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Effective Date: July 21, 2021
This Policy of Treatment of Personal Data of Arkangel AI (hereinafter the "Policy"), establishes the mechanisms, guarantees and instruments held by the holders of the information (hereinafter the "Data Subject" and / or "Data Subjects") that we collect and treat as Responsible and / or Responsible for the Processing of Personal Data in accordance with the provisions of Law 1581 of 2012, Decree 1377 of 2013 and other applicable rules on the protection of personal data. Due to the commercial activity that develops Arkangel AI, collects, and in some cases, communicates to third parties, information about employees, suppliers and customers. In that order of ideas, the following Policy is intended to provide them with a clear picture regarding the personal data Arkangel AI collects, the treatment given to them and the procedures that the Holders have at their disposal to enforce the rights derived from those. Therefore, the Holders must read in advance and in detail the information contained in this Policy. This Arkangel AI Privacy Notice describes how we collect and treat your personal information related to all Arkangel AI and Hippocrates AutoML algorithms (together, the "Cloud Services" or "Services"). We offer the Cloud Services directly or through our authorized partners. When we refer to our customers in this notice, we also refer to our partners and their customers. In case of disagreement with this Policy, Data Subjects should refrain from providing their personal data to Arkangel AI.
By creating a user through the Platform and/or accessing or using the Platform, you are agreeing to the Personal Data Processing Policy of ARKANGEL AI S.A.S. (hereinafter "Arkangel AI" or the "Company") and all the Terms and Conditions contained therein. This Authorization describes how we collect and process your personal information related to all Arkangel AI and Hippocrates AutoML algorithms (together, the "Cloud Services" or "Services"). We offer the Cloud Services directly or through our authorized partners. When we refer to our customers in this notice, we also refer to our partners and their customers. It is also understood that you accept all other operating rules, policies and procedures that may be published by Arkangel AI on the website www.arkangelai.com. The owner of the information, authorizes Arkangel AI freely, prior, express and duly informed to treat their personal data or personal data of those who are authorized, to offer all Arkangel AI Services to the User. In your capacity as owner of the Information you expressly, freely and informed that you are aware of the following considerations when using the Platform provided by Arkangel AI: (i) That Arkangel AI disclaims liability for breach of its obligations related to the handling of personal data, (ii) that you authorize Arkangel AI to treat your personal data in relation to this policy and the terms and conditions of the Company, (iii) that Arkangel AI may obtain authorization through different means, such as data message, internet, websites and / or any other means that allows obtaining the consent of the Holder, and (iv) that Arkangel AI may treat sensitive data of each Holder only when there is prior, express and informed consent of the Holder of such data. Arkangel AI clarifies to Clients (as defined below this term) or whoever registers to make use of this Platform, that the Diagnostic Images and/or Clinical Data (as defined below these terms) belonging to third parties, may be considered Personal Data and/or Sensitive Data if they are associated with any data that personally identifies a Patient, individual or group of individuals. By way of example, this data includes: name, national identification number, passport, address, telephone, e-mail, image of the owner, among others. It is the responsibility of the User who uploads such data of third parties and/or of the Client that covers such User, to have the prior, express, informed and written authorization of the owner. Such authorization shall make it clear to the owner of the data that they will be transmitted to Arkangel AI and will be treated in accordance with this data protection policy. The purposes of the Personal Data processed by Arkangel AI, as appropriate are: 1. Employee Data. Arkangel AI will process the data collected in these Databases to: Create specific files for each employee with their Personal Data in order to use them whenever required. To comply with the obligations undertaken by Arkangel AI in favor of the employee in the development of their employment contract. To advance the affiliations of employees and beneficiaries that it designates, aimed at fulfilling the obligations under the labor law generated as a result of the linking of the employee with Arkangel AI. Assignment of users and corporate email accounts or any other software for internal use, which brings with it the generation and sending of correspondence in development of the contract signed between the employee and Arkangel AI. Compliance in payment of payroll and parafiscal obligations caused in favor of the employee by virtue of their employment relationship. Management of accounting and labor information for compliance with contractual and legal requirements. 2. Suppliers. The data compiled in this Database will be used for the following purposes: Collect general and contact information of all Suppliers who have provided, provide and may come to provide services in favor of Arkangel AI. Monitoring the execution of agreements, contracts, or purchase orders generated under the business relationship between Arkangel AI and the Supplier. Accounting records and internal monitoring of payments to suppliers. Request for quotations, proposals and generation of purchase orders. Compliance with administrative, contractual, accounting and / or tax obligations. Manage and use the information to perform control and prevention of fraud, control and prevention of money laundering and terrorist financing. 3. Clients. The data compiled in this Database will be used for the following purposes: Provide access to use the services offered by the Platform. Custody of the information collected in the servers contracted by the Company to store and manage Personal Data. Communicate and allow access to Personal Data provided to third party suppliers and business partners who perform analytical and general support services improvements and natural or legal persons shareholders of Arkangel AI. Manage and use the information to perform control and prevention of fraud, control and prevention of money laundering and terrorist financing. Perform in accordance with the law, reports to credit bureaus for breach of financial obligations arising from the business relationship. Register to access the Platform. Be subject to analysis to improve and evolve the Platform through rounds of feedback and usage data from Users and Customers. Identify percentages, segmentation and business intelligence, allowing to acquire knowledge for the technological evolution of Arkangel AI. Provide free and paid testing services, related to the analysis of Diagnostic Images and/or Clinical Data loaded on the Platform. To diagnose problems with our servers, software, to administer our site, to collect demographic information and to track visitors to our website. Marketing and communication of Arkangel AI. 4. Children and Adolescents. Arkangel AI may request data from minors for the following purposes: Analyze them through the Platform for the detection of various medical conditions. Store contact information (physical mailing address, email and telephone). To communicate with the child's representative, in case of requiring, updating, modifying and/or confirming data and information. To store and keep with high security standards, all Sensitive Personal Data, related to health, such as Diagnostic Images, clinical data, medical history and medical results. Be subject to confidentiality, reserve and non-disclosure, except in the cases established in the law 1581 of 2012, article 6. To deliver results of Diagnostic Imaging analysis to the Client who is in charge of the minor, where data related to Health is evidenced. The rights of children and adolescents prevail over any other. Arkangel AI will respect the best interests of the child and provide clear, detailed, comprehensive and sufficient information for them to grant a free and informed consent through their guardians or representatives. All those who according to this data protection policy have the quality of Holder may request Arkangel AI, at any time, not to be sent promotional or advertising information, or to be sent only certain information of interest. However, we clarify that Arkangel AI will not remove your Personal Data user when it comes to making a collection management for payment obligations of the service you have outstanding. 5. Patients. The data compiled in this Database will be used for the following purposes: Analyze them through the Platform for the detection of different medical conditions. Validate information and identification of the Holder. Store contact data (physical mail address, email and telephone). Communicate with the Data Subject in case of requiring, updating, modifying and/or confirming data and information. To store and keep with high security standards, all Sensitive Personal Data, related to health, such as Diagnostic Images, Clinical Data, medical history and medical results. To deliver the results of the analysis of Diagnostic Images to the Beneficiary who is in charge of the minor, where data related to Health are evidenced. It is clarified that the Client contracting the software is the Responsible for the Processing of Personal Data of Patients when personal data is provided in the same Arkangel AI platform; therefore, it is its obligation as Responsible to have the prior authorization, expressly informed and in writing of the Patients to treat their Personal Data through the Arkangel AI Platform. Arkangel AI will perform the custody of the Personal Data of the Patients in its capacity as Caregiver and will store them in its encrypted Databases while they are at rest and in transit between under the architecture Health Insurance Portability and Accountability Act (HIPAA), in which access to personal data and / or sensitive data of all Patients and Users, will be restricted for all staff, employees, contractors and agents of Arkangel AI. All persons who have this access for maintenance and support are subject to strict contractual obligations of confidentiality and may be sanctioned or terminated if they do not comply with them. Likewise, all databases comply with all protocols for cybersecurity and handling of Sensitive Personal Data established by the Colombian State and are in safe harbors. The Client with the acceptance of this Policy, declares that it has the prior, express written authorization by the Patient to perform the Processing of Personal Data. Arkangel AI is exempt from any liability in the event that the Client, does not comply with the above obligation.
Effective Date: July 21, 2021
By creating a user through the Platform and/or accessing or using the Platform, you are agreeing to the Personal Data Processing Policy of ARKANGEL AI S.A.S. (hereinafter "Arkangel AI" or the "Company") and all the Terms and Conditions contained therein. This Authorization describes how we collect and process your personal information related to all Arkangel AI and Hippocrates AutoML algorithms (together, the "Cloud Services" or "Services"). We offer the Cloud Services directly or through our authorized partners. When we refer to our customers in this notice, we also refer to our partners and their customers. It is also understood that you accept all other operating rules, policies and procedures that may be published by Arkangel AI on the website www.arkangelai.com. The owner of the information, authorizes Arkangel AI freely, prior, express and duly informed to treat their personal data or personal data of those who are authorized, to offer all Arkangel AI Services to the User. In your capacity as owner of the Information you expressly, freely and informed that you are aware of the following considerations when using the Platform provided by Arkangel AI: (i) That Arkangel AI disclaims liability for breach of its obligations related to the handling of personal data, (ii) that you authorize Arkangel AI to treat your personal data in relation to this policy and the terms and conditions of the Company, (iii) that Arkangel AI may obtain authorization through different means, such as data message, internet, websites and / or any other means that allows obtaining the consent of the Holder, and (iv) that Arkangel AI may treat sensitive data of each Holder only when there is prior, express and informed consent of the Holder of such data. Arkangel AI clarifies to Clients (as defined below this term) or whoever registers to make use of this Platform, that the Diagnostic Images and/or Clinical Data (as defined below these terms) belonging to third parties, may be considered Personal Data and/or Sensitive Data if they are associated with any data that personally identifies a Patient, individual or group of individuals. By way of example, this data includes: name, national identification number, passport, address, telephone, e-mail, image of the owner, among others. It is the responsibility of the User who uploads such data of third parties and/or of the Client that covers such User, to have the prior, express, informed and written authorization of the owner. Such authorization shall make it clear to the owner of the data that they will be transmitted to Arkangel AI and will be treated in accordance with this data protection policy. The purposes of the Personal Data processed by Arkangel AI, as appropriate are: 1. Employee Data. Arkangel AI will process the data collected in these Databases to: Create specific files for each employee with their Personal Data in order to use them whenever required. To comply with the obligations undertaken by Arkangel AI in favor of the employee in the development of their employment contract. To advance the affiliations of employees and beneficiaries that it designates, aimed at fulfilling the obligations under the labor law generated as a result of the linking of the employee with Arkangel AI. Assignment of users and corporate email accounts or any other software for internal use, which brings with it the generation and sending of correspondence in development of the contract signed between the employee and Arkangel AI. Compliance in payment of payroll and parafiscal obligations caused in favor of the employee by virtue of their employment relationship. Management of accounting and labor information for compliance with contractual and legal requirements. 2. Suppliers. The data compiled in this Database will be used for the following purposes: Collect general and contact information of all Suppliers who have provided, provide and may come to provide services in favor of Arkangel AI. Monitoring the execution of agreements, contracts, or purchase orders generated under the business relationship between Arkangel AI and the Supplier. Accounting records and internal monitoring of payments to suppliers. Request for quotations, proposals and generation of purchase orders. Compliance with administrative, contractual, accounting and / or tax obligations. Manage and use the information to perform control and prevention of fraud, control and prevention of money laundering and terrorist financing. 3. Clients. The data compiled in this Database will be used for the following purposes: Provide access to use the services offered by the Platform. Custody of the information collected in the servers contracted by the Company to store and manage Personal Data. Communicate and allow access to Personal Data provided to third party suppliers and business partners who perform analytical and general support services improvements and natural or legal persons shareholders of Arkangel AI. Manage and use the information to perform control and prevention of fraud, control and prevention of money laundering and terrorist financing. Perform in accordance with the law, reports to credit bureaus for breach of financial obligations arising from the business relationship. Register to access the Platform. Be subject to analysis to improve and evolve the Platform through rounds of feedback and usage data from Users and Customers. Identify percentages, segmentation and business intelligence, allowing to acquire knowledge for the technological evolution of Arkangel AI. Provide free and paid testing services, related to the analysis of Diagnostic Images and/or Clinical Data loaded on the Platform. To diagnose problems with our servers, software, to administer our site, to collect demographic information and to track visitors to our website. Marketing and communication of Arkangel AI. 4. Children and Adolescents. Arkangel AI may request data from minors for the following purposes: Analyze them through the Platform for the detection of various medical conditions. Store contact information (physical mailing address, email and telephone). To communicate with the child's representative, in case of requiring, updating, modifying and/or confirming data and information. To store and keep with high security standards, all Sensitive Personal Data, related to health, such as Diagnostic Images, clinical data, medical history and medical results. Be subject to confidentiality, reserve and non-disclosure, except in the cases established in the law 1581 of 2012, article 6. To deliver results of Diagnostic Imaging analysis to the Client who is in charge of the minor, where data related to Health is evidenced. The rights of children and adolescents prevail over any other. Arkangel AI will respect the best interests of the child and provide clear, detailed, comprehensive and sufficient information for them to grant a free and informed consent through their guardians or representatives. All those who according to this data protection policy have the quality of Holder may request Arkangel AI, at any time, not to be sent promotional or advertising information, or to be sent only certain information of interest. However, we clarify that Arkangel AI will not remove your Personal Data user when it comes to making a collection management for payment obligations of the service you have outstanding. 5. Patients. The data compiled in this Database will be used for the following purposes: Analyze them through the Platform for the detection of different medical conditions. Validate information and identification of the Holder. Store contact data (physical mail address, email and telephone). Communicate with the Data Subject in case of requiring, updating, modifying and/or confirming data and information. To store and keep with high security standards, all Sensitive Personal Data, related to health, such as Diagnostic Images, Clinical Data, medical history and medical results. To deliver the results of the analysis of Diagnostic Images to the Beneficiary who is in charge of the minor, where data related to Health are evidenced. It is clarified that the Client contracting the software is the Responsible for the Processing of Personal Data of Patients when personal data is provided in the same Arkangel AI platform; therefore, it is its obligation as Responsible to have the prior authorization, expressly informed and in writing of the Patients to treat their Personal Data through the Arkangel AI Platform. Arkangel AI will perform the custody of the Personal Data of the Patients in its capacity as Caregiver and will store them in its encrypted Databases while they are at rest and in transit between under the architecture Health Insurance Portability and Accountability Act (HIPAA), in which access to personal data and / or sensitive data of all Patients and Users, will be restricted for all staff, employees, contractors and agents of Arkangel AI. All persons who have this access for maintenance and support are subject to strict contractual obligations of confidentiality and may be sanctioned or terminated if they do not comply with them. Likewise, all databases comply with all protocols for cybersecurity and handling of Sensitive Personal Data established by the Colombian State and are in safe harbors. The Client with the acceptance of this Policy, declares that it has the prior, express written authorization by the Patient to perform the Processing of Personal Data. Arkangel AI is exempt from any liability in the event that the Client, does not comply with the above obligation.
Effective Date: July 21, 2021
Arkangel AI SAS, a company identified with Nit. 901.378.659-4 (hereinafter "Arkangel AI") company domiciled in the city of Bogota, located at the address Calle 61 #37-51, with telephone 3107791950, and email hola@arkangel.ai, hereby allows to establish the principles and parameters by which it will advance the processing of personal data collected in the development of its corporate purpose, in the qualities of both responsible and in charge of handling the information. This Personal Data Processing Policy describes how we collect and process your personal information related to all Arkangel AI and Hippocrates AutoML algorithms (together, the "Cloud Services" or "Services"). We offer the Cloud Services directly or through our authorized partners. When we refer to our customers in this notice, we also refer to our partners and their customers. All of the above is based on the statutory law 1581 of 2012, regulated by National Decree 1377 of 2013, and Decree 1074 of 2015, complementary circulars and their constitutional foundations regarding the protection of privacy, protection of personal data and the right to Habeas Data. 1. Definitions. In accordance with Law 1581 of 2012 and for the proper interpretation of this Policy should be understood as: Authorization and/or Authorizations: Prior, express and informed consent of the Data Subject to process his/her personal data that do not have the characteristic of public. Database and/or Databases: Organized set of data that are subject to processing by Arkangel AI. It can be digital or physical according to their form of storage. Client and/or Clients: Refers to the hospital or hospitals, medical laboratories, health professionals, and in general any natural or legal person public or private along with their delegates who access or use the Platform to make use of it. User and/or Users: Refers to the individual who operates the Platform directly. Such individual may or may not be linked to an account of a main Client, such as a hospital network. In the event that this individual does not belong to an account, he/she is considered a Client and a User simultaneously. Personal Data and/or Personal Data: It is any information linked or that may be associated to one or several natural persons, identifying them. Sensitive Personal Data and/or Sensitive Personal Data: Those that affect the privacy of the Holder or whose improper use may generate discrimination. Reason for which they enjoy special protection, in this case it refers to Personal Data related to health. Data Processor: Natural or legal, public or private person who by himself or in association with another person carries out the processing of Personal Data on behalf of the Data Controller. Diagnostic Image and/or Diagnostic Images: Set of studies, which through technology, obtain descriptive data of the human body, by way of example these include: blood samples, X-rays, fundus images, ultrasound, computed tomography, magnetic resonance imaging, among others. Clinical Data and/or Medical History: Multiform data set that through technology, obtain descriptive data of the human body, by way of example these are: laboratory results, symptoms, family history, medical notes, among others. Children and Adolescents: Refers to minors who, through their representative or guardian, authorize the processing of their Personal Data for the purposes described in this Policy. Patient and/or Patients: Natural person who receives services and/or medical care from a Client or a User. Platform: Refers to the technological structure designed by Arkangel AI built from artificial intelligence, composed of a multichannel software that includes a mobile application, a web application, Hippocrates AutoML and APIs. Supplier and/or Providers: Third parties and/or business allies that perform analytics and general support services improvements to Arkangel AI for the development of its business activity. Data Controller: Natural or legal person, public or private, which by itself or in association with others, decides on the Personal Data Base and its treatment. Data Controller: The natural person whose Personal Data is the object of processing. Processing of Personal Data: Any operation or set of operations carried out on Personal Data, such as collection, storage, use, deletion, etc. Habeas Data: Fundamental right of every person to know, update, rectify and/or cancel at any time the information of their property, handled by third parties. 2. What does our Policy cover? The treatment to be performed by Arkangel AI acting as Data Controller and / or Data Processor will be to collect, store, process, use, manage, circulate and transmit Personal Data, strictly following the guidelines established by law, with the following purposes, as appropriate: 2.1. Employees. Arkangel AI will treat the data collected in these databases for the following purposes: Create specific files for each employee with your Personal Data in order to use it whenever required. To comply with the obligations undertaken by Arkangel AI in favor of the employee in the development of their employment contract. To advance the affiliations of employees and beneficiaries that it designates, aimed at fulfilling the obligations determined by labor law generated as a result of the linking of the employee with Arkangel AI. Assignment of users and corporate email accounts, which brings with it the generation and sending of correspondence in development of the contract signed between the employee and Arkangel AI. Compliance in payment of payroll and parafiscal obligations caused in favor of the employee by virtue of their employment relationship. Management of accounting and labor information for compliance with contractual and legal requirements. 2.2. Suppliers. The data compiled in this Database will be used for the following purposes: Collect general and contact information of all Suppliers who have provided, provide and may come to provide services in favor of Arkangel AI. Monitoring the execution of agreements, contracts, or purchase orders generated under the business relationship between Arkangel AI and the Supplier. Accounting records and internal monitoring of payments to suppliers. Request for quotations, proposals and generation of purchase orders. Compliance with administrative, contractual, accounting and / or tax obligations. Manage and use the information to perform control and prevention of fraud, control and prevention of money laundering and terrorist financing. 2.3. Clients. The data compiled in this Database will be used for the following purposes: Provide access to use the services offered by the Platform. Custody of the information collected in the servers contracted by the Company to store and manage Personal Data. Communicate and allow access to Personal Data provided to third party suppliers and business partners who perform analytical and general support services improvements and natural or legal persons shareholders of Arkangel AI. Manage and use the information to perform control and prevention of fraud, control and prevention of money laundering and terrorist financing. Perform in accordance with the law, reports to credit bureaus for breach of financial obligations arising from the business relationship. Register to access the Platform. Be subject to analysis to improve and evolve the Platform through rounds of feedback and usage data from Users and Customers. Identify percentages, segmentation and business intelligence, allowing to acquire knowledge for the technological evolution of Arkangel AI. Provide free and paid testing services, related to the analysis of Diagnostic Images and/or Clinical Data loaded on the Platform. To diagnose problems with our servers, software, to administer our site, to collect demographic information and to track visitors to our website. Marketing and communication of Arkangel AI. 2.4. Children and Adolescents. In compliance with the provisions of Law 1581 of 2012 and Decree 1074 of 2015, all data of the minor will always be requested under the signed consent of the representative of the minor who will be previously informed by the Client about the treatment that will be given, the purposes, and in full knowledge that it is not in the obligation to deliver the same. Similarly be treated in accordance with the development of the Colombian Constitutional Court, that is, always respecting their fundamental rights and seeking the achievement of their welfare and the development of their best interests. Thus, Arkangel AI may request data from minors for the achievement of the following purposes: Analyze them through the Platform for the detection of various medical conditions. Store contact information (physical mailing address, email and telephone). To communicate with the child's representative, in case of requiring, updating, modifying and/or confirming data and information. To store and keep with high security standards, all Sensitive Personal Data, related to health, such as Image, Image of the child and the child's representative, in case the child's representative requires, updates, modifies and/or confirms data and information. To store and preserve with high security standards, all Sensitive Personal Data, related to health, such as Diagnostic Images, Clinical Data, medical history and medical results. Be subject to confidentiality, reserve and non-disclosure, except in the cases established in the law 1581 of 2012, article 6. To deliver Diagnostic Imaging analysis results to the Client who is in charge of the minor, where data related to Health is evidenced. The rights of children and adolescents prevail over any other. Arkangel AI will respect the best interests of the child and provide clear, detailed, comprehensive and sufficient information for them to give a free and informed consent through their guardians or representatives. 2.5. Patients. The data compiled in this Database will be used for the following purposes: Analyze them through the Platform for the detection of different medical conditions. Validate information and identification of the Holder. Store contact data (physical mail address, email and telephone). Communicate with the Data Subject in case of requiring, updating, modifying and/or confirming data and information. To store and keep with high security standards, all Sensitive Personal Data, related to health, such as Diagnostic Images, Clinical Data, medical history and medical results. Deliver results of the analysis of Diagnostic Imaging to the Holder who is in charge of the child, where data relating to health are evidenced. Arkangel AI clarifies to the Clients contracting the software or whoever registers to make use of this Platform, that the Diagnostic Images and/or Clinical Data belonging to third parties, may be considered Personal Data and/or Sensitive Data if they are associated with any data that personally identifies a Patient, individual or group of individuals. By way of example, this data may include your name, identity card, address, telephone, mail, image of the owner, among others. Therefore, it is your obligation as Responsible to have the prior, express written authorization informed and informed of the Patients to treat their Personal Data through the Platform Arkangel AI. Such authorization shall make it clear to the owner of the data that they will be transmitted to the Arkangel AI Platform and will be treated in accordance with this data protection policy and the Terms and Conditions of the company. The Customer with the acceptance of this Policy, declares that it has the prior, express written authorization by such Patient and / or third parties to perform the processing of their Personal Data. In the event that such data belong to a minor, they must have the same authorization signed by the adult and representative of the minor. Arkangel AI will perform the custody of the Personal Data of the Patients in its capacity as Responsible and store them in their encrypted databases while they are at rest and in transit between under the architecture Health Insurance Portability and Accountability Act (HIPAA), in which access to personal data and / or sensitive data of all Patients and Users, will be restricted for all staff, employees, contractors and agents of Arkangel AI. All persons who have this access for maintenance and support are subject to strict contractual obligations of confidentiality and may be sanctioned or terminated if they do not comply with them. Likewise, all Databases comply with all cybersecurity protocols and handling of Sensitive Personal Data established by the Colombian State and are in safe harbors. The Client declares that it has notified the owner of the data through its data protection policy and its Authorization for Processing expressly the following: (i) that the Images, Clinical Data and Personal Data of the Patient and/or third party will be processed through the Platform; (ii) that the Images, Clinical Data and Personal Data will be processed by Arkangel AI for the purposes provided in this data protection policy. Likewise, Arkangel AI reserves the right to require the Client to physically demonstrate the prior, express, informed and written authorization of the Patient authorizing the processing of his Personal Data. Arkangel AI disclaims any liability in the event that the Client does not comply with the above obligation. 2.6. Exceptions Arkangel AI does not share the Data of our Users or Customers with companies, organizations or persons outside Arkangel AI, except in the following cases: With your consent: We will share Service Data outside of Arkangel AI when we have your consent. For example, when you or one of our customers decides to purchase a service from a third party through Arkangel AI Marketplace or Hippocrates AutoML, or uses a third party application that requests access to your information, we will request permission to share the information with that third party. With your administrators and authorized resellers: When you use the Cloud Services, your administrator and resellers authorized to administer your or your organization's account will have access to certain Service Data. For example, they may be able to perform the following actions: View account or billing information, activities and statistics. Change your account password Suspend or terminate access to your account. Access your account information to comply with laws, regulations, legal processes or mandatory governmental requirements Restrict the ability to delete or edit your information or your privacy settings For External Processing: We provide non-sensitive, non-personally identifiable information from use of the Platform to our affiliates, partners and other trusted businesses or persons for processing by us in accordance with our instructions, confidentiality agreements and under this Privacy Notice and other appropriate security and confidentiality measures. For Legal Reasons: We may share Service Data outside of Arkangel AI if we have a good faith belief that access to such information and its use, preservation or disclosure is reasonably necessary to: Comply with applicable laws, regulations, legal process or a mandatory governmental requirement. We share information about the type and number of requests we receive from governments in our Transparency Report. Execute applicable agreements, including investigations of potential violations. Detect, prevent or otherwise address technical, fraud or security issues. Protect against harm to the rights, property or safety of Arkangel AI, as well as our customers, users or the public, as required or permitted by law. If Arkangel AI is involved in a reorganization, merger, acquisition or asset sale, we will continue to ensure the confidentiality of your personal information and will notify affected users before this information is transferred or becomes subject to a different privacy policy. 3. What personal data do we process? Arkangel AI processes the following types of data: 3.1. Employee Information. It is that information provided by Employees, by digital, electronic, telephone, verbal and / or any other means of contact established by Arkangel AI, in order to link labor Arkangel AI and fulfill all obligations under the employment contract. The information that Arkangel AI processes from the Employees is: Identification data, and contact: Name, date of birth, identification, physical and email address, telephone, cell phone, information of studies (academic certifications) and employment information (labor certifications, resume, education, experience, links with entities). Family information data: Name of spouse and children, name and identification of children, social security affiliations, age, date of birth and health status. Employment data and information: Employment contract, training received, psychological evaluation report, photographic record and performance evaluation. Social security data and information: EPS affiliation, pension fund, ARL, compensation fund, payment of allowances and benefits. 3.2. Information from Suppliers: It is the information received from service providers and other third parties who provide their information to Arkangel AI. In general, the Holders are not required to provide this information and it will be treated in accordance with the provisions of paragraph 2.2 of this Policy. The information that Arkangel AI processes from Suppliers is: Identification and contact data: name, nationality, physical and email address. Data relating to the provision of services: Any content of any email you send by virtue of the provision of their services, all information contained in their sales invoices, quotations, proposals and / or presentations. 3.3. Customer Information: It is that information provided by Customers, by means of: (i) filling out forms loaded and visible on the Platform, which allow the proper functioning of the same, and/or (ii) when the Holders provide their email address to subscribe to updates and correspondence by email, telephone, fax or e-mail. The information Arkangel AI processes from Customers is: Identification and contact data: name, type of ID and ID number, physical and email address, profession, country and/or any content of any email you send us. Data about the Customers' device: With respect to each of your visits made to the Arkangel AI Platform, technical information about the Holder's device is collected. This information is collected and analyzed on both a personal and aggregated basis. In addition the information may include the Uniform Resource Locator ("URL") of the website you just came from, the URL you go to next, the browser you use and your Internet Protocol ("IP") address, which is a number that is automatically assigned to your computer each time you browse the web, allowing web servers to locate and identify your computer. 3.4 Patient Information: It is that information of the Patients, considered Sensitive Personal Data, related to health, which is provided and incorporated by the Client in the Platform, in order to be subject to analysis. It is clarified that the Customer with the acceptance of this Policy, declares that it has the prior, express written authorization by the Patient to treat their data and entrust them to Arkangel AI for the purposes defined in paragraph 2.4 of this Policy. The information processed from the Patients is: Identification and contact data: name, type of identification and identification number, physical and email address, country; any content of any email you send us. Sensitive Personal Data related to health: Diagnostic Images, Clinical Data, medical history, medical results and analysis. Data related to analysis results: Creation and conformation of Diagnostic Imaging and/or Clinical Data analysis results or reports. 3.5 Information of Children and Adolescents: Are those data provided under the consent of the minor's representative who will be previously informed about the treatment that will be given to them, the purposes and in full knowledge that he/she is not under the obligation to deliver them. It is clarified that Children and Adolescents act as Patients. Therefore, it is the Client the Responsible for the Treatment of their Personal Data and who incorporates such information in the Platform. It is clarified that the Customer with the acceptance of this Policy, declares that it has the prior express written authorization by the representative of the child, to treat the Personal Data of the child and entrust them to Arkangel AI for the purposes defined in paragraph 2.5 of this Policy. The information processed from Children and Adolescents is: Identification and contact data, of the minor and his or her representative: name, type of identification and identification number, physical and email address, country; any content of any email you send us. Sensitive Personal Data related to health: Diagnostic Images, Clinical Data, medical history, medical results and analysis. Data related to medical analysis results: Creation and conformation of Diagnostic Imaging and/or Clinical Data analysis results or reports. 4. Will Arkangel AI share any personal information provided by users? Arkangel AI will NOT sell or rent your personal information in any form or to any third party without your express permission. Similarly, Arkangel AI will NOT use Medical Images or Clinical Data owned by the Client for the training of new algorithms of the company without your prior authorization. However, Arkangel AI may disclose all or part of the Client or User Data to third parties in the exceptions described in section 2.6 of this policy. 5. Transmission of Personal Data of Patients for treatment. Arkangel AI warns Clients and all Users who make use of this Platform, that the Diagnostic Images, Clinical Data, Statistical Data belonging to third parties or Patients, may be considered Personal Data and / or Sensitive Data, if they are associated with any data that personally identifies an individual or a group of individuals. By way of example, this data includes: name, national identification number, passport, address, telephone, e-mail, image of the owner, among others. The responsible for the Patient's Personal Data collected will be the Client. Therefore, it will be its obligation to have the express prior written authorization of the Patients to treat their Personal Data in order to comply with the provisions of Article 6 of Law 1581 of 2012. Arkangel AI, will carry out the custody and processing of Personal Data of Patients in its capacity as Agent in accordance with the definition included in Article 3 of the statutory law on Protection of Personal Data (Law 1581 of 2012) and other complementary rules. In its capacity as Agent, the Client confers to Arkangel AI, the following powers for the custody and processing of personal data of patients throughout the Platform: The study and / or analysis of Medical Images and / or Clinical Data, which otherwise are uploaded directly by the Client or Users designated by the Client, The generation of downloadable reports of the results of the analysis of the clinical data and/or medical images processed through the Platform, The generation of dashboards and dashboards of the usage of the Users assigned by the Client. For data provided through Hippocrates AutoML: The study and/or analysis of Client data banks through the Platform, for the construction of new algorithms, Preprocessing, mining and cleaning of Client's databases, and The continuous improvement of the service and updating of the Platform offered to the Client. Arkangel AI will perform the custody of the Personal Data in its capacity as Responsible and store them in their encrypted databases under the architecture Health Insurance Portability and Accountability Act (HIPAA), in which sensitive data may never be accessed by any collaborator or employee of Arkangel AI, these may only be accessed by the Data Protection Manager (DPO) for maintenance, support or updates of the User's database. All Arkangel AI databases contained in servers, comply with all protocols for cybersecurity and handling of Sensitive Personal Data established by Colombian law. In compliance with the requirements determined for this purpose by Law 1581 of 2012 and other provisions that regulate it, it is clarified that the Client, voluntarily transmitted to Arkangel AI Personal Data of Patients. The Client agrees to defend, indemnify and hold harmless Arkangel AI in respect of damages related to or resulting from the unauthorized use of any Information, or any breach of the Personal Data Processing Policy adopted by the User. 6. Transfers of your Personal Data to other countries. We have data centers around the world, primarily in the United States (us-east1) and Europe. We always provide all Arkangel AI Cloud Services, Hippocrates AutoML and data custody from safe harbors identified by the Superintendence of Industry and Commerce of Colombia. Data may be processed on servers located outside the country where our users and customers are located, as this process is usually performed by centralized or regionalized operations, such as billing, support and security. Regardless of where the Service Data is processed, we apply the same protections described in this Privacy Notice and comply with the regulations for such operation. If you would like to know the exact location of the server where your data is located, please request it in writing to soporte@arkangel.ai or your account manager. Arkangel AI states that such data, once the report is generated, is stored in the Google Cloud Platform (GCP) Cloud service whose service has the following certifications: CSA - Cloud Security Alliance Controls ISO 9001 - International Quality Standard ISO 27001 - Security Management Controls ISO 27017 - Cloud-Specific Controls ISO 27018 - Personal Data Protection SOC 2 - Security, availability and confidentiality report. Accordingly, Arkangel AI undertakes, during the term of its Services with the Client, to maintain the contracted GCP security service, which is governed by the standards listed in Section 7 of this Policy, or similar, being able to hire an equivalent one in terms of certifications and security offering. It is clarified to Users that with the use of the Services provided by Arkangel AI and by providing your Personal Data, you are accepting the transfer, storage and / or processing of Personal Data in the United States. 7. Security. We work hard to protect you and Arkangel AI from unauthorized access, modification, disclosure or destruction of information in our possession, including: We regularly review our information collection, storage and processing practices, including physical security measures, to protect against unauthorized access to our systems. We restrict access to personal information to Arkangel AI employees, contractors and agents who need it to process it for us. All persons who have such access are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to comply. 7.1. Security Levels of Data Subject Information. Technical summary of the GCP security service offered with Arkangel AI Cloud Services: Basic certifications: ISO 27001, ISO 27018, SOC, SOC 1, HIPAA, IRS 1075, CJIS. Monitoring system to check DDos security aspects, pen test. Specific solutions for access control and active directories. Possibility to configure disk snapshots. Market place with current market tools (firewall and UTM applications). Applications for data encryption at rest and in transit. Ability to request pen tests. Intrusion detection systems, changes in demand or requests, port scanning, malware distribution and the possibility of reporting any of these points within the "warehouse". Control and protection of the physical infrastructure. Data centers protected from flooding, extreme weather or seismic activity, with each area built independently and physically separated from the others. Redundant centers and in case of failure, automatic detour of all information to another center, with the assurance that traffic will be optimal and with optimized load balancing. Security operations centers responsible for monitoring, triage and execution of security programs. 24/7 support for on-site access and correction of security breaches. 7.2. Safety assurance. Arkangel AI clarifies to the client that is NOT responsible for the theft, destruction, loss or inadvertent disclosure of information or content, nor for security breaches when these are caused voluntarily or involuntarily by the Client and / or its delegated Users. By accepting this Policy, the Holders agree that they are solely responsible for maintaining the confidentiality of their password associated with their account and for restricting access to their password, computer and mobile device while connected to Arkangel AI services through the Platform. 8. Data Retention. Arkangel AI retains the Personal Data of the Data Subjects regardless of whether or not you use the Services, in order to maintain a history of information for the Data Subjects to review and / or request at any time. Also, we will retain your Personal Data as necessary to comply with a legal mandate, resolve disputes and enforce our agreements. In the event that for any reason Arkangel AI considers that it will not require the Personal Data provided by the Data Subjects and in order to comply with the provisions of this Policy and the Terms & Conditions, Arkangel AI will proceed to remove the Personal Data of the Users from the computer systems and Databases of the Company. 9. Revoke consent. Please note that because in the Platform may come to provide the following Personal Data, considered Sensitive Personal Data: Clinical, biological and genetic information. Information related to biological samples. History of clinical diseases. Laboratory results. Diagnostic imaging results. Clinical treatments. Physical and mental health status. Disability Risk of suffering diseases. Tests and/or Diagnostic Images. Any other health-related data requested by the Client and/or User to the Patient. All these Sensitive Personal Data whether or not related to health and without exception, will be treated only when there is explicit authorization by the Holder to perform such treatment, in order to comply with the provisions of Article 6 of Law 1581 of 2012. Such authorization must be requested by the Client and the Client must keep a copy of it at all times. Arkangel AI reserves the right to require the Client to physically demonstrate the prior, express and informed authorization of the Patient authorizing the processing of their Personal Data. Arkangel AI disclaims any liability in the event that the Client does not comply with the above obligation. In the event that the Client wishes to revoke the Authorization of Data Processing to Arkangel AI, it shall have the right to withdraw such consent to the processing of such information at any time by direct mail to dpo@arkangel.ai and Arkangel AI, will have 15 working days to respond. Please note that as long as there is argument and legal authorization to do so or if the withdrawal of consent was limited to certain processing activities Arkangel AI may continue to process the information. 10. Requests and complaints. In any case, Arkangel AI acting as Responsible, Responsible or as Holder of the information will receive requests, complaints and claims in exercise of the rights of the Holders of the information in the email: support@arkangel.ai This mail will be controlled and managed by the administrative area of Arkangel AI, who knows his legal obligations in order to meet the requirements that are raised by this channel. Any change in this channel will be informed in due form to the Holders of the information. The Holder of the information may request electronically, during working hours (GMT-5), Monday through Friday, information and/or queries about their Personal Data recorded in the Databases. The request must specify the following: (i) full and correct name of the Data Subject and/or his/her proxy, if applicable, (ii) identification of the Data Subject and his/her representative, in the event he/she acts through a proxy, (iii) data or authorization that you want to know, correct, modify, delete or revoke, with clear and detailed indication of the way in which the correction or modification is requested and (iv) e-mail where the Data Subject will receive an answer. However, if it considers, and for the sole purpose of establishing the full identity of the petitioner and Holder of the information, Arkangel AI may require to be identified, before proceeding to answer. The response to these consultations, will be sent by Arkangel AI in a maximum period of 10 working days from the date of receipt thereof. When it is not possible to answer the query within that period, you will be informed, stating the reasons for the delay and indicating the date on which your query will be addressed, which in no case may exceed 5 working days following the expiration of the first term. The response to the claims in which you request the deletion of your Personal Data, will be given within a maximum term of 15 business days from the day following the date of receipt. When it is not possible to address the claim within such term, you will be informed of the reasons for the delay and the date on which your claim will be addressed, which in no case may exceed 8 business days following the expiration of the first term. 11. Changes in the Policy. In case of changes in the Policy, Arkangel AI is obliged to publish and update it on the Platform, without being obliged to inform the Holders in a personalized way such modification. Therefore, the Holders may consult them at any time on the Platform for any situation, the link is https://www.arkangel.ai/es/pages/legal. 12. Prohibitions. In development of this Policy, and its proper implementation, the following prohibitions are established: Access, use, management, transfer, communication, storage and any other Processing of Personal Data without prior, express and informed authorization of the Patient authorizing the processing of their Personal Data by the Customer through the Platform. Access, use, management, transfer, communication, storage and any other processing of Personal Data of Children and Adolescents without prior, express and informed authorization of the legal representative of the minor authorizing the processing of their Personal Data by the Client through the Platform. Any treatment that comes to be done with respect to this type of data must be done ensuring the prevailing rights that the constitution recognizes these, and for the purposes specifically informed prior to the delivery of the same. The transfer, custody, or international storage of Personal Data to countries that do not provide adequate levels of data protection in accordance with the provisions of Law 1581 of 2012 and the standards set by the Superintendence of Industry and Commerce, applying the exceptions that have been established for these cases according to current regulations. 13. Rights of the Data Subject The Owners of the information contained in the databases and / or patients who treat Arkangel AI, have the rights listed below in accordance with the provisions of the Political Constitution of Colombia and the applicable and current regulations. The exercise of these rights may only be advanced exclusively by the Owner of the Personal Data or by persons authorized by him in accordance with the provisions of the law. To know, update and rectify their Personal Data. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or data whose processing is expressly prohibited or has not been authorized. Request proof of the Authorization granted to Arkangel AI by the Client except when expressly exempted as a requirement for treatment. Be informed by Arkangel AI, upon request, regarding the use that has been given to your Personal Data. File complaints with the Superintendency of Industry and Commerce for violations of the provisions of this policy and the laws governing the matter. To revoke 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 deletion will proceed when the Superintendence of Industry and Commerce has determined that in the processing the Controller or Processor has incurred in conduct contrary to this law and the Constitution. Access free of charge to your Personal Data that have been subject to Processing. Request the export of a file of Personal Data collected by Arkangel, including any other data you have provided. In case the user has an account on the Platform. Request the deletion of any Personal Data, not including data that Arkangel AI is required to retain for administrative, legal or security purposes. 14. Duties of the Client as Processor of Patient Data The Customer as Data Processor for the Patient, shall comply with the following duties, without prejudice of course to the other provisions of the law. Guarantee the Data Subject, at all times, the full and effective exercise of the right of Habeas Data. Request, and keep in the necessary cases, a copy of the respective Authorization granted by the Data Subject. Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access. Timely update, rectify or delete the data in accordance with the terms of the law. Update the information reported by the data controllers according to the terms agreed in the contracts with them. To process queries and claims made by the Data Controllers under the terms set forth in this policy and the law governing the matter. Socialize with the areas in charge of the Company the procedures and policies to ensure proper compliance with the law governing the matter. Refrain from circulating information that is being disputed by the Holder and whose blocking has been ordered by the Superintendence of Industry and Commerce. Allow access to the information only to persons who may have access to it. Inform the Superintendence of Industry and Commerce when there are violations to the security standards of the information and therefore there are risks in the administration of the information of the Holders. Comply with the instructions and requirements given by the Superintendence of Industry and Commerce. 15. Duties of Arkangel AI as Data Controller and Responsible for the Processing of Customer Data Arkangel AI in its capacity as Entrusted and Responsible for the Processing of Personal Data granted by the Client, will advance the management in compliance with the following duties, without prejudice to the other provisions of the law. 15. Duties of Arkangel AI as Processor and Responsible for the Processing of Customer Data Arkangel AI in its capacity as Entrusted and Responsible for the Processing of Personal Data granted by the Client, will advance the management in compliance with the following duties, without prejudice to the other provisions of the law. Guarantee the Client the information at any time and free of charge, the full and effective exercise of the rights to know, update, modify and rectify their data. Request, and keep in the necessary cases, a copy of the respective Authorization granted by the Client for the treatment of their data and of their Patients. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access. Timely update, rectification or deletion of data in accordance with the terms of the law. Rectify the information when it is incorrect and if there is a person in charge of handling it, confirm it. To process the consultations and claims formulated by the Client in the terms indicated in this policy and the law that governs the matter. Socialize with the areas in charge of the Company the procedures and policies to ensure proper compliance with the law governing the matter. Refrain from circulating information that is being disputed by the Client and whose blocking has been ordered by the Superintendence of Industry and Commerce. Inform at the Client's request about the use given to its data. Allow access to information only to persons who may have access to it. Inform the Superintendence of Industry and Commerce when there are violations to the security standards of the information and therefore there are risks in the administration of the information of the Holders. Comply with the instructions and requirements given by the Superintendence of Industry and Commerce. 16. Validity. This Policy in charge of Arkangel AI, who acts as Responsible and Responsible for the processing of information from third parties in parallel has been approved and therefore shall apply from January 15, 2021, with an indefinite term until a substantial reform to it is advanced, which will be duly informed through the channels provided. Version control: Version 2.5 , effective date: 07/21/2021, "Hippocrates AutoML Release" [Current]. Version 2.0, effective date: 25/01/2021, "Integral reform of the Data Protection Policy" [Current] [Version 2.0, effective date: 25/01/2021, "Integral reform of the Data Protection Policy" [Current Version 1.0, effective date: 01/07/2020, "Initial Version". Contact For further information, you may contact us by e-mail: hola@arkangel.ai Thank you for reading us, see you next time!
