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Privacy Policies

 

Last update: 04/10/2022

 
I. Objective

This privacy policy (the "Policy") regulates the handling of your personal data as regards to the website http://TuteurGroup.com (with its subdomains, the "Platform"), property of Tuteur S.A.C.I.F.I.A. ("Tuteur").

Through this Platform, we offer some assistance programs ("Assistance Programs" to people undergoing treatment with medications from Tuteur ("Patients" or "Users").

The aims of Assistance Programs are (1) to provide Patients with information, orientation and guidance on access to medication in general; (2) to accompany Patients during the medical treatment prescribed by a health professional; (3) to promote active involvement of Patients and their closed ones in healthcare; and (4) to guide Patients on the necessary steps in order to get access to medication (the "Assistance Program Objectives").

In order to achieve Assistance Program Objectives, we familiarize with the Patients and go through all the process with them to obtain the medication prescribed by health professionals. This allows for minimizing formalities and enhancing administrative management linked to access to medication.

Assistance Programs are free and Users can get access to them by telephone, e-mail or the Platform.

To access Assistance Programs, the Platform will ask Users to agree on Tuteur, on behalf of Assistance Programs, contacting them by telephone, e-mail or other means of the sort provided by the Users.

To achieve Assistance Program Objectives, Tuteur's representatives will also ask Users for personal data instructed in Item II, to which only Tuteur will have access. Said personal data will be stored in a database permanently protected, and it will be safeguarded pursuant to Personal Information Protection Law N° 25.326. Users may at any time revoke permission given to Tuteur.

In order to offer the services of the Platform, we must collect, store, handle and process certain personal data, hence it is essential you read, understand and accept this Policy before using and/or signing up on the Platform.

Only people of age (+18) are allowed to sign up and use the Platform. If you are underage, please do not use the Platform nor try to sign up.



II. Data collection

The User who wishes to use the Platform must perform an initial registration, where they will be asked to give their (a) name and last name; (b) ID number; (c) e-mail; and (d) contact telephone number. Once the initial registration is completed, Tuteur will contact the Patient and, depending on the particular needs each User manifests, will eventually require the following information: (1) sex, (2) date of birth, (3) age, (4) address, (5) medical insurance, (6) attending physician, (7) medication you are using, (8) product trade name, (9) active ingredient name, (10) lot number, (11) date of expiry, and (12) other medication related information. In addition, personal information linked to adverse events or other pharmacovigilance activities may be collected, pursuant to the purpose set forth in Item IV (2) (altogether, "Data"). Users must accept this Policy in order to use the Platform and the Assistance Programs. It is important that you understand and accept your duty to provide truthful, correct and updated Data. Lack of compliance will result in the deletion of your registration by Tuteur. Acceptance of this Policy implies your consent for us to collect and handle your Data for the abovementioned purposes. If you do not agree on how we handle your Data and on the abovementioned purposes, please do not perform the registration nor use the Platform. It is important that you are aware that refusal to provide your Data will result in you not being able to use our services nor the Platform.


III. Governing Principles for Data Handling

Data will be handled following these governing principles: Quality: in pursuant to this principle, we guarantee that Data collected will be appropriate, relevant and not excessive as to the setting and purpose for which they are collected, that collection will not be performed through disloyal, fraudulent means or means contrary to law provisions, that Data will be exact and updatable, that Data will be stored in a way that you may access it and that it will be destroyed once it is no longer necessary or relevant for the purpose it was collected. Purpose: in pursuant to this principle, we guarantee that Data collected from you will not be used with purposes other than the ones which drive the collection, mentioned in Item IV of this Policy. Information: in pursuant to this principle, we guarantee to provide you, via this Policy, with the entire information on the Data that will be collected, the purpose for such collection, the existence of a Data Bank where your Data will be stored, the results of conferring your Data, or the refusal to do so, and the cases in which you can exercise your right to access, rectification and deletion. Consent: the general principle states that the handling of your Data requires your written consent, unless the regulation presents an exception. Consent must be voluntary, explicit and informed, and must be performed in writing or other equivalent means, for which you must read and agree to this Policy in order to sign up as a User. Consent can be revoked at any time, with no retroactive effect. Assignment: we inform that the assignment of your data may only be performed in conformity with what is set forth in this Policy, respecting the purposes directly related to the legitimate interest of the assigner and assignee. Confidentiality: all people involved in the handling of your Data are compelled to professional secrecy. Your Data may only be disclosed to a third party in accordance with that is set forth herein. Security: Tuteur will take the necessary measures to ensure security and confidentiality of your Data, in order to avoid falsification, loss, unauthorized enquiry or handling, and which allow for the detection of deviations, inadvertent or not, of information, whether risks rise from human activity or instruments used. Documentation of personal data on files, records or data banks that do not meet the technical conditions of integrity and security is strictly forbidden.


IV. Purpose of your Data

Your Data will be used in order to (1) satisfy the Program Assistance Objectives and render services offered via the Platform; and (2) perform monitoring and follow up of adverse effects and pharmacovigilance. In this matter, a specific section in the Platform may require you to provide personal information linked to adverse events or other pharmacovigilance activities. This information is highly important from a health perspective, and it will be used to detect, assess, understand and avoid adverse events and other medication-related matters. We collect and process your information with such purposes in order to meet out legal obligations, and Health Authorities may require us to convey such information.


V. Storage

Tuteur will be the sole proprietor of the abovementioned data base, and will store it in its servers in Olleros 2770, Ciudad Autónoma de Buenos Aires. Data will be stored in digital files in the Platform permanently, and will be deleted only if the User or a next of kin, as representative, demands it in writing. Tuteur will protect the database according to standards of the current legislation and the industry practices that reasonably furnish the personal data with integrity and security. The database with your Data is due registered in the Access to Public Information Agency (Agencia de Acceso a la Información Pública), control authority under Law 25.326.


VI. Data Assignment and International Transfer

Tuteur guarantees to keep your Data confidential, avoiding access to third parties. However, in response to lack of compliance with the purpose of the Platform, Tuteur may hire a third party to render certain services. Therefore, it is important you understand that, by agreeing to this Policy, you explicitly and voluntarily give consent for Data to be transferred to a third party rendering computerized services of personal data as set forth in Article 25 of Law 25.326 (e. g., Platform maintenance and management). In addition, you must understand that, by virtue of the authority conferred, certain governmental bodies (including the Superintendency of Health Services or the National Administration of Drugs, Foods and Medical Devices [ANMAT]) may audit the Platform in accordance with applicable regulations, and, to that effect, said bodies may have access to your Data.


VII. Rights to Data Access, Cancelation and Rectification

We inform you that Data holder may execute the right to Data access for free in time periods not shorter than 6 months, unless legitime interest to that purpose is proven conforming to Law 25.326, Article 14, Paragraph 3. Now, therefore you may send an e-mail to sistemas@tuteurgroup.com requesting access to your Data and, in your case, ask for updating, modification or deleting. The Access to Public Information Agency, control authority under Law 25.326, is in charge of receiving claims and complaints about lack of compliance to personal data protection regulations. When exercising your right to access, you must show proof of identity. Once the identity is verified, Tuteur will provide an answer through the means chosen within ten (10) consecutive days, as it may be appropriate depending on what was requested by the Data holder. In addition, we inform that all people have the right to their Data, in the database, being rectified, updated and, if applicable, deleted or rendered confidential. In this regard, should it be appropriate and once your identity is validated, we shall perform updating, rectification and/or deleting operations within five (5) working days.


VIII. Cookies

By signing up, you state that you know and agree on Tuteur using a tracking system through Cookies. Cookies are small files stored in the hard disk, with a limited duration, which help customize services. We also offer certain features available only through the use of Cookies. Cookies are used to get to know the interests, behavior and demographics of visitors to the Platform, and, in so doing, to better understand their needs and interests and offering an enhanced service or providing them with related information. We also use Cookies to count and verify your number of registrations, your activity as visitor and other aspects for commercial agreements. The installation of Cookies is always for the benefit of the visitor, they will not be used with purposes other than the abovementioned. Installation, permanence and existence of Cookies in the User's device depend on the User's exclusive will and therefore may be deleted from device when the User wishes it. If you wish to know how to remove Cookies from the system, check the Help section on your browser. It is explicitly stated that such policies cover the use of Cookies by Tuteur, not by advertisers. We do not control the use of Cookies by third parties.


IX. Updates

Tuteur may alter and/or update this Policy, which shall be duly notified to Users and posted on http://tuteurgroup.com/.