Privacy Notice

This English version is a translation provided for reference only. In case of any discrepancy, the Spanish version prevails.

This Privacy Notice governs how Conexión Fácil will process the personal data you provide to us through our App, or as a result of your use of it. We understand the importance of your data, so we ask you to read this Privacy Notice carefully. If you do not agree with part or all of this document, please do not use the Application and avoid providing any personal data. Using the Application and providing personal data means that you have read and agree with the way your personal data will be processed in accordance with this Privacy Notice.

I. Party responsible for processing your information

Conexión Fácil, Sociedad de Responsabilidad Limitada de Capital Variable (hereinafter Conexión Fácil), is responsible for processing and safeguarding the personal data collected when registering to use our application “EasyMed” (hereinafter the App) and/or from those who use the services provided through the App. For any matter related to the processing of your personal data, you may go to the address at Insurgentes Sur número 1431, Piso 10, Interior A, colonia Insurgentes Mixcoac, Alcaldía Benito Juárez, C.P. 03920, Mexico City.

II. Information we collect and how we process it

At Conexión Fácil, we collect your personal information in order to provide you with our services and the use of our App, as described below. You provide this information yourself when you use our “EasyMed” Application, which happens when you register.

II.I. Data we collect

a. General information: Full name, date of birth, gender, type of identification (for doctors, the only option is their professional license, “cédula profesional”), CURP (Mexican population registry code), and institution of origin.

b. Contact details: email, mobile phone, home phone, optional second phone, full address.

c. Profile: photograph, email, type of caregiver.

II.II. Data we collect through third parties

When the administrator (“Administrator” means the doctor, nurse or any kind of caregiver) invites the Patient to access the App. The administrator will export from their database, or carry out a first patient registration with, the following data:
- a. First name(s), paternal surname, maternal surname.
- b. Email.
The patient user will receive the welcome email with their username and password.
- a. The user must download the “EasyMed” App and may log in after reading and accepting this privacy notice and the EasyMed terms and conditions.
At the first login, the following data will be requested:
1. Phone;
2. Date of birth;
3. Weight;
4. Height;
5. Medical conditions; and
6. City and State.

With this registration, the user can use the basic tools of the App.

When the administrator needs the patient’s complete information, they will send a notification with a link to the EasyMed website so the patient can complete their registration. The form requests the following data:

User/Patient Profile
- a. General information: Full name, gender, marital status, date of birth, blood type, height, type of identification, expiration date, identification number, CURP, Institution, search group (conditions they suffer from).
- b. Contact details: contact method, full address, email, mobile phone, home phone, work phone, emergency contact name, emergency contact phone number, medical expenses insurance, policy number.
- c. Profile: photograph. If the patient has medical coverage such as IMSS or ISSSTE, the following data will be requested: medical unit number, office number, place of birth.
When the family member needs to access their patient’s information and/or record care activities, they must complete the following personal data:

User/Caregiver Profile
- a. General information: Full name, date of birth, gender, type of identification (INE voter ID, driver’s license, passport), institution of origin.
- b. Contact details: email, mobile phone, home phone, second or additional phone, full address.
- c. Profile: photograph, email, type of caregiver.

II.II. Personal data of third parties. For any personal data of third parties that you provide to us, you must first obtain the consent of the owner of that data and inform them that they can obtain the corresponding privacy notice by requesting it by email at privacidad@conexionfacil.com, or in the App when registering. In any case, Conexión Fácil will comply with the provisions of the Mexican Federal Law on the Protection of Personal Data Held by Private Parties and its Regulations regarding the processing of personal data obtained indirectly.

III. Processing of Personal Data

Collecting and processing your Personal Information allows us to provide you with an excellent service so that you can use the services offered through the App, and to offer you features better suited to your needs, except where applicable regulations prohibit it. Accordingly, Conexión Fácil may use your Personal Information for the following purposes:

To identify and contact you.
To register you in our systems.
To verify your identity in compliance with legal requirements.
To provide you with the services and/or benefits you request or contract with us.
To help you get in direct contact with the “Administrator” for the purposes of the services we provide through the App.
To prepare and keep a record of the operations you carry out with us, and to inform you about them and follow up on them.
To make our App available to you.
To manage the services offered through the App, including the payment processing service and the digital account.
To respond to your comments, complaints and suggestions, and to provide you with support.
To contribute to the security of relationships, communications and transactions among the users of our platform.
To improve our services, develop new ones and offer you a better experience with the EasyMed App.
To carry out internal studies about your interests and behavior, in order to offer you better services and products, and to carry out statistical studies.
To offer you services and features better suited to your needs and to personalize our services to make your experience as comfortable as possible.
To improve our commercial and promotional initiatives in order to improve our offer of content and items, and to personalize that content, its presentation and services.
To provide you with information through different channels (email, short text messages (SMS), phone calls or any other means) about improvements or new features or services of the App.
To comply with legal obligations and requirements from competent authorities.
To comply with information requests from competent administrative or judicial authorities.
To carry out advertising and promotional announcements and contacts.
To carry out all kinds of marketing, advertising, commercial prospecting and/or market research activities.

If we use your data for any other purpose that is not compatible with those listed, we will inform you before processing it.

Conexión Fácil will keep your Personal Information for as long as necessary to fulfill the purposes for which it was collected.

IV. Transfer of your Personal Data

Safeguarding your privacy is very important. That is why we do not sell or trade information that identifies our users. Nor do we share or otherwise transfer your Personal Information to third parties, except as necessary to carry out the EasyMed data management process. For the export of patient data, the information we may share is the following:

a) Age.
b) Sex.
c) Geographic location: state, postal code, neighborhood, etc.
d) Medical conditions.
e) Medications/Treatments.
f) Care plan.
g) Vital signs.
h) Physical activity.
i) Diet plan.
j) Surveys.
k) Notes.
l) Wound care.

Conexión Fácil may assign, transmit and/or transfer your Personal Information to:

(i) “Administrator”: the doctor, nursing staff or any kind of caregiver, in order to provide the services offered in the App.

(v) “Public authorities”: administrative and judicial authorities that, in the exercise of their powers, request information, even if there is no order or executive or judicial summons to that effect, for the purposes of: (a) collaborating in the investigation and reporting of any unlawful act; (b) safeguarding a public interest, the pursuit or administration of justice, the recognition, exercise or defense of a right in a judicial or administrative proceeding, and/or the resolution of disputes; and (c) complying with any applicable law, regulation or legal provision, or with a duly founded and reasoned order from a competent authority.

Before being processed, the information or personal data will be duly dissociated, so that its owner cannot be identified in any way. Likewise, it will be used to give the User a better experience based on their interests and preferences (without the user being identified to third parties as a result), as well as for commercial prospecting purposes.

If Conexión Fácil decides to share your Personal Information with third parties other than those mentioned, we will request your prior and express consent, unless there is a legal authorization or obligation that allows it to be done without such consent.

You also give your express and informed consent for Conexión Fácil to assign, transmit or transfer your Personal Information to the recipients detailed in this Privacy Statement.

Finally, Conexión Fácil will not be responsible for the misuse of your Personal Information by any third party when those third parties directly collect and/or process your Personal Information.

V. How long will we store Personal Information?

We will only store personal information for as long as necessary to fulfill the purpose for which it was collected, to comply with regulatory or legal requirements, or during the statute of limitations for possible legal or contractual liabilities.

Once that period ends, the data will be deleted or anonymized so that no person can be identified, as permitted by the applicable regulations on the Protection of Personal Data Held by Private Parties.

VI. Automated decisions and profiling

Profiling is the evaluation of certain personal aspects, such as your interests, preferences, behavior or location, carried out by processing personal information automatically with statistical procedures. As a result of this processing, we may send you personalized communications, or show them to you within our App, that we believe may be of interest to you.

You have the right to request a review of a decision based on automated data processing.

VII. Confidentiality of Personal Information and User Responsibility

We will do everything within our power to protect the privacy of your Personal Information. Users are responsible for all acts carried out using their username and password.

Applicable regulations grant you certain rights over your Personal Information, such as: (i) access; (ii) updating; (iii) rectification; (iv) stopping the sending of advertising, offers and promotions; (v) deletion; (vi) revocation of consent; and (vii) confidentiality.

For any access, rectification, cancellation, objection or revocation regarding the handling of personal data obtained through the App, Conexión Fácil makes available the email address privacidad@conexionfacil.com and the phone number 558852-2777. Daniel Rosas Vilchis will be responsible for safeguarding and managing this information, in accordance with Chapter IV of the Mexican Federal Law on the Protection of Personal Data Held by Private Parties, article 21 of its Regulations, and the provisions of the Privacy Notice Guidelines issued by the Ministry of Economy (Secretaría de Economía).

To do so, the user must send a written request to that email address stating, clearly and promptly, which data they wish to access, and to what extent, or which data they wish to rectify, cancel, object to, or for which they wish to revoke their consent to processing, attaching the supporting documentation for their request.

Once the duly completed request is received at the email address indicated, Conexión Fácil will have twenty days (which may be extended for an equal period, depending on the circumstances of the case) to resolve the corresponding request.

If the user’s request is granted, Conexión Fácil must comply with it within fifteen days of the corresponding resolution.

IX. Changes to the Privacy Notice

If we make changes to our Privacy Notice, we will send an email to the owners of the personal data collected to inform them of those changes, including the link to consult them.

X. Applicable Law and Jurisdiction

This Privacy Statement will be governed by the Mexican Federal Law on the Protection of Personal Data Held by Private Parties, its Regulations and other legal provisions issued by the competent authorities. Any dispute or disagreement related to the interpretation, validity, execution or performance of this Privacy Statement will be resolved by the competent courts indicated in those legal provisions.

I agree with the privacy and data protection terms and conditions set forth in this Privacy Notice, including the purpose, processing and transfer of such data, and I hereby give my express, informed and unequivocal consent for these purposes. By completing the corresponding registration, I confirm that I have read and agree with this privacy notice.