Pills Tracker

Privacy and Personal Data Processing Policy

Effective date: June 1, 2026

Pills Tracker (“the App”) is owned and operated by LLC Neoproxima (the “Operator”).

LLC “Neoproxima”
Identification number: 400469587
Legal address: Georgia, Tbilisi, Davit Gamrekeli St. 19, office 614
Phone: +995 599 897 615
Contact email: info@neoproxima.pro
Website: https://neoproxima.pro/

1. General provisions

1.1. This Privacy and Personal Data Processing Policy governs the processing of personal data of users of the Pills Tracker application, website, web pages, interfaces, services and other related digital products provided by LLC Neoproxima, hereinafter the Operator.

1.2. This Policy applies to users from the Russian Federation, the Republic of Belarus, the Republic of Kazakhstan, the Republic of Armenia and Georgia, and also applies in other cases to the extent not inconsistent with applicable law.

1.3. By using the application, creating an account, entering data or continuing to use Pills Tracker functionality, the user confirms that they have read this Policy.

1.4. If certain application features require a separate consent, such consent is requested additionally in the application interface.

1.5. The country-specific annexes at the end of this document form an integral part of it.

2. Terms

2.1. Personal data means any information relating to a directly or indirectly identified or identifiable user.

2.2. Health data means information that the user independently enters into the application and that relates to medication intake, dosages, schedules, symptoms, wellbeing, notes and other medical or sensitive data.

2.3. Personal data processing means any operation or set of operations with personal data, including collection, recording, systematization, storage, updating, use, transfer, de-identification, blocking, deletion and destruction.

3. What data we process

The Operator may process the following categories of data:

3.1. registration data: name, email, phone number, login, password in encrypted form, user identifier;

3.2. account and service-use data: information about actions in the application, settings, subscription status, reminder parameters and use of features;

3.3. health and medication data voluntarily entered by the user: medication names, intake schedules, dosages, notes, symptoms, completion marks and other sensitive data that the user chooses to store in the application;

3.4. technical data: IP address, device type, OS version, application version, interface language, diagnostic data, crash information, technical logs, installation identifiers;

3.5. support data: correspondence, requests, attachments, problem descriptions and other data sent by the user to support.

4. Purposes of processing

Personal data is processed for the following purposes:

4.1. creating and maintaining an account;

4.2. providing application features, including medication schedules, storing notes and organizing reminders;

4.3. synchronizing data between the user’s devices;

4.4. ensuring the security of the account, application and infrastructure;

4.5. providing support and handling requests;

4.6. complying with applicable law;

4.7. sending service notifications;

4.8. improving the stability and quality of the application;

4.9. sending push notifications if the user has given a separate permission.

5. Legal bases for processing

5.1. The Operator processes personal data on the basis of:

  • the user’s consent;
  • the necessity of performing a contract with the user;
  • the necessity of fulfilling duties established by law;
  • the Operator’s legitimate interest in ensuring security, support and stable operation of the service, if this does not infringe the user’s rights.

5.2. Health data and other sensitive data are processed on the basis of a separate user consent, unless otherwise expressly provided by applicable law.

6. Operations with data

The Operator may collect, record, systematize, accumulate, store, update, change, extract, use, transfer, provide, grant access to, de-identify, block, delete and destroy data.

7. Transfer of data to third parties

7.1. The Operator may transfer personal data to third parties only to the extent necessary for the operation of the service, including:

  • hosting and infrastructure providers;
  • technical support providers;
  • notification delivery services;
  • contractors for maintenance and protection of the application;
  • public authorities in cases expressly provided by law.

7.2. The Operator does not sell users’ personal data.

7.3. Persons to whom data is transferred must maintain confidentiality and apply appropriate protection measures.

8. Servers and place of processing

8.1. The main server infrastructure of Pills Tracker is located in the Russian Federation.

8.2. For users to whom the laws of the Russian Federation apply, personal data is processed using databases located in the Russian Federation.

8.3. For users from the Republic of Belarus, the Republic of Kazakhstan, the Republic of Armenia and Georgia, use of the application means that their personal data may be transferred to and processed on servers located in the Russian Federation, to the extent necessary for the service to function, where legal bases provided by applicable law exist.

8.4. The user is notified of the location of the servers before providing consent to data processing.

9. Retention periods

9.1. Data is stored no longer than required for the purposes of processing.

9.2. After account deletion, personal data is deleted, de-identified or destroyed, except for data that must be retained by law, for information security, prevention of abuse, dispute resolution or compliance with mandatory requirements.

9.3. Technical logs and security journals may be stored for a limited period after account deletion.

10. Data protection

The Operator applies necessary legal, organizational and technical measures to protect data, including:

  • access control;
  • use of protected communication channels;
  • storage of data in a protected server infrastructure;
  • logging of security events;
  • restriction of contractor and employee access;
  • measures to prevent leaks, loss and unauthorized access.

11. User rights

The user has the right to:

11.1. obtain information about the processing of their data;

11.2. request clarification, correction and updating of data;

11.3. withdraw consent if processing is based on consent;

11.4. request cessation of processing, deletion, blocking or destruction of data in cases provided by law;

11.5. delete the account;

11.6. contact the Operator regarding data processing at info@neoproxima.pro.

12. Withdrawal of consent and account deletion

12.1. The user may at any time withdraw consent to personal data processing if processing is based on consent.

12.2. Withdrawal of consent may be submitted:

12.3. Upon withdrawal of consent, the Operator ceases processing unless other legal bases for continued processing exist.

12.4. Upon account deletion, the Operator deletes or de-identifies the user’s data, except for data that must be retained by law or to protect the Operator’s legitimate interests.

13. Children

The application is not intended for independent use by children without a legal representative, unless otherwise expressly stated in the application interface.

14. Medical disclaimer

Pills Tracker is not a medical device, does not perform diagnosis and does not replace a doctor’s consultation. The user independently verifies the correctness of prescriptions, dosages and medication regimens. See also: Medical disclaimer.

15. Changes to the Policy

The Operator may change this Policy. The current version is published at: https://pillstracker.pro/privacy/.

16. Contacts

Neoproxima LLC
Address: Georgia, Tbilisi, Davit Gamrekeli St. 19, office 614
Phone: +995 599 897 615
Email: info@neoproxima.pro

Annexes to Document 1. Country annexes to the Policy

Annex No. 1. Russian Federation

This annex applies to users to whom the personal data laws of the Russian Federation apply.

Processing of personal data of users from the Russian Federation is carried out using databases located in the Russian Federation.

Upon withdrawal of consent to personal data processing, the Operator ceases processing of such data and ensures their deletion or destruction within the period established by applicable law, unless otherwise provided by law or another lawful basis for processing.

Health data is processed as special categories of personal data and requires the user’s separate consent, unless otherwise permitted by law.

In case of a conflict between the general text of the Policy and this annex, this annex prevails.

Annex No. 2. Republic of Belarus

This annex applies to users to whom the personal data protection laws of the Republic of Belarus apply.

The user is notified that their personal data may be transferred to and processed on servers located in the Russian Federation, to the extent necessary for the application to work, where grounds provided by law exist.

Data relating to special personal data, including health information, is processed under an enhanced protection regime and on the basis of a separate user consent, unless otherwise provided by the laws of the Republic of Belarus.

The user may contact the Operator to request modification, cessation of processing or deletion of data in cases provided by law.

Annex No. 3. Republic of Kazakhstan

This annex applies to users to whom the personal data protection laws of the Republic of Kazakhstan apply.

The user is notified that their personal data may be transferred to and processed on servers located in the Russian Federation if such transfer is necessary for the application to work and complies with applicable requirements of the laws of the Republic of Kazakhstan.

Information about health, medications, dosages, symptoms and other sensitive data is processed only after the user provides a separate consent, unless otherwise expressly provided by law.

The user may withdraw consent and request clarification or cessation of processing in the cases and manner provided by law.

Annex No. 4. Republic of Armenia

This annex applies to users to whom the personal data protection laws of the Republic of Armenia apply.

The user is notified that their personal data may be transferred to and processed on servers located in the Russian Federation where lawful bases exist and where protection measures sufficient for the security of such data are observed.

Sensitive data, including health information, is processed on the basis of a separate user consent, unless otherwise expressly follows from the law.

With respect to sensitive data and cross-border transfer, this annex supplements the general Policy and applies preferentially in case of a discrepancy.

Annex No. 5. Georgia

This annex applies to users to whom the personal data protection laws of Georgia apply.

The user is notified that their personal data may be transferred to and processed on servers located in the Russian Federation, to the extent necessary to provide the service, where lawful bases exist and applicable data protection requirements are observed.

The user has the right to obtain information about processing, access data, request correction, deletion, cessation of processing and withdrawal of consent in cases established by Georgian law.

Health data is processed with enhanced protection measures and on the basis of a separate user consent, unless otherwise provided by law.