Colombia +57 (350) 318 9878 contacto@novafem.com.co

PROGENY SAS identified with NIT 900.834.428-2, hereinafter NOVAFEM, with main address at Calle 98 no.9ª-41 Of 402 in the city of Bogotá, telephone (1) 3598080, with institutional email info@novafem.com.co, informs its policy for the processing of personal data.

1. PURPOSE

This policy is issued in compliance with Law 1581 of 2012, Decree 1377 of 2013 and other regulations that modify or add the personal data protection regime. It has the following purposes:

A. Guarantee that NOVAFEM, as the person in charge of handling personal information, carries out the treatment of it in compliance with the applicable regulations.

B. Guarantee the rights of the Holders of the information.

2. RESPONSABLE.

PROGENY SAS identified with NIT 900.834.428-2, with main address at 98 Street No. 9- 41 of 402 of the city of Bogotá, telephone (1) 3598080, with institutional email info@novafem.com.co.

3.TREATMENT TO WHICH THE DATA WILL BE SUBJECTED.

In the development of its corporate purpose, NOVAFEM performs the processing of personal data of its patients, employees, suppliers, customers and users of its services, directly executing activity, or by contractors or agents.

Under the principles of purpose and freedom, the collection of personal data by NOVAFEM will be limited to those personal data necessary, relevant and appropriate for the purpose for which they are collected or required in accordance with current regulations. Except as expressly provided in the Law, personal data will not be collected without the Holder’s authorization.

NOVAFEM maintains the confidentiality of the personal data object of Treatment and may only disclose them at the express request of the monitoring and control entities and authorities that have the legal power to request it and will allow, at any time and free of charge, to know, update and correct the information Personnel of the Holder in accordance with article 8 of Law 1581 of 2012.

The personal data that NOVAFEM collects through its different media or channels will be used for the activities inherent to its corporate purpose. Likewise, the company may use your personal data to offer and / or inform you, others or services directly offered by NOVAFEM. NOVAFEM may transfer your personal data to third parties, affiliates or affiliates, in accordance with its personal data management policy.

Data processing includes the collection, storage, administration, use, transfer, transmission and destruction, in the manner allowed by law and is done with the following specific purpose for each case:

A.Treatment of personal data of patients:

The treatment of personal data of patients is intended to NOVAFEM contact them by text messages, email, physical mail, telephone, and any other suitable means of communication, to provide information, make appointments, confirm data for treatment delivery and in general to develop the actions required for the provision of medical services and treatments on male sexual health, so that in the development of consultations and other services, the doctor can perform diagnoses, treatments and other procedures inherent to health services offered The health data are considered by the law sensitive data and therefore the Holder is not obliged to supply them.

B. Processing of personal data of employees and former employees:

It is carried out to comply with the labor obligations borne by NOVAFEM, such as payroll payments, payments and reports to the general system of social security in health, attention to inquiries, requests, requests, actions and claims made by the Owner of the information. or by its legitimarios, or by entities of the general system of social security in health to which the Holder is or has been linked.

C. Treatment of personal data of Suppliers:

Allows the fulfillment of contractual obligations by NOVAFEM, such as payment of fees, reports of payments, reports or provision of information that by legal mandate or by internal policies has the obligation to perform, attention to queries, requests, requests, actions and claims, made by the Holder of the information or by his legitimarios.

D. Processing of personal data of Customers and / or users:

The treatment of personal data of Clients, has the purpose that NOVAFEM can comply with the contractual obligations under its charge, such as billing, payment reports or supply of information that by legal mandate or by internal policies has the obligation to perform, attention of inquiries, requests, requests, actions and claims, made by the Holder of the information or by his legitimarios.

E. Treatment of data of doctors and other health professionals:

The treatment of personal data of physicians and other health professionals is intended to periodically be contacted by text messages, email, physical mail, telephone, and any other appropriate means of communication, to provide information about issues of health and medical and scientific information. Likewise, for the participation of advanced projects for clinical studies or those that it sponsors. The data processing may involve the transfer to third parties with which NOVAFEM has agreements to carry out continuing education activities and for the purpose of granting attendance certificates.

4. RIGHTS OF THE HOLDERS

The holders of personal data have the following rights:

a) Know, update and rectify your personal data supplied to NOVAFEM as responsible for the Treatment. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose Treatment is expressly prohibited or has not been authorized.

b) Request proof of the authorization granted to the NOVAFEM except when expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of Law 1581 of 2012.

c) To be informed by NOVAFEM, upon request, regarding the use that has been given to their personal data.

d) Submit to the Superintendency of Industry and Commerce complaints for infractions of the provisions of law 1581 of 2012 and other regulations that modify, add or supplement.

e) Decline the authorization and / or request the deletion of the data when the Treatment does not respect the principles, rights and constitutional and legal guarantees. The revocation and / or suppression will proceed when the Superintendence of Industry and Commerce has determined that in the Treatment the NOVAFEM has incurred in conducts contrary to the Constitution and the law.

f) Access free of charge to your personal data that have been processed.

5. PROCEDURE FOR THE EXERCISE OF RIGHTS BY HOLDERS.

The Holders of personal data should direct their queries requests or claims to the mail.

a. Consultations: NOVAFEM must attend the consultations within a term of ten (10) business days from the date it was received. When it is not possible to comply with this time, the interested party must be informed, stating the reasons for the delay and the date on which the consultation will be attended within a term not exceeding five (5) days.

b. Claims: The Holder or successor who considers that the information contained in a database must be subject to correction, updating or deletion, or when it notices the alleged breach of any of the duties contained in the law or in this Policy, may submit a claim to NOVAFEM which will be processed under the following rules: i) The claim will be formulated by means of a request addressed to the NOVAFEM legal representative or to the area in charge of the Treatment, to the electronic mail: info@novafem.com.co with the identification of the Holder , the description of the facts that give rise to the claim, the address, and accompanying the documents you want to assert. If the claim is incomplete, NOVAFEM will require the interested party within five (5) days following the receipt thereof to correct the faults. After two (2) months from the date of the request, without the applicant submitting the required information, it shall be understood that the claim has been abandoned. ii) Once the complete claim has been received, a legend that says “claim in process” and the reason for it will be included in the database, in a term not exceeding two (2) business days. This legend must be maintained until the claim is decided. iii) The maximum term to attend to the claim will be fifteen (15) business days counted from the day following the date of its receipt. When it is not possible to attend the claim within said term, the interested party will be informed of the reasons for the delay and the date on which his claim will be handled, which in no case may exceed eight (8) business days following the expiration of the first finished. iv) The Holder or successor may file a complaint with the Superintendency of Industry and Commerce, once the process of consultation or claim has been exhausted before the Person in Charge of Processing or Responsible for Processing.

c. Revocatoria de la autorización y/o supresión del dato: Los Titulares podrán en todo momento solicitar a NOVAFEM la supresión de sus datos personales y/o revocar la autorización otorgada para el Tratamiento de los mismos, mediante la presentación de un reclamo, de acuerdo con lo establecido en el artículo 15 de la Ley 1581 de 2012, el decreto 1377 de 2013 y el Procedimiento indicado en esta Política.

If the respective legal term has expired, NOVAFEM has not eliminated personal data, the Holder shall have the right to request the Superintendence of Industry and Commerce to order the revocation of the authorization and / or the deletion of personal data.

Notwithstanding the foregoing, personal data must be retained when required for the fulfillment of a legal or contractual obligation.

6. TEMPORARY LIMITATIONS TO THE PROCESSING OF PERSONAL DATA

NOVAFEM can only perform the processing of personal data for as long as is reasonable and necessary, in accordance with the purposes that justified the processing, taking into account the provisions applicable to the subject in question and the medical, administrative, accounting, fiscal aspects , legal and historical information.

Once the purpose or purposes of the Treatment have expired or the maximum legal term in which NOVAFEM has the obligation to preserve personal data has expired, NOVAFEM will proceed to suppress the personal data in its possession.

NOVAFEM and the Treatment Managers shall document the procedures for the Treatment, conservation and suppression of personal data in accordance with the provisions applicable to the subject matter, as well as the instructions issued by the Superintendence of Industry and Commerce.

7. VALIDITY OF THE POLICY

This policy is effective as of June 1, 2015.