Privacy Policy

PRIVACY POLICY

TO THE HOLDERS OF DATA PROVIDED

TO INNOPHARMA, S. DE RL DE CV:

INNOPHARMA, S. DE RL DE CV,(hereinafter “INNOPHARMA”) with address at Prolongación Ingenieros Militares 76 A, Colonia San Lorenzo Tlaltenango, Alcaldía Miguel Hidalgo, CP 11210, Mexico City, informs you that it is responsible for the privacy and treatment of your personal data, including the sensitive ones, which it has collected from you, in accordance with INNOPHARMA's privacy policy and under the provisions of articles 17 section II of the Federal Law on Personal Data Held by Private Parties and 27 of the Regulations to the aforementioned Law, to protection of this privacy notice.

This privacy notice is of the comprehensive type, as provided by the articles of section I, Chapter V, of the Privacy Notice Guidelines, published in the Official Gazette of the Federation, on January 17, 2013.

Any data you provide to INNOPHARMA either those collected through questionnaires, guarantee cards, consents granted by telephone, written, electronic means, access to official websites and/or social networks controlled by INNOPHARMA or by filling out forms are subject to protection and will be handled with due confidentiality and for the purposes that are expressly indicated in each case.

This Privacy Notice only applies to personal data collected by INNOPHARMA within the United Mexican States, so it is exempt from corresponding to other third-party electronic platforms with possible links from the Sites of INNOPHARMA.

Please read this Notice of Privacybefore using the Site INNOPHARMA or to provide us with your personal data:

What is "Personal Data" according to this Privacy Notice?

"Personal Data" means any information concerning an identified or identifiable natural person and that is collected by INNOPHARMA, for the administration of its obligations or the provision of the services it provides.

Who is Responsible for the protection of your personal data?

INNOPHARMA, S. de RL de CV, with address at Prolongación Ingenieros Militares 76 A, Colonia San Lorenzo Tlaltenango, Delegación Miguel Hidalgo, CP 11210, Mexico City, is responsible for the processing of your personal data in accordance with the Federal Law on Protection of Personal Data Held by Individuals published in the Official Gazette of the Federation on July 5, 2010.

How to contact us?

Via email to the address: aviso.privacidad.colaboradores@glr.mx

For what purpose we collect and use your personal data?

The purpose of this notice is to ensure the privacy of the data provided by our clients, in order to be linked to the services and products provided by INNOPHARMA, guaranteeing your privacy and your right to informational self-determination.

Your personal data will be used for the following purposes: (i) comply with the company's internal policies and procedures, (ii) comply with applicable and current legislation and authority requirements; (iii) personnel administration; (iv) generation of studies, statistics, metrics, programs, reports, and projects; (v) evaluate the quality of the service; (vi) sending advertising and promotional material; (vii) monitoring of medical treatment; (viii) sending information about products, patient programs, and their updates; (ix) registration of users, customers and suppliers; (x) reception, documentation and monitoring of complaints and requests for technical service, which may apply; (xi) registration and activation of guarantees that may apply; (xii) access and security log; (xiii) compliance with pharmacovigilance and technovigilance; (xiv) fulfillment of obligations with customers and suppliers; (xv) medical promotion visit (xvi) coordination of congresses and medical or health events; (xvii) documentation and monitoring of reportable medical events; (xviii) provide services and products; (xix) inform about changes or new products or services that are related to the contracted or acquired by the client; (xx) recruitment and selection of external personnel; (xxi) the contracting, promotion and provision of the services and/or products offered; (xxii) the integration of the administrative file, contact information to follow up on requests and quotes; (xxiii) Contact information to manage payments and carry out the commercial relationship, analyze requests for contractual relationships, decide on discounts or surcharges; (xxiv) keep a record of customers and provide them with the best possible service and care; (xxv) contact customers when necessary, including completing transactions or providing you with personalized services, as well as in emergencies; (xxvi) achieve product delivery according to your specifications and needs; (xxvii) obtain your credit card information, which will only be used as a form of payment, if so indicated; (xxviii) receipt, documentation and monitoring of complaints and requests; (xxix) record of access to our facilities and security; (xxx) fulfillment of obligations with clients; (xxxi) inform about changes or new products or services that are related to the contracted or acquired by the client; (xxxii) provide the services and/or products that the client requires in terms of quality and quantity; (xxxiii) bank clarifications; (xxxiv) collection activities, including sending communications through emails, telephone calls, instant messaging services, short messages and other physical and/or electronic means of communication; (xxxv) generate the fiscal invoicing derived from the commercialization of the products and/or services.

What personal data do we collect and from where?

Your personal data held by INNOPHARMA and that are subject to protection, are those that have been collected: i) Personally, through our employees or at our reception, through questionnaires and filling out forms, quotes, signing contracts, filling out documents, satisfaction questionnaires and opinion of the service, as well as subscription to offers and contests or loyalty programs; ii) Directly, by telephone, writing or through email and other digital and electronic means, as well as by courier or certified postal mail, through requests, statements, notices, consents granted; iii) Indirectly, when you provide your personal data to one of our suppliers or third parties that provide us with databases and that support us during the ordering, delivery and marketing processes; iv) Electronically, by filling out the quote or advice form on our website, by interacting on our social networks or through cookies or web beacons, through access to websites controlled by INNOPHARMA that are linked to this Privacy Notice.

The data that INNOPHARMA obtains from you and, therefore, are subject to protection, are:

Identification.- Name, private and/or fiscal address, date and place of birth, age, private and mobile telephone number, email, official identification, signature, Federal Taxpayer Registry (RFC), Unique Population Registry Code (CURP), nationality , as well as your IP address and browser type when obtained by electronic means.

Labor.- Name of your company and contact information, line of business of the company, profession or occupation, position, work address, telephone number and company email.

Commercial.- Customer registration form, supplier registration letter, service provision letter, price list, contracts and agreements entered into, certifications, commercial invoices, technical specifications of merchandise or service, permits and authorizations from the authorities.

Financial or patrimonial.- Bank account, credit cards or method of payment, in order to make the corresponding charges or guarantees, tax information, tax data for billing.

What is "sensitive personal data" according to this Privacy Policy?

We inform you that in order to comply with the purposes set forth in this Privacy Notice, the following sensitive personal data will be collected and processed, where appropriate: present and future state of health, your racial or ethnic origin, genetic information, religious, philosophical beliefs and morals, union affiliation and/or political opinions or sexual preference, nationality or citizenship, as well as video recordings that may or may not be taken through closed circuits as means of surveillance.

We promise that they will be treated under the strictest security measures that guarantee their confidentiality.

In accordance with the provisions of article 9 of the aforementioned Law, we require your express consent for the processing of your sensitive personal data. By submitting sensitive personal data to us through the Site INNOPHARMA, you give your consent and expressly accept that this data is treated in accordance with the terms and conditions of this privacy notice.

How can you limit the use or disclosure of your personal data?

You can exercise your right to limit the use or disclosure through the Procedure for requesting ARCO rights detailed in this notice.

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Likewise, in the event that you receive advertising mail or electronic mail, it will contain instructions to opt out or stop receiving mail or electronic mail by following the instructions described above.

How can you access or rectify your personal data or cancel or oppose its use?

Unless the law, contract or internal policies and procedures of INNOPHARMA prevent it, you have the right, at all times, to access, rectify, cancel and oppose your personal data (ARCO Rights) or to revoke the consent that you have given us for said purpose.

Regarding the protection of personal data, ARCO Rights are the four types of rights that individuals have over personal data that are part of a database: access, rectification, cancellation and opposition.

Right of access: It consists of the right of a person to know their personal data in the possession of a person in charge. Through the right of access, the individual requests, following a procedure, information from the person in charge of the database, about what data he has and how he has obtained them, as well as to obtain information regarding the conditions in which his data is processed.

Right of rectification: It consists of the faculty of a person to be able to request the person in charge or holder of their personal data, the rectification of any particular data or of all, when they are inaccurate or incomplete.

Right of cancellation: It consists of the power of a person to be able to request the person in charge or holder of their personal data, the cancellation of a data that is unnecessary or irrelevant. The data will be blocked, that is, it will be identified and reserved in order to prevent its treatment when it is considered that it is not being treated in accordance with the principles and duties established by the Federal Law on Protection of Personal Data Held by Private Parties and its Regulation.

Right of opposition: It consists of the power of a person to be able to oppose, when there is legitimate cause or so that their data is not processed for specific purposes, the processing of their personal data included in a database.

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All your personal data is treated in accordance with the applicable legislation in force in the country. Therefore, we inform you that you have at all times the rights (ARCO) to access, rectify, limit, cancel or oppose the treatment that we give to your personal data; right that may be asserted through a written request in accordance with the procedure established by this Privacy Notice.

How can you revoke your consent for the processing of your data?

At any time, you may revoke the consent you have given us for the processing of your personal data, so that we stop using them, unless the legislation, contract or internal policies and procedures of INNOPHARMA prevent its revocation. To exercise these rights, you must comply with the Procedure for requesting ARCO rights detailed later in this notice.

Can your data travel to another country or be shared with others?

Your personal data may be transferred and processed inside and outside the United Mexican States, by persons other than INNOPHARMA. In this sense, your information may be shared with other companies INNOPHARMA, affiliates, suppliers, authorities, distributors, collaborators, business partners, or agents to help us provide services or perform treatments authorized by law.

We promise not to transfer your personal information to third parties other than those indicated above, without your consent, except for the exceptions provided for in article 37 of the Federal Law on Protection of Personal Data Held by Private Parties, as well as to carry out this transfer in the terms established by that law.

Except in the cases of article 37 of the Law: If you do not express your opposition for your personal data to be transferred, it will be understood that you have given your tacit consent for it. The respective opposition must be formulated and processed, according to the Procedure for requesting ARCO rights detailed in this notice.

Given that we will transfer some sensitive personal data, we require your express consent. By submitting sensitive personal data to us through the Sites INNOPHARMA, you give your express consent and expressly accept that this data is treated in accordance with the terms and conditions of this privacy notice, as long as there is no opposition referred to in the previous paragraph.

Modifications to the privacy notice

INNOPHARMA reserves the right to make modifications or updates to this Privacy Notice at any time, for the attention of legislative reforms, internal policies or new requirements for the provision or offering of our services or products. These modifications will be available to the public through our Internet page, privacy notice section.

Use of cookies and web beacons.

Cookies are text files that are automatically downloaded and stored on the hard drive of the user's computer equipment when browsing a specific Internet page, which allow the Internet server to remember some information about this user, including their preferences for the visualization of the pages in that server, name and password.

For their part, web beacons are images inserted into an Internet page or email, which can be used to monitor the behavior of a visitor, such as storing information about the user's IP address, duration of interaction time on said page and the type of browser used, among others.

We inform you that we could use cookies and web beacons to obtain personal information from you, such as the following: your browser type and operating system, the Internet pages you visit, the links you follow, the IP address, the site you visited before enter ours

These cookies and other technologies can be disabled. To find out how to do it, consult the help or technical support of your Internet browser.

To whom can you file your complaints and complaints about the improper processing of your personal data?

If you consider that your right to protection of personal data has been injured by any conduct of our employees or our actions or responses, or you consider that in the processing of your personal data there is a violation of the provisions set forth in the Federal Protection Law of Personal Data in Possession of Individuals, may file the corresponding complaint or denunciation before the IFAI.

Who will have access to my personal data?

A restricted number of employees of INNOPHARMA, and its affiliates, subsidiaries or parent company, certain companies with which INNOPHARMA may have joint programs and third parties that INNOPHARMA engages to perform activities for INNOPHARMA can access the

personal information. We train our employees on the importance of privacy and on how to treat personal data appropriately and securely. INNOPHARMA you understand that you provide your consent when you enroll in a program that is run in conjunction with another company that may require access to your personal information. In addition, it is practice INNOPHARMA require its vendors or contractors to keep your personal information confidential and to use your personal information only to perform functions for INNOPHARMA.

Notwithstanding the foregoing, INNOPHARMA you can transfer your personal data to third parties for the purposes established in this Privacy Notice. The above includes:

a) Your personal data mentioned above may be communicated to the competent authorities, in accordance with the applicable legislation, provided that it is a request that complies with the applicable legal requirements, binding and enforceable to INNOPHARMA, and is issued by a legitimate authority and competent in the exercise of its functions. These transfers may be national or international, to comply with the laws, regulations, regulations and/or judicial decisions of the states and/or countries where INNOPHARMA and its subsidiaries operate, as well as to exercise and enforce our rights.

b) INNOPHARMA may transfer all or part of the aforementioned personal data to web page support service providers, such as Google Analytics, in order for them to provide data such as your IP address, statistics service and analysis of usage information. from our page. These transfers can be national or international.

c) Finally, your personal data may be sent to marketing and advertising service providers for hosting information for sending emails and generating advertising.

How does INNOPHARMA protect the privacy of minors?

INNOPHARMA only collects personal data and sensitive personal data from minors (we define “minors” as those under the age of 18) on the Sites INNOPHARMA, when they are provided by their guardians or persons legally authorized to provide them to INNOPHARMA. We do not intentionally allow minors to order our products, communicate with us, or use any of our services online. In the event that you detect that a minor has provided us with personal data, contact us by the means specified in this Privacy Notice to implement the actions that you require in this regard.

How long will you keep INNOPHARMA Personal Information?

INNOPHARMA will keep your personal information for as long as it is necessary to comply with the purposes of personal data processing, as well as the applicable legislation, contracts, policies and internal procedures of INNOPHARMA.

Procedure for the exercise of ARCO rights

The exercise of ARCO rights refers to the right of the owner of personal data to request access, rectification, cancellation or opposition to the processing of their data.

Right of Access: that through which the owner may request and be informed about their personal data, their origin, the treatment to which they are subjected, the assignments made or intended to be made, as well as to have access to the notice of privacy to which the treatment is subject.

Right of rectification: that through which the owner may request the rectification of their personal data when they are inaccurate, incomplete, inadequate or excessive, whenever possible and does not require disproportionate efforts.

Right of cancellation: If the owner is aware that the treatment that is being given to his personal data contravenes the provisions of the Data Protection Law or that his personal data is no longer necessary for the fulfillment of the purpose(s). ) from the database

provided in the applicable provisions or in the privacy notice, you can request the cancellation of your data.

Right of opposition: that right that the owner has to oppose, for legitimate reasons, the processing of their personal data for one or more purposes, in the event that the data had been collected without their consent, when there are well-founded reasons for it and the law does not provide otherwise.

It is important to point out that in order to be able to make a request for ARCO rights, the owner or his legal representative must prove his identity or representation, respectively.

At any time, you can revoke the consent that, in your case, you have granted to INNOPHARMA for the processing of your personal data. However, it is important that you take into account that not in all cases your request can be met or the use terminated immediately, since it is possible that due to some legal obligation it is required to continue processing your personal data.

Likewise, you must consider that for certain purposes, the revocation of your consent will imply that you cannot continue to provide the service you requested, or the conclusion of your relationship with the INNOPHARMA.

The mechanism that has been implemented for the exercise of ARCO rights may be exercised by sending a request addressed to the email address "aviso.privacidad.colaboradores@glr.mx". In your request by email you must meet all the requirements listed below:

1. Provide the following information:

a. Name

b. Email

c. Telephone contact

d. city and state

e. Profession

f. Occupation

g. Relationship you have had with INNOPHARMA: (for example: I am a user of the product...)

h. area or person INNOPHARMA who has contacted you

i. means by which INNOPHARMA contacted you

j. Name of the product, service, event or program for which you were contacted.

2. Attach a copy of the documents that prove your identity or, where appropriate, the legal representation of the owner.

3. Provide a clear and precise description of the personal data with respect to which you seek to exercise any of your rights.

4. Provide any other element or document that facilitates the location of your personal data.

The term to provide you with a response regarding the determination adopted regarding your ARCO application is twenty (20) business days from the receipt of your duly completed application.

The aforementioned period may be extended only once for an equal period, as long as the circumstances of the case justify it.

For more information, please contact the Data Privacy Committee of INNOPHARMA to the email address: aviso.privacidad.colaboradores@glr.mx

Complaints regarding the handling of your personal data.

Any complaint or additional information regarding the processing of your personal data or doubt in relation to the Federal Law on Protection of Personal Data Held by Individuals or its Regulations, may be directed to the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI).

Modifications to the privacy notice.

This privacy notice may undergo modifications, changes or updates derived from new legal requirements, INNOPHARMA's own needs for the services it offers, privacy practices or other causes, for which INNOPHARMA reserves the right to make any necessary changes or updates to this privacy notice at any time.

It is because of that INNOPHARMA will post the updated version of the privacy notice on all the platforms where it collects information from the owners, so that the timely handling of the information provided is known at all times.