Privacy Notice (Global privacy policy)
Updated March 9, 2026

1. Data controller and scope of application

1.1. Global data controller
This Global Privacy Notice (hereinafter referred to as the "Notice") establishes the procedure for the processing and protection of personal data of users when accessing and utilizing this website (hereinafter referred to as the "Website"). The Website is owned, managed, and controlled centrally by Fazax Limited Liability Company (hereinafter referred to as the "Company"), acting as the principal international Data Controller for the Fazax group of companies ("Fazax Group"). The Company ensures unified corporate compliance and data privacy standards across all global jurisdictions of operation. 
1.2. Legal separation of liability and local entities
The Fazax Group conducts its international commercial activities through a network of local subsidiaries, affiliated entities, and authorized distributors. 
  • Local subsidiary structures (including, but not limited to, representative offices and affiliated legal entities operating in the Russian Federation, the People's Republic of China, the United States of America, and other jurisdictions) listed in the informational sections of this Website are separate, independent, and distinct legal subjects. 
  • This Website, its underlying hosting infrastructure, central databases, interactive feedback forms, and all communications transmitted through it are administered exclusively by Fazax Limited Liability Company. Local subsidiary entities do not possess direct access to the servers or IT infrastructure of this Website, do not engage in data collection via its digital interfaces, and assume no legal liability for the management or operation of this web resource. 
1.3. Consent to cross-border data transfer
Since this Website operates as a single, unified international informational resource, any personal data submitted by a user through interactive web forms or directed to the Company’s official corporate electronic communication channels is transmitted directly into the central information systems of the Company. By utilizing this Website and submitting information, you acknowledge that you are acting solely upon your own initiative and hereby provide your express, informed consent to the cross-border transfer of your personal data to the Company for the specific purposes set forth in this Notice. All activities on this Website are strictly governed by our global "Terms of use"

2. Categories of data and pharmaceutical industry specifics
As an international pharmaceutical group, Fazax distinguishes between standard communication categories of personal data and special categories of medical data, requiring strict adherence to global health sector regulations.

2.1. Standard personal data
During standard interaction with the Website (such as general inquiries, submission of applications within the "Careers" portal, or usage of contact forms), the Company processes: 
  • Contact information: full name, email address, and telephone number.
  • Professional attributes (for job applicants): professional qualifications, employment history, curriculum vitae (CV), and resumes.
  • Professional status (for healthcare professionals and B2B partners): medical specialty, place of practice, license numbers, or professional certificates (where applicable by local regulations). 
2.2. Special categories of medical data (Pharmacovigilance and clinical trials)
The Fazax Group rigorously adheres to international regulatory standards, including Good Pharmacovigilance Practices (GVP) and Good Clinical Practice (GCP):
  • Adverse event reporting data: When users submit patient safety or side effect reports via the Website, the Company processes specific medical data, including the patient's age, gender, medical history, concurrent therapies, and detailed descriptions of the reactions experienced. Pursuant to the binding global regulations of the WHO, FDA, EMA, and respective national health authorities, pharmacovigilance data is subject to mandatory centralization and indefinite, perpetual retention for global public health safety monitoring. Consequently, standard statutory rights regarding data deletion or erasure do not apply to these specific data sets.
  • Clinical trial registration data: When submitting preliminary requests or applications to participate in clinical research programs, the processing of specific medical indicators and health markers is conducted strictly within the authorized clinical protocol boundaries and on the basis of a separate, written Informed Consent form.
2.3. Automated data collection and cookies
Upon visiting the Website, certain technical parameters are automatically captured, including the user's IP address, geographic location data (at the country and city level), operating system details, browser type, and cookie files. The Website deploys a centralized consent management tool ("Cookie settings") that strictly blocks marketing, tracking, and analytical scripts from executing prior to obtaining the user's explicit affirmative action.

3. Regional compliance addendums
This section provides specific provisions applicable strictly to users residing within the designated jurisdictions below. These regional terms take absolute legal precedence over any conflicting general clauses within this Notice in order to guarantee full alignment with national data privacy statutes.
3.1. Provisions for residents of the United States (California privacy rights act — CPRA / CCPA and state privacy statutes)
  • Scope and privacy notifications: This clause applies strictly to residents of the State of California under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), as well as residents of other US states possessing comprehensive privacy statutes (including Texas, Virginia, Colorado, and Utah).
  • Categories of data collected and purpose: Within the preceding twelve (12) months, the Company has collected standard corporate communication identifiers (name, email, phone number) and professional/employment attributes (resumes, CV data) for business administration and talent acquisition. Special health data may be collected strictly for mandatory global pharmacovigilance tracking.
  • Do not sell or share my personal data: Fazax Limited Liability Company does not sell, lease, disclose, or share your personal information or sensitive personal data with third parties for commercial gain or cross-context behavioral advertising. To exercise your right to opt-out, you may use the dedicated "Do Not Sell or Share My Personal Information" link located in the Website footer, which directs to this compliance framework.
  • Your statutory consumer rights: Residents of California and states with equivalent privacy frameworks possess the right to request access to the specific categories of personal data collected, the right to request the deletion of their personal information (subject to binding regulatory exceptions, such as federal pharmacovigilance or clinical trial recording mandates), the right to correct inaccurate personal records, and the right to opt-out of automated profiling or cross-context commercial tracking through the Website’s interactive "Cookie settings" panel. The Company guarantees non-discrimination and will not penalize or deny services to any user exercising their statutory privacy rights.
3.2. Provisions for users in Mainland China (Personal information protection law — PIPL)
  • Cross-border transfer and separate consent: In compliance with the Personal Information Protection Law (PIPL) of the People's Republic of China, users accessing this Website from Mainland China acknowledge that all data entered into the Website’s interactive blocks or transmitted via electronic corporate mail will be exported outside the borders of the People's Republic of China to the central digital platform administered by Fazax Limited Liability Company. By clicking the submission button, the user provides their separate, explicit, and unconditional consent to the cross-border transfer of their personal information for standard communication, corporate inquiry, and patient safety monitoring purposes.
  • Data protection standards: The Company guarantees that all exported personal information will be protected using standard cryptographic protocols (SSL/TLS encryption) during transit and stored within secure cloud infrastructures that align with international corporate standards, ensuring a level of data protection that complies with prevailing international compliance principles.
  • Rights of data subjects in China: Users residing in Mainland China retain statutory rights under the PIPL to access, rectify, restrict, or request the erasure of their standard personal information. To exercise these rights, users may submit a structured request to the Company's central data administration using the official channels outlined in the "Contacts Us" webpage.
3.3. Provisions for users in the Russian Federation (Federal law No. 152-FZ)
  • Legal grounds and individual initiative status: Pursuant to the Federal Law of the Russian Federation No. 152-FZ "On Personal Data", Fazax Limited Liability Company hereby informs users within the territory of the Russian Federation that this Website operates strictly as a global international platform. The Company does not maintain localized digital infrastructure or primary databases within the Russian Federation. Any transmission of information by a user through the Website’s digital features or via direct electronic mail to corporate domain addresses is legally recognized as an individual, self-directed, and sovereign initiative of the user. Such action is executed solely at the user's own behest to establish or perform an information exchange process.
  • Consent to cross-border export: By executing a deliberate affirmative action (clicking any confirmation or submission button), the user issues a direct, explicit mandate to the Company to perform a cross-border export of their personal data to a foreign entity for the precise purpose of evaluating and processing their personal inquiry.
  • Separation of local entity liability: Subsidiary corporate entities, local affiliates, or authorized commercial distributors of the Fazax Group registered within the Russian Federation do not act as data controllers, operators, organizers, or beneficiaries of the data processing workflows occurring through this Website. All administrative, technical, and civil liabilities arising from Website data processing rest exclusively with Fazax Limited Liability Company.

4. Data retention and data subject rights
4.1. Periods of data storage
The Company stores your personal data only for the period strictly necessary to fulfill the specific purposes outlined in this Notice:
  • Standard commercial and general corporate inquiries are retained for a maximum duration of two years from the date of the final communication.
  • Job applicant dossiers and curriculum vitae (CV) submitted within the portal are stored for up to one year to evaluate potential talent acquisition opportunities.
  • Special categories of medical data, including all side effect disclosures and global pharmacovigilance tracking files, are subject to perpetual and permanent archiving under international public health safety laws and cannot be removed during the lifetime of the commercialized product.
4.2. Access and deletion parameters
Subject to the applicable regulatory restrictions stated within this Notice, global users possess the right to seek comprehensive disclosure regarding the specific categories of personal information held by the central corporate registry of the Company. Users may request structural correction of erroneous entries or full administrative erasure of standard communication data. To initiate a formal verification and exercise these rights, individuals must submit a validated request through the corporate channels provided on the "Contacts Us" webpage.


5. Document administration and amendments
5.1. Policy updates and tracking
The Company reserves the absolute discretionary right to modify, revise, or completely replace the technical provisions of this Notice at any time without prior individual notification. All modifications execute immediate legal force upon their public deployment on the Website interface. Your continued usage of the Website digital assets following the structural adjustment of this Notice serves as your binding and unconditional acceptance of the revised text.

6. Contact information for privacy inquiries
6.1. Dedicated communication channel
If you have any questions, comments, or structured requests regarding this Notice, the protection of your personal data, or if you wish to exercise your statutory rights to access, correct, or erase your standard information, you may contact our global data compliance administration. All such inquiries must be directed strictly to the Company's dedicated electronic communication inbox at privacy@fazax.org.
6.2. Request processing parameters
To protect your privacy and maintain corporate security, the Company reserves the right to verify your identity before fulfilling any data disclosure or erasure requests. Authorized compliance officers will evaluate and respond to your validated inquiries in accordance with the statutory timelines established by applicable international data protection standards.

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