Privacy Policy

Effective September 2026

This document constitutes the Privacy Policy of LAD S.A. (hereinafter, LAD, the “Controller” or the “Company”, interchangeably), which governs the processing of users’ personal data, its scope, and the rights of data subjects.

LAD’s Privacy Policy applies to all LAD Users, even if they are not duly registered (hereinafter, the “Users”). The remaining definitions used in LAD’s Terms and Conditions also apply to this Privacy Policy. Through this Privacy Policy, we inform You, as a LAD User, about how the Company collects and processes your personal information and the actions available to You regarding the use of your Personal Data.

1. Definitions

a. Personal Data: Information of any kind relating to identified or identifiable natural or legal persons. In simple terms, any information related to a person that allows that person to be identified (name, surname, identity card, identity document or passport, date of birth, medical data, health insurance, geographic location, sex, etc.).

b. Sensitive Data: Personal data revealing racial or ethnic origin, political opinions, religious, philosophical or moral beliefs, trade union membership, and information concerning health or sex life.

c. Processing of personal data: Systematic operations and procedures, whether electronic or otherwise, that allow the collection, retention, organization, storage, modification, linkage, evaluation, blocking, destruction and, in general, processing of personal data, as well as its disclosure to third parties through communications, consultations, interconnections or transfers.

d. Data Subject: Any natural or legal person whose data is subject to processing. In this case, the User of the service is the data subject of their personal data.

e. Controller of personal data: LAD is the Controller of all data collected through its mobile application or its website www.llamandoaldoctor.com, or through other means that may be made available to users in the future. LAD S.A.S is a company legally incorporated in the Eastern Republic of Uruguay, with RUT No. 218918230018 and registered address at Treinta y Tres 1271, Montevideo. The database where user data is stored and processed is located in the United States, on Amazon Web Services servers, the most widely recognized international provider of data storage and processing services worldwide.

f. Service Payers: organizations that finance LAD’s service for their clients, users, members or affiliates.

2. Data Collection

In compliance with applicable personal data protection regulations, in particular:

• Argentine Law No. 25,326 on personal data protection, Regulatory Decree 1558/01 and supplementary regulations (the “Argentine PDPL”).
• Regulation (EU) 2016/679 of the European Parliament and of the Council dated 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”).
• Brazil’s General Data Protection Law, Law No. 13,709 (the “LGPD”).
• Mexico’s Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP).
• Colombian Personal Data Protection Law No. 1581.

Llamando al Doctor collects personal data in its possession when the User:

1. completes forms on https://app.llamandoaldoctor.com (the “Site”), the app and/or the Company’s platform;
2. responds to a survey;
3. sends an email or contacts us by telephone, after which the information is entered into the corresponding forms.

What do we collect or may we collect?

LAD may collect or request the following data:

• First and last name.
• National Identity Document.
• Passport.
• Sex.
• Date of birth.
• Health plan / Obra Social and membership number.
• Email address.
• Telephone number.
• Password.
• Family members enrolled in a family plan.
• Specialty and reason for consultation.
• Medical Record, including medical history.
• Description of the consultation.
• Data related to health conditions or medical consultations.
• Your IP address.
• The type of device used to access the service.
• Web browser type.
• Operating system.
• Geographic location.
• Your voice and image during the video consultation, which are processed in real time to enable communication between the User and the medical professional. LAD does not record or store consultations as audio or video files.
• Consultation times.
• Consultation duration.
• Preliminary diagnosis.
• Medical progress notes.
• Medical test results.
• Outcome of consultations.

3. Purposes of Collection

Personal data collected by LAD will be processed, as applicable, for the following purposes:

a. Provision of the service. To identify the User, create and manage their profile or identifier within the platform, and enable access to and use of the services offered by LAD.

b. Medical care. To provide the medical professional with the information necessary to deliver the corresponding care, including medical history, reason for consultation, and other relevant clinical information.

c. Platform operation, security and improvement. Technical data related to the device, IP address, browser, operating system and use of the platform may be processed to enable operation of the service, maintain security and traceability, detect errors or misuse, measure performance, and improve the User experience.

Functional and performance analyses of the platform are carried out using technical data, internal identifiers and usage events. Their purpose is not to analyze the content of the Medical Record or to use clinical information for marketing activities.

d. Video consultations. Audio and video from the consultation are processed in real time solely to enable communication between the User and the medical professional. LAD does not record or store consultations as audio or video files.

e. Billing and operational management. Information relating to the consultation, including date, time, duration, specialty and other necessary data, may be used for administrative management and billing of services to Service Payers.

f. Medical Record. Information recorded by medical professionals as a result of a consultation may form part of the patient’s Medical Record and will be retained and made available to persons lawfully authorized to access it, in accordance with applicable law.

Where necessary for medical care, access to health benefits, coordination of the service, or compliance with legal or contractual obligations, certain information may be disclosed to Service Payers or other authorized recipients in accordance with this Policy and applicable law.

g. Technology tools and service providers. LAD may use its own or third-party technology services to operate, secure, maintain and properly provide the platform, subject to the conditions set out in this Policy.

4. Legal bases for processing

The legal basis applicable to the processing of personal data will depend on the purpose of the processing and the relevant law.

Depending on the circumstances, LAD may process personal data on the basis of the data subject’s consent, the provision of the service or performance of the relevant relationship, compliance with legal or regulatory obligations, and any other legal bases recognized under applicable law.

Where processing involves sensitive data or health-related information, LAD will apply the specific conditions and legal bases required by the relevant legislation.

5. Disclosure of Data to third parties and service providers

LAD may disclose or allow access to personal data where necessary to provide the service, where a valid legal basis exists, or where otherwise permitted or required under applicable law.

Possible recipients include, depending on the operation:

• Service Payers, where necessary to manage coverage, service delivery, billing, auditing, or other aspects of the relevant relationship.
• Medical professionals and authorized personnel, solely with respect to information necessary to perform their duties and in accordance with applicable permissions and responsibilities.
• Technology service providers, where necessary to provide infrastructure, storage, authentication, communications, video consultation, support, security, functional analytics, or other services required for operation of the platform.
• Judicial, administrative or regulatory authorities, where a valid request exists or LAD must make a disclosure in order to comply with a legal obligation.
• Other third parties, where authorized by the data subject or where another valid legal basis permits the disclosure.

LAD seeks to limit information disclosed to third parties to what is necessary for the relevant purpose and applies appropriate contractual conditions and data protection safeguards.

Where processing or disclosure is specifically based on the data subject’s consent, the data subject may withdraw such consent in accordance with applicable law. Withdrawal will not affect processing carried out previously or processing that must continue on another valid legal basis.

6. International Data Transfers

For the provision of the service, certain personal data may be stored or processed outside the country where the User is located, including through infrastructure and technology service providers located in the United States or other jurisdictions.

LAD will adopt the contractual, technical and organizational measures required under applicable law to protect personal data subject to international transfers.

Where applicable law requires the data subject’s consent or another specific mechanism to carry out an international transfer, LAD will apply the relevant mechanism.

7. Security

LAD implements technical and organizational measures intended to protect personal data against unauthorized access, loss, alteration, disclosure or destruction, taking into account the nature of the data processed and the risks associated with the processing.

No information system can guarantee absolute security. LAD reviews and adapts its protective measures in line with the evolution of its systems, services and risks.

The Site may contain links to third-party websites, with or without advertising content, whose privacy policies are independent of Llamando al Doctor. The linked sites have no relationship with Llamando al Doctor, and their existence does not imply any suggestion, invitation or recommendation to visit the destinations, or any relationship or association between Llamando al Doctor and such sites. Llamando al Doctor is not responsible and shall not be liable for the content, use or activities of these linked websites, or for any current or potential, material or moral, direct or indirect damages suffered by users arising from the information contained on such sites or from relationships users may establish with third parties whose services have been published on the Site.

8. Data retention and deletion

LAD will retain personal data for the periods required under applicable law and for as long as necessary for the purposes for which it was processed, compliance with legal or regulatory obligations, handling of data subject rights, and, where applicable, the defense of the rights of LAD or third parties.

Retention periods may vary depending on the nature of the information and the applicable jurisdiction, particularly with respect to clinical documentation. LAD does not apply a single automatic deletion period to all categories of information.

Where a valid deletion request must be honored, deletion will be carried out in the relevant systems, without prejudice to information that must be retained under applicable law.

Certain copies of information deleted from active systems may remain temporarily in technical backups until they are replaced, rotated or expire in accordance with their retention cycles.

9. Data subject rights

Data subjects may exercise the rights recognized under applicable law, including, as applicable, rights of access, rectification, updating, deletion, objection, restriction of processing, portability and confidentiality.

Requests may be submitted through the data protection tools available within the platform or through LAD’s enabled contact channels, including contacto@llamandoaldoctor.com.

LAD may request information reasonably necessary to verify the identity of the requester and protect the confidentiality of the information.

Users may request access to their Medical Record and to other personal data as provided under applicable law.

Where it is necessary to correct information contained in a Medical Record, LAD will apply the rectification mechanisms permitted under the relevant healthcare legislation, preserving the integrity, traceability and original clinical documentation. A Medical Record that has already been issued will not be modified in a manner that causes the original record of care to be lost.

The exercise of a right to deletion may be limited where a legal or regulatory obligation requires certain information to be retained.

10. Complaints to data protection authorities

Without prejudice to the support and rights-exercise channels offered by LAD, the data subject may submit inquiries, petitions or complaints to the competent data protection authority where permitted by applicable law in their jurisdiction.

LAD may guide the data subject regarding available channels for exercising their rights or submitting a complaint where necessary.

11. Data relating to minors

Where the service is used for the care of a minor, access and the relevant authorizations must be provided by the minor’s parents, legal representatives or authorized persons, in accordance with applicable law and the access model defined for the service.

The minor’s personal and health data will be processed exclusively for the provision of the service and for the other legitimate purposes described in this Policy.

Rights relating to such data may be exercised by the data subject or by their representative, as applicable according to the data subject’s age, degree of autonomy and applicable law.

12. Cookies and similar technologies

LAD’s websites and web applications may use cookies and similar technologies necessary for operation, security, authentication and provision of the service, as well as tools intended to understand and improve the operation and use of the platform.

Where applicable law requires consent for the use of non-essential cookies or technologies, the User may accept, reject or subsequently change their preferences through the consent management tool available on the site.

Rejecting non-essential cookies will not prevent the use of technologies that are strictly necessary for operation, security or provision of the service.

13. Consent

Where consent is the applicable legal basis, LAD will request a freely given, informed and unambiguous indication from the data subject, in accordance with the requirements established by the relevant legislation.

Acceptance of this Policy enables the User to understand the conditions under which LAD processes personal data. Depending on the purpose and applicable jurisdiction, certain processing activities may also rely on other legal bases, such as the provision of the service or compliance with legal or regulatory obligations.

Where processing is based on consent, the data subject may withdraw that consent through the available channels.

Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal, nor any processing that must continue on another valid legal basis, including applicable retention obligations.

14. Changes to the Privacy Policy

LAD may amend this Privacy Policy where necessary as a result of regulatory, operational or technological changes, or changes related to the services provided.

Where a new version applies to the User, LAD will make the relevant information available and, where necessary, may require renewed acceptance before allowing continued use of the service.

Failure to accept a new version may prevent continued use of the service where such acceptance is necessary, but will not by itself result in the automatic deletion of personal data.

Retention or deletion of data will continue to be governed by this Policy, applicable law and the rights of the data subject.

15. Contact

For questions relating to this Policy, privacy, personal data protection or the exercise of rights, Users may contact LAD at: