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Privacy notice

Effective date: February 1, 2021

This Privacy Notice applies to all websites, mobile applications and software (hereinafter the “Platform” or “Other Services”) owned and operated by Prosperia Health S. A de C. V. (hereinafter referred to as “PROSPERiA”), mexican society, with registered office in Avenida Álvaro Obregón, 213, 1st Floor, office 4, Col. Roma Norte, Cuauhtémoc, C. P. 06700, Mexico City). Our Privacy Notice is designed to help the user better understand how we collect, use, store, process and transfer your information when you use our services.

Carefully review this Privacy Notice and our Terms and Conditions. Unless otherwise defined, the terms used in this Privacy policy have the same meanings as those terms are defined in our Terms and Conditions. By using our services, you acknowledge all of the policies and procedures outlined in the previous documents. If you do not agree or are not comfortable with any aspect of this Privacy Notice or our Terms and Conditions, you must immediately discontinue use of the Platform and our services.

Content

 

  1. Important definitions

  2. Information collected by PROSPERiA

    • Information you give us is provided directly or through a third party

    • Information collected via tracking technologies

    • Other types of information

  3. How we use collected information

    • To provide you with services and to analyze and improve our services

    • To process, analyze, and deliver the results of a service requested

    • To allow you to recommend our services, or to share the results of the Holder with other people

    • To use your information self-reported, inferences, and derived data, so anonymised, for research purposes

    • To provide customer care

    • To conduct surveys, questionnaires and get feedback

    • For marketing communications

  4. With whom we share the information collected

    • Providers of general services

    • With business partners

    • At the request of legal instances

    • Business transactions

  5. Your choices

    • Marketing communications

    • Share results out of the services of PROSPERiA

  6. Security – How we protect the information

  7. ARCH rights – How you may access, rectify or cancel your personal data or to object to their use

  8. Revocation of your consent – How can revoke your consent to the use of your personal data

  9. Limitation of rights – How to limit the use or disclosure of your personal information

  10. Privacy of minors

  11. Linked web sites

  12. Statement of “do not track”

  13. Changes to the Privacy Notice

  14. Contact information

  15. Complaints or reports, and a competent authority

  16. Authorization and consent

 

1. IMPORTANT DEFINITIONS

(a) aggregate Information: information that has been anonymized and combined with that of other users and analyzed or evaluated as a whole, so that no specific individual can be identified.
Information is anonymized: information that has been stripped of registration information (e.g. your name and contact information) and other personal data so that it cannot be identified reasonably at the individual and put you at risk of potential.
(b) Information at the individual level: information on the sociodemographic characteristics of an individual, life-style, data or images nutritional and clinical, but that is not necessarily linked to the information of record or potential for individual identification.
c) personal Information: data that can be used to identify an individual, either alone or in combination with other information.
(d) log Information: information provided when you register as a user or customer of web services, mobile applications, or software.
e) sensitive Information: personal data affecting to the most intimate sphere of the Holder, or whose improper use can lead to discrimination or involves a serious risk to it. It is considered sensitive data which may reveal aspects such as racial or ethnic origin, state of present and future health, genetic information, religious beliefs, philosophical and moral, union membership, political opinions, sexual preference.
(f) Information reported: information you provide to us directly or through a third party; whether responding to questionnaires, forms, use our mobile apps, web platforms, or software related to our services, including personal and sensitive information.
g) Inferences and derived data: information, data, assumptions, or conclusions that are derived or calculated, directly or indirectly, of the information is self-reported and from other sources, such as medical images.
(h) Information behavior web: information about how you use our services is collected through history, cookies, web beacons, or web beacons, and similar technologies (for example, device information, IP address, browser type, domains, page views).

2. INFORMATION COLLECTED BY PROSPERiA
(a) Information you provide to us directly or through a third party

 

  • Information self-reported. To be able to provide the services of PROSPERiA related to the estimation of risk of development of diseases and the generation of suggestions focused on health, we treat the sensitive and personal information provided via survey, forms, applications, web platforms, and software. This information can include information about your personal traits (for example, weight and height), ethnic origin, diseases (e.g., type 2 diabetes and hypertension), other health-related information (for example, cholesterol levels, systolic and diastolic blood pressure) and information of family history. Before disclosing information about a member of the family, you must make sure that you have the permission of the member of the family to do so

 

  • Reference information. When you refer a person to any of the services of PROSPERiA, choose to receive your results or share them with another person, or if you need more information from one of our partners, we will ask you for an email address. We will use the email address you provided it only, as appropriate, to make the reference or to communicate your request for shared use, and we will tell you your contact who requested the communication. To participate in a referral program or to choose to share information with another person, you confirm that you are the owner of the e-mail address you have given your consent for PROSPERiA to communicate (for example, by email) with him or her. The owner of the e-mail address you can contact us info@prosperia.health to request that we remove this information from our database.

 

  • Customer service. When you contact PROSPERiA through info@prosperia.health, we collect information to: track and respond to your inquiry; to investigate any breach of our Terms and Conditions, Privacy Notice and applicable laws or regulations; and to analyze and improve our services.

 

(b) Information collected via tracking technologies (such as cookies, and similar technologies)

We and our business partners use cookies and similar technologies (such as beacons, tags, scripts, and device identifiers) to:

  • personalize and improve the user experience;

  • provide security;

  • analyze the use of our services (such as to analyse their interactions with the results, reports, and other features of the service);

  • to gather demographic information about our user base;

  • provide you with our services;

  • monitor the success of marketing campaigns; and

  • publish targeted advertising on our site and other sites on the Internet.

If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
We may receive reports based on the use of these technologies from external service providers as information is anonymized at the individual level or as aggregated information (as described in Section 4).

c) Other types of information
We are continuously working to improve our services with new products, applications and features, which may result in the collection of new and different types of information. We will update our Privacy Notice and/or seek your consent prior to further processing, as needed.

3. HOW WE USE COLLECTED INFORMATION
PROSPERiA will use and share your personal information with business partners or third parties only under the following conditions:

(a) To provide you with services and to analyze and improve our services. We use the information described above in Section 2 in order to operate, provide, analyze and improve our services. These activities may include, among other things, the use of your information consistent with this Privacy Notice:

  • to communicate with you and run your requests (for example, risk analysis, send results via email or text message, in response to requests for information);

  • send messages, and perform follow-up calls to their results focused on promoting prevention and early attention to health problems (for example, sending out personalized recommendations for medical services and/or products of health, called to promote to schedule an appointment with a medical specialist);

  • to enable and enhance your use of our website and mobile applications, including to provide content and customized information and to track the use of our services;

  • enforce our Terms and Conditions and other agreements;

  • monitor, detect, investigate and prevent behavior that is prohibited or illegal in our services, in order to combat spam and other security risks; and

  • perform research and development activities, which may include, for example, to perform analysis of data to develop new or enhance existing products and services, and perform quality control activities.


(b) To process, analyze, and deliver the results of a service requested
As described above, if you request to receive results of our analysis of images, or calculators of risk, you must provide an email address or mobile phone number. In addition, our services may require location information to customize the recommendations of suppliers, with and without profit, of health products and services. If you do not want to share this type of information, you can disable this feature in the device in which you use our services, however, some functions may be affected.

c) to allow you To recommend our services, or to share the results of the Holder with other people
PROSPERiA gives you the ability to share information directly with people who do not have participated in our service, when you provide directly an e-mail or mobile phone number to send the information. You should consider their options to share. Once you have chosen to share any personal information, the people with whom you share this information also may use or share your personal information, including any confidential information that you choose to send them.

d) To use your information self-reported, inferences, and derived data, so anonymised, for research purposes
PROSPERiA can be sponsored, funded, or work in collaboration with third parties, such as non-profit foundations, academic institutions, government bodies, business partners related to health care or pharmaceutical companies. PROSPERiA can study in a group or population specific; to identify areas or potential targets for health campaigns targeted; to conduct or support the development of strategies for health diagnostic, preventative or early, or devices to diagnose, predict or treat medical conditions, or other health conditions; working with the public, private entities and/or not-for-profit initiatives in health research. PROSPERiA used aggregate information self-reported, as explained in more detail below.
At the time you decide to use the services or software PROSPERiA, you agree that your information is self-reported to be used in accordance with the following principles:

  • Your information reported will be used for research purposes, but it will be anonymized, and will not be linked to contact information or personal data that enable individual identification.

  • PROSPERiA you can share summary statistics, which do not identify any particular individual or to contain information on an individual level, with research partners qualified.

You can withdraw your consent to participate in the investigation of PROSPERiA at any time by writing to info@prosperia.health. Any research involving your data that has already been performed or published prior to his retirement from the research of PROSPERiA will not be reverted or deleted.

e) To provide Customer service
When you communicate with PROSPERiA through info@prosperia.healthwe may use or solicit personal information, including confidential information, as necessary, to answer their questions, resolve disputes, and/or investigate and resolve problems or complaints. In some cases, we may request the processing of the personal information of a customer to resolve the dispute or request from another client. For example, if a customer reports a behavior that violates our Terms and Conditions, we will process separately the personal information of both clients and respond separately to each individual as appropriate. We will not share this personal information to another customer without your consent.

f) To conduct surveys, questionnaires and get feedback
We value your comments and we may send you surveys, questionnaires or requests for testimonials to improve and optimize our services. If you do not wish to receive these requests, you can unsubscribe from email communications with the button at the end of the email, or by contacting info@prosperia.health.

(g) For marketing communications
When you provide your personal and contact information to receive the results of any of the services or platforms of PROSPERiA, you agree that we may send to you by means of contact provided, notifications about offers, products, services or promotions of PROSPERiA, our partners and/or our business partners. You can unsubscribe from receiving these marketing communications at any time. To cancel your subscription, click the link in the footer of the page for that order or send a direct request to info@prosperia.health. You may not opt out of receiving messages are not promotional with regard to the operation of the platforms, such as technical notices, purchase confirmations, or emails related to the service you have requested.

4. WITH WHOM DO WE SHARE THE INFORMATION COLLECTED
(a) providers of general services
We share the information described in Section 2 with our third party service providers to which we provide the services necessary for the proper performance of our services. Service providers are third parties (other companies or individuals) who help us provide, analyze and improve our services. While PROSPERiA carried out directly by the majority of data processing activities required to provide our services to you, we hired some third-party service providers to help us to support our services, including the following areas:

  • Storage in the cloud, services of information technology (IT) and security. Our storage providers in the cloud, provide secure storage for the information in the databases of PROSPERiA, ensure that our infrastructure can support the continued use of our services by customers and users of PROSPERiA, and protect data in the event of a natural disaster or other disruption of our service. Our suppliers of IT services and security to help with intrusion detection and prevention measures to stop any possible cyber attack.


(b) business partners
With the aim of complying with contracts of collaboration or the provision of services, we share information collected through our software and platforms with third parties. The type of information shared, includes:

  • Aggregate information. We may share aggregated information anonymized, with third parties. This information is different from the information of “individual-level” because it does not identify or reveal the data of any particular person. For example, aggregate information may include a statement that “20% of our users have a high risk of developing diabetic retinopathy”, without providing any data or test results specific to any individual user.

  • Contact details and inferences. Our products and services, can be implemented in points physical or digital channels of commercial partners as part of service contracts. These cases can be identified by customizing the colors and logo of the business partner, and a seal with the legend “Powered by PROSPERiA”. The information provided through these services will be subject to the Privacy Notice of PROSPERiA and the Privacy Notice of the business partner.


c) To request legal
In certain circumstances, your personal information may be subject to processing in accordance with the laws, regulations, subpoenas, governmental order or other citations. For example, it is possible to be asked to disclose personal information in coordination with the regulatory authorities in response to legal requests from public authorities, including to meet the requirements of national security or law enforcement. PROSPERiA will preserve and disclose all information to the authorities in charge of law enforcement, or other aśi request backed by a court order, or if you have a good faith belief that such preservation or disclosure is reasonably necessary to:

  • to comply with legal process or regulatory requirements, or obligations that PROSPERiA may have in accordance with the rules, laws and regulations, ethical and professional;

  • enforce Terms and Conditions of PROSPERiA;

  • respond to claims that any content violates the rights of third parties;

  • or protect the rights, property or personal safety of PROSPERiA, its employees, its users, partners, customers, and the general public.


d) business Transactions
In the case of PROSPERiA go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, it is likely that your personal information may be among the assets transferred. In such a case, your information would remain subject to the policies of the Notice of pre-existing Privacy.

Derived from the services of our suppliers and/or contracts with business partners, your information may be stored and processed in Mexico or in any other country in which PROSPERiA or its subsidiaries, affiliates, business partners, or service providers maintain facilities and, therefore, your information may be subject to the laws of those other jurisdictions which may be different from the laws of your country of residence.

5. YOUR CHOICES
a) marketing Communications
As noted in Section 3.g. it is possible that you may receive emails or notifications of products and promotions after you have used any of the services offered, directly or indirectly, by PROSPERiA. You can view or update your notification preferences through the button in the lower part of promotional communications by e-mail or by contacting info@prosperia.health.

(b) to Share results out of the services of PROSPERiA
You can decide to share your personal information with friends and/or family members, physicians or other health professionals and/or other people outside of our services. These third parties may use your personal information differently than we do in this Privacy Notice. Make these choices carefully and review the Privacy Notices of the third parties involved. In general, it can be difficult to contain or retrieve personal information once it has been shared or disclosed. PROSPERiA not have any liability for any consequences that may result due to an individual's decision to disclose or share personally identifiable information with others.

6. SECURITY – HOW WE PROTECT THE INFORMATION
PROSPERiA takes seriously the trust you place in us. PROSPERiA implemented appropriate physical, technical and administrative safeguards to prevent unauthorized access or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of the information and safeguard your personal information. Our team reviewed and upgraded regularly our security practices to help ensure the integrity of our systems and your information. These practices include, among others, the following areas:

  • Encryption. PROSPERiA figure, or encrypts the confidential information for transmission to the remote servers.

  • Storage of data on servers that follow high safety standards. PROSPERiA stores the data collected during the use of our software, web site and mobile applications, servers, AWS comply with the privacy standards (HIPAA“the Health Insurance Portability and Accountability Act).

  • Limited access to essential personnel. We limit access to information to authorised personnel in job functions, with strict access controls.


7. ARCH RIGHTS – HOW YOU MAY ACCESS, RECTIFY OR CANCEL YOUR PERSONAL DATA OR TO OBJECT TO THEIR USE
You have the right to know what personal data we hold about you, what we use, and the conditions of use we give them (Access). Also, it is your right to request the correction of your personal information in case of it is outdated, inaccurate or incomplete (Rectification); that we delete from our records or databases when you consider that the same is not being used in accordance with the principles, duties and obligations provided in the regulations (Cancellation); as well as oppose the use of their personal data for specific purposes (Opposition). These rights are known as ARCO rights.

The procedure of ARCO rights, is required in writing by the Holder of the rights by sending an e-mail to the address info@prosperia.health.

8. REVOCATION OF YOUR CONSENT – HOW CAN REVOKE YOUR CONSENT TO THE USE OF YOUR PERSONAL DATA
You can revoke the consent that, in your case, we have granted for the processing of your personal data. However, it is important to note that not in all cases, we will be able to meet your application or terminate use of it immediately, because it is possible that by any legal obligation required to continue treating your personal data. Likewise, you must consider that for certain purposes, the revocation of your consent will imply that we cannot continue to provide the service requested, or the conclusion of your relationship with us.

To know the procedure and requirements for the revocation of consent please send us an e-mail to the address info@prosperia.health.

9. LIMITATION OF RIGHTS – HOW TO LIMIT THE USE OR DISCLOSURE OF YOUR PERSONAL INFORMATION
So that you can limit the use and disclosure of your personal information, you must submit your request in writing to free the addresses mentioned above.

10. PRIVACY OF MINORS
PROSPERiA is committed to protecting the privacy of children and adults. Or PROSPERiA nor any of its services are designed for, intended to attract, or directed to children under the age of 18 years. However, a parent or guardian may authorize the taking of images or clinical samples, create an account and provide information related to, your child under the age of 18 years. The parent or guardian assumes full responsibility for ensuring that the information you provide to PROSPERiA about your child is kept safe and secure and that the information presented is accurate.

11. LINKED WEB SITES
PROSPERiA can include in their apps, platforms, reports, marketing communications, social networking, or web page, links to services, allies and/or trading partners, and third-party websites operated by organizations not affiliated with PROSPERiA, that may be of interest to our users, customers and partners. PROSPERiA does not review or endorse, and is not responsible for the privacy practices of these organizations. We recommend that you read the Privacy Agreements of each and every one of the websites that you visit. This Privacy statement applies solely to information collected by PROSPERiA and our service providers on our behalf.

12. STATEMENT OF “DO NOT TRACK”
Some browsers have a “do not track” feature that allows you to tell websites that you do not want your activity to be tracked online. At this time, due to the lack of industry standards, we do not respond to the signs of “do not track” browser. The options you select are browser-specific and device.

13. CHANGES TO THE PRIVACY NOTICE
PROSPERiA modify this Privacy Notice from time to time. We recommend re-visit this page periodically to stay aware of any changes to this Privacy Notice. If we change this Privacy Notice, we will do so to the public through our web site. Whenever we make any substantial changes, we will post a notice on our website prior to the change becoming effective.

By continuing to access or use the services after any changes to this Privacy Notice will become effective, you agree to be subject to the Privacy Notice revised and updated. If any change is unacceptable to you, you can stop using our services and to request the deletion of their account at any time.

14. CONTACT INFORMATION
If you have any questions about this Privacy Notice or wish to make a complaint, request or query, please send an e-mail to PROSPERiA to info@prosperia.health.

15. COMPLAINTS OR REPORTS, AND A COMPETENT AUTHORITY
If you believe that your right to the protection of their personal data has been injured by the conduct or omission on our part, or presumed to be a violation of the provisions of the Federal Law of Protection of Personal Data in Possession of Individuals, its Regulations and other applicable regulations, you can lodge your complaint or grievance with the National Institute of Access to Information and Data Protection (INAI). For more information, please visit her official page of the Internet www.inai.org.mx.

16. AUTHORIZATION AND CONSENT
Mexico city, February 1, 2021. With the acceptance in this section, I give my express consent for my personal data to be treated according to what is stated in this privacy notice. With the acceptance in this section, I give my express consent for my data to be shared within and outside of the country with the people, companies, organizations and authorities stated in this Privacy Notice.