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PRIVACY POLICY
BIOREVIT PLATFORM

  1. Introduction
    This Privacy Policy explains how Center for Bioinformatics Skopje (“Company”, “we”, “us”,
    “our”) collects, uses, stores, transfers, and protects personal data in connection with the BioRevit
    Platform (the “Platform”).
  2. Identity of the Controller
    Center for Bioinformatics Skopje (CB)
    Registered seat: [insert address]
    Registration number: [insert number]
    Contact email: [privacy@…]
  3. Scope and Applicability
    This Policy applies to personal data processed:
    i. When you access our website;
    ii. When you create an account;
    iii. When you purchase or manage a subscription;
    iv. When you interact with Platform content;
    v. When you contact customer support;
    vi. When you receive marketing communications.
    This Policy does not apply to third-party websites linked from the Platform.
  4. Categories of Personal Data
    4.1 Information You Provide Directly
    We may collect:
    a. Full name
    b. Email address
    c. Account credentials
    d. Subscription details
    e. Billing information (processed by third-party payment processors)

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f. Communication content
g. Preferences relating to content usage
4.2 Information Collected Automatically
When you use the Platform, we may collect:
i. IP address
ii. Device identifiers
iii. Browser type and version
iv. Operating system
v. Time zone settings
vi. Access timestamps
vii. Log files
viii. Technical diagnostics
ix. Usage statistics
4.3 Platform Usage and Interaction Data
We may collect information regarding:
x. Video segments accessed
xi. Frequency of usage
xii. Session duration
xiii. General content category preferences
This data is used for service optimization and content improvement.

  1. Explicit Statement on Health and Special Category Data
    The Platform is a digital wellness content service.
    We do not intentionally collect or process special categories of personal data under Article 9
    GDPR, including:
    a) Medical diagnoses
    b) Clinical treatment data
    c) Biometric data
    d) Genetic data
    e) Data concerning physical or mental health conditions
    The Platform does not provide medical assessments, medical monitoring, or healthcare
    services.

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  1. Legal Bases for Processing
    The Company is established in North Macedonia and operates under Macedonian Laws; the
    Platform is made available to users within the European Union and other jurisdictions. Where
    the General Data Protection Regulation (GDPR) applies pursuant to Article 3(2) (offering
    services to individuals in the Union), we process personal data strictly in accordance with Article
    6 GDPR.
    Depending on the nature of the processing activity, we rely on the following lawful bases:
    6.1 Performance of a Contract (Article 6(1)(b) GDPR)
    We process personal data where such processing is necessary to enter into or perform a
    subscription agreement with the user.
    This includes processing required to:
    i. create and manage user accounts;
    ii. authenticate access credentials;
    iii. provide subscription-based access to digital content;
    iv. deliver audiovisual wellness content through the Platform;
    v. process subscription payments through authorized payment providers;
    vi. respond to user inquiries and provide customer support;
    vii. maintain and administer the contractual relationship.
    Without this processing, we would be unable to provide the Platform services.

6.2 Legitimate Interests (Article 6(1)(f) GDPR)
We process certain personal data on the basis of our legitimate interests in operating, securing,
and improving the Platform as a digital service.
These interests include:
i. ensuring Platform security and preventing unauthorized access;
ii. detecting and preventing fraud or misuse;
iii. maintaining system integrity and network security;
iv. analyzing usage patterns to improve service performance;
v. optimizing user experience and content delivery;
vi. protecting our legal rights and enforcing our Terms.
Where we rely on legitimate interests, we have conducted an internal assessment to ensure that
our interests are not overridden by the rights and freedoms of users. Such processing is limited
to what is proportionate and reasonably expected in the context of a subscription-based digital
service.
6.3 Consent (Article 6(1)(a) GDPR)
In certain circumstances, we rely on the user’s explicit consent to process personal data.

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This applies in particular to:
a) optional sending promotional or marketing communications;
b) deploying non-essential cookies or similar tracking technologies;
c) optional subscribing users to newsletters or optional communications.
Where processing is based on consent, users may withdraw their consent at any time without
affecting the lawfulness of processing carried out prior to withdrawal.
6.4 Compliance with Legal Obligations (Article 6(1)(c) GDPR)
We may process personal data where necessary to comply with applicable legal and regulatory
obligations, including but not limited to:
a) tax and accounting requirements;
b) financial reporting obligations;
c) lawful requests from public authorities;
d) regulatory compliance duties in jurisdictions where we operate.

  1. Purposes of Processing
    We process personal data for clearly defined and limited purposes consistent with the nature of
    the Platform as a subscription-based digital wellness service.
    These purposes include:
    i. administering user accounts;
    ii. managing subscription plans and renewals;
    iii. processing and verifying payments;
    iv. delivering audiovisual content and enabling Platform functionality;
    v. personalizing content recommendations based on general usage behavior;
    vi. improving Platform design, performance, and user experience;
    vii. maintaining technical infrastructure and ensuring cybersecurity;
    viii. preventing abuse, fraud, and unauthorized access;
    ix. communicating service updates, support responses, and transactional notices;
    x. complying with applicable legal and regulatory obligations.
    We do not sell, rent, or trade personal data to third parties.
  2. Cookies and Tracking Technologies
    The Platform uses cookies and similar technologies for:
    i. Authentication
    ii. Security
    iii. Platform functionality
    iv. Analytics

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v. Performance monitoring
Non-essential cookies are deployed only after obtaining valid user consent.
Users may manage cookie preferences via the consent banner or browser settings.
Withdrawal of cookie consent does not affect the lawfulness of prior processing.

  1. Recipients of Personal Data
    We may share personal data with:
    a. Payment service providers
    b. Cloud infrastructure providers
    c. Hosting services
    d. IT and security providers
    e. Analytics providers
    f. Legal and professional advisors
    g. Regulatory or public authorities when legally required
    All processors are contractually bound by data processing agreements in accordance with Article
    28 GDPR.
  2. Data Retention
    We retain personal data only for as long as necessary to fulfill the purposes described in this
    Policy, including:
     Duration of the subscription relationship;
     Legal retention obligations;
     Legitimate business needs such as dispute resolution or enforcement of agreements.
    Retention periods are periodically reviewed.
  3. Data Security Measures
    We implement appropriate technical and organizational measures, including:
     Encrypted transmission (SSL/TLS)
     Secure server infrastructure
     Access limitation policies
     Authentication mechanisms
     Internal confidentiality obligations
     Periodic security assessments
    Despite these measures, no system can guarantee absolute security.

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  1. Data Subject Rights
    Under the GDPR, users have the right to:
     Access their personal data
     Rectify inaccurate data
     Request erasure
     Restrict processing
     Object to processing
     Request data portability
     Withdraw consent at any time
    Requests may be submitted to: [insert email].
    We will respond within one month in accordance with Article 12 GDPR.
  2. Right to Lodge a Complaint
    Users have the right to lodge a complaint with:
     The Agency for Personal Data Protection of North Macedonia; or
     The supervisory authority in their EU Member State of residence.
  3. Children’s Data
    The Platform is not directed to individuals under 18 years of age.
    We do not knowingly collect data from minors.
  4. Updates to This Privacy Policy
    We may update this Privacy Policy from time to time to reflect:
    i. changes in applicable law or regulatory guidance;
    ii. technical or operational modifications to the Platform;
    iii. updates to our processing practices;
    iv. expansion of our services to new jurisdictions.
    Where changes are material, we will provide appropriate notice through the Platform or, where
    required by law, by direct communication to registered users.
    The “Last updated” date at the top of this Policy indicates when the most recent revisions were
    made.

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Continued use of the Platform following an update constitutes acknowledgment of the revised
Privacy Policy.

  1. Contact Information
    For any questions regarding this Privacy Policy or our data processing practices, users may
    contact us at:
    Center for Bioinformatics Skopje
    [Insert address]
    Email: [privacy@…]

Skopje, North Macedonia
Last updated: February 2026

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