Privacy Policy

PRIVACY POLICY

1. General Provisions

1.1. This Privacy Policy (hereinafter, the "Policy") defines the procedure, conditions and purposes for collecting, using, storing, transferring and protecting the personal data of users (hereinafter, the "User" or, in the plural, the "Users") processed by FOM GROUP Foreign Enterprise Limited Liability Company (hereinafter, "FOM") when they use FOM's official website, mobile applications, Telegram bots, referral programs and other software components (hereinafter collectively, the "FOM Resources").

1.2. This Policy has been prepared in accordance with the requirements of Law of the Republic of Uzbekistan No. ZRU-547 dated 2 July 2019 "On Personal Data".

1.3. The Policy takes effect when it is published on the FOM Resources and remains in effect until a new version is adopted. FOM may amend this Policy unilaterally.

1.4. FOM processes personal data on one or more of the following lawful grounds:

  • consent of the personal-data subject (the User);

  • the need to enter into or perform an agreement to which the User is a party, including under a Public Offer or the User Agreement (hereinafter, the "Agreement");

  • performance of obligations imposed on FOM by the applicable laws of the Republic of Uzbekistan;

  • pursuit of the legitimate interests of FOM or third parties where this does not violate the User's rights and freedoms.

1.5. By accepting this Policy through continuing registration or authorization, placing an order or taking another action indicating acceptance of this Policy, including retaining a selected checkbox in the relevant field, the User freely, voluntarily and in their own interest consents to FOM processing their personal data under this Policy, including to receive marketing and advertising communications from FOM by SMS, telephone calls, email, push notifications, Telegram bots and other electronic communications. The User may opt out of advertising and marketing communications at any time by sending a request to info@fom.group or by another method provided by the FOM Resources.

1.6. The User's consent under clause 1.5 includes consent to the collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, anonymization, blocking, deletion and destruction of personal data and to other actions involving personal data that are necessary to achieve the processing purposes specified in this Policy. Consent to analytical and marketing cookies is requested separately in accordance with section 3 of this Policy. Where the laws of the Republic of Uzbekistan require separate consent for another purpose of processing personal data, FOM requests such consent separately for the relevant purpose.

1.7. The User may withdraw consent to personal-data processing at any time by sending a written request to info@fom.group. FOM stops processing and destroys or anonymizes the User's data within 30 calendar days after receiving the request, except where FOM has a lawful right or obligation to continue processing the data without consent.

2. Collection and Use of Personal Data

2.1. FOM collects personal data provided by Users during registration and data that may be obtained while they use the FOM Resources, including, without limitation:

  • surname, first name and patronymic;

  • sex, age, country of residence and preferred language of communication;

  • contact details: telephone number and email address;

  • credentials: login, password and password-recovery information;

  • geolocation data and information about the device used to access the FOM Resources;

  • data about reserved goods and the contents of the User's orders;

  • the content of requests and correspondence with the artificial-intelligence information assistant (AI chat), in accordance with clause 2.5 of this Policy.

The User is responsible for information voluntarily provided through the FOM Resources, including information containing third-party personal data. The User warrants that they have the rights and grounds required to transfer such information to FOM.

2.2. FOM uses personal data exclusively for the following purposes:

  • identifying the User to provide access to the FOM Resources;

  • providing personalized services, including sending notifications, requests and information about functions of the FOM Resources;

  • improving the quality and functionality of the FOM Resources;

  • collecting statistics and analysing User preferences;

  • processing and transferring product-reservation requests to Partners;

  • preventing fraud;

  • ensuring information security;

  • complying with legal requirements.

2.3. For analytics, operational optimization and collection of statistical indicators, User data is used, where possible, in anonymized form that excludes identification of a specific individual.

2.4. Anonymized statistical data that does not enable identification of the User may be used by FOM without restriction for analytical, statistical and research purposes.

2.5. In connection with use of the artificial-intelligence information assistant (AI chat), FOM applies the following additional rules:

2.5.1. FOM collects and stores the content of the User's requests and the AI chat's responses;

2.5.2. use of the AI chat does not require or imply that the User will disclose health information. FOM does not actively request such information and recommends that Users not include data in correspondence where there is no direct need to disclose it. If the User includes such information in a request on their own initiative, the User thereby gives FOM separate consent to process it solely for the purposes specified in this clause;

2.5.3. processing purposes: providing and improving the AI chat, ensuring information security, reviewing claims and disputes (including use as evidence in accordance with the applicable Public Offer), and complying with the laws of the Republic of Uzbekistan, including artificial-intelligence legislation;

2.5.4. to generate responses, the User's requests may be transferred to an external artificial-intelligence technology provider that acts under an agreement with FOM and undertakes to protect personal data at a level equivalent to this Policy. Such transfer is made in accordance with clause 4.5 of this Policy. The User also understands and agrees that certain data may be processed using the infrastructure of FOM's technology partners, including providers of artificial-intelligence, cloud-storage, analytics and communications services;

2.5.5. Artificial intelligence is an informational tool and is not medical, legal, financial or other professional advice. Artificial-intelligence responses do not guarantee a result and do not replace consultation with the relevant specialist.

2.5.6. FOM is not responsible for decisions made by the User solely on the basis of information received through artificial intelligence.

2.5.7. The User understands and agrees that responses generated by artificial intelligence may contain errors, inaccuracies or incomplete information. The User must independently assess the information received and, where necessary, consult the appropriate specialists.

2.6. The User independently decides whether to provide personal data to FOM. Failure to provide certain data may make it impossible to register the User, use individual functions of the FOM Resources, reserve goods or obtain individual services.

3. Use of Cookies and Other Technologies

3.1. Cookies and other data-collection technologies are used on the website and in mobile applications to improve the quality of services provided by the FOM Resources. Strictly necessary cookies enable the basic operation of the FOM Resources and do not require the User's consent. Analytical and marketing cookies are used to analyse User behaviour and display relevant advertising and may be used only with the User's consent.

3.2. With the User's consent, the website uses Mixpanel, a product-analytics service provided by Mixpanel, Inc. The Mixpanel SDK creates pseudonymous distinct_id and device identifiers in the browser's local storage; FOM does not link them to the User's account or to FingerprintJS data. FOM sends manually defined usage events, the selected interface language, a normalized screen name and the selected Region identifier (region_id) to Mixpanel's European data-ingestion endpoint. When an event is sent, Mixpanel receives the internet connection's IP address and may use it to derive an approximate country, region and city. FOM does not send the User's name, phone number, account or session identifiers, search text, medicine or prescription data, QR-code contents, uploaded images or full page addresses to Mixpanel.

3.3. When the User first visits the FOM website, a cookie-settings banner is displayed through which the User may accept or reject analytical and marketing cookies. The User may change their choice at any time through the cookie-settings section available on the website.

3.4. The User may also configure their browser to block cookies, but some functions of the FOM Resources may then be unavailable.

3.5. The User understands that disabling certain categories of cookies may limit the functionality of the FOM Resources and that FOM does not guarantee correct operation of all functions if the User changes browser settings.

4. Storage and Protection of Personal Data

4.1. Users' personal data is stored in the FOM database for as long as necessary to achieve the processing purposes, perform contractual obligations, comply with the laws of the Republic of Uzbekistan, protect FOM's rights and legitimate interests and review potential claims and disputes, or until the User's consent is withdrawn where continued storage and processing is not required to perform FOM's obligations, comply with the laws of the Republic of Uzbekistan, protect FOM's rights and legitimate interests, prevent fraud or resolve potential disputes.

4.2. FOM takes all necessary measures to protect personal data against unauthorized access, loss, alteration or destruction using modern security technologies.

4.3. FOM uses reliable authentication and authorization systems to prevent unauthorized access to Users' personal data.

4.4. If a data leak or security threat is detected, FOM notifies Users in the cases and in the manner required by the laws of the Republic of Uzbekistan, where such notification is mandatory, and takes all measures to prevent further leakage and minimize potential consequences.

4.5. Users' personal data may be stored and processed through cloud services using servers located both within and outside the Republic of Uzbekistan in the cases and in the manner permitted by the laws of the Republic of Uzbekistan, including requirements governing cross-border transfers of personal data.

4.6. When the personal-data retention period expires or the User withdraws consent to processing, unless otherwise provided by law, FOM undertakes to anonymize or delete the User's personal data from its database.

4.6.1. Personal data is not deleted where its retention is necessary for FOM to perform its obligations, protect FOM's rights and legitimate interests, prevent fraud, fulfil requirements of state bodies or comply with the laws of the Republic of Uzbekistan.

4.7. Where personal data is transferred to third-party organizations, such as partners or government bodies, those third parties must maintain data confidentiality and security in accordance with applicable standards and laws. Personal data is transferred only to the extent necessary to achieve the relevant processing purpose. After receiving personal data, third parties bear independent responsibility for complying with legal requirements in their further processing of that data.

4.8. FOM regularly conducts internal security audits to assess risks and the effectiveness of personal-data protection measures.

4.9. Where necessary to perform the Agreement, FOM may engage third-party companies to provide data-processing services. FOM undertakes to enter into an agreement with them ensuring compliance with all personal-data protection standards required by law.

4.10. FOM regularly updates its security procedures in light of new threats and technological changes to ensure a high level of personal-data protection.

5. Transfer of Data to Third Parties

5.1. FOM may transfer the User's personal data to third parties in the following cases:

  • where required to perform the Agreement;

  • at the request of government bodies, subject to compliance with the laws of the Republic of Uzbekistan;

  • where transfer is necessary to improve the functionality of the FOM Resources;

  • at the User's own initiative, to the Partner (pharmacy) to which the User sends a product-reservation request or otherwise discloses data to receive a service.

5.2. When data is transferred to third parties, FOM undertakes to ensure that those third parties adopt data-protection measures meeting this Policy and applicable law.

6. User Rights and Procedure for Exercising Them

6.1. The User has the following rights:

  • access to their personal data stored in the FOM database;

  • correction or updating of their personal data;

  • submission of a request to delete their data from the FOM database when they stop using the FOM Resources.

6.2. FOM may refuse to provide the User with information about details of processing their personal data where:

  • providing that information would violate the rights and legitimate interests of third parties;

  • the requested information has already been provided to the User in full;

  • the request constitutes an abuse of rights (is spam, contains obscene language or is resubmitted without any change in circumstances).

    6.3. FOM may request additional information to verify the User's identity before providing access to personal data, making changes or deleting data.

7. Amendments to the Privacy Policy

7.1. FOM reserves the right to amend this Policy at any time. All amendments take effect when published on the official FOM Resources.

7.2. If the Privacy Policy is amended, FOM notifies Users through the FOM Resources. Continued use of the FOM Resources after amendments are made constitutes the User's agreement with the new version of the Policy.

7.3. If the categories of data collected are expanded or the purposes of processing are changed or expanded, FOM undertakes to request renewed consent from Users. In other cases, continued use of the FOM Resources after the ten-day period following notice of amendments constitutes the User's unconditional agreement with the updated Policy.

8. Limitation of Liability

8.1. FOM takes reasonable and sufficient measures to protect personal data but does not guarantee the absolute security of information when data is transmitted through information and telecommunications networks.

8.2. FOM is not liable for:

  • actions by the User that result in disclosure of their credentials;

  • transfer by the User of their personal data to third parties;

  • operation of third-party resources accessed through the FOM Resources;

  • actions of third parties that obtain access to data because the User violated security rules.

9. Force Majeure

9.1. FOM is not liable for breach of data-protection obligations due to force majeure, including cyberattacks, actions of government bodies, communications-infrastructure failures, data-centre accidents and other circumstances beyond FOM's reasonable control.

10. Contact Information

10.1. Users may contact FOM with questions or requests concerning the use of personal data at info@fom.group. User requests must contain information that makes it possible to identify the applicant as a personal-data subject.

Effective date: 03.08.2026