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PRIVACY AND PERSONAL DATA PROTECTION POLICY

Amapola Technologies (hereinafter "Amapola"), as a provider of development, marketing, implementation, training, and technical support services for processes, digital messaging services, campaigns, call center infrastructure, collections processes, among others, firmly believes in transparency and in respecting people's fundamental rights and freedoms in the proper processing of your personal data.

This Privacy and Personal Data Protection Policy of Amapola (hereinafter "Privacy Policy") was created to inform individuals about what data we collect, why we collect it, and how you can exercise your rights under Ecuador's Organic Law on Personal Data Protection (hereinafter "LOPDP"); and to strengthen the company's commitment to the right to personal data protection of all individuals whose data we process.

Amapola offers various Products and Services, always respecting its clients' preferences. For this reason, we adopt compliance with the LOPDP and applicable personal data protection regulations in all our processes.

It is very important to Amapola that you read this Privacy Policy in its entirety, so that you understand how we process your personal data.

PAY CLOSE ATTENTION! LET'S BEGIN:

In this Privacy Policy you will find all the relevant information that applies to our use of the personal data of our clients, potential clients, users, and/or suppliers contained in the databases we manage, regardless of the channel or medium you use to interact with us.

1. PURPOSE

This Policy establishes and informs of the procedures and purposes used by the company Amapola Technologies in the processing of the personal data of its clients or suppliers.

The user acknowledges that this Policy may be modified by Amapola whenever deemed necessary, and likewise acknowledges that they may access the Policy whenever they consider it necessary.

By accepting this Policy, the user acknowledges having read the entire content of this document and agreeing to the conditions established herein.

2. DIGITAL CHANNELS OR MEDIA. -

In this Privacy Policy, when we talk about the means for you to communicate with us, we generally refer to any of the digital, voice, or in-person channels or media you use to interact with us. The main ones are:

Our Website: https://galenoia.com

Email: info@galenoia.com

Phone: +1 608 580 8397

3. GLOSSARY

In compliance with the principle of transparency and fairness, the following definitions are provided to improve your understanding of and interaction with us:

Personal Data: Data that identifies or makes a natural person identifiable, directly or indirectly.

Data Subject: Natural person whose data is processed by Amapola Technologies. In our relationship with you, personal data of clients, potential clients, users, and/or suppliers may be processed.

Data Controller: Amapola Technologies decides on the purpose and processing of your personal data, and is therefore responsible for the processing of your personal data.

Data Processor: A natural or legal person, public or private authority, or other body that, alone or jointly with others, processes personal data on behalf of a data controller.

Recipient: Natural or legal person to whom personal data has been disclosed.

Personal Data Protection Officer: Natural person responsible for informing the controller or processor of their legal obligations regarding data protection; monitoring or overseeing regulatory compliance in this regard; cooperating with the Personal Data Protection Authority, serving as a point of contact between it and the entity responsible for data processing, and with the Data Subject regarding the processing of your personal data in order to exercise your rights.

Processing: Any operation or set of operations carried out on personal data, whether by automated, partially automated, or non-automated technical procedures, such as: collection, gathering, obtaining, recording, organization, structuring, storage, custody, adaptation, modification, deletion, indexing, extraction, consultation, preparation, use, possession, exploitation, distribution, assignment, disclosure or transfer, or any other means of enabling access, matching, interconnection, restriction, erasure, destruction and, in general, any use of personal data.

Personal Data Protection Authority: Independent public authority responsible for overseeing the application of this law, its regulations, and the resolutions it issues, in order to protect the fundamental rights and freedoms of natural persons with regard to the processing of your personal data.

Applicable Laws: Data protection regulations, in particular Ecuador's Organic Law on Personal Data Protection.

4. PRINCIPLES

We process your personal data in compliance with all the principles set out in the LOPDP. Below, we explain the most relevant ones:

4.1 Transparency

We are 100% transparent with you about the data we collect and/or process about you, and we explain why we use it and for what purposes.

In this Privacy Policy, we make available to you, on a permanent basis, so that you may consult it whenever you deem appropriate, all information about each of the processing activities carried out on your personal data.

4.2 Fairness

In this Privacy Policy, we clearly make available to you why we are collecting, storing, using, consulting, and/or disclosing your personal data, as well as the ways and means in which such data is or will be processed for lawful and fair purposes in one way or another.

4.3 Security

We are committed to ensuring the security, secrecy, and confidentiality of your data and personal information, for which we adopt appropriate and necessary security measures.

5. DATA CONTROLLER

Who is responsible for processing your personal data?

Amapola Technologies is responsible for the processing of your personal data, in accordance with what we inform you in this Privacy Policy.

6. WHAT PERSONAL DATA IS PROCESSED, FOR WHAT PURPOSE, AND WHY DO WE PROCESS IT?

The data processed by Amapola Technologies will be that provided by the Client and/or Contracting Party and/or Suppliers for the request and maintenance of the contractual relationship, through any channel, that generated as a result of that relationship, as well as data obtained from publicly accessible databases.

When the Client and/or Contracting Party provides data on third parties, including whoever assumes payment for the contracted services, such data will be processed as part of managing the request and maintaining the contractual relationship once it begins. By accepting these terms regarding the processing of personal data, and being aware of this processing, you declare that the data is accurate and that you have informed these third parties of its content and of the corresponding rights they hold regarding Data Protection. Notwithstanding the foregoing, Amapola Technologies will make every effort to act appropriately with regard to the processing of such third parties' data.

Likewise, the personal data of the Client and/or Contracting Party and/or Suppliers may be obtained through duly authorized third-party sources, such as agents, brokers, insurance advisors and brokers, alternative distribution channels, among others, notifying you of the origin of the data in a timely manner, in express compliance with personal data protection regulations, such as, for example: companies that, with your consent, forward us your request for information or for the contracting of Amapola Technologies' products and services.

The Client and/or Contracting Party and/or Beneficiary acknowledges that the information provided is complete, correct, and up to date, and, in the event of providing information about third parties, including but not limited to their beneficiaries, acknowledges having previously obtained their consent to share their Personal and sensitive Data with the controller.

What personal data is being processed?

As a general rule, Amapola Technologies will only process the Personal Data of children and adolescents when their legal representative has given consent for such processing, when it is necessary for the performance of the service agreement, for compliance with a legal obligation, and/or for the satisfaction of a legitimate interest of Amapola.

What for? – Purposes of processing: The purpose of the processing we carry out is the proper performance of the contract entered into with the Data Subject. In addition, we need to process your personal data to provide the highest quality of our Products and Services, to adapt to your needs, and to improve your experience so that you can better enjoy such Products and Services. Processing your data will allow us to be more efficient and will therefore help us continue to maintain the highest levels of security and trust in the services we provide you.

7. HOW LONG IS THE DATA RETAINED?

We will retain your data for the time necessary to fulfill each purpose described in each processing activity and to determine any liability that may arise from that purpose, as well as to comply with the deadlines set by Ecuadorian regulations for each particular case, such as the time necessary for the statute of limitations on legal actions.

We rely on the following criteria to determine the retention period for your personal data:

(a) The duration of the use of the personal data to provide the service.

(b) Regulatory or legal obligation.

(c) Internal guidelines.

Notwithstanding the above, as a general rule, once you have ceased to be an Amapola client, we will retain your information for a period of up to one (1) year.

We may contact you about Products or Services offered by Amapola during this time, unless you have voluntarily opted out of receiving any type of commercial communication from us.

8. RECIPIENTS

Who are the recipients of the data? Are there international data transfers?

To carry out the processing purposes described, we may use authorized subcontractors acting on behalf and in the name of Amapola, as data processors, who are contractually bound by our instructions, solely for the lawful purposes described and for the period of time strictly necessary for that purpose.

Amapola, as part of the MEG Corporate Group, informs you that, in order to fulfill the purposes set out in this Privacy Policy, your personal data may be shared with other affiliated companies located abroad. These international transfers will be carried out under strict security measures and in accordance with the MEG Group's binding corporate rules.

In addition, in the event of a legal obligation or requirement to do so, we may disclose your data to the competent public authorities in compliance with such legal obligation or requirement.

We may carry out international transfers to authorized subcontractors/suppliers acting on behalf and in the name of Amapola, always in accordance with the provisions of the Applicable Laws. We will adopt the organizational, technical, and contractual measures necessary to guarantee the protection and security of your data.

9. RIGHTS

What rights do you have as a data subject?

Personal data protection regulations grant you certain rights over your data that, as applicable, you may exercise against Amapola. Below, we detail what they are and how you can exercise them.

Remember that, in order to exercise any of these rights, Amapola will require the documents and validations necessary to verify that you are the Data Subject.

9.1 Right of access

It is your right to request details of the data we hold about you and how we process it.

9.2 Right of rectification and update

It is your right to obtain the correction of inaccurate or erroneous data, as well as to complete any data that is incomplete.

9.3 Right of erasure

It is your right to request the deletion or erasure of your data and information under certain circumstances. However, please note that there are certain instances in which we are legally entitled to continue retaining and processing your data, such as, for example, to comply with a legal data retention obligation.

9.4 Right to object

It is your right to object to us processing your data for a specific purpose, under certain circumstances provided for by the regulations and related to your personal situation.

9.5 Right to portability

It is your right to request that we provide your personal data in a structured, commonly used format.

9.6 Right to restriction

It is your right to restrict or limit the processing of your data under certain circumstances.

9.7 Right not to be subject to automated individual decisions

It is your right to request that, under certain circumstances, you not be subject to a decision based solely on the automated processing of your data, including profiling, that produces legal effects concerning you or similarly significantly affects you.

10. EXERCISING YOUR RIGHTS

In compliance with your right to personal data protection, Amapola provides the email address info@galenoia.com as a contact channel to submit any request related to the exercise of your rights.

Remember that you must attach the documentation requested for your security and to verify your identity.

It is important to note that when exercising a right, you must clearly specify which one you are exercising.

11. WHAT IS YOUR RESPONSIBILITY REGARDING THE DATA PROVIDED?

The data subject guarantees that the data provided to Amapola is true, accurate, complete, and up to date. To this end, the Data Subject is responsible for the accuracy of the data provided and will keep it duly updated so that it reflects their actual situation.

They will be liable for any false, excessive, or inaccurate information provided and for any direct or indirect damages this may cause to Amapola or to third parties.

If you fail to provide all the personal data required to access any feature of the Products or Services, through any of the contracting channels, we will not be able to provide you with our Products and Services.

In this regard, incorrect data voluntarily provided by the Data Subject to Amapola will be the sole and exclusive responsibility of the Data Subject.

12. WHAT HAPPENS IF YOU PROVIDE US WITH THIRD-PARTY DATA?

We offer Products and Services that require or request that we process the personal data of a third party that you provide to us. If you provide us with personal data of third parties, you guarantee that you have informed them about the purposes and the manner in which we need to process your personal data.

13. CHANGES TO THE PRIVACY POLICY AND FURTHER DATA PROCESSING

Amapola reserves the right to update this Privacy and Personal Data Protection Policy at any time. If we do so, we will notify you through various means when the change in question is significant for your privacy, so that you can review the changes, assess them, and, where applicable, exercise your rights. In any case, we suggest that you review this Privacy Policy from time to time in case there are minor changes or we introduce any interactive improvements. Remember that you can find our Privacy Policy on our Platform.

Should Amapola require further processing of your personal data for a purpose other than those set out in this Privacy Policy, you will be informed beforehand, including all legally required information as well as the purposes intended for such processing.

14. SECURITY AND CONFIDENTIALITY IN THE PROCESSING OF YOUR INFORMATION

Amapola is committed to ensuring the security, secrecy, and confidentiality of your data, communications, and personal information. That is why, as part of our commitment and in compliance with the Applicable Laws, we have adopted the most appropriate security measures.

When we receive customer data, we use security procedures and functions to prevent any unauthorized access.

Personal data that we may collect through the various communications we maintain with you will be treated with absolute confidentiality, and we are committed to keeping it secret and ensuring the duty to safeguard it by adopting all necessary and reasonable measures.

In the event of personal data security breaches that pose a risk to individuals' rights, Amapola Technologies will take the necessary measures to remedy the situation and mitigate any negative effects such a breach may have caused. It will also notify the Data Subjects and the Personal Data Protection Authority, when required to do so by the Applicable Laws.

15. INFORMATION FOR DATA SUBJECTS WHO HAVE INTERACTED WITH AMAPOLA

This Policy informs that the personal data of individuals and contacts who, without being clients, have interacted or had some contact with Amapola, will be processed in accordance with the principles set out in this Privacy and Personal Data Protection Policy and the Applicable Laws.

1. Data:

At Amapola, we process the personal information that non-clients provide when requesting information about a Product or Service through our customer service channels, as well as data generated or estimated by Amapola.

The data that Amapola may process are as follows:

Data obtained from the Data Subject: this is data provided by the Data Subject during any inquiry or interaction with Amapola.

Data generated or estimated by Amapola: this is data resulting from analyses carried out by Amapola based on the Data Subject's available data for internal management and commercial service purposes, as well as, where applicable, for the other purposes indicated in the following section.

Amapola also collects information from certain organizations/third parties that have lawful legitimizing bases and consents granted by the Data Subject, when appropriate and to the extent we have legal grounds to do so.

2. Why do we process your data?

At Amapola, we process the Data Subject's data to provide the information requested through our service channels and/or to offer you Products or Services that may interest you, as well as for other purposes permitted or authorized under the terms informed in this Privacy and Personal Data Protection Policy.

To this end, Amapola informs you that the legitimizing basis enabling the various processing activities is legitimate interest. Legitimate interest constitutes a legitimizing basis for processing, provided that the interest in processing the Data Subject's data for the stated purpose falls within your reasonable expectations based on your relationship as a party interested in the Products and Services.

In this regard, we consider the following to be covered by legitimate interest and, therefore, Amapola, in order to respond to the request made by the Data Subject, may use, among the categories of data collected in the corresponding section of this Privacy and Personal Data Protection Policy, those that are necessary for the proper performance of the requested service, as well as the other processing activities indicated below. The specific data processed will be identified as applicable, in the registration on the Platform, during conversations held in commercial phone support, by email, or at branches. In this regard, the processing activities that may be necessary to fulfill this management will be as follows:

3. Assistance to the Data Subject through any authorized channel.

Analyzing or predicting, in a very basic way, aspects related to their personal preferences and interests so that Amapola can offer them personalized Product and Service offers.

4. Data retention periods

Data will be processed solely and exclusively for the time necessary and for the purposes set out in this Privacy and Personal Data Protection Policy.

5. When is this policy updated?

To check for any modifications to this Comprehensive Privacy Notice, we recommend that you frequently visit our Platform, in the Privacy and Personal Data Protection Policy section. Last updated: February 2025.

Your data is very important to us!

FAQS

Check out our frequently asked questions to clear up any doubts and learn more about Galeno IA.

ABOUT THE APPLICATION

Galeno IA is a platform based on an LLM designed specifically for physicians. Its goal is to generate answers and clinical case analyses using only medically verified sources, facilitating evidence-based clinical decision-making.

With a properly recorded clinical case, Galeno IA analyzes and retrieves information exclusively from verified medical sources through Google Cloud, ensuring that answers come from validated scientific literature, clinical practice guidelines, and trusted medical databases, such as those from the Mayo Clinic and Cleveland Clinic.

To get a timely response for the case analyzed, it's essential to enter a well-structured clinical case with all the basic elements, such as:
• Identification details (name, age, sex, occupation if relevant).
• Personal and family history (previous illnesses, current medication, habits, allergies).
• Physical examination and review of systems (relevant findings).
• Laboratory results and complementary studies (if available).
• Previous treatments and therapeutic approaches.

No. This tool supports clinical analysis and helps optimize time, but it does not replace medical judgment or the in-person evaluation of the patient. The final interpretation of the information and the therapeutic decision must remain the responsibility of the healthcare professional.

It has nothing to do with ChatGPT or similar tools, for several reasons:
The fundamental difference lies in its approach — Galeno uses Med-Gemini, which is specifically designed and optimized for healthcare applications. This means training on large volumes of medical data, deep knowledge of medical terminology, and a strict focus on safety and accuracy.
ChatGPT and similar tools, on the other hand, are general-purpose language models without certified medical specialization. Galeno, in contrast, specializes in the unique needs of the healthcare sector, with data and algorithms adapted for clinical tasks, a rigorous emphasis on the accuracy of medical information, and compliance with privacy standards (such as HIPAA).

OPERATION AND ACCESS

Yes, the platform requires an Internet connection to access the up-to-date database and generate analyses in real time.

Yes, Galeno IA's Specialist Plan offers support for the 10 most in-demand and recognized medical specialties, including: Internal Medicine, Pediatrics, Cardiology, Gynecology, Neurology, Psychiatry, Traumatology, Surgery, among others. And the Medical Board and Plus Plan offers support for more than 50 medical specialties.

Galeno IA and Google Cloud's LLM obtain information exclusively from verified medical sources, such as:
• Medical records across all medical specialties from prestigious institutions in the US, UK, India, and others.
• Official clinical practice guidelines.
• Scientific articles indexed in trusted databases such as PubMed, MedMC, HealthSearch, and others. • Medical protocols and consensus statements endorsed by recognized institutions.

A Large Language Model (LLM) is an artificial intelligence model trained on large volumes of medical data. Its function is to process natural language and generate responses based on scientific evidence, helping physicians analyze clinical information more quickly and accurately.

If you feel the answer doesn't match your clinical judgment, you can:
• Review and adjust the information entered in the clinical case.
• Check the medical sources recommended by the tool.
• Supplement the evaluation with additional literature and your professional judgment.

Galeno IA immediately analyzes the clinical case, whether typed or dictated by voice, and within a couple of minutes generates a complete, categorized analysis for the physician to easily read, while also providing tools to explain the diagnosis to the patient in simple, concise language backed by certified medical literature.

The tool allows different types of analysis, such as:
• Comparisons with clinical practice guidelines.
• Evaluation of diagnostic probabilities based on the information entered.
• Analysis of treatment options supported by medical literature.
• Review of clinical trends in similar cases.

Yes. Galeno IA can generate comparisons between different treatment options based on clinical guidelines and recent scientific evidence for each specialty, producing an individual report for each specialty and helping assess which treatment option best fits the patient's context.

The database is updated periodically with new clinical guidelines, recent research, and scientific publications indexed on Google Cloud, ensuring information aligned with the latest medical advances.

Yes. Galeno IA includes a reporting component that allows the recorded information to be analyzed, supporting drug procurement management and the distribution of medical practice resources at different scales, enabling a thorough analysis of clinical data — making it a valuable complement to health research.

Only a certified physician may use the tool. However, under the guidance of a certified instructor, Galeno IA is ideal for medical education, allowing students to analyze clinical cases, understand treatment guidelines, and improve their clinical reasoning skills in a safe environment based on certified medical evidence.

PRIVACY AND SECURITY

Yes. The application complies with international data protection regulations, such as HIPAA and GDPR, ensuring the confidentiality of all information entered.

No, the application does not store personally identifiable patient information. The data entered is processed in real time and is not saved on the platform.

TECHNICAL SUPPORT

You can contact the technical support team directly from the application or write to info@galenoia.com

In the "Help" section within the platform, you'll find a form to send comments or suggestions directly to the development team, who provide support 24/7.

View all frequently asked questions

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