PRIVACY POLICY
(Updated on October 24, 2024)

1. PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy provides information about how the platform dedicated to well-being and mental health, composed of the website www.Neomente.com and the mobile application “Neomente” (hereinafter referred to as “the Platform”):

• Collects personal data from all individuals who access or use the Platform (the “Users”). “Personal Data” is understood as any information related to a person that allows them to be identified (name, surname, ID, date of birth, medical data, health insurance, geographic location, gender, etc.).

• The purpose for collecting this Personal Data.

• How Users’ Personal Data is used.

• The rights Users have regarding their Personal Data.

At NEOMENTE, we are committed to safeguarding the Personal Data and privacy of our Users, and we are fully aware of the sensitive nature of some of the data that may be provided due to the characteristics inherent to the services we offer. Therefore, we strive to comply with all applicable data protection laws in Argentina (Law 25.326, Regulatory Decree 1558/2001, and regulations issued by the Data Protection Directorate of the Access to Public Information Agency).

2. PLATFORM OWNER AND DATA CONTROLLER
The Platform is owned by QUIES MENTIS SAS, a company legally established in the Republic of Argentina, located at Junín 674 1B, Autonomous City of Buenos Aires, CUIT 30-71653502-5. QUIES MENTIS SAS is responsible for all data collected through the Platform or any future means made available to Users, in accordance with Law 25.326 on Personal Data Protection of the Republic of Argentina.

3. DATABASE. REGISTRATION. LOCATION.
The NEOMENTE database is located in the United States, hosted on Google Cloud servers. By accepting this Privacy Policy, the User consents to the transfer of their data to the United States for the purpose of providing the best possible service.

Once the data has been transferred to the United States, the laws of that country will also apply, which may allow access to the information by authorities, such as law enforcement agencies. Consequently, when legally or judicially required by authorities in that country, the User accepts and consents that NEOMENTE may allow access to those entities.

The NEOMENTE databases are registered with the Data Protection Directorate of the Access to Public Information Agency, in accordance with Article 3 of Law 25.326.

4. CONSENT
By using the Platform, Users accept this Privacy Policy and give their express, free, and informed consent for NEOMENTE and/or third parties designated by NEOMENTE to process their personal data, including data that may be considered sensitive (such as health-related information), as set forth herein. If the User does not agree with this Privacy Policy, they must not use the Platform or NEOMENTE’s services.

5. MINIMUM AGE TO USE THE PLATFORM
By using the Platform, the User declares and guarantees that they are over 14 years old and have the legal capacity to consent to the processing of their data by NEOMENTE.

If a User and/or their legal guardian or custodian becomes aware that a minor under their care has used NEOMENTE’s services without authorization, they must immediately contact NEOMENTE to request deletion of the minor’s personal data.

6. VOLUNTARY PROVISION OF DATA
The User is not obliged to provide any personal data to NEOMENTE. However, to register and use the Platform’s services, Users will be asked for data such as name, ID, address, email, date of birth, health insurance information, mental and/or physical health details, among others. Providing this data is strictly voluntary and necessary to access the services offered on the Platform.

7. DATA QUALITY
The User declares and guarantees that any personal data and other information provided to NEOMENTE is always truthful, accurate, current, and authentic, and agrees to update it when necessary.

8. DATA COLLECTED

1. Personal Data
   NEOMENTE may request access to personal data such as full name, address, date of birth, email address, or phone number to deliver the Platform’s services.

Data is collected through:

• The Platform registration form.

• The Admission, Diagnosis and Feedback Protocol form.

• The Clinical Decision Support System (CDSS) registration form.

• IP address, device type, browser type, operating system, geographic location, session time and duration.

Telehealth sessions are private and not recorded.

2. Sensitive Data
   Sensitive data is collected with informed consent through:

• The Admission, Diagnosis and Feedback Protocol.

• The CDSS form.

• Initial Screening Questionnaire (based on the MINI interview).

• Therapy-administered scales and forms.

• Daily Logs in the app.

• Medical history and presumptive diagnosis.

For therapists, the registration form also includes:

• Professional license

• National ID

• Malpractice insurance

• Hepatitis B vaccination

• Curriculum vitae

• Health provider registration

• Degree certificates

• Contact information

9. PURPOSE OF DATA USE
NEOMENTE will use User data solely to provide services, including:

• Creating a user ID

• Enabling professionals to access relevant clinical information

• Optimizing the user experience

• Managing billing

• Storing medical history

• Sending marketing and newsletters (with opt-out option)

10. CONFIDENTIALITY
NEOMENTE will not sell or share Users’ Personal Data, except as provided in this Policy or when required by judicial or governmental authorities, or when illegal or suspicious activity is detected.

Industry-standard security measures like firewalls and SSL are used.

11. DATA SECURITY
While NEOMENTE applies high-security standards, it cannot guarantee absolute protection due to the nature of Internet communications. NEOMENTE is not liable for unauthorized interceptions or breaches by third parties.

12. DATA SHARING WITH THIRD PARTIES
NEOMENTE may share data with third parties, particularly therapists, to ensure proper service delivery and treatment.

13. DATA RETENTION PERIOD
NEOMENTE will retain data as long as the User is registered and for up to ten (10) years thereafter for dispute resolution, troubleshooting, and compliance.

14. SUPERVISORY AUTHORITY
The National Directorate for Personal Data Protection (Dirección Nacional de Protección de Datos Personales) is the supervisory authority. Located at Sarmiento 1118, 5th Floor, Buenos Aires, phone: +54 11 5300-4000.

15. THIRD-PARTY SITES
The Platform may link to unrelated third-party sites (e.g., for payments). This Policy does not apply to those sites. Users should review the third-party sites’ privacy policies.

16. USER RIGHTS REGARDING THEIR DATA
Users may:

• Request access to their data

• Request correction

• Request deletion

To exercise these rights, Users must email soporte@Neomente.com with valid legal ID. Medical records are retained for 10 years, as per Law 26.529.

Users can also request deletion of data related to devices, IP, or location history. Medical records remain available upon request.

17. POLICY UPDATES
NEOMENTE may update this Privacy Policy. Users will be notified via the Platform. If a User disagrees with the updated terms, they must stop using the service. All data will be deleted, except for billing and medical records, per Law 26.529.

18. CONTACT
For any questions regarding this Policy, please contact: admin@Neomente.com