NUTRACEUTICALS & LIFE PHARMA LAPHIFARMA S.A.S.

I. INTRODUCTION

NUTRACEUTICALS & LIFE PHARMA LAPHIFARMA S.A.S. (hereinafter, "LAPHIFARMA"), recognizes the importance of privacy and protection of personal data of its employees, customers and other members of the community. Therefore, it is committed to protect the privacy and personal data of its users, in compliance with the Organic Law of Personal Data Protection of Ecuador and other applicable regulations.

II. PERSONAL DATA THAT MAY BE PROCESSED AND THEIR PURPOSES

LAPHIFARMA processes the personal data detailed below, provided by its different stakeholders in their commercial, contractual, labor, etc. relationships.

CUSTOMERS

LAPHIFARMA may process the following personal data of its natural person clients: 1) Identifying information (such as name, identity card, date of birth, sex, age); 2) Contact information (such as telephone, email, home address, work address, emergency contact, social networks); 3) Images collected through video surveillance cameras that LAPHIFARMA, in case of having contracted such service, or images captured during the provision of any of our services (e.g., monitoring, patrolling, etc.); 4) Economic data (information on bank accounts, credit cards); 5) Any information subscribed and delivered in the different forms, contracts and annexes in the different forms, contracts and attachments in connection with the different services provided by LAPHIFARMA. 4) Economic data (information about bank accounts, credit cards); 5) Any information subscribed and delivered in the different forms, contracts and annexes in relation to the services to be received by LAPHIFARMA.

LAPHIFARMA will process the personal data described herein for the following purposes: 1) For the formalization, development and execution of the contract; 2) For the provision of the contracted services; 3) For the sending of notifications and/or natural medicinal products related to the contracted service; 4) For the offering of sis products and services; 5) For the fulfillment of legal obligations or court orders.

WORKERS

LAPHIFARMA may process the personal data of the employee: 1) that are directly provided by the employee; 2) those available in publicly accessible databases that may be necessary for the development of the employment relationship; and, 3) those to which the employer may have access in the framework of the employment relationship with the employee. This includes, among others, images of the employee that may be collected by video surveillance camera circuits or other image collection mechanisms. 
LAPHIFARMA may process the personal data described herein solely for employment and administrative purposes; as well as for security purposes.

SUPPLIERS

The personal data that may be processed are the following: 1) Identifying data (such as full names and surnames, identification number); 2) Contact data (such as physical address, email address, telephone, emergency contact, position, domicile, work address); 3) Family data; 4) Economic data (information on bank accounts, credit cards, financial situation); 5) Information on studies and trainings that are relevant to the provision of the service offered as a supplier; 6) Information reflected in personal documents such as identity card, voting ballot, or others that are required for the perfection of the commercial relationship; and 7) Any other personal data provided directly by the Supplier through forms or contracts signed between the parties, within the framework of their commercial and contractual relationship.

LAPHIFARMA will process the personal data described herein for the following purposes: 1) For the formalization, development and execution of the commercial relationship; 2) For the sending of notifications related to the commercial relationship; 3) For the qualification of suppliers; 4) For the fulfillment of legal obligations or court orders.

VIDEO SURVEILLANCE

LAPHIFARMA may process videos and/or images of individuals recorder by the company's security cameras. These personal data will be processed exclusively to ensure the safe of our employeses, customers, suppliers, amogs others, and to prevent risk situation, thereby maintaining a safe environment in our facilities.

III. DATA TRANSFERS

LAPHIFARMA will only share with third parties (transfer/share) the personal data of its various stakeholders if there is a legal basis for doing so. It will be understood that there is a legal basis for such communications when a legal rule requires the communication, it is necessary for the provision of the contracted service or the owner has given us his consent.

IV. RETENTION PERIODS OF PERSONAL DATA

LAPHIFARMA will keep the personal data of its different stakeholders for the duration of the commercial, contractual, labor, etc. relationship commercial, contractual, labor, etc. relationship. Once the relationship has ended, we will keep your data for the periods established in the current regulations which, in general, will be for a maximum period of 10 years from the end of the commercial relationship. During this period the data will be kept for the purpose of responding to requests from the Control Authorities, competent public sector entities, Courts and Tribunals, as well as to respond to any queries or complaints. Without prejudice to the periods referred to above, the holder may request the deletion of their data at any time.

V. PERSONAL DATA PROTECTION MEASURES

LAPHIFARMA will take technical, organizational and legal security measures to protect the personal data of its users against unauthorized access, loss, alteration or destruction.

VI. RIGHTS OF THE HOLDERS OF PERSONAL DATA

The holders of personal data may exercise the following rights in relation to the processing of their personal data:
a. The right of access to their data contained in the  files/banks/databases of LAPHIFARMA.
b. The right to rectify and update any data that may be incorrect or incomplete.
c. The right to the deletion of your personal data, in the cases provided for in the regulations in force.
d. The right of opposition, which allows you to request the cessation of all or some of the processing, such as the sending of communications for purely commercial purposes.
e. The right to the suspension of data processing, for a limited period of time and in the cases provided for in the regulations in force.
f. The right to portability, which will allow you to request that we send you your personal data in a compatible, updated, structured, common, interoperable and machine-readable format, preserving its characteristics.
g. The right to revoke the consent given for the processing of their data.

To exercise their rights, the holders of personal data must submit a written request to LAPHIFARMA, specifying the right they wish to exercise and the information necessary to identify the holder of the personal data. LAPHIFARMA will respond to the requests of the holders within the term established by the Law. For this purpose, LAPHIFARMA has made available the e-mail protecciondedatos@laphifarma.com.ec

VII. BASIS OF LEGITIMACY

LAPHIFARMA will process the personal data of its different stakeholders only when it has a legitimate basis for this purpose. LAPHIFARMA undertakes to request your consent prior to the processing of your personal data; notwithstanding the fact that in the absence of such consent it is entitled to process personal data under other grounds of legitimacy expressly provided for in the Law (such as the existence of a contractual relationship, a legal or judicial order, the need to protect a vital interest, etc.).

VIII. CHANGES TO THE PRIVACY POLICY

LAPHIFARMA reserves the right to modify this privacy policy at any time, without notice.