1. Personal Data Processing Controller:
Específicos Stendhal, S.A. de C.V., Administración Stendhal, S.A de C.V., Stendhal Colombia S.A.S., Stendhal Costa Rica S.A., Stendhal S.A., Stendhal Panamá, S.A., and Stendhal Américas, S.A., (all of them with the address: Camino a Santa Teresa No. 1040, Mezzanine 1, Col. Jardines en la Montaña, Alcaldía Tlalpan, C.P. 14210, Ciudad de México, México); and Stendhal Perú S.A. (National Taxpayer Registry (RUC, acronym in Spanish) No. 20535696251, with the address: Calle Río de la Plata No. 315, Urbanización Santa Cruz, Distrito de San Isidro, Lima, Perú), hereinafter jointly referred to as "Stendhal", in accordance with the provisions of Local Laws, Regulations, Decrees, Norms, and other applicable provisions on the Protection of Personal Data (hereinafter, “the Law"), hereby discloses this Privacy Notice regarding the processing of your personal data.

2. Collection of Personal Data:
Stendhal collects your personal data for the purposes set forth in this Privacy Notice. In this regard, we state that your data shall be processed and safeguarded based on the principles of lawfulness, quality, consent, information, accuracy, effective updating, purpose, loyalty, confidentiality, proportionality, security, legality, transparency, relevance, legitimacy, and responsibility, enshrined in the applicable Laws, with the exception of any case in which said information is required to be disclosed by court proceedings and/or government authority, in absolute compliance with legal provisions and responsibilities.

Your personal data may be stored and processed in any country where our facilities or service providers may be located, including but not limited to: Guatemala, El Salvador, Panama, Costa Rica, Peru, Ecuador, and the Dominican Republic; it may also be transferred to our affiliates or subsidiaries within the same corporate group. By using our Site or giving your consent (where required by law), you agree to said information being transferred and/or sent to countries other than your country of residence. For this purpose, this document shall be construed as express authorization.

We inform you that your data shall be processed for the duration of the relationship between you and Stendhal.

The data we may require includes, but is not limited to:

Personal information: Full name, address, telephone number(s), email address, mobile phone number, date of birth, age, sex, city, residential status and, where applicable, personal information of one or more family members.
Academic information: Professional license number or registration, specialty license number, or Medical College member/registration number.
Employment information: Employment history or experience, current or previous role or position, work address, information generated during the recruitment, selection, and hiring processes, Curriculum Vitae.
Financial information: Bank account number (only where a contractual relationship exists).
We may also request (applicable only to Stendhal patients):

Sensitive information: Age, sex, weight, height, conditions that are treatable with any of Stendhal’s pharmaceutical products, other prior or current conditions that could coexist with the condition that is the reason for entry into the program and details of any symptoms or conditions that may manifest during the period of use of Stendhal’s pharmaceutical products.
All requested data must be provided voluntarily. If you do not wish to provide it, Stendhal shall not be able to use said data for the purposes described herein.

3. Main Purposes:
Stendhal may collect and process your personal data for any of the following main purposes:

Carry out visits and promote products from Stendhal’s portfolio;
Ask your opinion on medicinal products and medical conditions;
Carry out feasibility analyses;
Invite you to participate in treatment adherence programs;
Deliver scientific, promotional, and educational material and medical samples of Stendhal products.
Request information about the impact and results that our products have had on your patients;
Send key clinical messages about Stendhal's product portfolio;
Feed and update our database of expert physicians;
Identify you as a potential candidate to participate in events, courses, and congresses with healthcare specialists;
Control attendance at events;
Contact you and send you relevant information about our products;
Conduct satisfaction surveys;
Issue certificates of participation in educational events, conferences, colloquia, symposia, conventions, seminars, and presentations, as applicable;
Extend invitations to events organized by Stendhal;
Confirm the identity of the person Stendhal intends to contact;
Establish communication with you to provide follow-up of product advocacy you may conduct on behalf of Stendhal;
Stendhal may contact you by telephone and/or send you emails and/or use other physical and/or digital means of communication including, but not limited to, instant messaging applications and home visits. The foregoing may occur for any situation related to the activities conducted by Stendhal.
Send announcements, promotions, and advertising materials of our services and/or products (including new services and/or products) by any digital means;
Extend invitations to events;
Carry out surveys, research, analyses, statistical reports, and evaluations in relation to activities carried out by Stendhal, its affiliates, and/or suppliers;
Report adverse events per the pharmacovigilance programs for our products.
Secondary Purposes:

Provide information, services, products, or events, which include sending promotional material and newsletters from any media belonging to Stendhal, as well as related sponsors and advertisers;
Carry out surveys to evaluate the quality of services and conduct internal analysis thereof;
Conduct studies for statistical or internal control purposes;
Receive and reply to comments and suggestions;
Receive and reply to complaints, questions, requests, and claims related to Stendhal;
Provide information related to any activity conducted by Stendhal for special events;
Record phone calls exclusively for purposes of quality, service, and functionality assurance;
Follow up on any relationship that may have been generated between you and Stendhal;
Promote products offered by Stendhal.

4. Audio Processing
You hereby give your express consent for Stendhal to record communications for quality improvement purposes. In the case of phone calls, you shall be duly informed about such intention to record during the call and before recording begins; you shall have the option to ratify your consent or revoke at that time. Such recording and processing shall not entitle you to claim any financial compensation for its use as long as we comply with the security measures required the Law; likewise, these recordings shall never be used for profit. If you do not express your duly justified opposition, it will be understood that you have given your consent for the purposes set forth herein.

5. Measures to Limit the Use or Disclosure of Your Data:
We hereby inform you that your personal data shall be kept secure under administrative, physical, and technical security measures, which have been implemented in accordance with the Law, with the objective of protecting your data against any damage, loss, alteration, destruction, or unauthorized use, access, and processing, as well as limiting any risk that may arise, to the extent possible.

6. Sensitive Personal Data Processed by Stendhal:
In addition to the aforementioned personal data, for the purposes set forth in this Privacy Notice and per the provisions of the Law, Stendhal may also use Sensitive Personal Health Data when it is justified and required by the circumstances.

In view of the foregoing, by accepting this Privacy Notice, you give consent for the aforementioned Sensitive Personal Data to be processed per the provisions hereof.

7. Exercise of ARCO Rights:
As the Holder of your personal data, you may access your information free of charge at any time. You may also exercise your rights to Access, Rectify, Cancel or Oppose use your data, and/or revoke the consent that you may have granted us for the use and processing of your data. To exercise any of these rights, you must submit a request by contacting the Legal Department at datos.personales@stendhalpharma.com or at the address: Camino a Santa Teresa No. 1040, Mezzanine 1, Col. Jardines en la Montaña, Alcaldía Tlalpan, C.P. 14210, Ciudad de México, México to the attention of the Legal Department; or call +52 (55) 2000 6630 (charged to your telephone bill).

The Request to exercise your rights as a data holder must state, at minimum, the following information: (i) your full name and email or mailing address to provide a response to your Request; (ii) documents that prove your identity (i.e., Personal Identification Document, National Identity Card (DNI) or immigration card) or, as applicable, the legal representation exercised by the person processing the Request on your behalf (i.e., power of attorney signed before 2 (two) witnesses, as well as a notarized or certified copy of the official identification documents of the grantor of the power of attorney and the legal representative, and a copy of the Personal Identification Document of the grantor of the power of attorney and the legal representative); (iii) a clear description of the personal data over which any of the aforementioned rights are to be exercised; and (iv) any other information or document that may contribute to locating the personal data in question. In the case of requests to Rectify personal data, you must state the modifications to be made and provide documentation that justifies your request.

Stendhal has a period of 20 (twenty) business days from the date on which your Request was received to inform you by email or at the address provided in your Request of the decision taken and, if applicable, Stendhal shall have an additional period of 15 (fifteen) business days from the date of notification to act upon said decision. The aforementioned period may be extended once for an equal amount of time, provided that it is justified by the circumstances of the case.

In Costa Rica, Stendhal has a period of 5 (five) business days from the date on which your request was received to inform you by email or at the address provided in your request of the decision taken and act upon said decision, if applicable. The aforementioned period may be extended once for an equal amount of time, provided that it is justified by the circumstances of the case.

In Peru, Stendhal has a period of 20 (twenty) calendar days to respond to requests regarding the right of access and 10 (ten) business days to respond to requests regarding the rights of rectification, cancellation, and opposition. If Stendhal informs you that you have failed to meet the minimum requirements for submitting your request, you must rectify this situation within 5 (five) business days of receiving such notice; otherwise, your request shall be deemed not submitted and voided. If Stendhal informs you that your request requires additional information in order to be processed, you must provide said information within 10 (ten) business of receiving such notification; otherwise, your request shall be deemed not submitted and voided. The aforementioned period may be extended once for an equal amount of time, provided that it is justified by the circumstances of the case.

In the Dominican Republic, Stendhal has a period of 10 (ten) business days from the date on which your request was received to inform you by email or at the address provided in your request of the decision taken; in the event that the information in question comes from a public entity or institution, Stendhal shall have an additional period of 5 (five) business days for a total of 15 (fifteen) business days from the date of notification to act upon said decision. The rights of the Rightsholder may be denied based on matters of national security, public order and safety, or the protection of the rights and interests of third parties, per the provisions of the Law.

In Ecuador, Stendhal has a period of 15 (fifteen) calendar days from the date on which your request was received to inform you by email or at the address provided in your request of the decision taken.

8. Transfer of Data:
Personal Data collected by Stendhal shall be used for the purposes for which it was provided, as set forth above, and shall only be transferred to Stendhal’s affiliates or subsidiaries and each of the departments within them, as well as to third parties hired by Stendhal to process and analyze said information. The recipient of your information shall be appointed by Stendhal and required to treat your personal data with the same levels of security used by us and as required by the Law.

9. Security:
We only collect information that we consider reasonably necessary to serve the legitimate interests of our business and to fulfill our legal obligations. We protect Rightsholders and their disclosed information using industry protection standards as required by the Law. Regardless of whether there is "guaranteed online or offline security,” we shall make every commercially reasonable effort to ensure that the collection of information carried out by us complies with all applicable Laws.

Currently, each means of collection of information, including digital applications, uses a variety of security measures intended to protect the information and prevent unauthorized use by users within and outside the company, including administrative, technical, and physical security measures per the provisions of the Law. This protects confidential information, such as confidential numbers, online applications, and financial information, against loss, damage, misuse, interception, or sabotage.

Our practices regarding communication systems, software, and physical and digital databases are designed to assist us in maintaining the authenticity, integrity, and confidentiality of said information. It is important to state that, regardless of us using all the means necessary to ensure the security of the information when it is transmitted through third parties (service providers), we cannot by any means guarantee the security of the information during such transmissions.

10. What we will not do with the information
Sell, lease, or otherwise commercialize the information to third parties outside the companies controlled by and/or related to Stendhal (with the exception of agreements entered into while the companies in question were related to Stendhal and later came out of Stendhal’s control), or allow our affiliates to sell or lease the information to third parties previously or currently not controlled by Stendhal;

Function as an evaluation agency for services and activities involving the Rightsholder, nor provide any type of information related to the financial situation, purchasing power, personality, character, reputation, personal characteristics, or lifestyle of the Rightsholder to any such evaluation agencies;

Disclose, reproduce, send, share, or show the data or reports derived therefrom to third parties not associated to Stendhal, especially through any means of mass communication such as print, television, radio, or any other form of broadcasting or publishing, digital or otherwise.

11. Changes to this Privacy Notice:
This Privacy Notice may be amended in the future. In any case, any and all modifications shall be made known to you by publishing the new Privacy Notice on the following website: http://www.stendhalpharma.com/Paginas/AvisoPrivacidadSimplificado.aspx; you may also request it at datos.personales@stendhalpharma.com

12. Contact Information:
For any matter related to this Privacy Notice and regarding your personal data, you may contact us at datos.personales@stendhalpharma.com or at the address: Camino a Santa Teresa No. 1040, Mezzanine 1, Col. Jardines en la Montaña, Alcaldía Tlalpan, C.P. 14210, Ciudad de México, México, for the attention of the Legal Department; or call +52 (55) 2000 6630

Last updated: May 2024