Privacy Notice

DEFINITIONS

Confidentiality Agreement: The confidentiality agreement entered into between the Controller and LifeNome Genomics AI®, with the latter acting as the Data Processor, whereby the latter undertakes before the Controller to maintain strict confidentiality regarding any Personal Data or Sensitive Personal Data that it may come to possess and that may be directly linked to the User's identity, and which is attached to this Privacy Notice as an annex.

Consent.- The expression of will by which the User authorizes the Controller to process the User's Personal Data and Sensitive Personal Data.

Consent shall be given implicitly by accepting the legal terms and conditions and this Privacy Notice, and explicitly through the applicable authentication method in the case of Sensitive Personal Data.

General Data: Full name, email address, telephone number, gender, and a password for the creation of and access to the User's Salud.ia account.

Personal Data: Personal data means any information that the User shares with and adds to the Salud.ia application.

Sensitive Personal Data: Any data that the User, or the Laboratories collaborating with the Controller, provide to Salud.ia and that includes information affecting the User's private sphere, as expressly disclosed when completing the initial questionnaire. Likewise, all information provided by the User regarding their Health Status, and the genetic information and blood analysis data obtained by Salud.ia through the Laboratories or provided by the User, exclusively in relation to blood analysis and DNA information.

Failure by the User to provide relevant information regarding their health status, sensitive personal data, or any other information necessary for the proper provision of the service may limit or affect the adequate processing of their data by Salud.ia.

Consequently, the User releases Salud.ia from liability for any effects arising from the lack of accuracy, updating, or completeness of the information provided.

Data requiring express consent: All data referring to the User's Sensitive Personal Data. For this purpose, the User must authenticate their identity through email prior to providing their personal data to Salud.ia.

Health Status: The condition of the User in relation to the absence of diseases.

Laboratories: Chopo (Grupo Diagnóstico Médico PROA, S.A. de C.V.) and ZenGen Granatum-Bioworks, S.A.P.I. de C.V.

Law: Personal Data Protection Law Held by Private Parties.

Representative: A person authorized to act on behalf of the User, either by means of a power-of-attorney letter signed by the User, the Representative, and two witnesses, specifying the authority to exercise on behalf of the User the rights established by the Law; or by means of a power of attorney granted before a public notary for administrative acts or a specific power of attorney for exercising the rights established by the Law.

Revocation of Consent.- The User may revoke their consent for the processing of their personal data by following the procedure established in section 2.3 of this Privacy Notice.

User: Adult persons who have read and accepted the terms and conditions established by Salud.ia in order to contract and use this application, as well as authenticate their identity and consent through email confirmation.

PRIVACY NOTICE

I.- IDENTITY AND ADDRESS OF THE CONTROLLER

The Controller is Genetria, S.A.P.I. de C.V., with its registered address at Montecito, Exterior No. 38, Interior Floor 2, Office 4, Colonia Nápoles, Postal Code 03810, Benito Juárez Borough, Mexico City, Mexico.

II.- PERSONAL DATA SUBJECT TO PROCESSING AND ITS PROCESSING

All data provided by the User to Salud.IA shall be processed in accordance with the provisions established in Section II of this Privacy Notice.

The Controller shall be responsible for ensuring the accuracy of the sensitive personal data relating to the User's DNA and blood biomarkers obtained through the Salud.ia platform.

Salud.ia shall not be responsible for sensitive personal data corresponding to blood biomarkers that the User manually uploads or modifies.

The User acknowledges and accepts that any other Personal Data and Sensitive Personal Data uploaded to the Salud.ia application shall be the User's sole responsibility regarding its accuracy, considering that the Controller does not require certification or validation of the information provided to the application.

Therefore, any omission, inaccuracy, or failure to update the User's Personal Data or Sensitive Personal Data must be corrected through the ARCO Rights Procedure established in Section V of this Privacy Notice.

The Controller shall not use the User's Personal Data or Sensitive Personal Data for marketing, advertising, or commercial prospecting purposes without the corresponding consent of the data subject.

Notwithstanding the foregoing, the User acknowledges and accepts that their information and other data derived from the use of Salud.ia may be used for the development, improvement, training, validation, and optimization of Salud.ia's technological systems, algorithms, and artificial intelligence, as well as the technological tools of LifeNome Genomics AI®, provided that such information has been previously dissociated or anonymized in such a way that neither the User, their identity, nor their records can be directly or indirectly identified.

1.- DATA FOR CREATING A USER PROFILE

Personal Data to be Collected.- The Controller shall request that the User provide their email address, full name, gender, and date of birth in order to create their profile account in the Salud.ia application.

Primary Purposes of Processing.- Through this account, the User will have access to the information provided by Salud.ia, including general information about the User's health and key areas related to their well-being.

2.- DATA FOR OBTAINING GENERAL INFORMATION RELATED TO THE USER'S HEALTH

Data to be Collected.- The Controller shall collect the following Sensitive Personal Data: i).- height and weight; ii).- body type; iii).- education level; iv).- annual income; v).- diseases (type 1 diabetes, hypertension, moderate-risk cancer, chronic respiratory diseases, long COVID, high cholesterol and triglycerides, type 2 diabetes, heart disease, high-risk cancer, Alzheimer's disease, kidney disease, cerebrovascular accident); vi).- medication intake; habits related to the consumption of tobacco, vaping products, or alcohol; vii).- nutrition habits; viii).- habits related to physical activity; ix).- data relating to emotional status; x).- data relating to sleep and sleep habits.

Primary Purposes of Processing.- The Sensitive Personal Data mentioned in the preceding paragraph shall be collected in order to provide information related to the following aspects: nutrition, physical activity, sleep habits, stress management, mental health, and habits related to alcohol and tobacco consumption for the User.

Express Consent.- In order to collect the Sensitive Personal Data mentioned in this section, the User must authenticate the consent granted for these purposes by means of email authentication.

3.- DATA FOR OBTAINING THE USER'S GENETIC INFORMATION AND BIOMARKERS

Data to be Collected in the First Phase.- At this stage, Salud.ia will request the User's General Data as a first phase.

Primary Purposes of Processing in the First Phase.- To order: i) a DNA test to obtain the User's genetic data; and/or ii) a blood test to obtain the User's blood biomarkers (objectively measurable biological characteristics, such as molecules, proteins, genes, or images).

Primary Purposes of Processing in the Second Phase.- The Controller shall send the Sensitive Personal Data obtained from the DNA and/or blood tests to LifeNome Genomics AI®, so that it may process such data through artificial intelligence algorithms and mechanisms.

Sensitive Personal Data Obtained in the Second Phase.- The information obtained from the DNA and/or blood tests consists of the User's genetic data and blood biomarkers.

Primary Purposes of Processing.- For Salud.ia to provide a personalized risk assessment with specific recommendations based on the User's personal information.

This information consists of the User's genetic data or biomarkers, according to the analyses performed under the terms established by Salud.ia, and specific recommendations based on the User's unique information.

Using the User's genetic data and biomarkers, Salud.ia shall provide specific recommendations (products, nutrition plan, exercise routine) and a health risk assessment for the User in the following areas: i) cardiovascular; ii) metabolic; iii) cognitive; iv) hepatic/renal; v) immunological; vi) nutritional; and vii) physical condition.

Express Consent.- In order to collect the Sensitive Personal Data mentioned in this section, the User must authenticate the consent granted for these purposes through email authentication.

III.- OPTIONS AND MEANS TO LIMIT USE OR DISCLOSURE

The purposes for processing the Personal Data and Sensitive Personal Data that we collect are limited exclusively to the purposes established in Section II of this Privacy Notice.

Consequently, limiting the processing of personal data may affect the services provided by Salud.ia and may result in limitations regarding the information made available to the User.

Users may send an email to support.saludia@genetria.mx for the purpose of limiting the receipt of communications or promotions from the Controller.

For this purpose, the email sent by the User to the Controller at support.saludia@genetria.mx must include the following information:

The User's full name and, if acting through a representative, the representative's full name.
Attach to the email a PDF document containing a copy of the official identification (valid INE or passport) of the User and, where applicable, the Representative.
If exercising the right to limit the processing of Personal Data through a Representative, the Representative must attach to the email a public deed or power of attorney signed before two witnesses, through which authorization is evidenced (the User's consent granting authority to the Representative).
Indicate the email address through which notifications from the Controller may be received.
Specifically identify the Personal Data or Sensitive Personal Data for which the User wishes to limit processing and clearly indicate the type of limitation requested.

The Controller may request additional information or clarifications from the User within a maximum period of 5 business days. Within a maximum period of 10 business days following such clarification and/or request to limit the processing of Personal Data or Sensitive Personal Data, the Controller shall inform the applicant (the User or their Representative), via the email address provided, of the terms and scope of the implementation of the requested limitation.

IV.- EXERCISE OF ARCO RIGHTS (ACCESS, RECTIFICATION, CANCELLATION, AND OPPOSITION TO THE PROCESSING OF PERSONAL DATA AND SENSITIVE PERSONAL DATA)

The User, either directly or through their Representative (as defined by the Law), may exercise their ARCO Rights in accordance with the provisions established in this section:

1.- EMAIL REQUIREMENTS

The User or their Representative must exercise their ARCO Rights by sending an email to the following email address: support.saludia@genetria.mx.

The email through which the User or their Representative initiates this procedure must include:

The User's full name and, if acting through a representative, the representative's full name.
Attach to the email a PDF document containing a copy of the official identification (valid INE or passport) of the User and, where applicable, the Representative.
If exercising the right to limit the processing of Personal Data through a Representative, the Representative must attach to the email a public deed or power of attorney signed before two witnesses, through which authorization is evidenced (the User's consent granting authority to the Representative).
Indicate the email address through which notifications from the Controller may be received.
Specifically identify the Personal Data or Sensitive Personal Data in respect of which the ARCO Rights are being exercised.
Clearly specify the request corresponding to the ARCO Right or Rights being exercised.
Submit a separate email for each ARCO Right being exercised if more than one ARCO Right is requested.
If the User or Representative is exercising the right to Rectification of Personal Data or Sensitive Personal Data, specify the personal data to which the request relates, as well as the correction to be made, and attach the documentation supporting the validity of the request to the email.

2.- PROCEDURE FOR RESPONDING TO A REQUEST TO EXERCISE ARCO RIGHTS

The Controller may request additional information or clarifications from the User within a maximum period of 5 business days. Within a maximum period of 10 business days following such clarification and/or request concerning the limitation of Personal Data or Sensitive Personal Data, the Controller shall inform the applicant (the User or their Representative), via the email address provided, of the terms and scope of the response regarding the applicable ARCO Right being exercised.

The User or their Representative must submit a separate email for each ARCO Right being exercised if more than one of these rights is requested.

2.1.- RIGHT OF ACCESS TO PERSONAL DATA AND SENSITIVE PERSONAL DATA

The User may at all times access their Personal Data by accessing the Salud.ia application and reviewing their Personal Data and Sensitive Personal Data in Section V.

If the User or their Representative requests delivery of their Personal Data or Sensitive Personal Data, they may download such information directly from the application.

2.2.- RIGHT TO RECTIFICATION OF PERSONAL DATA AND SENSITIVE PERSONAL DATA

The User shall have the right to rectify their Personal Data or Sensitive Personal Data in cases of inaccuracy, omission, or failure to keep such data up to date.

Within 5 business days following receipt of the request for correction of personal data, the Controller shall send a communication requesting that the User or their Representative approve the modifications to be applied to the relevant personal data.

The User or their Representative shall respond to the email by accepting or clarifying the modifications to be applied. Once the Controller receives this second email, it shall implement the requested modifications and notify the User or their Representative of the implementation and the effective date thereof. Such implementation must occur within ten days following receipt of the email in which the User or their Representative confirms the modifications to be applied by the Controller.

2.3.- RIGHT TO THE CANCELLATION OF PERSONAL DATA OR SENSITIVE PERSONAL DATA

If the User or their Representative exercises the right to cancel Personal Data, the Controller shall proceed to block the use of any personal data or sensitive personal data belonging to the User.

For this purpose, within five business days, the Controller shall send an email to the address provided by the User or their Representative requesting confirmation of their consent for the User to cease having access to Salud.ia, for the Controller to refrain from processing the User's Personal Data or Sensitive Personal Data, and for the use of the User's Personal Data and Sensitive Personal Data (as applicable) to be blocked for a period of ten years from the date on which the cancellation of the Personal Data and/or Sensitive Personal Data is requested.

The cancellation of Personal Data or Sensitive Personal Data shall not apply in the cases established by Law.

Once the ten-year period has elapsed, the Controller shall delete the User's Personal Data and Sensitive Personal Data and shall no longer retain them.

2.4.- RIGHT TO OBJECT TO THE PROCESSING OF PERSONAL DATA

The User may object to the processing of their Personal Data, provided that they specify the reason for requesting such cancellation and that the grounds for objection are legitimate.

For this purpose, the User must describe the damages and harm caused by the processing of personal data, in accordance with the provisions of the Federal Civil Code.

The User may also request opposition to the processing of their Personal Data or Sensitive Personal Data if the processing carried out by Salud.ia, in accordance with the processing purposes established in this Privacy Notice (see Section II), produces unwanted effects or significantly affects their interests, rights, or freedoms, and is intended to evaluate, without human intervention, certain personal aspects of the User or to analyze or predict, in particular, their professional performance, economic situation, health status, sexual preferences, reliability, or behavior.

For the foregoing, the User must describe the corresponding effect referred to in the preceding paragraph that gives rise to the alleged impact.

In case of doubt, the User agrees to submit to the procedure established by Law for users, which shall be heard before the Ministry of Anti-Corruption and Good Governance.

V.- PROCEDURE FOR COMMUNICATING CHANGES TO THE PRIVACY NOTICE

Any modification to this Privacy Notice shall be communicated by Salud.ia at the time the User accesses the application through the Privacy Notice and its effective date.

Transfer of Personal Data or Sensitive Personal Data

The Controller shall not transfer any Personal Data or Sensitive Personal Data belonging to the User