PRIVACY POLICY and NOTIFICATION FORM

Menarini Sağlık ve İlaç San. Tic. A.Ş (Menarini Turkey/Company)’s Policy for the Protection of Privacy and Notification Form

1. Menarini Turkey’s Policy

Menarini Turkey, registered at the address of Maslak Mah. Sümer Sok. No:4 Maslak Office Building (MOB) Kat: 7-8 34485 Maslak, Sarıyer, İstanbul, is the data controller of the personal data herein and the publisher of the website,

Menarini Turkey takes seriously the privacy of users of the Company’s website (the “Site” or “Website”) and the protection of personal data and takes necessary administrative and technical measures in this regard. This Privacy Policy and the Notification Form (the “Policy”) explains with which reasons the data is collected, to whom and with which reasons the processed data is transferred by Menarini Turkey, as the Data Controller, as well as the method of the data collection, the legal reasons, the rights of the data subjects, and the Site's practices regarding data security.

Visiting most pages on our Site does not require any form of registration of personal data. However, some services and in order to fulfill the requirements arising out of law, the disclosure of certain personal data and/or transferring the data to third parties and abroad may be required. These data will be collected and processed only with your express consent or in accordance with the other data processing conditions set forth under the Data Privacy Law.

2. The Method and Reasons of Collecting and Processing Personal Data – Legal Reasons

The Controller collects personal data (such as your name, address, phone number or e-mail address, gender, age, etc.) when these data are requested from you explicitly and/or when you voluntarily provide these data through the Site or when you visit the Site automatically or non-automatically, verbally, written or electronically.

If the data processing is obligatory for the legitimate interest of the Company and/or if it is obligatory for fulfilling Company’s legal requirements and/or if it is directly related with execution and performance of an agreement, with the reasons given below, the personal data that you provide us may be processed and transferred without your explicit consent:

(i)to process all the inquiries and requests you voluntarily submit (including those for technical assistance),

(ii)to give you access to the information and services offered through the Site, including information about our Company and products,

(iii)to be seen by duly registered healthcare professionals the scientific information services requested,

(iv) to process your job applications and

(v) to increase the Site’s use and functionality by offering you a more pleasant visit of the Site via cookies.

Apart from the above, the Company will process your personal data including personal data of special nature with the following purposes, with your explicit consent:

(i) to comply with the pharmacovigilance obligations for the side effect/adverse event notifications that are made; on this basis, to notify the Ministry of Health and other related public authorities and institutions regarding the side effect/adverse event notifications within the scope of the relevant legislation; to do the necessary follow-ups,

(ii) to answer your questions concerning side effect/adverse event notifications and to contact you in case it is required to do necessary follow-ups pursuant to the related regulations,

(iii)to gather information on these matters, to record, assess, archive these and to take the necessary precautions in order to minimize the harm that the drugs may cause in order to ensure the safe use of the products and to monitor systematically the side effects/adverse events in order to protect the public health.

Your personal data will be processed within the scope of the conditions for data processing regulated under the Data Privacy Law, in line with laws, morals and good faith, truly, and by providing actuality when necessary, with determined, clear and legal reasons, and proportionate to and limited with the reason of process; such personal data will only be kept during the time necessary for its processing reason.

The Site is generally not offered for use of children. The Controller will not knowingly collect or process personal data collected from children for any purpose whatsoever, including disclosure to third parties without the explicit consent of a relative or guardian.

Users should not supply personal data of third parties to the Controller, unless they have been duly authorized by the data subject –in any case, if required by the law, users should seek and obtain the relevant Data Subject’s consent, after enlightenment of the subject in line with the Data Privacy Law and other relevant regulation.

3. Recording of Navigation Data

When you visit our Site, we may automatically collect (that is to say, otherwise than by registration) information that does not identify you personally (i.e., type of browser and operating system operational use, the domain name of your origin website, the amount of visits, average time spent, pages viewed).

4. Communication of Personal Data and Purposes of Transfer

Our Company may transfer the personal data collected if it is necessary to perform the purposes mentioned above, in line with the fundamental principles introduced by the Data Privacy Law and within the scope of the data processing requirements set forth by the law;

(i)To business partners, consultants, subcontractors and other third parties that we have their support in technic, administrative and other areas,

(ii) To our subsidiaries and affiliates within the Menarini group which we cooperate in technical, administrative and other areas.

In addition, your personal data may be transferred to the Ministry of Health and other relevant public authorities and institutions, as well as public and private health institutions serving your health services, for the purposes of performing pharmacovigilance obligations.

Apart from that, if it is explicitly regulated by law and/or if it is obligatory to perform legal requirements, personal data may be shared with supervisory and regulatory public institutions in line with relevant legislation.

As a global Company, we may import services such as storing, hosting, cloud computing, and call center, which makes it compulsory to transfer of the data abroad, to unsafe countries. Within this framework and if it is necessary for the purposes of process described above, in accordance with the Data Privacy Law, provided that your explicit consent is obtained or by complying with all legislation and by obtaining necessary permissions and undertakings, it will be possible to transfer personal data to third parties we cooperate in technical, administrative and other areas, located abroad.

Please note that some of the contact details indicated on our Site refer to people or entities other than the Company. We are neither responsible for, nor do we control, any personal data you may submit to such contact details. We will normally indicate when the contact details refer to third parties.

5. Your Rights Concerning Your Personal Data

In compliance with the Data Privacy Law, as the data subject you have the following rights:

• To learn whether your personal data is processed or not
• To request information in that regard,
• To learn the purpose of the processing of your personal data and whether it is used in accordance with that purpose,
• To know the third parties domestic and abroad whom your personal data is transferred to,
• To request correction in cases where your personal data is processed erroneously or deficiently, and when you enforce this right, to request notification of the correction to third parties to whom your personal data is transferred,
• To request destruction or deletion of your personal data, in the event the purposes for processing your personal data cease to exist and when you enforce this right, to request notification of this to third parties to whom your personal data is transferred,
• To object to the outcome of the analysis of the collected information made by automatic systems,
• To claim for damages in case you suffer any loss because of a process violating the law.

6. Cookies

The processing of the personal data of users who visit the Website is limited to so-called “navigation data”, i.e. the data transmitted to the Website and required to operate the computerized systems set up for the Website’s management, as well as Internet communication protocols. By way of example, the IP addresses or the domain names of the computers used to visit the Website and the other parameters relating to the operating system used to connect to the Website all fall in this category. The Company collects such and other data (for example, the number of visits and the time spent on the Website) for truly statistical purposes and in an anonymous manner in order to monitor the functioning of the Website and improve its efficiency. The data in question are neither collected to be associated with other information regarding the users of the Site nor do they make the identification of users possible; however, due to their nature, such data may potentially lead to the identification of users if processed and associated with other data held by third parties. For this reason, navigation data are immediately de-identified after processing and may only be retrieved by the Company to ascertain, as well as identify the authors of, potential IT-related offenses committed to the detriment of the Website or through the Website. Notwithstanding the latter exception, navigation data as described above are only kept for a limited time, in compliance with the applicable legal provisions.

Cookies are small files saved on the hard disk. There exist two macro-categories of cookies: “technical cookies” and “profiling cookies”.

Technical cookies are necessary for the correct functioning of a website and make navigation possible for the user; without them, the user may be unable to view the website’s pages correctly or to use some services.

Profiling cookies are designed to create profiles of the user so as to send on-line commercial ads in line with the preferences the user has expressed during navigation.

Cookies can further be classified as

• “session” cookies, which are immediately deleted after the navigation browser is closed;
• “persistent” cookies, which are stored in the browser for a given period of time. These are used, for example, to recognise the device that connects to the Website, so as to render the authentication operations easier for the user.
• “site’s own” cookies, also known as “first party” cookies, generated and managed directly by the manager of the website that the user is navigating;
• “third party” cookies, generated and managed by subjects other than the manager of the website that the user is navigating.

The types of cookie used on the Website

The Website uses the following types of cookies:

(i) “first party” cookies, which can be either “session” or “persistent”; these are necessary to make the navigation of the Website possible, and are required for purposes of internal security and system administration;

(ii) “third-party”, “persistent” cookies, used by the Website in order to send statistical information to the Google Analytics system, through which the Company may carry out statistical analyses of the accesses/visits to the Website. These cookies are used exclusively for statistical purposes and retain information in aggregate form. Using a pair of cookies (respectively, a persistent cookie and a session cookie, the latter of which is deleted when the user closes the browser), Google Analytics also saves the timestamp of the start of the visit and the exit from the Website. It is possible to prevent Google from using cookies to collect data, and therefore to prevent their consequent processing, by downloading and installing the browser plug-in available at the following website: tools.google.com/dlpage/gaoptout

Since the Company does not own the source codes of some or all third-party cookies, it is not currently able to technically prevent their writing; for this reason, it is not possible to give users the option to disable cookies directly from this page. Nevertheless, users may disable the majority of third-party cookies in use on this website by following the procedures described in the privacy policy documents of the relevant cookie owners –available by clicking on the links provided in the table below- or by amending their browser’s settings. In any case, we would like to draw your attention on the fact that disabling cookies may impair the possibility of using the Website and/or prevent the user to take full advantage of the functions and services available thereon.

The following table reports the details of the cookies that are present on the Website. Beside each “third-party” cookie is displayed the link to the privacy policy of the subject other than the manager of the Website on which the user is navigating, who generates and manages such cookies:

7. Data Security

The Controller has implemented precautions and procedures to ensure the security of your personal data and strives to keep them up to date. Your data are reasonably protected against loss, destruction, falsification, manipulation, unauthorized access or unauthorized disclosure.

8. Links to Other Websites

This Site may contain links to the websites of other companies of the Menarini Group or of third parties as a service to our users. This Policy does not apply to these websites. If you visit these sites, you agree that the Controller is not responsible for the availability of these sites or their content.

9. Enforcing the Rights

As regulated under Section 5 above, you have rights such as the right to request access to your personal data processed by the Controller, the right to request the update and correction of your personal data. In addition to that, data subjects have right to withdraw the explicit consent that they previously gave. We notify you that upon withdrawal of consent, we do not process personal data.

In order to enforce your rights, it is sufficient for you to contact us through the contact information below:

dataprivacy@menarini.com.tr

Menarini Sağlık ve İlaç San. Tic. A.Ş.

Maslak Office Building (MOB), Maslak Mah. Sümer Sok. No:4 Kat:7-8 34485

Maslak, Sarıyer, İstanbul

Tel: +90 212 467 11 11

Fax: +90 212 467 12 12

Best regards

Menarini Turkey