LEGAL NOTICE AND PRIVACY POLICY

SALMA HEALTH - UAE

Last Updated: February 6, 2026

We consider the privacy of our patients and users to be paramount. For this reason, we apply a policy of transparency to all our processes so that users are always informed and maintain control over their privacy.

Please read these terms carefully, which are intended to govern access to and use of this Application, and in general, the relationship between the Application and its users.

The services offered by this Application are for informational and monitoring support purposes. This Application does not, under any circumstances, offer medical diagnoses to its users. This Application can never replace the opinion of a physician or the need for an individualized medical consultation. If you are experiencing a medical emergency, you must consult with a healthcare professional immediately.


1. WHO IS RESPONSIBLE FOR YOUR DATA?

TRILEMA MIDDLE EAST - FZCO has developed this application (hereinafter the "APPLICATION") as part of a remote patient monitoring project that promotes health tracking and self-monitoring. You participate in this program as a patient of one of the participating healthcare facilities in the United Arab Emirates.

The data controller for your personal data is the participating healthcare facility where you are enrolled in the remote patient monitoring program. The contact details and information regarding the processing of your data through this APPLICATION are detailed in the informed consent you signed when accepting to participate in the program.

If you have any questions regarding this matter, you may contact the technical patient support service at soporte.salud@fundaciontrilema.org, and they will direct you to the appropriate contact method for your healthcare facility.

The legal basis for processing your data is founded on obtaining your consent and compliance with applicable UAE healthcare regulations and data protection laws.

Your Data Rights

You have the right to: - Access your personal data - Request rectification of inaccurate data - Request deletion of your data when no longer necessary - Limit the processing of your data - Object to processing for specific purposes - Withdraw your consent at any time.

You may exercise these rights through the contact method indicated by your participating healthcare facility or through soporte.salud@fundaciontrilema.org.

You also have the right to file a complaint with the relevant Data Protection Authority if you believe that the data controller has violated your rights.

You may contact the Data Protection Officer of your participating healthcare facility through the contact method indicated in the informed consent you signed. If you have any questions regarding this matter, you may contact us by email at soporte.salud@fundaciontrilema.org.

Your personal data will be retained for the period you participate in the monitoring program and, following your request for deletion or program completion, for the retention period established by UAE healthcare regulations (25 years from the last clinical entry).


2. TRILEMA MIDDLE EAST - FZCO CONTACT INFORMATION

Company Name: TRILEMA MIDDLE EAST - FZCO

License Number: 33786

Legal Status: Freezone Company

Issuing Authority: Dubai Integrated Economic Zones Authority

Registered Address: DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates

Manager: Maria Amor Alonso Navarro

Support Email: soporte.salud@fundaciontrilema.org

License Issue Date: August 14, 2023

License Expiry Date: August 13, 2026

Licensed Activities: - Medical and Surgical Equipment Trading - Information Technology Consultants - Computer Systems & Communication Equipment Software Trading - Computer Systems & Communication Equipment Software Design

Data Protection Officer: As designated by your participating healthcare facility


3. HOW WE OBTAIN YOUR DATA

The APPLICATION may obtain information through the following channels:

This information is collected to offer you our services according to your healthcare needs, always seeking to improve your experience as a user.

The APPLICATION creates a profile based on the information you provide. No automated decisions will be made based solely on this profile without human oversight.

The APPLICATION collects only data that is adequate, relevant, and limited to what is necessary for the provision of our monitoring services.


4. PURPOSES FOR USING YOUR DATA

We use your data for:


5. DATA RECIPIENTS AND PROCESSORS

In their capacity as data processors, the following entities will have access to your data:

AWS (Amazon Web Services) - UAE Region

As cloud infrastructure and data hosting provider. Data is stored exclusively within UAE data centers, ensuring compliance with data localization requirements. AWS maintains internationally recognized security certifications including ISO 27001, ISO 27017, ISO 27018, and SOC 2.

Integrated Medical Device Providers

When you use Bluetooth-enabled medical devices (such as blood pressure monitors, glucose meters, heart rate monitors, or other monitoring equipment), data from these certified devices may be transmitted to the Application to support your healthcare monitoring.

All data processors are bound by data processing agreements that ensure compliance with UAE data protection requirements and maintain the same level of security and confidentiality as TRILEMA MIDDLE EAST - FZCO.


6. TERMS OF USE

Application Purpose and Limitations

The APPLICATION has been developed by TRILEMA MIDDLE EAST - FZCO to provide support for recording information related to your medical condition, pharmacological treatment, self-monitoring variables, and health events. The information contained in the Application is for guidance purposes only and has been selected based on current scientific evidence to the greatest extent possible. However, it is not intended to replace the work of healthcare professionals under any circumstances.

The APPLICATION should not be considered a medical device or medical software application in any case. All information provided by the user must always be verified and confirmed with a physician or pharmacist in case of any doubt or health risk that may arise from its use. Therefore, any damage caused by the use of the information contained in this software application shall be the exclusive responsibility of the users themselves.

Use by Minors

Use of the services available in this Application by persons under 18 years of age requires prior authorization from their parents, guardians, or legal representatives, who will be considered legally responsible for any acts performed by minors under their care.

Legal representatives of minors have full responsibility for access to internet content and services by such minors. Software programs and filtering and blocking tools are available to control access to inappropriate content or websites for minors.

Disclosure to Third Parties

Data controllers will provide information to third parties when required by law, subpoena, or legal proceeding. In such cases, you will be informed prior to disclosure unless legally prohibited from doing so.


7. DATA SECURITY

The APPLICATION implements appropriate technical and organizational measures to provide a level of security appropriate to the risk, ensuring the confidentiality, integrity, and availability of your data.

Storage Infrastructure

The SALMA platform utilizes secure cloud infrastructure with the following security characteristics:

Cloud Infrastructure: - The APPLICATION uses AWS (Amazon Web Services) infrastructure located exclusively in UAE data centers - All data is stored within the United Arab Emirates in compliance with data localization requirements - AWS data centers are among the most secure in the world and are subject to the strictest controls to meet the most demanding security and data protection standards - AWS maintains certifications including ISO 27001, ISO 27017, ISO 27018, SOC 2, and other internationally recognized security standards

Data Processing Agreements: - A comprehensive data processing agreement has been executed with AWS that regulates and establishes the obligations and responsibilities contained in current data protection regulations - AWS provides contractual commitments regarding data security, privacy, and compliance with applicable laws

Platform Security

SSL/TLS Encryption: The APPLICATION incorporates SSL/TLS (Secure Socket Layer/Transport Layer Security) certificates throughout its infrastructure, utilizing industry-standard encryption protocols that encrypt all data transfers, preventing third parties from gaining access to confidential information.

End-to-End Security: All communications between the mobile application, web platform, and servers are encrypted using current industry standards, ensuring that data cannot be intercepted or accessed by unauthorized parties during transmission.

Mobile Application Security

The APPLICATION implements comprehensive security for native mobile applications, including:

These security layers protect against both passive and active analysis attempts, ensuring application integrity without impacting source code, functionality, or the development process.

Access Security (Authentication, Authorization, and Audit)

The APPLICATION incorporates comprehensive access control mechanisms:

Authentication:

Process of verifying the digital identity of users through secure login credentials, ensuring that users are who they claim to be. The system supports: - Username and password authentication - Multi-factor authentication when required by healthcare facilities - Biometric authentication options on supported devices - Single Sign-On (SSO) integration with healthcare facility systems

Authorization:

Process by which the APPLICATION's database authorizes identified users to access specific resources and functionalities based on their role (patient, caregiver, healthcare professional, administrator).

Audit Trail:

The system records all access to resources made by users, whether authorized or not, creating a complete audit trail for security monitoring and compliance purposes.

Communication Channel Security

The Application ensures secure communication with:

Security Best Practices for Users

Verify Server Authenticity:

Ensure that the server you connect to is located in the correct domain, even when using links saved in bookmarks.

Avoid Suspicious Links:

Do not use web addresses (URLs) or links received through electronic messaging (email, SMS, etc.) that request you to perform any action with your personal data.

Direct URL Entry:

Type website addresses directly into your browser rather than clicking on links.

Device Security:

- Keep your mobile device's operating system updated - Use device lock screens with PIN, password, or biometric authentication - Only download the APPLICATION from official app stores (Apple App Store, Google Play Store) - Be cautious when using public Wi-Fi networks for accessing health information - Report lost or stolen devices immediately to your healthcare facility


8. YOUR RIGHTS REGARDING YOUR DATA

You have the right to obtain confirmation about whether the APPLICATION is processing personal data concerning you.

You also have the right to access your personal data, request rectification of inaccurate data, or request deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

Under certain circumstances, you may request limitation of the processing of your data, in which case we will only retain it for the exercise or defense of claims.

Under certain circumstances and for reasons related to your particular situation, you may object to the processing of your data. The APPLICATION will cease processing the data, except for compelling legitimate reasons or for the exercise or defense of possible claims.

You have the right to request portability of your data and to withdraw consent for processing at any time.

You may exercise your rights by contacting the APPLICATION through the contact details previously mentioned, indicating “Data Protection Rights” in the subject line and attaching a copy of your Emirates ID or other valid legal identification document.

You have the right to file a complaint with the relevant supervisory authority.


9. YOUR OBLIGATIONS REGARDING THE DATA YOU PROVIDE

As the owner of your data, you must ensure its accuracy and agree to communicate any changes that occur.

Providing personal data is mandatory to use the services of the APPLICATION. Failure to provide the requested personal data or refusal to accept this data protection policy makes registration and use of this Application impossible.

As a user, you agree that information provided to the APPLICATION about third parties (such as family members or caregivers) has been collected in accordance with current regulations and after obtaining the consent of the data subject.

As a user of this Application, you agree to use the App, services, and content in accordance with UAE law, ethics, good customs, and public order.

You agree not to conduct advertising, promotional, or commercial activities through the Application, nor to use the content and, in particular, information obtained through the App to send advertising, send messages for direct sales purposes, or for any other commercial purpose, nor to collect or store personal data of third parties.

This Application may contain links to third-party websites, whose privacy policies are external to the APPLICATION. When accessing such websites, you must decide whether to accept their privacy and cookie policies.


10. UPDATES TO THIS LEGAL NOTICE

This LEGAL NOTICE will be updated periodically. The conditions that are in force and published at the time of using the Application or services will apply. We ask that you read this information carefully before using the Application, and periodically, in order to stay fully informed.

If you have any questions regarding this Legal Notice, you may contact us using the contact details previously referenced.


11. CONSENT

You declare that you have been informed of the conditions regarding the protection of personal data, accepting and consenting to the manual and automated processing thereof by the APPLICATION in the manner and for the purposes indicated in this Personal Data Protection Policy.

You may revoke any authorization at any time through the contact details provided.


12. APPLICABLE LAW AND JURISDICTION

This LEGAL NOTICE is governed by the laws of the United Arab Emirates. For any disputes arising from this Application, the parties submit to the jurisdiction of the courts of Dubai, expressly waiving any other jurisdiction that might correspond to them.


13. APPLICATION CONTENT AND LINKS

Links contained in our Application may direct to third-party web content. The purpose of such links is solely to facilitate your search for resources that may interest you on the Internet. However, such pages do not belong to the APPLICATION, and we do not review their content. Therefore, the APPLICATION assumes no responsibility for the content, information, or services that may appear on such sites, which shall be solely informative and shall in no case imply any relationship between the APPLICATION and the persons or entities owning such content or owners of the sites where they are found. The APPLICATION cannot be held responsible for the operation of the linked page or possible damage that may result from access to or use thereof.

Links to the APPLICATION's websites must respect the following conditions:

  1. Establishment of the link shall not imply any type of agreement, contract, sponsorship, or recommendation by the APPLICATION of the page creating the link.
  2. The website establishing the hyperlink shall not contain information with illegal, discriminatory content, contrary to commonly accepted ethical principles, or contrary to public order, nor shall it contain content contrary to any rights of third parties.
  3. The APPLICATION may request removal of a link to its website, without needing to give any reason. In such case, the page that created the link must proceed with its immediate removal upon receiving notification from the APPLICATION.
  4. The APPLICATION is not responsible in any way for, nor guarantees, the quality, accuracy, reliability, correctness, or morality of content or services that the establishment of the hyperlink may offer. The user assumes, under their exclusive responsibility, the consequences, damages, or actions that may result from access to the hyperlinked website.
  5. The website establishing the hyperlink may not contain trademarks, trade names, logos, slogans, or other distinctive signs belonging to the APPLICATION except for those signs that form part of the hyperlink itself.

14. INTELLECTUAL AND INDUSTRIAL PROPERTY

All elements that form the Application, including its structure, design, source code, logos, trademarks, and other distinctive signs appearing therein, are owned by the APPLICATION or its collaborators and are protected by corresponding intellectual and industrial property rights under UAE law and international treaties.

The images and other graphic elements contained are also protected by corresponding intellectual and industrial property rights.

The APPLICATION expressly prohibits “framing” or the use by third parties of any other mechanisms that alter the design, original configuration, or content of our platforms.

Use of content must respect its particular licensing. Therefore, use, reproduction, distribution, public communication, transformation, or any other similar or analogous activity is totally prohibited unless prior express authorization from the APPLICATION is obtained.

Regarding citations of third-party products or services, the APPLICATION recognizes in favor of their owners the corresponding industrial or intellectual property rights. Their mere mention or appearance on the website does not imply the existence of rights or any responsibility over them, nor endorsement, sponsorship, or recommendation.


15. LIABILITY

The APPLICATION does not guarantee the absence of errors in accessing the Application or its content, nor that it is up to date, although we are committed to making every effort to, where applicable, avoid, correct, or update them.

Both access to the APPLICATION and the use that may be made of the information contained therein is the exclusive responsibility of the person who performs it.

The APPLICATION is not responsible for possible security errors that may occur or possible damage that may be caused to the user's computer system (hardware and software), files, or documents stored therein, as a consequence of the presence of viruses on the user's computer used to connect to the services and content of the Application, a browser malfunction, or the use of non-updated versions thereof.

The APPLICATION is not responsible for information and content stored, including but not limited to forums, chats, blogs, comments, social networks, or any other means that allows third parties to publish content independently on it.

However, in compliance with applicable UAE laws, the APPLICATION makes itself available to all users, authorities, and security forces, actively collaborating in the removal or, where appropriate, blocking of all content that could affect or contravene national or international legislation, third-party rights, or morality and public order. If you believe that there is content on the website that could fall under this classification, please contact us.

The APPLICATION is not responsible for responses made through the various email addresses that appear on its platform. Therefore, in no case can legally binding effects be derived from them.


16. COOKIE POLICY

What Are Cookies?

The APPLICATION and its domains use cookies (small information files that the server sends to the computer of whoever accesses the page) for the correct functioning and visualization of the Application by the user, as well as the collection of statistics.

Use of Cookies

The APPLICATION, or on its behalf, a third party contracted for the provision of audience measurement services, may use cookies when a user navigates through the sites and pages of the website.

The APPLICATION's web servers automatically detect the IP address and domain name used by the user. All this information is recorded in a server activity file that allows subsequent processing of data to obtain statistical measurements that allow knowing the number of page impressions, number of visits made to web services, etc.

Third-Party Services

Additionally, the APPLICATION has presence on third-party portals and services for which, if you wish to know the privacy and cookie conditions, you must consult the policies provided by them:

Types of Cookies Used

Specifically, the cookies used by this Application are as follows:

Essential Cookies: - JSESSIONID - Used for session management. This cookie is essential for the Application to function properly. - Authentication cookies - Used for user authentication and password management.

Analytics Cookies: - **_ga, _gid, _gat** - These cookies are used by Google Analytics to distinguish users and throttle request rates. Duration: up to 2 years for _ga, 24 hours for _gid.

Google Analytics is a simple and easy-to-use tool that helps website owners measure how users interact with site content. When a user navigates website pages, Google Analytics provides the website owner with JavaScript tags (libraries) to record information about the page a user has viewed; for example, the URL of the page. Google Analytics JavaScript libraries use HTTP cookies to “remember” what a user has done on previous pages or interactions with the website.

Cookie Management and Removal

You may at any time access your browser settings to accept or reject all cookies, or select those whose installation you allow and which you do not, following one of the following procedures, depending on the browser you use:

Consent to Cookie Use

By using the APPLICATION, you declare that you have been informed of the conditions regarding the use of cookies, accepting and consenting to their use by the APPLICATION in the manner and for the purposes indicated in this Legal Notice.


17. FAMILY AND CAREGIVER INVOLVEMENT

The APPLICATION recognizes the important role that family members and caregivers play in supporting patient health in UAE culture. With your authorization, designated family members or caregivers may:

You maintain full control over what information caregivers can access and may modify or revoke these permissions at any time through the Application settings or by contacting your healthcare facility.


18. LANGUAGE

This Legal Notice and Privacy Policy has been prepared in English. In case of any translation into other languages, the English version shall prevail in case of discrepancies.


19. CONTACT FOR QUESTIONS OR CONCERNS

If you have any questions regarding this Legal Notice and Privacy Policy, or if you wish to exercise your data protection rights, you may contact:

Technical Patient Support:

Email: soporte.salud@fundaciontrilema.org

Your Healthcare Facility:

Please refer to the contact information provided in your informed consent documentation.

Data Protection Officer:

As designated by your participating healthcare facility (contact details provided in your informed consent).


By using the Salma Health Application, you acknowledge that you have read, understood, and agree to be bound by this Legal Notice and Privacy Policy.


Document Version: 1.0

Last Updated: February 6, 2026

Applicable to: Salma Health Application - United Arab Emirates