Privacy Policy of Spharma LLC
Version effective from February 25, 2026, Tashkent
Introduction
This Privacy Policy (hereinafter — the "Policy") has been developed by Spharma LLC (state registration No. 2435800, TIN: 311 243 300), hereinafter — the "Company", "we", "us".
The Policy defines the procedures for collecting, processing, storing, using, and protecting personal data of users of the Spharma mobile application (hereinafter — the "Application", the "Service") in accordance with the Law of the Republic of Uzbekistan "On Personal Data" (No. ZRU-547, dated 02.07.2019).
By using the Application, the User unconditionally agrees to this Policy and the terms of personal data processing. If you do not agree with the terms, please refrain from using the Application.
1. User information processed by Spharma
1.1. Data provided voluntarily by the User
Provided during registration and use of the Service:
- Phone number — for registration and login via SMS code (OTP).
- Email address — for email-based registration (optional).
- First and last name — for profile personalization (optional).
- Date of birth — for personalized offers (optional).
- Gender — for personalized offers (optional).
1.2. Data collected automatically
Collected automatically during use of the Application:
- IP address — for session security.
- Device type and name — for managing active sessions.
- Date and time of access — for session logging.
1.3. Loyalty program data
- Loyalty card number and unique identifier.
- Bonus points balance.
- Transaction history (points accrual and redemption).
1.4. Security data
IP addresses and device identifiers may be used to detect activities that violate applicable laws, as well as to prevent fraud and unauthorized access.
1.5. Information from counterparties
We may receive transaction information from partner pharmacies in the course of fulfilling agreements within the loyalty program.
1.6. Data we do NOT collect
- Geolocation (GPS coordinates).
- Payment data (bank card numbers, account details).
- Medical information and prescriptions.
- Contacts, photos, and files from your device.
2. Purposes of personal data processing
2.1. Principle of minimality
The Company collects only the information that is necessary and retains it no longer than required for the purposes of processing, unless otherwise stipulated by the legislation of the Republic of Uzbekistan.
2.2. Main purposes of processing
| No. | Purpose |
|---|---|
| 2.2.1 | Compliance with the legislation of the Republic of Uzbekistan |
| 2.2.2 | User registration, authentication, and identification |
| 2.2.3 | Sending SMS verification codes |
| 2.2.4 | Managing User profile and settings |
| 2.2.5 | Loyalty program operation (points accrual and redemption) |
| 2.2.6 | Displaying personalized offers and recommendations |
| 2.2.7 | Ensuring security and preventing fraud |
| 2.2.8 | Improving Application quality and user experience |
| 2.2.9 | Communication with Users, processing inquiries and requests |
| 2.2.10 | Protecting the legitimate interests of the Company |
3. Terms of processing and data transfer to third parties
3.1. General principles
Personal data processing is carried out in accordance with this Policy and the Company's internal regulations. We do not sell Users' personal data. Confidentiality of information is guaranteed.
3.2. Data transfer is permitted in the following cases
- With the explicit consent of the User — under the terms provided by this Policy.
- SMS provider (Playmobile) — phone number and verification code for sending SMS messages. Data transferred: phone number, message text.
- Partner pharmacies — loyalty card data and transaction information for points accrual and redemption during purchases. Data transferred: loyalty card identifier, transaction amount and type.
- In accordance with legal requirements — upon request from authorized state bodies in the manner prescribed by the legislation of the Republic of Uzbekistan.
- To protect the rights and interests of the Company — in case the User violates the terms of use of the Application.
All third parties are required to ensure the confidentiality and security of transferred data in accordance with the Law of the Republic of Uzbekistan "On Personal Data" (No. ZRU-547).
4. Protection of personal information
4.1. Organizational and technical measures
The Company takes the necessary organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, and distribution.
4.2. Security mechanisms in place
- Passwords are stored in encrypted form (bcrypt) and are never stored in plain text.
- Authentication is performed using time-limited JWT tokens.
- Sessions automatically expire after 7 days of inactivity.
- All connections are protected by the HTTPS/TLS protocol.
- Data access is restricted to authorized personnel only.
- Confidentiality regime and compliance monitoring are ensured by internal regulations.
4.3. Regulatory framework
Personal data protection is carried out in accordance with the Law of the Republic of Uzbekistan "On Personal Data" (No. ZRU-547, dated 02.07.2019) and other regulatory legal acts.
5. User rights
5.1. Modification and deletion of information
The User has the right to:
- Access their personal data through the profile section of the Application.
- Modify their personal data in the profile settings.
- Delete their account and associated data through the Application or by contacting spharma.uz@gmail.com.
- Withdraw consent to data processing by ceasing to use the Application and deleting the account.
5.2. Right of access to information
In accordance with Article 22 of the Law of the Republic of Uzbekistan "On Personal Data", the User has the right to obtain the following information:
- Confirmation that personal data is being processed.
- Grounds and purposes of processing.
- Methods of data processing.
- Information about the operator and persons with access to the data.
- Composition of processed data and sources of their acquisition.
- Terms of data processing and storage.
- Information about cross-border data transfers.
Requests should be submitted in writing to spharma.uz@gmail.com. The review period is 30 (thirty) days from the date of receipt, with the possibility of extension up to 60 (sixty) days if necessary.
5.3. Right to object
The User has the right to withdraw consent or raise objections to the processing of personal data on legitimate grounds by submitting a written request to spharma.uz@gmail.com. The User also has the right to file a complaint with the supervisory authority in accordance with the legislation of the Republic of Uzbekistan.
6. Minors' data
The Application is not intended for persons under the age of 16. The Company does not knowingly collect personal data from minors. If we become aware that data has been provided by a person under 16, we will take immediate steps to delete it.
7. Cookies and analytics
The mobile application does not use cookies. We do not use third-party analytics systems or advertising trackers.
8. Changes to the Policy
The Company reserves the right to modify and/or supplement this Policy by publishing an updated version. In the event of significant changes, we will notify Users through the Application. Continued use of the Application after changes are published constitutes the User's acceptance of the updated Policy.
Governing law — the legislation of the Republic of Uzbekistan.
9. Contact information
For questions related to this Policy, please contact us:
- Company: Spharma LLC
- State registration: No. 2435800
- TIN: 311 243 300
- Email: spharma.uz@gmail.com
Appendix: Definition of terms
- Personal data — any information relating to an identified or identifiable natural person (personal data subject).
- Personal data processing — any action (operation) or set of actions performed on personal data: collection, recording, systematization, accumulation, storage, clarification, use, transfer, depersonalization, blocking, deletion, and destruction.
- User — a natural person using the Spharma Application.
- Service / Application — the Spharma mobile application providing access to the pharmaceutical catalog and the loyalty program.
- Loyalty program — a bonus program that allows Users to accumulate and use bonus points when making purchases at partner pharmacies.