of managing Personal Data

2.1. NORAMEDA follows the Personal Data management principles listed below:

• 2.1.1. Personal Data are managed in the legal, integral and transparent manner.
• 2.1.2. Personal Data are collected for the pre-set, clearly defined and legal purposes and shall not be managed in a way incompatible with the purposes above.
• 2.1.3. Personal Data is adequate, appropriate and limited to the ones required for seeking the purposes above.
• 2.1.4. Personal Data is managed legally that is, only in the cases, when:
• 2.1.4.1 You give your consent or it might be concluded that you have given your consent to use the data for a particular purpose (e. g., subscription of a newsletter, participation in questionnaires and games (quizzes), placing an order or answering other questions regarding your contact information);
• 2.1.4.2 An agreement is made or fulfilled with you as one of the parties thereof;
• 2.1.4.3 Management of your Personal Data is required due to a legal interest of NORAMEDA or a third party receiving your Personal Data, if such legal interest is superior to your interests and basic rights and freedoms requiring to ensure protection of your Personal Data;
• 2.1.4.4 Management of your Personal Data is required for fulfilment of legal obligations applicable to NORAMEDA.
• 2.1.5. Personal Data is accurate and shall be updated, if necessary.
• 2.1.6. Personal Data is stored in the form you could be identified during the period required to achieve the pre-set purposes and not longer.
• 2.1.7. Personal Data is managed in the way ensuring the appropriate safety of Personal Data; your data is managed by the authorized staff exclusively.
• 2.1.8. All information on Personal Data being managed is confidential, unless disclosure of such data is required by legal acts.

2.2. The following persons are entitled to use services provided through GUDRUCIO VAISTINE website:

• 2.2.1. Any capable natural person from 18 years of age;
• 2.1.2. Any legal entity;
• 2.1.3. Any authorised representative of the persons listed above.

3. Personal Data management and storage period

3.1. NORAMEDA respects your right to privacy. Your Personal Data are collected and otherwise managed on GUDRUCIO VAISTINE website for the following purposes:

• 3.1.1. In order to process your service orders;
• 3.1.2. In order to issue financial documents;
• 3.1.3. In order to resolve issues concerning provisions of services;
• 3.1.4. In order to fulfil other contractual obligations;
• 3.1.5. For the purposes of e-marketing;
• 3.1.6. For the purposes of direct marketing (offering gods and services to persons and/or asking their opinion on the goods and services being offered);
• 3.1.7. For the purposes of administration of e-queries and comments;
• 3.1.8. For the purposes of pharmacovigilance (claim processing).

3.2. Information is received and generated during your usage of GUDRUCIO VAISTINE website and intended in Section 3 of the Privacy Policy.

3.3. You must provide consistent and accurate Personal Data. It is required for making of fulfilment of the agreement made with you. Provision of Personal Data for the purposes of pharmacovigilance is the obligation intended by legal acts. In the case of your failure to provide Personal Data for the purposes above, NORAMEDA shall not be able to fulfil the agreement made with you, your order placed in the e-shop and its legal obligations regarding the pharmacovigilance duly.

3.4. Managing and storing your Personal Data, NORAMEDA implements the organizational and technical data protection measures guaranteeing protection of Personal Data from accidental or illegal destruction, replacement, disclosure or any other illegal management. Storage premises of the collected data is physically protected from access by outsiders. Your Personal Data are protected from illegal access through computer network.

3.5. Your Personal Data are managed for the purposes and on the legal bases listed below:

• 3.5.1. For the purposes of direct marketing (offering gods and services to persons and/or asking their opinion on the goods and services being offered): 10 years from the moment of receiving your consent for management of your Personal Data (or the moment of receiving data, if the consent is optional);
• 3.5.2. For the purposes of administration of e-queries: 2 months; for the purposes of administration of comments: 3 years from the moment of provision;
• 3.5.3. For the purposes of e-marketing: 2 years from the last purchase made by a particular customer or the moment of last sing-in to the customer account;
• 3.5.4. For the purposes of pharmacovigilance (claim processing): 5 years from the moment of reporting a side effect of a drug;
• 3.5.5. If your Personal Data is used for illegal activity, identity theft or other violation having led or leading to investigation by legal authorities, if NORAMEDA receives complaints about you or if NORAMEDA notices any violation of the Privacy Policy and/or regulations on GUDRUCIO VAISTINE website made by you, and if a legal requirement is being claimed, executed or defended, your Personal Data can be managed as long as necessary.

3.6. Personal Data shall be deleted automatically on expiry of the terms above.

3.7. NORAMEDA is entitled to use impersonalised data not related to your person directly (information on services ordered) for the statistical purposes. Such statistical information shall be collected and managed in the way to prevent identification of a person or disclosure of other Personal Data, based on which identification of a person is possible.

3.8. You shall be using GUDRUCIO VAISTINE website and downloading content at your own risks. NORAMEDA shall not be liable for possible harm, especially if such harm is made to your data sets, hardware and/or software.

4. Ways to receive information

4.1. NORAMEDA can use the following information retrieved during your usage of GUDRUCIO VAISTINE website in the following ways:

• 4.1.1. Your IP address. Your IP address is the number automatically attributed to your computer by your Internet service provider (ISP). IP address is identified and stored in your server log together with the time of your visit and the page(s) you have visited. Collection of IP addresses is normal practice in the Internet done automatically by most websites. NORAMEDA uses IP addresses for the purposes to assess usage level of GUDRUCIO VAISTINE website, management of server issues and administration of GUDRUCIO VAISTINE website. NORAMEDA can also use and disclose them for other purpose just like Personal Data. NORAMEDA kindly notices that IP addresses, server log entries and related information is treated as Personal Data, if this is required by laws or other applicable legal acts.
• 4.1.2. Your browser information. Most browsers collect particular information, such as media access control (MAC), type of your computer (Windows or Macintosh), screen resolution, operating system, Internet browser and version, cookies (for cookie policy see below), pixel tags, web beacons and other similar technologies.

4.2 Browser information processed with Google Analytics is used by NORAMEDA for assessment and improvement of visit statistics of GUDRUCIO VAISTINE. For more information, please visit https://www.google.com/policies/privacy/partners/.

5. Data protection and Facebook usage

5.1. GUDRUCIO VAISTINE website is using plugins of www.facebook.com social network. The networked is managed by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter referred to as Facebook).

5.2. When you open web pages with the said plugin using GUDRUCIO VAISTINE website, you connect to the Facebook server, your browser receives a particular notice and the plugin appears on the website. This is how the Facebook servers are informed on the pages of GUDRUCIO VAISTINE website visited by you. If you are registered member of Facebook at the moment, Facebook shall attribute such information to your personal Facebook user account. Information on using plugin functions (e. g., pressing the Like button or leaving a comment) is also attributed to your Facebook account. If you are against collection of information about you by Facebook through GUDRUCIO VAISTINE site, disconnect from your Facebook account before visit GUDRUCIO VAISTINE site.

5.3. The Facebook plugin above does not affect data collected by NORAMEDA and thus provides you with information corresponding the level of NORAMEDA knowledge. Please find more information on data collected and used by Facebook, your rights and your privacy protection possibilities in the privacy notices by Facebook.

6. Use of Personal Data for marketing (advertising and market research) purposes

6.1. NORAMEDA also provides the following services:

• 6.1.1. Delivery of newsletters with the latest offers / advertisements of goods and queries of customer opinion about the goods and services offered;
• 6.1.2. Registration of regular client.

6.2. If you give your clear consent for the use of your Personal Data for the purposes of direct marketing (advertising and market research), e. g. , push the corresponding button on a page of GUDRUCIO VAISTINE website, your Personal Data shall be stored and used for the said purposes.

6.3. For example, NORAMEDA shall deliver you various advertisements of services and goods offered by NORAMEDA company, including GUDRUCIO VAISTINE, or other offers. NORAMEDA shall use communications channels indicated by you at the moment of giving your consent, for example, by e-mail, if you give your e-mail address; by phone, SMS or mobile applications, if you give your phone number; by regular mail (parcel), if you give your address.

6.4. Giving your clear consent for the use of your Personal Data for the purposes of direct marketing (advertising and market research) shall mean allowing NORAMEDA to send advertisements of the services offered on NORAMEDA website by mail. Moreover, using your data, NORAMEDA can create and review your user profile in order to enable sending personalised advertisements that might be interesting to you in the opinion of NORAMEDA.

6.5. If you give your clear consent for the use of your Personal Data for the purposes of direct marketing, NORAMEDA will be able to use your data for the analysis and improvement of efficiency of its websites, advertisements and market researches as well as for other marketing and sales purposes of the company.

6.6. Having fulfilled your order, NORAMEDA can ask you to evaluate its work by e-mail.

7. Transfer of Personal Data to third parties

7.1. Data management subjects (data managers, such as Server host, Website administrator and parcel delivery companies) hired by NORAMEDA are entitled to manage your Personal Data to the extent absolutely necessary to fulfil their functions. NORAMEDA is entitled to transfer your Personal Data to third parties in the manner and on the bases intended by laws and other applicable legal acts of the Republic of Lithuania exclusively.

7.2. Willing to improve supply of NORAMEDA and GUDRUCIO VAISTINE products, NORAMEDA personalises assessment of which NORAMEDA hyperlinks have been used. You give your consent for such practice during the registration process. Therefore, NORAMEDA might need to transfer your Personal Data for further processing by other companies of NORAMEDA Group or other companies providing their services to NORAMEDA. Such service providers might, for example, be authorized to send newsletters to you.

7.3. NORAMEDA does hereby guarantee that your Personal Data shall not be transferred to third parties for commercial purposes. However, NORAMEDA reserves the right to provide information about you, if it is its legal obligation intended by laws or if NORAMEDA is required to provide such information by legal authorities or prosecutors.

7.4. Your personal Data shall not be transferred to third states.

8. Your rights

8.1. You are entitled to change and/or update information provided in the registration form.

8.2. You are obliged to provide correct Personal Data in the registration form. NORAMEDA is not liable for correctness of your Personal Data indicated in the registration form or any harm caused by provision of incorrect Personal Data.

8.3. If personal Data is being managed with your consent, you are entitled to revoke such consent for management of your personal Data any time by giving a personal or written notice at the address Gyneju Str. 16, 01109, Vilnius or by e-mail info@norameda.com and delivering your identity documents or certified copies thereof. Such revocation shall not affect legality of consent-based management of your Personal Data before revocation. If you disagree with or revoke your consent for management of your Personal Data for the purposes of direct marketing, such kind of management shall be terminated and your profile and Personal Data shall be deleted.

8.4. You are also entitled to:

• 8.4.1. Check whether your data is being managed by NORAMEDA and if yes, to make yourself aware of what data is being managed and how;
• 8.4.2. Require to correct inaccurate or supplement incomprehensive Personal Data;
• 8.4.3. Require to stop managing Personal Data, except of storage, if your data is being managed against applicable laws;
• 8.4.4. Require to limit managing Personal Data on the bases intended in GDPR;
• 8.4.5. Require to delete your Personal Data (‘the right to be forgotten’) on the bases intended in GDPR;
• 8.4.6. Receive a copy of your Personal Data in the normally used and computer-readable format, if management of such data is based on your consent or an agreement;
• 8.4.7. Disagree with management of your Personal Data, when NORAMEDA manages such data seeking its own legal interests; in such cases NORAMEDA will stop managing your Personal Data, unless they will be able to prove that your data is being managed for the convincing legal reasons superior to your interests, rights and freedoms or with the aim to express, fulfil or defend legal requirements;
• 8.4.8. Lodge a complaint at the State Personal Data Inspectorate.

8.5. You can exercise your rights listed above (except of the one mentioned in Section 8.4.8 above) by contacting NORAMEDA in person or in written at the address Gyneju Str. 16, 01108, Vilnius or by e-mail info@norameda.com and delivering your identity documents or certified copies thereof. Having received your application regarding Personal Data management, NORAMEDA shall reply to you within one month from the contact date.

8.6. If you have any questions regarding your rights discussed above or the Privacy Policy hereto, please feel free to send us the e-mail letter with ‘Data protection’ in the subject line to info@norameda.com.

9. Cookie Policy

9.1. Cookies are small pieces of textual information received by the browser of your device from the websites you are visiting and stored at your device. Cookies enable GUDRUCIO VAISTINE website to remember information on your browsing habits, actions, searches and settings in order for you to use all functionality of the Website and to make future visits on GUDRUCIO VAISTINE website simpler and more useful.

9.2. You can choose if you wish to accept cookies. If you disagree with storage of cookies at your computer or other end device, you can change browser settings and disable all cookies or enable/disable them one by one. However, it should be noted that such disabling may slow down your Internet speed, limit some functions of the Website or even block access to the Website. For more information, please visit allaboutcookies.org.

9.3. Information on the cookies used

9.4. Without violation of legal provisions NORAMEDA can relate information received from cookies with personal information received by other means, e. g., information on using goods.

9.5. GUDRUCIO VAISTINE website can display hyperlinks to websites, products and services offered by third parties. Privacy policies of the relevant third parties shall apply to the services or products offered by the third parties through hyperlinks on GUDRUCIO VAISTINE website.

10. Changes to the Privacy Policy

10.1. NORAMEDA shall be entitled to change the Privacy Policy unilaterally, either in part or in full, having informed you on such changes on GUDRUCIO VAISTINE website.

10.2. If you disagree with management of your personal data following the new version of the Privacy Policy, you shall be entitled to exercise your rights in relation to personal data management listed above.

10.3. Supplements to and changes in the Privacy Policy shall become effective on the day they are published on GUDRUCIO VAISTINE website.