Clínica Santa Clarita S.C. (hereinafter referred as “Clínica Santa Clarita”), with address at Calle 10 #8452 Zona Centro, Tijuana, Baja California, México, C.P. 22000, it is responsible for the treatment of your personal data, the use that is given and its protection.

You can send an email to ARCO (Access, Certification, Cancellation and Opposition), to the person responsible for the care and handling of your personal data to the following e-mail address info@novastem.mx or by telephone: +52 664-231-7220, with the responsible ARCO.

Your personal data will be used for the following purposes:

• Carry out the development and analysis of research studies
• Respond any complaint, question or concern
• Send notifications, reminders and follow-ups to participants of the studies that are allowed by the law.
• Create a database (including a database regarding sensitive data) for purposes of medical care, statistics, improved care and/or quality procedures.
• In general to attend the requirements of the authorities and to comply with the applicable law; and, Billing, and collection services.

For the purposes indicated in the present privacy policy, we can collect your personal data in different ways: when you provide them to us directly; when you visit our website or use our online services, social networks and when we collect information through other sources that are allowed by the law.

We collect your personal data directly when you provide them to us by various means, when you register on our website, by telephone or e-mail and when we collect information through other sources that are allowed by the law. The data that we collect may be, among others:

• Name and/or business name
• Address
• Telephone
• Business Information and/or profesional
• E-mail

We inform you that to comply with the purposes provided in this privacy policy, there will be personal data collected and treated as sensitive, as those that refer to: sexual preference, physical condition, state of health, disability and medical documents, banking information, among others. We commit that it will be treated under the strictest security measures that will ensure its confidentiality. This process it’s required so that Clínica Santa Clarita can generate the service that you are requesting, so we ask you to indicate your acceptance in the treatment of such data. Clínica Santa Clarita has policies and procedures to maintain the security and protection of personal data, especially the Sensitive Personal Data. Therefore, the Personal Data including the Sensitive Personal Data provided voluntarily, whether you provide them to us directly, when you use our online services or by any other means, and those generated as a result of the research are treated and kept confidential through technological means and protection procedures. However, it is clear that no communication of data over the Internet is totally secure, for which reason Clínica Santa Clarita cannot guarantee that your personal data will be free of any damage, loss, alteration, destruction, or the use, access or unauthorized treatment.

The holders have the possibility to limit the use or disclosure of your personal data by sending a request to the next e-mail address: info@novastem.mx in Spanish or English. If you have any questions or comments please contact us to the phone number +52 664-231-7220 with the responsible ARCO.

You have the right to access your personal data we possess and the details of its treatment, as well as to correct them if inaccurate or incomplete; cancel them when you consider that they are not required for any of the purposes outlined in this privacy policy, when they are being used for purposes which are not consensual or you have finished the contract or service relationship, or, to oppose the processing of such personal data for specific purposes. The mechanism that has been implemented for the exercise of such rights are through the presentation of the respective application, by sending an e-mail to the following e-mail address: info@novastem.mx, in Spanish or English. If you have any questions or comments please contact us to the phone number +52 664-231-7220 with the responsible ARCO. This information is protected under the applicable law.

At all times, you can revoke your consent that you gave us for the processing of your personal data, in order for us to stop making use of such information. For such purposes, it is necessary to submit your request by sending an email to the next e-mail address: info@novastem.mx in Spanish or English. If you have any questions or comments please contact us to the phone number +52 664-231-7220 with the responsible ARCO. This information is protected under the applicable law.

We compromise not to transfer your personal information to third parties without your previous consent, with the exceptions provided for in article 37 of the “Ley Federal de Protección de Datos Personales en Posesión de Particulares”, and as well to make this transfer in the terms established in the above mentioned Federal Law, except in the cases mentioned in article 37 of such Law:

• When the transfer is provided in a law or treaty that Mexico is part.
• When the transfer is necessary for the prevention or medical diagnosis, the provision of health care, medical treatment or health services management.
• When the transfer is made to subsidiaries or affiliates under common control of the responsible, or to a parent company or any company of the same group of the responsible that operates under the same processes and internal policies.
• When the transfer is necessary by virtue of an executed or to be executed contract, in which participate the responsible and a third party.
• When the transfer is necessary or legally required for the safeguard of public interest, or for the power of attorney or administration of justice.
• When the transfer is precise for the establishment, exercise or defense of a right in a judicial process.
• When the transfer is precise for the maintenance or fulfilment with a legal relationship between the responsible and the holder.

We reserve the right to make at any time modifications or updates to this privacy policy, according to legislative reforms, internal policies or new requirements for the benefits of offering our services or products.

This modifications will be available to the public through the following means:

• Advertisement seen on the website (section privacy notice); or,
• We will send you an e-mail to the e-mail address that you have provided us.

The cookies are files that are automatically downloaded and stored on the hard drive of the computer of the user to navigate on a specific website, that allows to remember some facts about this user, among them, your preferences for viewing the pages on that server, name and password. On the other hand, the web beacons are images inserted in a web page or e-mail, that can be used for tracking the behavior of a visitor, like storing information about the user's IP address, length of time for interaction in this page and the type of browser been used, among others. We inform you that we use cookies and web beacons to obtain personal information of you, like the following:

• Your type of browser and operating system.
• The web pages you visit.
• The links you follow.
• The IP direction.
• The website you visit before entering ours.

This cookies and other technologies can be disable. There are various sites on our website that can be connected to other web sites that do not operate under the site's privacy policies. When you connect to other web sites, the privacy practices of our web site as well as this policy have no validity. We invite our users to review the privacy policy of each website before revealing any personal information.

If you consider that your protection of personal data has been injured by any conduct of our employees or of our actions or responses, or suspected that in the process of your personal data there is a violation of any of the provisions established in the Federal Law for the Protection of Personal Data in Possession of Individuals (“Ley Federal de Protección de Datos Personales en Posesión de los Particulares”), you may complaint or report to the Federal Institute of Access to Information and Protection of Data (Instituto Federal de Acceso a la Información y Protección de Datos “IFAI”). For more information visit www.ifai.org.mx

Date of last update: September 17, 2015.