SECTION ONE: The Privacy Policy.

This Privacy Policy (hereinafter referred to as the “Privacy Policy”) governs the use of the mobile application known as Medicenter (hereinafter referred to as the “Application”), which is operated by Medicenter Company LLC, located at 8 The Green, Suite 16614, Dover, DE 19901, USA, contact e-mail data@medicenter.com (hereinafter referred to as “MEDICENTER” and, collectively with the users, as the “Parties”) whose main function is to provide an application that enables its users to securely digitize, store, and share their health records with Third Parties (hereinafter referred to as the “Service”).

1.1. Registration with the Application confers the status of user of MEDICENTER (hereinafter referred to as “Users” or the “User”).

1.2.  By completing the registration form and creating an account, the User acknowledges and agrees to fully and unconditionally accept all terms and conditions set forth in the Privacy Policy as published by MEDICENTER.

Accordingly, the Privacy Policy constitutes a valid and binding agreement between the User and MEDICENTER with respect to privacy. Furthermore, the use of the Service implies the full and unreserved acceptance of the User Terms and Conditions (hereinafter referred to as the “User Terms and Conditions”) and the Application Cookie Policy, which are published by MEDICENTER in the Application and which are supplemented by the Privacy Policy.

ANY PERSON WHO DOES NOT ACCEPT THESE DOCUMENTS, WHICH ARE MANDATORY AND BINDING, SHALL REFRAIN FROM USING THE APPLICATION.

1.3. MEDICENTER may amend the Privacy Policy at any time. Changes to the Privacy Policy will be communicated in a timely manner through the contact channels enabled by the User and, if applicable, indicated by the User.

The User agrees that they will be notified of any changes to the Privacy Policy as soon as MEDICENTER has published them on the Application. Furthermore, the User understands and accepts that the continued use by the User of the Service after such new version has been published shall be deemed to constitute acceptance of such changes to the Privacy Policy. Consequently, the User agrees to check the Privacy Policy from time to time.

1.4. MEDICENTER considers the protection of Personal and Sensitive Data to be of vital importance. If you have any questions regarding the Privacy Policy, please contact us at data@medicenter.com.

SECTION TWO: Who is responsible for processing Personal Data and Sensitive Data provided by Users?

2.1. All Personal Data and Sensitive Data provided or collected through the Application will be processed by MEDICENTER, whose contact details are listed below, as Database Controller.

Database Controller:

Identity: Medicenter Company LLC

Postal address: 8 The Green 16614, Dover, DE 19901, United States

Contact e-mail: data@medicenter.com

SECTION THREE: What information does MEDICENTER collect and how is it collected?

3.1. MEDICENTER collects two types of information under applicable data protection laws: I) Personal Data (hereinafter referred to as the “Personal Data”) and II) Sensitive Data (hereinafter referred to as “Sensitive Data”). “Data” shall be referred to as “Data” when both categories are referred to interchangeably.

3.1.2. In general, the User’s Personal Data will include: (I) e-mail account; (II) first name, last name, (III) date of birth, (IV) and user name.

3.1.3. Generally, the Sensitive Data of the User includes: (i) racial and ethnic origin, (ii) place of birth, (iii) place of residence, (iv) type and number of health insurance coverage, (v) blood group and blood factors, (vi) information on toxic habits, (vii) gender condition and/or data related to sexual life, (viii) current and/or past diseases, (ix) current and/or past medications and/or treatments, (x) health history and/or any other health data of family members, and/or the definitions established by the applicable legislation of each country, which shall prevail.

In order to make the experience of using the Application full and pleasant, MEDICENTER suggests that the User complete the Profile with their Sensitive Data; however, this is not mandatory and is optional. If the User does not complete their profile with the Sensitive Data, some MEDICENTER services may not be available or may be disabled, in accordance with Law No. 25.326 on Protection of Personal Data.

3.2.  MEDICENTER may use various methods to verify and validate the User’s identity during registration, which may include third-party services that request biometric data. However, MEDICENTER does not guarantee that the User will be willing to complete the account creation process. MEDICENTER will only verify and validate that the biometric data scanned at the time of account creation matches the scanned identification or passport.

3.3   If MEDICENTER identifies any irregularities during the account creation process, including but not limited to identity theft, unauthorized account creation, falsified documentation, or unlawful intent, it will promptly close the account and report the issue to the appropriate authorities.

3.4. Other information that MEDICENTER may collect:

(I)   Registration and Usage Information: When Users use the Services, MEDICENTER will collect the Personal Data required to provide those Services effectively.

(II)   Additional information that Users want to digitize: Information that Users want to upload to their MEDICENTER account, such as, but not limited to, X-rays, ultrasound scans, CT scans, MRI scans, blood tests, urine tests, among others.

(III)   Information regarding communication with MEDICENTER: MEDICENTER will access the information provided by Users to address any questions or concerns related to the use of the Application.

(IV)   Non-identifying information: MEDICENTER may also collect other information, such as zip codes, demographics, information regarding the User’s use of the Service and general project-related data (“Non-Identifying Information”). MEDICENTER may aggregate information collected from registered and unregistered MEDICENTER users. In some cases, MEDICENTER may convert Personal Information (generally, e-mail addresses) into a form of non-identifying information.

SECTION FOUR: Sensitive Data.

4.1. The User acknowledges and understands that MEDICENTER collects health-related data, referred to as “Sensitive Data”. By consenting, the User gives informed and explicit permission for the processing of both Personal Data and Sensitive Data If you have any questions regarding the processing of your Sensitive Data, please contact data@medicenter.com.

4.2. Any processing of Sensitive Data by MEDICENTER will be conducted in compliance with Law No. 25.326 on the Protection of Personal Data and Regulatory Decree No. 1558/01, provided that the User or their authorized representative has given and maintained valid consent for these purposes.

4.3.  No Personal Data or Sensitive Data will be processed by MEDICENTER for purposes other than those specified in the Services described in the User Terms and Conditions, in the Cookie Policy of the Application and in this Privacy Policy.

4.4.  MEDICENTER also provides within its infrastructure, the technical and legal means necessary for the confidential preservation and conservation of Sensitive Data and Personal Data, in general, in accordance with the applicable regulations and with the aim of preserving your rights, your intimacy, your privacy and your anonymity.

The User may, at any time, modify and/or delete their Personal Data and/or Sensitive Data. However, the User acknowledges that such actions may ultimately lead to a partial or complete disruption of certain functions within the Application. Additionally, the User has the option to permanently delete their account directly from their profile within the Application

4.5. Except as provided in Section Eight of this Privacy Policy and the exceptions provided by law, MEDICENTER shall not assign or transfer Personal Data and/or Sensitive Data to any third party without the consent of the User and/or the Represented Party.

SECTION FIVE: Information Collected Automatically.

MEDICENTER and its third-party service providers, including analytics and third-party content providers, may automatically collect certain information from the User whenever the User accesses or interacts with the Service or the Application. This information may include, but is not limited to, the browser and operating system used by the User, the search terms entered by the User into a search engine that led to the Service, the areas of the Service visited by the User, the links clicked by the User, the pages or content viewed by the User and for how long, other similar information and statistics about User interactions, such as content response times, download errors and length of visits to specific pages, and other information commonly shared when browsers communicate with websites. MEDICENTER performs these actions to enhance both the service quality and functionality of the application. For more information, please refer to the Cookie Policy.

SECTION SIX: For what purpose does MEDICENTER collect the information?

6.1. MEDICENTER collects and processes Personal Data and Sensitive Data of users for specific and limited purposes only. By using our Application, you agree with and consent to the processing of your Personal Data for the following purposes:

6.1.1) Operation of the Application:

6.1.1.a) Registration and Authentication: We collect Personal Data necessary to create and maintain your account and to authenticate your identity when you log in.

6.1.1.b) Provision of Services: We use your information to provide and improve the services offered by the Application. To operate, evaluate and improve MEDICENTER’s products and services.

6.1.1.c) Personalization: We use information about your preferences and activities to personalize your experience on the Application by providing relevant content and recommendations. 

6.1.2) Application Development and Improvement:

6.1.2.a) Analytics and Statistics: We collect and analyze application usage and performance data to improve our features, identify problems, and optimize performance.

6.1.2.c) Research and Development: We use anonymized and aggregated data to conduct internal research and to develop new features and services.

6.1.3) Security:

Protection and Prevention: We use your Personal Data to protect the safety of our users and systems, prevent fraud, abuse and unauthorized activity, and ensure compliance with our policies.

6.1.4) Legal Compliance:

We process your Personal Data in order to comply with our legal, regulatory and administrative obligations and the information requirements of competent administrative or judicial authorities.

6.1.5) Advertising and Marketing Purposes:

6.1.5. a) Personalized Advertising: By accepting this Privacy Policy, you expressly consent to MEDICENTER’s use of your Personal Data and Sensitive Data to send you commercial communications and personalized advertising related to MEDICENTER’s products and services, as well as those from third parties we believe may interest you. We will ensure your identity and anonymity are protected through appropriate data anonymization measures.

6.1.5. b) Market Segmentation and Analysis: We use your Data to perform market segmentation and analysis to better understand your preferences and behaviors and to provide you with more relevant advertising.

6.1.6 Statistical and Educational Purposes:

When a User adds diseases to their profile, these conditions may be classified according to the WHO ICD-11 standard, contributing to the development of a global health database. This information will be essential to understand the behavior of some diseases in relation to a specific geographic location, to a specific treatment, to possible associations with other diseases and/or signs and symptoms, and to possible interactions with certain diseases.

The analysis of all this information will make it possible to discover the emergence of new diseases, new potential treatments for existing diseases, to establish health prevention mechanisms, to know and detect new adverse effects of medicines, among others.

MEDICENTER may market the above information to companies, official bodies, universities, among others, while ensuring the User’s identity and anonymity through effective anonymization techniques.

6.1.7.) Transfer of Data to Third Parties:

6.1.7. a) Collaboration with Third Parties: With the User’s informed consent, we will share data with our business partners and advertisers for the advertising and marketing purposes described above, while preserving the User’s identity and anonymity through appropriate disassociation mechanisms.

6.1.7. b) Service Providers: We may share User Data with service providers who help us operate and improve our Application, always under strict conditions of confidentiality and security.

6.2.    MEDICENTER may send its Users notifications, news and updates that may be of interest to them, in addition to those of an institutional or legal nature.

6.3.  If MEDICENTER needs to close an account, it may take steps to anonymize the data and other information. However, MEDICENTER reserves the right to retain and access this anonymized data as necessary to comply with applicable legislation.

6.4.  MEDICENTER will use the information provided by the User to analyze their behavior and activity within the Application, including geographical locations, usage sessions, time spent in the Application, and frequency of use. This analysis intends to enhance the Service and deliver better solutions tailored to the User’s needs.

SECTION SEVEN: What privacy choices do Users have?

7.1. Users have choices regarding the privacy practices and communications described in this Privacy Policy. 

Personal Information: Users may refuse to provide Personal Information, or any data, whether sensitive or not, but in that case, it is possible that some or all of the Services may not be available to Users.
Additionally, any health records voluntarily provided by the User will be centralized and stored as part of this process.

Cookies: Users have the option to manage their cookie preferences, both on the website and in the MEDICENTER application. In this regard, the web browser or the application installed on the User’s mobile device may allow the User to enable or disable certain cookies. However, disabling cookies could impact the availability of key functions and potentially diminish the overall user experience. For more information, please refer to the Website Cookie Policy and the Application Cookie Policy.

Registration and Account Information: Users have an Account, and can generally review and edit Personal Information directly or by contacting MEDICENTER at info@medicenter.com. Users may contact MEDICENTER with questions about their account information or other Personal Information.

Communication: Notices, Alerts and Updates from MEDICENTER: 

Marketing: MEDICENTER may send newsletters or marketing content about MEDICENTER, the Application and the Service using various communication channels, such as e-mail, SMS or WhatsApp text messages, or pop-up notifications; Users may opt out of receiving these communications by following the instructions indicated in the communications they receive. 

Informational and Other Communications: MEDICENTER will send communications as deemed necessary in connection with: (I) the Service; (II) notices containing important information; and (III) other communications that Users may request from MEDICENTER. 

SECTION EIGHT: Do we share/transfer data?

8.1. MEDICENTER will share and/or transfer information only for the purposes described in this Privacy Policy and in the manner described in Section Six herein.

8.2.  MEDICENTER may also share non-identifying information with third parties solely for the purposes described in Section Six herein.

8.3. MEDICENTER may also disclose information it has collected about the User with the User’s consent, as described in this Privacy Policy, or in the following circumstances:

1. Service Providers: MEDICENTER may contract with third party companies and individuals to facilitate the Service, to provide the Service on MEDICENTER’s behalf, to perform activities related to the Service (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and enhancement of MEDICENTER’s functionality) or to assist MEDICENTER in analyzing how the Service is used. These third parties may access the User’s Personal Information solely for the purpose of carrying out these functions on behalf of MEDICENTER. Any such changes will be duly notified to the User, who will be required to give prior express consent.
2. Legal and Research Purposes: MEDICENTER will disclose information to government agencies as required by the above laws in response to lawful requests by government agencies, including to meet national security or law enforcement requirements. MEDICENTER will disclose information about the User to government authorities or law enforcement officials or private parties when MEDICENTER, in its sole discretion, believes that such disclosure is necessary or appropriate to respond to legal claims and legal process (including, without limitation, subpoenas or court orders) or to (a) protect the property and rights of MEDICENTER or any third party, (b) protect the safety of the public or any person, or (c) prevent or stop an activity that MEDICENTER may consider to be illegal, fraudulent, unethical or at risk of being illegal, fraudulent or unethical.

8.4.  Since MEDICENTER is a U.S. company, MEDICENTER processes and stores User information in the United States, but MEDICENTER’s service providers may process and store User information in other locations.

8.5.  The Service is operated by MEDICENTER’s team at its headquarters in Delaware, United States. MEDICENTER uses service providers to operate the Application and provide the Services. Not all of these service providers are located in the United States and may process User Data in the United States.

SECTION NINE: How long do we retain the information?

9.1. MEDICENTER will retain the information associated with the Data for a period of 10 (ten) years from the last time a record of use is obtained from the User. However, after TEN (10) years, and in the event that the User does not express interest in having the original copy of their health records, MEDICENTER will automatically delete and destroy them, except in those cases in which it must retain them in order to comply with a legal requirement, such as a court order.

SECTION TEN: Confidentiality and Security of Information.

10.1. MEDICENTER has implemented reasonable security measures to protect Users’ information and to prevent unauthorized access to, alteration, disclosure or unauthorized destruction of their data. Information collected by MEDICENTER is kept strictly confidential. Access to Personal Data and Sensitive Data is restricted to those MEDICENTER employees, contractors, operators and representatives with a need to know such data in order to perform their functions or to develop or improve our Services. MEDICENTER holds its suppliers to the same standards of legality, security and confidentiality. MEDICENTER does not provide access to this information to third parties outside of MEDICENTER, except at the express request of the User and only for the user’s own Personal Data.

10.2.  Notwithstanding the foregoing, given that the Internet is an open, publicly accessible system, MEDICENTER cannot guarantee that unauthorized third parties will not be able to overcome the security measures and use the User’s information improperly.

SECTION ELEVEN: Changes in Company Structure.

11.1. MEDICENTER reserves the right to transfer the information collected in the event of sale or merger of the company, or an acquisition of the principal assets of MEDICENTER, or any other transfer of the information to another entity. In such event, MEDICENTER will take reasonable steps to ensure that such information is used in a manner consistent with this Privacy Policy.

SECTION TWELVE: What rights do Users have?

12.1. MEDICENTER respects the rights of Users with regard to the protection of Personal Data. To this end, the User acknowledges and accepts that they have the following rights

1. Right to be informed. The User has the right to receive clear, transparent and easily understandable information about the way in which MEDICENTER uses their Personal Data and the rights to which they are entitled. Therefore, MEDICENTER provides the User with the information contained in this Privacy Policy.
2. Right of access and rectification. Users have the right to access, correct or update their Personal Information at any time.
3. Right to restrict processing. Under certain circumstances, Users have the right to limit the processing of their Personal Data, with the consequences of partial or total non-access to the Service.
4. Right to object. Under certain circumstances, Users have the right to object to certain types of processing, including processing for direct marketing purposes, by notifying MEDICENTER through the aforementioned channels.
5. Right to withdraw consent. Users have the right to withdraw their consent at any time. Users may withdraw their consent to the processing of their Personal Information at any time by contacting MEDICENTER. In this case, not all services may be available to the User.

12.2. Data subjects may exercise the aforementioned rights by sending a written request to MEDICENTER at data@medicenter.com. MEDICENTER will endeavor to respond to the request in a timely manner and to enforce the User’s applicable rights.

12.3.  If Users believe that their data protection rights have been violated, they may lodge a complaint with the supervisory authority of the place of residence of the User. 

SECTION THIRTEEN: Can children under the age of 18 use the MEDICENTER Service?

The Service is not intended for or directed to children under the age of 18.  MEDICENTER does not knowingly collect information, including Personal Information, from children or others who are not legally permitted to use the MEDICENTER Application and Service. For more information, please refer to the User Terms and Conditions.

If MEDICENTER is notified that it may have collected information from a child under the age of 18 whose registration information was not provided by their parents and/or guardians and/or legal representatives, MEDICENTER will promptly delete such information, unless MEDICENTER is required by law to retain such information.  Users should contact MEDICENTER if they believe that MEDICENTER has inadvertently collected information from a child under the age of eighteen (18).

SECTION FOURTEEN. Links to Other Websites.

14.1. The Application contains links to other websites. If the User decides to click on a third-party link, the User will be directed to the website of that third party. The link made by MEDICENTER to a website does not constitute an endorsement, authorization or representation of MEDICENTER’s affiliation with that third party or an endorsement of its privacy or information security policies or practices. MEDICENTER has no control over third party websites. These other websites may place their own cookies or other files on the User’s computer, collect data or request Personal Data from the User. MEDICENTER recommends that the User read the privacy policies or statements of the other websites they visit.

SECTION FIFTEEN. Changes to this Privacy Policy.

15.1. Changes to this Privacy Policy will be posted on the Application. If MEDICENTER makes a material change to MEDICENTER’s Privacy Policy, MEDICENTER will provide notice on the Application and/or by e-mail to the address that the User has verified in their account. 

SECTION SIXTEEN. Applicable Law. Disputes.

Any dispute arising from the interpretation or execution of this Privacy Policy, or for any other reason related thereto, shall be governed by the applicable law of the Republic of Argentina, and any discrepancy related thereto shall be resolved before the ordinary courts of the Province of Salta, Republic of Argentina.

SECTION SEVENTEEN. Contact.

If Users have any questions or concerns regarding MEDICENTER’s Privacy Policy, they should contact MEDICENTER. All contacts and requests regarding this Privacy Policy should be sent to data@medicenter.com

APPENDIX A: INFORMED CONSENT

By accepting this Privacy Policy, I declare that I have been informed:

• That the main service of MEDICENTER is to provide an Application that allows its users to securely digitize, store and share their health records with third parties.
• That my data will be processed for the following purposes:

1. Identification and conservation of the same in order to provide me with the service referred to in item (i).
2. Personalization and improvement of the service where possible.
3. Compliance with IT security requirements.
4. Compliance with any type of legal requirement (administrative or judicial).
5. Response to my requests and personalization of my preferences.
6. For advertising, marketing, statistical and educational purposes, as well as the transfer of data to third parties, always preserving my identity and anonymity by the appropriate dissociation mechanisms.
7. Sending of promotional, informative and educational materials, among others.
8. Development of new functionalities.
9. Creation of user profiles through the analysis of various variables, always in an anonymized form.
10. Allowing of third parties outside MEDICENTER to access my data, at my express request, when I generate a link and/or QR access code.

• That I will knowingly and voluntarily upload my Sensitive Data to MEDICENTER, that I will be able to delete and/or edit it at any time, and that it will be treated with respect for my privacy, anonymity and my rights under applicable laws and regulations, except in the case provided for in item (iv) of this Informed Consent, which refers to the transfer of data to Third Parties.
• I am aware that MEDICENTER’s responsibility extends up to the moment I decide to share my Health Records with a Third Party through a QR code and/or link, of my own free will. In such a case, I am aware that the treatment of my information will be the responsibility of the aforementioned third parties and, in the hypothetical case of their misuse, I will indemnify MEDICENTER against any type of claim for misuse, defamation, violation of privacy, of my anonymity, as well as of my rights under the applicable laws and regulations. Furthermore, I hereby acknowledge that MEDICENTER has provided me with the e-mail address data@medicenter.com for the purpose of receiving any requests related thereto and for exercising the rights set forth in this authorization.
• Considering the above and the purpose of the service offered by MEDICENTER, I voluntarily, previously, expressly, informed and unequivocally authorize MEDICENTER, and those to whom the rights are assigned, to process my data provided in the Application, as defined in the User Terms and Conditions, Privacy Policy and Cookies Policy of the Application, with the main purpose of contracting, executing and marketing MEDICENTER’s services, as well as contact by telephone, electronic (SMS, chat, e-mail, software applications, websites and other means considered electronic), physical and/or personal means.
• I give my consent to MEDICENTER to process my Personal Data and Sensitive Data, having read, understood and accepted all the terms and conditions established in the Privacy Policy and in the Terms and Conditions of the Shared Documents, and I therefore commit myself to acquaint myself with the same, as well as their modifications and new versions available in the Application.
• I authorize MEDICENTER to modify or update its contents in order to comply with legislative and/or administrative reforms of state or municipal nature, internal policies or new requirements for the provision or offer of services or products, giving prior notice through the MEDICENTER Application, by e-mail or any other means of contact that I may declare.
• That I have the right as a data subject to access (“Right of Access”) and to correct, modify or update the Data (“Right of Rectification”). MEDICENTER may deny such requests (hereinafter referred to as the “Requests”) if it is required or permitted to retain the data under applicable laws The aforementioned rights may be exercised through the channels provided by MEDICENTER, by sending an e-mail to data@medicenter.com, in which I must identify myself and specify the Data that I wish to access, rectify or remove.
• That I have been informed that, notwithstanding any other provision of the Privacy Policy to the contrary, MEDICENTER may disclose certain data if it believes in good faith that such disclosure is reasonably necessary to:

1. a) avoid legal liability;
2. b) comply with a legal or regulatory requirement; and/or
3. c) protect the rights, property, or safety of MEDICENTER, its User Patients, or others.

• That MEDICENTER will process my data under its legal responsibility and will retain and store my data for a period of ten (10) years. After the expiry of the period mentioned in this Section, MEDICENTER will destroy my Data.
• That this informed consent, as well as the relationship with MEDICENTER, shall be governed and interpreted in accordance with the legislation in force in the Argentine Republic.