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Privacy Policy and Personal Data Protection

Introduction

Telepatía S.A.S., with NIT 901.863.452-7, domiciled in Medellín, in compliance with Law 1581 of 2012 and its regulatory decrees, commits to guarantee the protection and adequate management of personal data collected through the Telepatía application, a platform that uses artificial intelligence (AI) to optimize the interaction between Health Professionals and Users through technological means.

By authorizing the processing of their Personal Data, the Data Subject expresses their consent for such data to be processed in accordance with the provisions of this Privacy Policy and Personal Data Protection and the Terms and Conditions applicable to Users, which form an integral part of this document. In that order of ideas, by authorizing the Processing of their Personal Data, the Data Subject declares having read and understood its content.

1. OBJECTIVE

The objective of this Privacy Policy and Personal Data Protection, (hereinafter "Privacy Policy"), is to comply with Statutory Law No. 1581 of 2012, its Regulatory Decree 1074 of 2015 (Chapter 25) and other regulations governing Personal Data Protection.

2. SCOPE

This Privacy Policy is applicable both to Telepatía S.A.S., as Data Controller and its direct and indirect employees, as well as to all those third natural or legal persons to whom it Transmits Personal Data of the Data Subjects that comprise the Interest Groups of the Data Controller, when they perform any Processing on them at their request.

Insofar as this Privacy Policy is applicable only whenever Telepatía S.A.S. acts as Data Controller, the Data Subject exempts the company from the Processing of Personal Data that Health Professionals may perform and recognizes that such operations will be covered by the particular data processing policies of health service providers.

3. IDENTIFICATION OF THE DATA CONTROLLER

  • COMPANY NAME: TELEPATÍA S.A.S.
  • DOMICILE: MEDELLÍN
  • ADDRESS: Calle 7 # 18 - 85
  • EMAIL: info@telepatia.ai
  • PHONE: 3146566962

4. DEFINITIONS

For the purposes of this Privacy Policy, the following shall be understood as:‍

ADOLESCENT: Persons between 12 and 18 years of age (Code of Children and Adolescents, article 3).

‍AUTHORIZATION: Prior, express and informed consent of the Personal Data Subject to carry out the Processing of their personal data, which may be collected in a written, oral or unequivocal manner that allows to reasonably conclude that they granted the authorization.

‍PRIVACY NOTICE: Document generated by the Data Controller, made available to the Data Subject to inform them of the existence of data processing policies, how to access them, and the characteristics of the processing intended to be given to Personal Data.

‍DATABASE: Organized set of personal data, physical or electronic, subject to manual or automated Processing.

‍PERSONAL DATA: Any information linked or that may be associated with one or more determined or determinable natural persons. The nature of Personal Data may be public, semi-private, private or sensitive.

‍PRIVATE DATA: Data that by its intimate or reserved nature is only relevant to the Data Subject.

‍PUBLIC DATA: Data qualified as such according to the law or the Constitution and that which is not semi-private, private or sensitive.

‍SENSITIVE DATA: Data that affect the privacy of the Data Subject or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, health data, or biometric information.

‍DATA OF CHILDREN AND/OR ADOLESCENTS: The same rules and procedures as Sensitive Data will apply, and no Processing will be given that may violate or threaten their development.

‍SEMI-PRIVATE DATA: Data that is not intimate or public, and whose knowledge may interest a group of people or society in general (e.g., social security or financial information).

‍RIGHT OF HABEAS DATA: The right of all persons to know, update, and rectify information collected about them in databases.

‍DATA PROCESSOR: Natural or legal person, public or private, that performs the Processing of Personal Data on behalf of the Data Controller.

‍INTEREST GROUPS: Groups of natural persons with respect to whom the Data Controller and/or Data Processors perform any Processing of Personal Data.

‍CHILD: Persons between 0 and 12 years of age (Code of Children and Adolescents, article 3).

‍PERSONAL DATA PROTECTION OFFICER: Person or Area responsible for ensuring compliance with Personal Data Protection regulations.

‍PQR'S: Petitions, consultations, and complaints regarding Personal Data Protection.

‍DATA PROTECTION: All measures necessary to provide security to records, avoiding adulteration, loss, consultation, or unauthorized access.

‍DATA CONTROLLER: Entity that decides on the Database and/or Processing of data.

‍DATA SUBJECT: The natural person whose personal data is subject to Processing.

‍TRANSFER: When a Data Controller and/or Processor located in Colombia sends information or personal data to another Data Controller within or outside the country.

‍TRANSMISSION: Processing that involves communication of Personal Data for Processing by the Processor on behalf of the Controller.

‍PROCESSING: Any operation or set of operations on personal data, such as collection, storage, updating, use, circulation, transfer, transmission or deletion.

5. GUIDING PRINCIPLES

The following are the Guiding Principles regarding Personal Data Protection, and will apply to the Processing carried out by the Data Controller, its employees, and third parties to whom it Transmits or Transfers Personal Data:

  • PRINCIPLE OF LEGALITY: Processing will be carried out in accordance with the legal requirements established in Statutory Law 1581 of 2012 and its regulatory decrees.
  • PRINCIPLE OF PURPOSE: Processing must obey a legitimate purpose, informed to the Data Subject.
  • PRINCIPLE OF FREEDOM: Processing can only occur with prior, express, and informed consent of the Data Subject. Public Data are exempt as per the law.
  • PRINCIPLE OF TRUTHFULNESS OR QUALITY: Information must be truthful, complete, accurate, updated, verifiable, and understandable.
  • PRINCIPLE OF TRANSPARENCY: The Data Subject has the right to obtain information about their data at any time and without restrictions.
  • PRINCIPLE OF ACCESS AND RESTRICTED CIRCULATION: Personal data cannot be made available on the Internet unless access is restricted to authorized parties.
  • PRINCIPLE OF SECURITY: Information must be protected by technical, human, and administrative measures to avoid unauthorized access or alteration.
  • PRINCIPLE OF CONFIDENTIALITY: All persons involved in Processing must guarantee confidentiality, even after their relationship with the Processing ends.

PRINCIPLE OF NECESSITY: Only data strictly necessary for the informed purposes will be collected and processed.