PRIVACY POLICY

BOU YOUNES PHARMACEUTICALS

1. INTRODUCTION

At Bou Younes Pharmaceuticals (”Bou Younes”, the “Company”, “we”, “our”, or “us”), we recognize that protecting the privacy and confidentiality of Personal Information is fundamental to maintaining the trust of our customers, healthcare professionals, suppliers, business partners, employees, and visitors to our website.

We are committed to processing Personal Information responsibly, transparently, securely, and in accordance with applicable laws, regulations, and internationally recognized privacy principles.

This Privacy Policy describes how Bou Younes Pharmaceuticals collects, uses, stores, shares, protects, and otherwise processes Personal Information obtained through our website located at https://bygroup-mena.com, as well as through any communications initiated via the Website.

Our objective is to ensure that every individual interacting with Bou Younes Pharmaceuticals clearly understands:

• what information we collect;
• why we collect it;
• how it is used;
• with whom it may be shared;
• how long it is retained;
• the measures implemented to protect it; and
• the rights available to individuals regarding their Personal Information.

By accessing or using this Website, you acknowledge that you have read and understood this Privacy Policy.

Where your consent is required under applicable law, your continued use of the Website constitutes your agreement to the collection and processing of your Personal Information as described herein.

Nothing contained in this Privacy Policy shall be interpreted as creating contractual rights beyond those provided under applicable law.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to all Personal Information collected by Bou Younes Pharmaceuticals through the Website, including information obtained when you:

• browse or interact with the Website;
• submit inquiries through our online forms;
• request information regarding our products or services;
• communicate with us by email, telephone, or electronic correspondence;
• subscribe to newsletters or other communications;
• register for conferences, webinars, exhibitions, educational events, or promotional activities;
• request commercial or regulatory information;
• report product quality concerns or adverse events where applicable; or
• otherwise voluntarily provide Personal Information while interacting with the Company through the Website.

This Privacy Policy applies exclusively to Personal Information collected by or on behalf of Bou Younes Pharmaceuticals through the Website.

It does not apply to:

• third-party websites accessible through external links;
• websites operated by manufacturers represented by Bou Younes Pharmaceuticals;
• distributors, suppliers, or business partners operating independent platforms;
• social media platforms operated by third parties; or
• websites whose privacy practices are governed by separate privacy policies.

Users are encouraged to review the privacy policies of any third-party websites before submitting Personal Information.

3. DEFINITIONS

For the purposes of this Privacy Policy, the following terms shall have the meanings assigned below.

“Applicable Law”

Means all applicable laws, regulations, governmental decisions, regulatory guidance, and legally binding requirements relating to privacy, data protection, electronic communications, cybersecurity, and pharmaceutical regulation.

“Personal Information”

Means any information relating to an identified or identifiable natural person, whether directly or indirectly.

Depending on your interaction with the Website, Personal Information may include, without limitation:

• full name;
• professional title;
• employer or organization;
• business address;
• email address;
• telephone number;
• IP address;
• browser information;
• operating system;
• device identifiers;
• geographic location (where available);
• communications submitted through the Website;
• preferences;
• marketing subscriptions; and
• any additional information voluntarily provided by you.

Personal Information does not include information that has been irreversibly anonymized so that it can no longer identify an individual.

“Processing”

Means any operation performed on Personal Information, whether automated or manual, including collection, recording, organization, storage, consultation, use, modification, disclosure, transmission, sharing, restriction, deletion, destruction, or any other handling of Personal Information.

“Cookies”

Means small electronic files placed on a user’s device that enable the Website to recognize browsers, improve functionality, remember preferences, analyze Website performance, and support security.

“Healthcare Professional”

Means any physician, pharmacist, nurse, hospital, clinic, healthcare institution, wholesaler, distributor, or other licensed healthcare professional or healthcare organization interacting with Bou Younes Pharmaceuticals.

“Website”

Means the official Bou Younes Pharmaceuticals website together with all associated webpages, online services, and digital platforms operated by the Company.

4. INFORMATION WE COLLECT

Bou Younes Pharmaceuticals collects only the Personal Information reasonably necessary to conduct its legitimate business activities, provide requested services, comply with legal and regulatory obligations, and improve users’ experience while interacting with the Website.

The categories of information collected depend upon the nature of your interaction with the Company.

4.1 Information You Voluntarily Provide

We may collect Personal Information that you voluntarily provide when you:

• submit an inquiry;
• complete an online contact form;
• request product information;
• communicate with our commercial or regulatory teams;
• subscribe to newsletters or promotional communications;
• register for educational or professional events;
• request quotations or commercial proposals;
• participate in surveys;
• submit comments or feedback; or
• otherwise contact Bou Younes Pharmaceuticals.

Such information may include:

• your name;
• company name;
• position or professional title;
• telephone number;
• email address;
• business address;
• professional specialty;
• correspondence;
• and any additional information you voluntarily choose to provide.

4.2 Information Automatically Collected

When you access the Website, certain technical information may be collected automatically through cookies and similar technologies.

This information may include:

• IP address;
• browser type and version;
• operating system;
• device type;
• language preferences;
• pages visited;
• referring website;
• session duration;
• date and time of access;
• clickstream data;
• navigation behavior;
• and other technical identifiers necessary for security, analytics, and Website performance.

This information is generally used in aggregated form and, where possible, does not directly identify individual users.

5. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Bou Younes Pharmaceuticals processes Personal Information only where there is a legitimate and lawful basis for doing so. Depending on the nature of the interaction, the Company may process Personal Information on one or more of the following legal grounds:

• where the individual has provided consent;
• where processing is necessary to respond to an inquiry or request initiated by the individual;
• where processing is necessary for the performance of a contract or for the implementation of pre-contractual measures;
• where processing is required to comply with applicable legal, regulatory, judicial, or governmental obligations;
• where processing is necessary to protect the legitimate interests of Bou Younes Pharmaceuticals, provided that such interests are not overridden by the rights and freedoms of the individual concerned; or
• where processing is otherwise authorized or required under Applicable Law.

Where processing is based upon consent, individuals may withdraw their consent at any time. Withdrawal of consent shall not affect the lawfulness of any processing carried out prior to such withdrawal.

6. PURPOSES FOR WHICH WE USE PERSONAL INFORMATION

Bou Younes Pharmaceuticals processes Personal Information solely for legitimate business, operational, regulatory, and administrative purposes.

Depending upon the nature of your relationship with the Company, Personal Information may be used to:

• respond to inquiries, requests, and communications;
• provide information regarding products distributed by the Company;
• process requests for quotations, commercial proposals, and business opportunities;
• maintain business relationships with customers, suppliers, healthcare professionals, and commercial partners;
• administer customer support services;
• improve the functionality, security, and performance of the Website;
• conduct statistical analysis and monitor Website usage;
• personalize user experience where appropriate;
• administer educational activities, conferences, exhibitions, webinars, and scientific events;
• distribute newsletters and other marketing communications where legally permitted;
• protect the Company’s legal rights and legitimate business interests;
• detect, investigate, and prevent fraud, cyber threats, unauthorized access, or other unlawful activities;
• comply with internal governance policies and corporate compliance programs;
• satisfy contractual obligations owed to business partners;
• comply with applicable pharmaceutical regulations; and
• fulfill any other purpose disclosed at the time Personal Information is collected.

Bou Younes Pharmaceuticals shall not process Personal Information for purposes materially incompatible with those described in this Privacy Policy unless otherwise permitted or required by Applicable Law.

7. PHARMACEUTICAL REGULATORY COMPLIANCE

As a pharmaceutical distribution company, Bou Younes Pharmaceuticals operates within a highly regulated industry.

Accordingly, Personal Information may be processed where necessary to comply with applicable pharmaceutical legislation, regulatory obligations, governmental directives, and public health requirements.

Without limitation, such processing may include:

• responding to inquiries relating to pharmaceutical products;
• maintaining records required by competent regulatory authorities;
• responding to inspections or investigations conducted by governmental authorities;
• ensuring product traceability where legally required;
• documenting quality-related communications;
• maintaining compliance records;
• responding to recalls, safety notices, or regulatory alerts; and
• fulfilling any legal obligation imposed by the Ministry of Public Health or other competent regulatory authority.

Nothing contained in this Privacy Policy shall limit the Company’s ability to process Personal Information where such processing is required by law or by a competent governmental authority.

8. PRODUCT QUALITY COMPLAINTS AND PHARMACOVIGILANCE

Where individuals contact Bou Younes Pharmaceuticals regarding the quality, safety, performance, or use of pharmaceutical products, the Company may collect and process the Personal Information reasonably necessary to investigate, document, assess, and respond to such communications.

This may include information relating to:

• product quality complaints;
• adverse events;
• product safety reports;
• medical inquiries;
• technical complaints;
• product recalls;
• regulatory reporting obligations; and
• any other information necessary to comply with applicable pharmacovigilance or product safety requirements.

Where required by Applicable Law, such information may be disclosed to:

• the relevant product manufacturer;
• competent health authorities;
• regulatory agencies;
• authorized service providers assisting in pharmacovigilance activities; or
• other entities legally entitled to receive such information.

Bou Younes Pharmaceuticals shall process such information solely to the extent necessary to comply with applicable legal and regulatory obligations and to promote patient safety.

9. MARKETING COMMUNICATIONS

Where permitted by Applicable Law, Bou Younes Pharmaceuticals may use Personal Information to communicate with individuals regarding:

• corporate news;
• product announcements;
• educational content;
• scientific updates;
• conferences;
• promotional activities;
• newsletters; and
• other information relating to the Company’s business activities.

Marketing communications shall only be sent where:

• the recipient has expressly subscribed;
• an existing business relationship permits such communication under Applicable Law; or
• another lawful basis exists.

Recipients may unsubscribe from marketing communications at any time by following the unsubscribe instructions contained in the communication or by contacting the Company directly.

The withdrawal of consent to receive marketing communications shall not affect communications necessary for legal, regulatory, contractual, or administrative purposes.

10. COOKIES AND SIMILAR TECHNOLOGIES

The Website uses cookies and similar technologies to improve functionality, enhance user experience, analyze Website performance, maintain security, and facilitate efficient navigation.

Cookies may be used to:

• remember user preferences;
• recognize returning visitors;
• improve Website functionality;
• monitor Website traffic and usage patterns;
• generate statistical reports;
• maintain session integrity;
• prevent fraudulent activity; and
• enhance cybersecurity measures.

Most web browsers permit users to manage or disable cookies through their browser settings.

Users should be aware that disabling certain cookies may affect the availability or functionality of portions of the Website.

Where required by Applicable Law, Bou Younes Pharmaceuticals shall obtain appropriate consent before placing non-essential cookies on a user’s device.

11. DISCLOSURE OF PERSONAL INFORMATION

Bou Younes Pharmaceuticals respects the confidentiality of Personal Information and does not sell, rent, lease, trade, or otherwise commercially exploit Personal Information for monetary consideration.

Personal Information shall only be disclosed where such disclosure is necessary for legitimate business purposes, required by Applicable Law, authorized by the individual concerned, or otherwise permitted under this Privacy Policy.

Subject to applicable legal and regulatory requirements, Personal Information may be disclosed to the following categories of recipients:

11.1 Service Providers

The Company may engage carefully selected third-party service providers to assist in operating its business and Website, including providers of:

• website hosting and maintenance;
• cloud computing and data storage;
• cybersecurity services;
• information technology support;
• analytics services;
• email communication platforms;
• customer relationship management systems;
• document management;
• marketing support;
• professional consulting services; and
• other business support functions.

Such service providers shall process Personal Information solely on behalf of Bou Younes Pharmaceuticals and only to the extent necessary to perform the services requested.

The Company requires such providers to implement appropriate confidentiality obligations and security measures consistent with Applicable Law.

11.2 Regulatory Authorities

Bou Younes Pharmaceuticals may disclose Personal Information where disclosure is necessary or appropriate to comply with:

• applicable laws and regulations;
• governmental requests;
• judicial orders;
• subpoenas;
• investigations;
• regulatory inspections;
• licensing obligations;
• public health requirements; or
• requests from competent authorities.

Nothing in this Privacy Policy shall prevent the Company from complying with any legal obligation requiring the disclosure of Personal Information.

11.3 Professional Advisers

Personal Information may be disclosed, where reasonably necessary, to the Company’s:

• legal advisers;
• external auditors;
• accountants;
• insurers;
• compliance consultants;
• financial advisers; and
• other professional advisers,

provided that such recipients are subject to appropriate confidentiality obligations.

11.4 Business Partners

Where necessary to provide requested services or facilitate legitimate business activities, Bou Younes Pharmaceuticals may share limited Personal Information with manufacturers, suppliers, distributors, logistics providers, or other commercial partners.

Such disclosures shall be limited to the minimum information reasonably necessary for the relevant business purpose.

11.5 Corporate Transactions

In the event of a proposed or completed merger, acquisition, corporate restructuring, financing transaction, asset sale, reorganization, joint venture, or similar corporate transaction, Personal Information may be transferred to the acquiring or successor entity, provided appropriate safeguards are maintained.

12. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Due to the international nature of the pharmaceutical industry, Personal Information may occasionally be transferred to, processed, or stored in jurisdictions outside Lebanon.

Where such transfers occur, Bou Younes Pharmaceuticals shall take reasonable measures to ensure that Personal Information continues to receive an appropriate level of protection consistent with this Privacy Policy and Applicable Law.

Where required, the Company shall implement appropriate contractual, organizational, or technical safeguards designed to protect Personal Information transferred across international borders.

13. DATA SECURITY

Bou Younes Pharmaceuticals recognizes that information security is an essential component of responsible data governance.

Accordingly, the Company implements commercially reasonable administrative, organizational, physical, and technical safeguards designed to protect Personal Information against:

• unauthorized access;
• accidental loss;
• misuse;
• unlawful disclosure;
• destruction;
• alteration;
• corruption; and
• unauthorized processing.

Such safeguards may include, where appropriate:

• secure hosting environments;
• encryption technologies;
• firewalls;
• access controls;
• authentication procedures;
• password management;
• monitoring systems;
• cybersecurity protocols;
• employee confidentiality obligations;
• periodic security assessments; and
• internal governance procedures.

The Company regularly reviews and updates its security measures in light of technological developments, operational requirements, and evolving cybersecurity risks.

Nevertheless, no electronic transmission or method of electronic storage can be guaranteed to be entirely secure.

Accordingly, while Bou Younes Pharmaceuticals endeavors to protect Personal Information using commercially reasonable safeguards, the Company cannot warrant or guarantee absolute security.

14. DATA RETENTION

Bou Younes Pharmaceuticals retains Personal Information only for as long as reasonably necessary to achieve the purposes described in this Privacy Policy or to comply with applicable legal, contractual, regulatory, accounting, tax, or pharmaceutical record-retention obligations.

The applicable retention period depends upon several factors, including:

• the nature of the information;
• the purpose for which it was collected;
• legal obligations applicable to the Company;
• regulatory requirements;
• operational necessity; and
• the Company’s legitimate business interests.

Upon expiration of the applicable retention period, Personal Information shall be securely deleted, anonymized, or otherwise disposed of in accordance with the Company’s internal policies and Applicable Law.

• request confirmation as to whether we process your Personal Information;
• request access to the Personal Information we hold about you;
• request the correction of inaccurate or incomplete Personal Information;
• request the deletion of your Personal Information where permitted by Applicable Laws;
• request the restriction of certain processing activities;
• object to specific categories of processing where permitted by Applicable Laws;
• withdraw your consent at any time where processing is based on your consent, without affecting the lawfulness of processing carried out prior to such withdrawal;
• request information regarding the manner in which your Personal Information is processed; and
• lodge a complaint with the competent supervisory or regulatory authority, where such right is provided under Applicable Laws.