Privacy Statement

Effective Date: 05/09/

Table of Contents

● Introduction ● Data Protection Officer ● How we collect and use (process) your personal information ● Use of the Promotal Medconnect website ● Cookies and tracking technologies ● Use of the Promotal Medconnect services ● When and how we share information with third parties ● Transferring personal data to the U.S. ● Data Subject rights ● Security of your information ● Data storage and retention ● Questions, concerns, or complaints

Introduction

Promotal Medconnect is a comprehensive virtual healthcare solution provider, facilitating
remote medical consultations and collaborations among healthcare professionals.

We understand that you are aware of and care about your own personal privacy interests, and
we take that seriously. This Privacy Notice describes the Promotal Medconnect’s policies and
practices regarding its collection and use of your personal data and sets forth your privacy
rights. We recognize that information privacy is an ongoing responsibility, and so we will from
time to time update this Privacy Notice as we undertake new personal data practices or adopt
new privacy policies.

For the purposes of providing telemedicine services, we may also collect and store sensitive
health data, including medical history, diagnostic test results, and medications, for example. All
health data is processed and stored in accordance with applicable laws and regulations,
including HIPAA and GDPR.

Data Protection Officer

Promotal Medconnect is headquartered in 7 rue du fossée blanc, Gennevilliers, 92230 in
France.

Promotal Medconnect has appointed an internal data protection officer for you to contact if
you have any questions or concerns about Promotal Medconnect’s personal data policies or
practices. If you would like to exercise your privacy rights, please direct your query to Promotal
Medconnect’s data protection officer.

Promotal Medconnect’s data protection officer’s name and contact information are as follows:

Victor Mouradian Promotal Medconnect 7 batiment b, rue du fossée blanc, Gennevilliers, 92230, France vmouradian@promotal.com

Our Data Protection Officer is responsible for ensuring that our data handling practices are
compliant with applicable laws.

How we collect and use (process) your personal information

Promotal Medconnect collects personal information about its website visitors and customers.
With a few exceptions, this information is generally limited to:

● name ● surname ● email ● phone number ● date of birth ● gender ● Postal address

We use this information to provide our customers access to our telemedicine platform.

Health related information:

● Medical History ● Diagnostic Test Results ● Medications ● Treatment Plans ● Physician's Notes

We use this health-related information to facilitate accurate and effective medical
consultations.

We do not sell personal information to anyone and only share it with third parties who are
facilitating the delivery of our services.

Use of the Promotal Medconnect Website

As is true of most other websites, Promotal Medconnect’s website collects certain information
automatically and stores it in log files. The information may include internet protocol (IP)
addresses, the region or general location where your computer or device is accessing the
internet, browser type, operating system, and other usage information about the use of
Promotal Medconnect ’s website, including a history of the pages you view. We use this
information to help us design our site to better suit our users’ needs. We may also use your IP
address to help diagnose problems with our server and to administer our website, analyze
trends, track visitor movements, and gather broad demographic information that assists us in
identifying visitor preferences.

Promotal Medconnect has a legitimate interest in understanding how members, customers and
potential customers use its website. This assists Promotal Medconnect with providing more
relevant products and services, with communicating value to our sponsors and corporate
members, and with providing appropriate staffing to meet member and customer needs.

How we collect and use (process) your personal information

We collect information through the platform which is used to facilitate telemedicine
consultations. This information is only accessible by authorized healthcare professionals and is
encrypted for your security.

Transferring Personal Data to the U.S.

If at any time we must transfer personal data to the U.S., it will be done in compliance with the
EU-U.S. Privacy Shield Framework or similar legal mechanisms.

Sharing information with third parties

The personal information Promotal Medconnect collects from you is stored in one or more
databases hosted by third parties located in France. These third parties do not use or have
access to your personal information for any purpose other than cloud storage and retrieval. On
occasion, Promotal Medconnect engages third parties to send information to you, including
information about our products, services, and events.

A list of our third-party sub processors can be found here:

Ordoclic
Omnidoc
Stellair
AWS
Twilio
Sendgrid

We do not otherwise reveal your personal data to non- Promotal Medconnect persons or
businesses for their independent use unless:

(1) you request or authorize it;

(2) it’s in connection with Promotal Medconnect - hosted and Promotal Medconnect co-
sponsored conferences as described above;

(3) the information is provided to comply with the law (for example, compelled by law
enforcement to comply with a search warrant, subpoena, or court order), enforce an
agreement we have with you, or to protect our rights, property or safety, or the rights, property
or safety of our employees or others;

(4) the information is provided to our agents, vendors or service providers who perform
functions on our behalf;

(5) to address emergencies or acts of God; or

(6) to address disputes, claims, or to persons demonstrating legal authority to act on your
behalf. We may also gather aggregated data about our services and website visitors and
disclose the results of such aggregated (but not personally identifiable) information to our
partners, service providers, advertisers, and/or other third parties for marketing or promotional
purposes.

If you are a member of a third party service, the aforementioned connections may allow that
service to connect your visit to our site to your personal data.

Data Subject rights

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy
laws provide certain rights for data subjects. Data Subject rights under GDPR include the
following:

● Right to be informed ● Right of access ● Right to rectification ● Right to erasure ● Right to restrict processing ● Right of data portability ● Right to object ● Rights related to automated decision making including profiling

This Privacy Notice is intended to provide you with information about what personal data
Promotal Medconnect collects about you and how it is used.

If you wish to confirm that Promotal Medconnect is processing your personal data, or to have
access to the personal data Promotal Medconnect may have about you, please contact us.

You may also request information about: the purpose of the processing; the categories of
personal data concerned; who else outside Promotal Medconnect might have received the
data from Promotal Medconnect ; what the source of the information was (if you didn’t provide
it directly to Promotal Medconnect ); and how long it will be stored. You have a right to correct
(rectify) the record of your personal data maintained by Promotal Medconnect if it is
inaccurate. You may request that Promotal Medconnect erase that data or cease processing it,
subject to certain exceptions. You may also request that Promotal Medconnect cease using
your data for direct marketing purposes. In many countries, you have a right to lodge a
complaint with the appropriate data protection authority if you have concerns about how
Promotal Medconnect processes your personal data. When technically feasible, Promotal
Medconnect will—at your request—provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be
provided within a reasonable time frame, Promotal Medconnect will provide you with a date
when the information will be provided. If for some reason access is denied, Promotal
Medconnect will provide an explanation as to why access has been denied.

Most requests will be handled within one month of receipt. Requests that are more
complicated will be responded to within three months of receipt.

For questions or complaints concerning the processing of your personal data, you can email us
at privacy@promotal.com.

Alternatively, if you are in the European Union, you can also have recourse to the European
Data Protection Supervisor or with your nation’s data protection authority.

Security of Your Information

All data is encrypted during transmission and when stored. We employ state-of-the-art firewalls
and intrusion detection systems to prevent unauthorized access.

Data storage and retention

Your personal data is stored by Promotal Medconnect on its servers, and on the servers of the
cloud-based database management services the Promotal Medconnect engages, located in
France.

Promotal Medconnect retains service data for the duration of the customer’s business
relationship with the Promotal Medconnect and for a period thereafter, to analyze the data for
Promotal Medconnect’s own operations, and for historical and archiving purposes associated
with Promotal Medconnect’s services.

Promotal Medconnect retains prospect data until such time as it no longer has business value
and is purged from Promotal Medconnect systems. All personal data that Promotal
Medconnect controls may be deleted upon verified request from Data Subjects or their
authorized agents.

Medical records are retained for a period that is consistent with applicable laws and
regulations.

For more information on where and how long your personal data is stored, and for more
information on your rights of erasure and portability, please contact us at:
privacy@promotal.com

Children’s data

We do not knowingly collect data from children under the age of 16 without parental consent.
Age verification steps are in place to ensure this.

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please
contact us at:

Promotal Medconnect 7 batiment b, rue du fossée blanc, Gennevilliers, 92230, France privacy@promotal.com +33 (0)2 43 05 17 76