PRIVACY POLICY

PRIVACY POLICY
The Privacy Policy of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' sets out the terms and rules for using the clinic's website https://spina.net.ua (the 'Website'). The Privacy Policy of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' has been developed in accordance with the Law of Ukraine 'On Personal Data Protection', the Law of Ukraine 'On Information', Cabinet of Ministers of Ukraine Resolution No. 61 of 09.08.1993 'On the List of Information Not Constituting a Trade Secret', and the provisions of the Civil and Commercial Codes of Ukraine.

This Privacy Policy of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' has been adopted to safeguard and protect clinic Clients' personal data (including those of Website users), confidential information containing personal data, and confidential information owned by the clinic 'Spine Surgery by Professor Iakiv Fishchenko'; and to regulate access to, provision of and transfer of that information.

The Privacy Policy of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' applies to all Website users, both those without a Website account (unregistered users) and those with any available type of account. An account means the combined information about a Client and their authentication details (username and password).

1. DEFINITIONS
The terms used in this Policy have the following meanings:

1.1. Personal data — information or a set of information about an individual who is identified or can be specifically identified.

1.2. Confidential information — information held, used or controlled by individual persons or legal entities and disclosed at their discretion under conditions they establish.

1.3. Confidentiality of information — the property of information being protected against unauthorised access.

1.4. Information confidentiality regime — legal, medical, organisational, technical and other measures to protect personal data.

1.5. Owner of confidential information — a person who lawfully holds confidential information, has restricted access to it and has established an information confidentiality regime for it.

1.6. Access to confidential information — familiarisation of specified persons with confidential information with its owner's consent or on another lawful basis for granting access to personal data.

1.7. Client — an individual or legal entity with legal capacity, having reached the age of 18, who has fully accepted all terms of this Privacy Policy by registering on the Website or in the Application, and has an individual username and password and a Client account for using the services of this Website and the Applications.

1.8. Counterparty — a party to a civil-law contract to whom the owner of confidential information has transferred that information on condition that its confidentiality is maintained.

1.9. Website — the website https://spina.net.ua, including all its subdomains, under the organisational control of the management of the clinic 'Spine Surgery by Professor Iakiv Fishchenko'.

1.10. Application — a computer program or software usable on tablets, smartphones and other mobile devices, distributed under an adhesion agreement (a free public offer) granting a person who joins that agreement permission, free of charge, to use the application for its intended purpose, under the organisational control of the management of the clinic 'Spine Surgery by Professor Iakiv Fishchenko'.

1.11. Transfer of confidential information — transfer of confidential information recorded on the website of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' by its owner or the Website owner under a contract, to the extent and on the terms provided by that contract, including the Counterparty's acceptance of contractual measures to protect its confidentiality.

1.12. Provision of confidential information — transfer by its owner of confidential information recorded on the website of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' to public authorities, other state bodies or local government bodies for the performance of their functions.

1.13. Disclosure of confidential information — an act or omission resulting in confidential information, in any possible form (oral, written or another form, including through technical means), becoming known to third parties without its owner's consent or contrary to a civil-law contract.

2. CONFIDENTIAL INFORMATION
2.1. Confidential information includes:

2.1.1. Personal information supplied by the Client when registering or leaving comments on the Website: telephone number, email address, first name and surname.

2.1.2. Data transmitted automatically when visiting the Website: IP address, browser information, duration of the visit, the address of the referring website, and so on.

2.1.3. Information about the Client seeking medical care, laboratory results and other information about the Client's health that is confidential under applicable legislation.

3. ESTABLISHING AN INFORMATION CONFIDENTIALITY REGIME
3.1. An information confidentiality regime is considered established after the Client consents to the collection, processing, dissemination of and access to personal data when registering on the Website, and the clinic 'Spine Surgery by Professor Iakiv Fishchenko' adopts measures to protect confidentiality, namely: legal entities approve the Privacy Policy of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' and restrict access to confidential information by establishing procedures for its handling and monitoring compliance with those procedures.

3.2. By using any part of the Website and Applications, the Client consents to:

3.2.1. processing of their personal data from primary sources to the following extent: personal details (age, sex, marital status, family composition, etc.); actual and officially registered residence; military registration information; health-related data in accordance with applicable legislation; taxpayer identification number information; electronic identification data (biographical information, telephone numbers); and recorded images (photographs).

3.2.2. use of personal data, including actions by the database owner to process those data and actions granting other parties involved in personal-data-related relationships partial or complete processing rights (Article 10 of the Law of Ukraine 'On Personal Data Protection');

3.2.3. dissemination of personal data, including actions by the personal data database owner to transfer information about an individual from the database (Article 14 of the Law of Ukraine 'On Personal Data Protection');

3.2.4. third-party access to personal data, defining the personal data database owner's actions upon receiving a third party's request for access, including the procedure for a personal data subject to access information about themselves (Article 16 of the Law of Ukraine 'On Personal Data Protection').

4. CLIENT RIGHTS AND OBLIGATIONS (WEBSITE USERS)
4.1. The Client (Website user) has the right to:

4.1.1. use all technical features of the website of the clinic 'Spine Surgery by Professor Iakiv Fishchenko';

4.1.2. access any public information posted on the Website;

4.1.3. have their personal data protected from third parties under the conditions established by applicable Ukrainian legislation and this Privacy Policy;

4.1.4. use information from the Website for personal, non-commercial purposes.

4.2. The Client (Website user) undertakes to:

4.2.1. provide and publish accurate personal information when registering;

4.2.2. use the Website and Applications only for purposes that do not conflict with agreements between the Client (User) and the clinic 'Spine Surgery by Professor Iakiv Fishchenko', applicable Ukrainian legislation or principles of reasonableness and morality;

4.2.3. be responsible to third parties for their acts or omissions when using the Website and/or Applications;

4.2.4. independently and at their own expense settle all third-party claims related to the Client's acts or omissions when using the Website and/or Applications.

4.3. The Client (Website user) is prohibited from:

4.3.1. inciting religious, racial or ethnic hatred;

4.3.2. engaging in actions intended to mislead other users;

4.3.3. engaging in actions that violate any person's honour, dignity, rights or freedoms;

4.3.4. registering an account on behalf of a third party or instead of another person;

4.3.5. allowing third parties to use their account and/or its username and password;

4.3.6. posting advertising, erotic, pornographic or offensive material;

4.3.7. posting information that infringes third parties' rights and legitimate interests (including photographs and videos whose main subject is a person who has not consented to publication of their image or video on the Website);

4.3.8. posting computer viruses or programs capable of interrupting or disrupting the normal functioning of any person's computer hardware, software or telecommunications equipment;

4.3.9. any use of Website information for commercial purposes.

5. RIGHTS AND OBLIGATIONS OF THE CLINIC 'SPINE SURGERY BY PROFESSOR IAKIV FISHCHENKO'
5.1. The clinic 'Spine Surgery by Professor Iakiv Fishchenko' has the right to:

5.1.1. establish, change or revoke an information confidentiality regime in writing in accordance with applicable legislation;

5.1.2. use information constituting a trade secret and/or confidential information for its own needs in a manner consistent with legislation;

5.1.3. permit or prohibit access to confidential information and determine the procedure and conditions for access;

5.1.4. make confidential information available for civil-law transactions under contracts containing provisions protecting its confidentiality;

5.1.5. require legal entities and individuals granted access to confidential information, and public authorities, other state bodies and local government bodies supplied with such information, to comply with their confidentiality obligations;

5.1.6. require persons who gain access to confidential information accidentally or by mistake to protect its confidentiality;

5.1.7. if the Client posts information on the Website or through the Applications, or performs other actions inconsistent with applicable Ukrainian legislation or this Privacy Policy, remove all or part of that information at its discretion without notice, including information whose compliance with legislation is difficult to determine; where substantiated complaints about the Client's inappropriate conduct on the website of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' are received from other clients, the clinic reserves the right to block the Client's page;

5.1.8. amend the Privacy Policy to improve the security system further in accordance with applicable legislation;

5.1.9. send the Client advertising and informational messages; if the Client wishes to stop receiving mailings from the clinic 'Spine Surgery by Professor Iakiv Fishchenko', they must notify the clinic 'Spine Surgery by Professor Iakiv Fishchenko' by any convenient means.

5.2. The clinic 'Spine Surgery by Professor Iakiv Fishchenko' undertakes to:

5.2.1. protect its rights, in the manner established by applicable legislation, this Policy and employment and civil-law contracts, in the event of third-party disclosure, unlawful acquisition or unlawful use of confidential information, including seeking compensation for losses arising from infringement of its rights.

6. PROTECTION OF INFORMATION CONFIDENTIALITY
6.1. To protect confidentiality, employees of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' whose duties give them access to confidential information must:

6.1.1. give a written undertaking not to disclose confidential information or sign a confidentiality and non-disclosure agreement;

6.1.2. comply with the information confidentiality regime established by the clinic 'Spine Surgery by Professor Iakiv Fishchenko';

6.1.3. not disclose confidential information containing the Client's personal data or owned by the clinic 'Spine Surgery by Professor Iakiv Fishchenko', and not use it for personal purposes without the owners' consent;

6.1.4. not disclose the above confidential information after termination of their employment agreement (contract);

6.1.5. compensate the Client for losses if the employee is responsible for disclosure of confidential information obtained in the course of their duties;

6.2. Relations between the clinic 'Spine Surgery by Professor Iakiv Fishchenko' and its counterparties concerning non-disclosure of confidential information are governed by legislation, contracts and this Privacy Policy. The clinic's contracts with counterparties include a clause requiring the Counterparty not to disclose information constituting a trade secret and/or confidential information.

6.3. The clinic 'Spine Surgery by Professor Iakiv Fishchenko' takes all necessary organisational and technical measures to protect personal data against accidental or fraudulent access, destruction, distortion or other unlawful actions.

7. PROCEDURES FOR STORING, USING, PROVIDING AND RECORDING CONFIDENTIAL INFORMATION
 7.1. Paper and electronic media containing confidential information of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' are kept outside working hours only in safes or locked drawers; electronic information databases are protected with appropriate security passwords.

7.2. When working with electronic media, employees of the clinic 'Spine Surgery by Professor Iakiv Fishchenko' may not, without prior management approval:

7.2.1. copy electronic media containing confidential information, take copies outside the office or transfer them to persons without access to trade secrets and/or confidential information;

7.2.2. disclose confidential information to clinic employees or other persons who do not have access to it.

7.4. The Company's confidential information may be supplied to counterparties when entering into agreements, at their request and with prior approval from the personal data owners.

7.5. Confidential information may be supplied only by the clinic head or their deputies, and only upon a written request from representatives of public authorities, regulatory bodies or law-enforcement agencies.

7.6. A designated person keeps records of electronic media containing confidential information.