Privacy Policy Cromodata

At Cromodata, we are committed to protecting the privacy and security of our users’ personal data (hereinafter, the “Users”). This Privacy Policy (hereinafter, the “Policy”) describes how we collect, use, store, and protect the information you provide (hereinafter, “Personal Information” or “Information”), in strict compliance with applicable data protection regulations, including, but not limited to, the Health Insurance Portability and Accountability Act (HIPAA), the General Data Protection Regulation (GDPR), and other relevant local regulations (e.g., Argentine Law 25,326 on Personal Data Protection).

Use of Cromodata is governed at all times by our Terms and Conditions (hereinafter, the “Terms”), which form part of this Privacy Policy as a complementary and binding document. Both the Terms and this Policy are available at any time at www.cromodata.com.

Access, navigation, registration, or use of Cromodata’s services implies the explicit acceptance of both the Terms and this Privacy Policy.
For interpretative purposes, the definitions set out in the Terms will apply. In the event of any discrepancy between this Policy and the Terms, the specific provisions regarding personal data processing in this Policy shall prevail.
Please read this Privacy Policy carefully to understand our practices regarding your Information.


1. INFORMATION WE COLLECT
When you interact with Cromodata’s website (hereinafter, the “Site”), we may collect and process different types of Personal Information in order to provide our services and manage our business relationships. Among others, this data includes:

1. Personally Identifiable Information
-  Contact information: full name, email address, phone number, and job title.
- Billing and payment information: billing address, debit/credit card numbers, security codes, and other details necessary to process payments.
2. In certain cases, we may also request additional information such as physical address, copies of identification documents, or proof of address. Such details are required to comply with identity verification processes and local or international regulations, ensuring the legitimacy and security of operations carried out on our platform.
3. Information About Site Usage
 We collect information about how Users interact with Cromodata, including details about completed transactions, interests in specific datasets or services, and usage frequency. This information allows us to better understand Users’ preferences, optimize their experience, improve the Site’s functionality and content, and develop new tools or services that meet their needs.
4. Technical and Connection Information
 While you use the Site, we may collect technical information such as IP address, browser type, operating system, and other device identifiers. This data is essential for monitoring the Site’s performance, strengthening security measures, and preventing unauthorized access or suspicious activities.


2. MEDICAL INFORMATION
Users understand and agree that Cromodata’s services include the collection of medical data from various sources, such as healthcare providers, insurers, researchers, and other entities. Likewise, Users acknowledge that Cromodata processes this information to de-identify and anonymize it for subsequent sublicensing.

Such data may include medical images, patient demographic information, medical records, and other related data. We ensure compliance with applicable data protection and privacy regulations at all times.


3. COOKIES
We use cookies on the Site to enhance the User’s experience. Cookies are small text files sent by a web server to your browser and stored locally on your device, uniquely identifying your browser on each visit. Cookies do not harm your device nor do they contain viruses.

However, you can configure your browser settings to delete or reject cookies at any time. Please note that disabling or rejecting cookies may affect certain Site features or services, potentially limiting your experience or access to some content.


4. PURPOSE OF THE INFORMATION
We use the Personal Information collected through the Site and our Insight platform for various business and operational purposes, including:

1. Facilitating account creation and login processes
 We use Personal Information to register User accounts and enable secure access to our services.
2. Publishing testimonials (with prior consent)
 If a User wishes to share their experience, we may publish testimonials about our services, but only with the User’s explicit and prior consent.
3. Requesting feedback and contacting you regarding your use of the Site or the Insight platform
 We use your contact details to request feedback on your experience, aiming to improve our services, and to communicate any updates or changes related to your use of the Site or the Insight platform.
4. User account administration
 Personal Information allows us to manage and maintain your account on the Site, ensuring access to your account settings, preferences, and personalized features.
5. Sending information about products, services, new features, or changes to our terms, conditions, and policies
 We use Users’ contact information to keep them informed about product or service updates, new features, and important changes in our Terms of Use, Privacy Policies, and other relevant documents.
6. Maintaining the security of the Site and the Insight platform
 Collected information is used to monitor and protect the integrity of our Site and platform, preventing unauthorized access, fraud, or suspicious activities.
7. Complying with legal and regulatory obligations
 We use Personal Information to fulfill legal, regulatory, and statutory requirements, including tax obligations and privacy regulations.
8. Responding to legal requests and preventing harm
 We may use User Personal Information to comply with legal requests, such as court orders, or to prevent fraud or other illegal activities that may compromise the security of our Users or our platform.
9. Processing orders, payments, returns, and exchanges made through the Site
 We collect and process your information to handle transactions made on our Site, including purchases, payments, returns, and product or service exchanges.

Using Personal Information in these ways allows Cromodata to provide a more personalized, secure, and efficient experience, while ensuring compliance with our legal obligations and meeting Users’ expectations.


5. MINORS
Cromodata’s services are intended exclusively for persons who have reached the age of majority according to applicable laws. By registering and using the Site, you represent and warrant that you are at least 18 years old or the minimum required age in your jurisdiction.

We reserve the right to verify a User’s age at any time. If we discover that a User has provided false information about their age or has registered as a minor, Cromodata may suspend or terminate their account immediately, and we will take any necessary steps to remove associated personal data, in strict compliance with applicable privacy and child protection regulations.

6. USER RIGHTS
Cromodata fully recognizes and respects Users’ rights regarding their Personal Information. Users may, at any time:

- Access: Request information about the data that Cromodata has collected and is processing about them.
- Rectify: Request the correction of any inaccurate, incomplete, or outdated Personal Information.
- Erase: Request the deletion of their Personal Information should they decide to stop using Cromodata’s services and no legal obligation requires its retention.

To exercise these rights, Users should send an email to: info@cromodata.com, including “Personal Information Request” in the subject line. Users must provide sufficient information to verify their identity (full name, the email address associated with the Cromodata account, etc.). We will handle such requests securely and efficiently.


7. SECURITY AND CONFIDENTIALITY OF PERSONAL INFORMATION
Cromodata has implemented appropriate technical and organizational security measures to protect Users’ Personal Information from unauthorized access, as well as from alteration, disclosure, or destruction. We recognize the importance of confidentiality and are committed to handling all Personal Information with the highest degree of protection.

7.1 Restricted Access to Information
Access to Personal Information is strictly limited to:

1. Authorized employees: Cromodata team members who need the data to operate, develop, or improve our services.
2. Authorized contractors and representatives: Service providers and partners working with us under confidentiality agreements and requiring access to perform specific tasks.

7.2 Sharing of Personal Information
Cromodata does not share Users’ Personal Information with third parties, except in the following situations:

1. In the cases described in this Policy.
2. If required by law, court order, or applicable regulations that compel Cromodata to disclose such information.
3. When the User has given express consent for their data to be shared.

Outside of these circumstances, Users’ Personal Information will not be disclosed, transferred, or sold to third parties.

7.3 Data Retention and Deletion
Cromodata is not obligated to retain Users’ Personal Information for a specific period. Data will be deleted when:

- The purpose for which it was collected has been fulfilled.
- The User requests its deletion, and there is no legal or regulatory obligation that justifies continued retention.


8. CHANGES TO THE PRIVACY POLICY
Cromodata reserves the right to modify this Privacy Policy at any time. Users will be notified of any new versions of this Policy in the following ways:

1. Publication on the Site
 The updated version will be posted on our official website (www.cromodata.com), where Users may review it at any time.
2. Email Notification
 We will send an email to the registered address of each User, informing them of the changes.

Continued use of the Site after such modifications are posted constitutes acceptance of the updated terms. If the User does not agree with these changes, they should cease using the Site and may request the deletion of their account and personal data.

The effective date of any modifications to this Privacy Policy will be clearly indicated at the beginning of the document to ensure Users can easily identify the latest version.


9. REGULATORY COMPLIANCE
Cromodata operates in strict compliance with all applicable regulations, including HIPAA, GDPR, CCPA, and, where appropriate, Argentine Law 25,326 on Personal Data Protection, thereby ensuring the protection and privacy of data in accordance with current legal standards.


10. CONTACT
If Users have any questions or concerns about this Policy or our privacy practices, they may reach out at any time by emailing:
 info@cromodata.com

Last Update: 28/03/2025
For any additional questions or requests, please do not hesitate to contact us. At Cromodata, we value the trust you place in our services and work continuously to ensure the protection of your data.