Privacy
Policy.

Akman Pharma Ltd. and its subsidiary(ies) (the "Company") is committed to protecting your privacy and to controlling your personal data in a proportional, open, and transparent manner. This Privacy Policy refers to the method by which the Company collects and processes your personal data, and informs you of your rights, in accordance with national legislation (Law 2472/1997 on personal data protection) and the EU General Data Protection Regulation (GDPR nr. 2016/679). It is intended for natural persons who are existing or potential collaborators of the Company, or who had a business or employment relationship with the Company in the past, and more generally for any natural person who willingly sends data or comes into contact with the Company through any available means.

1. Akman Pharma Ltd.

Since we started our activity in the pharmaceutical field, the Company's goal has been to combine the rapid progress in science with a successful and innovative business venture, paving the way for the creation of a new market. Working with consistency and dedication, Akman Pharma became a well-renowned company specializing in the promotion, sales, and distribution of pharmaceutical products.

2. Collection and Processing of Personal Data

We collect and process different types of personal data, which we get from existing and potential collaborators and clients, in person, or through third parties that allow us to access these personal data, having secured the consent of the data subjects. We may also collect and process personal data from publicly accessible sources, such as lists of healthcare professionals, lists of association/union members, mass communication media, and the Internet, which we are legitimately acquiring and are permitted to process.

3. Personal Data of Minors

We do not collect personal data for individuals under 18 years of age for business purposes, as we understand the importance of privacy protection when it comes to minors, and we do not provide to them services associated with the information society. Exclusively for the purpose of insuring the dependent members of our employees' families and for the provision of additional benefits, we collect personal data on minors only under the condition that we have first secured the consent of their parents or legal guardian.

4. Why Do We Process Your Personal Data and on Which Legal Basis?

We process your personal data in accordance with the GDPR and national data protection legislation, for one or more of the following reasons:

• For the execution of a contract: We process personal data in order to carry out business transactions and to offer products and services under the provisions of our contracts with clients.
• For reasons of protection of legitimate interests: We process personal data to secure legitimate interests pursued by us or by third parties, including IT security, prevention of criminal acts, asset protection, risk management, and preparation of legal claims.
• Because you have given your consent: If you have expressly given us your consent for the processing of your data, the legitimacy of such processing is based on this consent. You have the right to revoke your consent at any time; however, any processing that has taken place prior to revocation shall not be affected.

5. Who Are the Recipients of Your Personal Data?

For the fulfillment of our contractual, legal, or regulatory obligations, your personal data may be forwarded to several of our Company's departments, as well as to various service providers and vendors who sign contracts with the Company undertaking to maintain confidentiality and data protection. We may disclose data pertaining to you for any of the reasons mentioned above, if we are legally obligated to do so, or if you have given your consent. Recipients may include:

• Supervisory and other regulatory and public authorities (e.g. EOF and law enforcement authorities)
• Credit and financial institutions for payment data
• External legal counselors, financial and business consultants, auditors and accountants
• Travel agencies and congress organization agencies
• Storage, filing, and file management companies
• Cloud storage and data processing providers
• Webpage development and support companies
• Contract Research Organizations (CROs)
• Healthcare service providers

6. Personal Data Transmission Outside the EEA

Your data may be transmitted to third countries outside the European Economic Area within the framework of cooperation with foreign companies whose products we distribute, or where you have given your consent. All parties responsible for processing in third countries are required to comply with European data protection standards and to provide appropriate assurances regarding the transmission of your data.

7. Automated Decision Making and Profile Creation

In general, we do not use any automated decision-making process for the creation and conduct of business activity. We may process some of your data in an automated manner for the purpose of assessing certain aspects (limited profile creation) in order to sign or execute a contract with you. We may only disclose data pertaining to you for the reasons mentioned above, if we are legally obligated to do so, or if you have given your consent.

8. Marketing Activities and Profile Creation

We may process your personal data for the purpose of informing you in relation to products, services, and suggestions that may interest you. The personal data we process consists of information you provide to us and data we collect when there is activity on your part relative to our products and services. In certain cases, limited profile creation is used to provide you with targeted scientific or marketing information. We may use your personal data to promote our products and services only if we have your explicit consent or a legitimate interest to do so. You have the right to object at any time to the processing of your personal data for marketing purposes by contacting the Company in person or in writing.

9. For How Long Do We Maintain Your Personal Information?

We shall maintain your personal data for as long as we have a business, educational, or other relationship with you. After our business relationship ends, we may retain your data for up to ten (10) years in accordance with:

• Pharmacovigilance (PHV) data maintenance requirements
• Tax details maintenance requirements
• Regulatory compliance requirements
• Personnel details maintenance requirements

10. Security of Personal Data

We acknowledge the importance of the protection of privacy and personal information, and we use appropriate technical measures such as anonymization, pseudonymization, data encryption, firewalls, and privacy by design and by default, as well as organizational measures including strict access policies, employee confidentiality commitments, personnel training, and periodic audits. Any employee of Akman Pharma Ltd. with access to personal data uses such information exclusively to serve the stated objectives. The information you give us is transmitted exclusively in the manner described in this Privacy Policy.

11. Your Rights

You have the following rights regarding the personal data we maintain on you:

• Access: Receive a copy of the personal data we maintain on you and verify that we are processing it legitimately. Contact us at info@akmanpharma.de.
• Correction: Request correction of any missing or inaccurate data we maintain on you.
• Erasure ("right to be forgotten"): Request deletion of your personal data when there is no longer a legitimate reason to process it.
• Objection: Object to processing based on legitimate interest where there is something special regarding your situation. You may also object at any time to processing for direct marketing purposes, including profile creation related to direct marketing.
• Restriction: Request that we limit the processing of your personal data when data is inaccurate, used illegally, no longer required, or while awaiting confirmation of our legitimate reasons to use it.
• Portability: Receive a copy of your personal data in a structured, commonly used, and machine-readable format, or request direct transmission to another organization of your choice.
• Withdrawal of consent: Withdraw your consent at any time. Any revocation shall not affect the legitimacy of processing that took place prior to withdrawal.

To exercise any of your rights or for further questions regarding the use of your personal data, contact us at: info@akmanpharma.de

12. Changes to This Privacy Policy

We may from time to time change or amend our Privacy Policy. You may be updated on any changes through the website of Akman Pharma Ltd. With each update, the respective revision date will be mentioned at the end of the policy. We recommend that you review this Policy from time to time to always be updated on how we process and protect your personal information.

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