Last update: February 18, 2019
Our Privacy Policy

Welcome to our privacy policy! It is wonderful that you want to learn more about the way we keep your information safe. This policy will provide you with information about how we handle your personal data
when you visit our website (no matter where you visit the site from) or if you use our services or apps. The policy also tells you about your privacy rights and how the law protects you.

So, if you are looking for more information on how we collect, store, use and distribute the personal data we collect, this is the right place for you!

Now, to start, some practical but very important details for you to consider!

Who we are
The Babylon Consult Group is made up of several different legal entities from around the world. Read more about the Babylon Consult Group here.

This privacy policy is issued on behalf of all companies in the Babylon Consult Group. All the companies from the Babylon Consult Group have decided that the Romanian company Babylon Consult LLC will be
our global data administrator (the one responsible and liable for data). When we use “we” in this policy, we are actually talking about Babylon Consult LLC.

How to get in touch with us
We have not appointed a Data Protection Officer (DPO) to be responsible for overseeing questions related to this privacy policy.

If you have any questions about this policy, please contact us at:
Babylon Consult LLC, 3 Intrarea Unditei, District 1, post code RO-014113, Romania
Att: Privacy policy
Or via e-mail at: privacy@babylonconsult.ro
Phone number: +40722223010

Please include your name and, if known, the name of the relevant Babylon Consult Group company. It is absolutely fine if you do not have this information, and so we will treat your request as if the question is
addressed directly to Babylon Consult LLC.

Your rights as a person from whom we have personal data available (data subject).

You can change your account information by sending an email. If you would like to unsubscribe from newsletters or marketing emails, for example, you will be able to do so via the link provided in those
emails. If you wish to delete placed cookies, our cookie policy will help you do this (more on this later in the Cookies Policy).

At any time we hold or process your personal data, you have the following rights:
– Right of access – you have the right to request a copy of the information we hold about you.
– Right to rectification – you have the right to correct inaccurate or incomplete data we hold about you.
– The right to be forgotten – in certain circumstances you may request that the data we hold be deleted from our records. If we are legally obliged to keep the information or if deletion is impossible or
inappropriate, we will not delete it, but we will only keep it for as long as necessary and in accordance with the time limits in our data systems.
– Right to restrict processing – if there are certain conditions that may apply in order to have the right to restrict processing.
– The right to portability – you have the right to transfer the data we hold to another organization.
– The right to object – you have the right to object to certain types of processing, such as direct marketing.
– The right to oppose automated processing, including profiling – you also have the right not to allow IT systems to make decisions about you directly (this does not include general marketing based on your
age, gender and language).
– The right to a legal review – if we refuse your request based on the right of access, we will give you the reason why it was refused. In this situation, you have the right to file a complaint.

One thing to keep in mind before contacting us. Our sites and applications may contain links to other sites that are not owned or controlled by us. It could be, for example, social media platforms / services.
We are not responsible for the privacy practices of these sites, so if you have any questions about such sites, you should contact those sites directly.

We also strongly encourage you to know and read the privacy policies of other sites, as they may collect, store, use and share your personal information with ease.

Complaints about our conduct
You have the right to complain if you feel that the Babylon Consult Group is not fulfilling its responsibilities regarding your data.
You can contact us on this e-mail account privacy@babylonconsult.ro. We will send you a confirmation within 5 days and we will do our best to resolve the issue within one month. If the problem is difficult or
requires a lot of work, it may take longer, but we will keep you posted.
You always have the right to complain to the authorities, but because we take privacy issues seriously, we’d appreciate it if you could talk to us first. The authority that has the right to investigate us is the
Romanian Agency for Data Protection. You can see additional information on their website: https://dataprotection.ro

You can make complaints about:
– how your personal data has been processed;
– how your request for data access has been handled;
– how the complaint was handled;
– the appeal you can make against any decision taken as a result of a complaint.

Our data collection rules
We take privacy very seriously, so we will only ask for the information we need to provide you with excellent services.

Whenever we collect customer data, we make sure that:
– We ask permission to collect the data
– We use the data only for the agreed reason and for the necessary time
– We will at least comply with local data protection laws in the country where we offer you a service through our website or applications.
– We keep the data we are obliged to have at our disposal
– Explain why we need data and how we will use it (unless we have a legitimate reason not to do so)
– We regularly check and update privacy information (we may also check data against other databases to make sure they are correct)
– We do not share data with anyone if we do not have legal or legitimate reasons or if we do not have your consent or if you are a child under the age of 16, the consent of your parents.

Data collection in our online channels
We collect personal and anonymous information from you when you visit any of the babylonconsult.ro sites or when you use one of our apps.
When you visit our online channels, you will be able to check if we collect data in the terms and conditions of the site.
We also receive information through a third party when you visit our page on sites or social media channels (for example, Facebook, Twitter, Youtube, Instagram, Whatsapp, Wechat, etc.).

The types of personal information we collect
When you visit any of these online channels, we may collect:
– Registration information we use to help you set up an account, depending on your account type (e.g., your name, company, your position within the company, official ID information, country, gender, date of
birth, email address, username and password).
Information about payments or transactions that we use when you purchase products or use online services (e.g., mailing address, phone number or credit card number, bank accounts, banking
companies).
– Location or IP address information, which we use to provide you with relevant content online.
– Information you have publicly submitted through comments, feedback and reviews on our sites, blogs and forums.
– Information you have sent to a person or group using our messaging, chat, or public posting services
– The information you provide when you use our own online or third-party channels (such as social networks) or if you connect your Babylon Consult registration account to a third-party platform.

Why we need to process personal data
In legal terms, the way we “process data” describes how we collect, store, use, distribute and delete the data we receive from customers. When you share your personal information with us on our online
channels, we will process your data as described in this privacy policy.

Because we are a global company that sells services directly to customers, we need to process customers’ personal data so that:
– Customers can order services and download files in electronic format from our online platform Babylon Consult and want them to be delivered in hardcopy wherever they want
– Customers can register for any accounts and services they want to use
– Customers can use the online and offline Babylon Consult experiences we have created for them
– Customers can exchange information on our public forums
– We can send customers all the information they have requested or we can answer their questions
– We can ask customers to give us feedback about our services through questionnaires and surveys
– We can provide our customers with relevant information about our products and services.

Always keep in mind that if you use a Babylon Consult service through a third-party channel, such as social media or a Babylon Consult app, that third party may also process your personal data according to
its own privacy processes.

We may use the decision-making option to automatically process your personal information for certain services and products. An example is our efforts to prevent and detect fraud on inet.babylonconsult.ro.
You can request a manual review of the accuracy of an automatic decision if you are not satisfied with it.

How we process personal data
When you visit our online channels or use third-party sites or platforms, we use technologies such as cookies, flash cookies, pixels and web beacons to process your personal data.

Please visit our Cookies Policy for more information, including information on how to delete cookies on your device and how to prevent them from being placed there in the first place.

Please note that if you enable a cookie prevention feature on your device, some of our services and features on the site will no longer work.

We also collect information from other trusted sources so that we can update or add the personal information we have collected.

Exchange of information with trusted subsidiaries (other Babylon Consult companies)
Our subsidiaries (other companies in the Babylon Consult Group) may sometimes have access to your information to provide you with services on our behalf. Because the Babylon Consult Group wants your
data to be confidential, we have made the decision to implement the same privacy protection around the world so that you feel safe regardless of the Babylon Consult Group company that uses your data.
Babylon Consult Group companies will act as “data processors” and will be subject to data processing laws. They need your personal data to be able to:
– Deliver the products and services you have requested
– Get in touch with you regarding your account or transactions.
– Send you information about our sites, applications and policies
– Send you any newsletter you have subscribed to (you can unsubscribe at any time)
– To process the information that the subsidiary is officially contracted to process on our behalf, e.g. to
make a purchase placed by you, to manage the activity of your Babylon Consult ID account or your VIP
account data.
– To identify, review and stop any activity that could violate our policies or the law

Sharing information on public forums and chat
Since everyone can read our public forums and chat services, the public can see any personal information you share on them.

If you wish to remove your personal information from the public areas of the site, please send an email to our customer service. If we cannot delete your personal information for any reason, we will let you
know why. If you are under 16, you will need permission from a parent or guardian to use our public forums or chat.

Disclosure of your Babylon Consult ID profile
You can use your Babylon Consult code on the third-party sites of our trusted partners so that you can order services without creating a separate account. If you choose to use your Babylon Consult ID
account, we will have access to some of the information you provide on third-party websites. We will collect, store, use and process this information according to this Privacy Policy. Third-party sites will also
be able to access certain information in your Babylon Consult ID profile so that you can participate in experiences on their site. Read the privacy policy if you want to learn more about how they use your
information.

Sharing information on Social Media (features) and widgets
Some of our sites may include social media links, such as the “like” Facebook button, widgets such as the “Share” button, and interactive mini-programs. If you click on any of these links, the functions may
collect your IP address and record the page you are currently visiting. Functions may also use cookies to make the function work properly. Social media features and widgets are hosted by third parties or may
be hosted directly on our site. When you use these features and widgets, your personal data will be processed by that third party according to its own privacy policies.

Exchange of information with other companies
Check out here our list of trusted third-party categories to whom we can share your information.

We will not share your personal information outside of the Babylon Consult group except for the following:
– When we have to apply the terms of use or the policies we ask customers to accept;
– When we need to protect the safety, security, rights and property of our customers or our third party partners;
– When we face legal proceedings or if the disclosure of data is required by law;
– When we contact other companies, such as payment providers, IT platform providers, fraud detection and prevention service providers, survey providers, product catalog providers and customer service
providers, to provide services on our behalf; we have contracts with companies to ensure that they only use your personal information for agreed services and to meet the legal requirements of the company;
– When we store your information using secure cloud storage services / facilities. We have contracts with companies to ensure that we only use your personal information for agreed-upon services and
meet legal requirements;
– If there is a merger, acquisition or sale of assets that involves sharing information with a third party – in this case we will send you an email and post a notice on our website to publish the change of ownership
and you we will also communicate how your data will be used and give you options regarding your personal data;
– When you have given us permission to share your information with third parties so that they can send you information about their products and promotions (you may opt out of these messages by contacting
our Babylon Consult customer team, although in some cases, contact the third party directly);
– When you have given us permission to share your information with third parties, they may provide you with information and marketing promotions about our products and services (for example, personalized
advertising provided through a social media platform). You can opt out of such marketing activities by changing your cookie settings on your device. In some cases, you may need to contact a third party
directly (if social media changes your privacy settings and requests that the information collected by the third party site be deleted)
– When you ask us to share your personal information with third-party sites or platforms, such as social networking sites – after it has been shared, your personal data will be processed by that third party
according to their own privacy processes.
How long do we keep your personal information?
We will retain your personal information for as long as your account is active or for as long as is necessary to provide a service. We have so-called retention policies for each of the categories of
personal information we process.
If you wish to cancel your account or delete your data, we will only keep the information we need for legal reasons, to resolve disputes or to implement our agreements.

Our cookie policy
Cookies are small data files that your browser places on your computer or device. A cookie does not contain or collect information. However, when read by a server through a web browser, it can help a
website provide an easier-to-use service – for example, recalling previous purchases or account details.

Like most websites, our online channels and apps collect certain information (for example, information about IP addresses, browsers used, internet service providers, reference pages, exit pages, operating
systems, the time period they were accessed, the hours they were accessed and clickstream data). This information will not be linked to any other information we collect about you unless you have agreed
that we can do so.

Both we and our third-party visitor facilitators use browser storage, application storage, cookies, pixels, flags, scripts, and trend analysis tags, site administration, and user movement tracking through the site
and the collection of demographic information about our global user base. We may receive reports on these from our third-party partners on an individual and aggregated basis. For more information about
cookies, read the full Cookie Policy.

Our employees and collaborators are authorized or independent individuals or individual companies

Whether you are an existing employee or collaborator, or you are applying for a job or service contract, we will process specific information relevant to your employment and application. The principles of this
Privacy Policy will apply to your employment and application or collaboration.

Babylon Consult Partners
We define Babylon Consult Partners as other companies doing business with the Babylon Consult Group.
We process information about Babylon Consult Partner companies for collaboration and evaluation.

Data security and integrity
The security, integrity and confidentiality of customer information are extremely important to us. We use technical, administrative and physical security measures to protect personal information from
unauthorized access, disclosure, use and modification. All external transfers containing personal information are made using encrypted technology. Credit card information is taken over by authorized
service providers that comply with Card Payment Industry (PCI) standards and have adequate safeguards.
Although we regularly review our security procedures and evaluate new technologies and methods to make our online channels more secure, no security measures are perfect or impenetrable. Our
customers, employees and partners also play an important role in protecting information. We encourage customers to choose passwords that are difficult for others to guess and to keep their
password secret. If you notice any omissions or concerns about our security, please contact our Babylon Consult customer support team as soon as possible.

If we ever encounter a data breach in which customer information is exposed to the risk of misuse, we will contact customers in accordance with legal requirements. If necessary, we will also contact the data
protection authorities.

Global data transfers, storage and processing
Given that we are a global company, we may transfer your personal information to the individual subsidiaries of the Babylon Consult Group or to third parties around the world for the purposes
described in this Privacy Policy. Whenever your personal information is transferred, stored or processed by us or the companies that provide such services on our behalf, we will take reasonable steps to
protect the privacy of your personal information. In addition, when we use or disclose personal information, we comply with our mandatory corporate rules when they become effective.

Binding corporate rules give you the best security when it comes to how your information is processed.

Mandatory corporate rules and local legal requirements
We want to make sure that we use at least the data privacy and security standards resulting from the General European Data Protection Regulation (“GDPR”) anywhere in the world, where we collect, store,
use or share your personal data. If local rules require more from us, we will adapt our practice to ensure that your data is safe with us, no matter where you are in the world! In order to commit to this promise,
we have implemented something called Mandatory Corporate Rules, with effect from June / 2016, “Mandatory Corporate Rules”. These rules are set by European data authorities across the European
Union (EU) and set some of the highest standards in the world for data collection, storage, use and sharing.

Note to California Residents: If you are a resident of California, you are permitted by Section 1798.83 of the California Civil Code to request information from third parties regarding the disclosure of your
personal information by certain members of the Babylon Consult Group for marketing purposes. With respect to these entities, this privacy policy applies only to activities in the State of California.

Notice to Australian residents: As to how we process your information to comply with local law, in addition to the Privacy Policy the following will apply: We generally collect personal information directly
from you if this is the case. This is reasonable and practical, but it may also obtain information from other trusted sources to update or supplement the personal information that you have provided or have
processed automatically.

We may also use your personal information to inform you about Babylon Consult group or third party products and services. From time to time, we and The Babylon Consult Group entities and our business
partners may contact you by mail, telephone, email or other electronic messaging services (such as text, voice, sound or image messages, including use of automated calling systems) and services (including
discounts and Special Offers). If you no longer wish to receive marketing or promotional information from us and Babylon Consult Group entities or our partners, you may unsubscribe at any time. There are
certain messages regarding the goods and services we offer, from which you cannot unsubscribe. If the Babylon Consult Group faces a data breach and your information is involved, we will contact you if
there is a risk of serious injury and if we are legally obliged to do so. In some cases, the Babylon Consult Group will also be legally obliged to contact data protection authorities when a data breach of personal
information occurs.

We will take reasonable steps (if any) to destroy or identify personal information when it is no longer needed.

Changes to this Privacy Policy
We may modify this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements, or other purposes. We will notify users in advance by e-mail and post the information on
our online channels if these changes are important and we will ask for your consent if legally required.

Categories of third party suppliers
Babylon Consult Group works with several trusted partners to ensure that we offer you, our business partners and our employees the best possible experience. This means that sometimes we have to allow
third parties to process personal data.

To give you an overview, we have classified the types of suppliers we use and what we use them for into categories.

However, if you’d like to know which cookies we place on your devices, please see our detailed list of cookies.

We process personal data with suppliers in the following categories:
– IT service providers – we use a number of trusted partners worldwide to provide us with IT services and systems administration services – both in terms of customer and partner activities as well as our
internal IT and Administration Systems.
– The global payment provider and processing partners – to ensure a safe and efficient payment process both online and in our stores, either through billing or money transfers.
– Cloud storage partners – we store our data and your data at secure data centers around the world.
– Fraud prevention and identification of partners and agencies – working with the Babylon Consult group around the world to ensure that the Babylon Consult group is not defrauded.
– Storage, packaging, transportation and delivery performed by Partners – helps us put our products in the hands of our customers and business partners around the world.
– Catalogue printing, correspondence and postal and Parcel Service Partners – helps us send you and ensures that documents, letters, magazines and catalogues reach you.
– Marketing partners – to be able to provide you with targeted and personalized ads, promotions and campaigns, both when interacting with Babylon Consult on our online platforms, as well as on social
networks, on the internet or through other channels.
– Social Media Partners – introduces you and allows you to interact with the Babylon Consult Group on the platforms you are on.
– Surveys, questionnaires and product review providers – help us ensure that we receive your feedback on your experience with Babylon Consult, which is very important to us!
– Worldwide tax and customs authorities, regulators and other authorities – which require reporting of processing activities under certain circumstances.
– Worldwide professional advisers – including lawyers, bankers, auditors and insurers, who provide consulting, banking, legal, insurance and accounting services to the Babylon Consult Group.