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DATA PROCESSING POLICY

National Dental Prosthesis Clinic S.A.S. (DENTAL ELITE)

PERSONAL DATA PROTECTION PROCESSING POLICY

National Dental Prosthesis Clinic S.A.S.

 

In compliance with the provisions of Statutory Law 1581 of 2012 and its Regulatory Decree 1377 of 2013 (today Chapter 25 of Decree 1074 of May 26, 2015), the company Clínica Nacional de Prótesis Dental S.A.S., adopts this policy for the treatment of personal data, which will be informed to all holders of the data collected or obtained in the future in the exercise of professional, commercial and labor activities, thus guaranteeing, Clínica Nacional de Prótesis Dental S.A.S. the rights of privacy, intimacy, good name, habeas data.

In the processing of personal data, and consequently all its actions will be governed by the principles of legality, purpose, freedom, truthfulness or quality, transparency, restricted access and circulation, security and confidentiality.

All people who, in the development of different activities, in the exercise of professional, commercial, labor and other activities, whether permanent or occasional, will supply the company Clínica Nacional de Prótesis Dental S.A.S. any type of information or personal data, you will be able to know it, update it and rectify it.

DATA PROCESSING RESPONSIBLE

NAME: National Dental Prosthesis Clinic S.A.S. (DENTAL ELITE)

NIT: 900.388.106-2.

ADDRESS: Carrera 44 #5 A – 66 Tequendama and Av. 3 Norte 44N – 63 Vipasa.

EMAIL: info@clinicaelitedental.com.co

PHONE: (+57) 320 8377257.

AREA OF APPLICATION.

This policy will be applicable to personal data registered in any database of Clínica Nacional de Prótesis Dental S.A.S., whose owner is patients, clients, employees, ambassadors, suppliers, commercial allies and in general to any natural or legal person who has a relationship with our company

 

DEFINITIONS. For the purposes of this policy and in accordance with current regulations on the protection of personal data, the following definitions will be taken into account.

AUTHORIZATION: Prior, express and informed consent of the Owner to carry out the Processing of personal data.

PRIVACY NOTICE: Verbal or written communication generated by the person responsible, addressed to the Owner for the processing of their personal data, through which they are informed about the existence of the information processing policies that will be applicable to them, the way to access to them and the purposes of the treatment that is intended to be given to personal data.

DATABASE: Organized set of personal data that is subject to processing.

CAUSEAGRENT: person who has succeeded another due to the latter's death (heir).

PERSONAL DATA: Any information linked or that can be associated with one or several specific or determinable natural persons.

PUBLIC DATA: It is data that is not semi-private, private or sensitive. Public data are considered, among others, data relating to the marital status of people, their profession or trade, and their status as a merchant or public servant. Due to its nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed judicial rulings that are not subject to confidentiality.

SENSITIVE DATA: Sensitive data is understood to be data that affects the privacy of the Owner or whose improper use may lead to discrimination, such as revealing racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, organizations. social, human rights or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.

PROCESSOR: Natural or legal person, public or private, who, by themselves or in association with others, carries out the Processing of personal data on behalf of the person responsible for the Treatment.

RESPONSIBLE FOR THE TREATMENT: Natural or legal person, public or private, who alone or in association with others, decides on the database and/or the Processing of the data.

OWNER: Natural person whose personal data is the subject of Treatment. PROCESSING: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

TRANSFER: the transfer of data takes place when the person responsible and/or in charge of the processing of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is responsible for the treatment and is located inside or outside from the country.

TRANSMISSION: processing of personal data that involves the communication thereof within or outside the territory of the Republic of Colombia when its purpose is to carry out processing by the person in charge on behalf of the person responsible.

BEGINNINGS.

For the purposes of guaranteeing the protection of personal data, our company will apply the principles provided for in statutory law 1581 of 2012 in its article 4, Decree 1377 of 2013, article 15 of the Political Constitution, Chapter 25 of decree 1074 of 26 May 2015, Regulatory Decree 886 of 2014, Decree 090 of January 18, 2018 and based on this, the processing, transfer and transmission of personal data must be carried out:

PRINCIPLE OF LEGALITY REGARDING DATA PROCESSING:

Data processing is a regulated activity, which must be subject to the current and applicable legal provisions governing the subject.

 

PRINCIPLE OF PURPOSE:

The personal data processing activity carried out by THE COMPANY or to which it has access, will obey a legitimate purpose in accordance with the Political Constitution of Colombia, which must be informed to the respective owner of the personal data.

 

PRINCIPLE OF FREEDOM:

The processing of personal data can only be carried out with the prior, express and informed consent of the Owner. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal, statutory, or judicial mandate that requires consent.

 

PRINCIPLE OF TRUTHFULNESS OR QUALITY:

The information subject to Personal Data Processing must be true, complete, accurate, updated, verifiable and understandable. The Processing of partial, incomplete, fragmented or misleading data is prohibited.

PRINCIPLE OF TRANSPARENCY:

In the processing of personal data, THE COMPANY will guarantee the Owner their right to obtain, at any time and without restrictions, information about the existence of any type of information or personal data that is of interest or ownership.

PRINCIPLE OF ACCESS AND RESTRICTED CIRCULATION:

The processing of personal data is subject to the limits derived from the nature of the data, the provisions of the law and the Constitution. Consequently, the treatment can only be carried out by people authorized by the owner and/or by the people provided for by law. Personal data, except public information, may not be available on the Internet or other means of dissemination or mass communication, unless access is technically controllable to provide knowledge restricted only to the owners or third parties authorized in accordance with the law. For these purposes, THE COMPANY's obligation will be medium.

SAFETY PRINCIPLE:

The information subject to treatment by THE COMPANY must be handled with the technical, human and administrative measures that are necessary to provide security to the records, avoiding their adulteration, loss, consultation, unauthorized or fraudulent use or access.

PRINCIPLE OF CONFIDENTIALITY:

All people who, in THE COMPANY, administer, manage, update or have access to information of any type found in databases, are obliged to guarantee the confidentiality of the information, for which they undertake to conserve and maintain in a manner strictly confidential and not reveal to third parties all the information that they come to know in the execution and exercise of their functions; except when these are activities expressly authorized by the data protection law. This obligation persists and will continue even after its relationship with any of the tasks included in the Treatment has ended.

 

RIGHTS OF THE INFORMATION OWNER.

In accordance with what is contemplated by the current applicable regulations on data protection, the following are the rights of the owners of personal data:

1. Access, know, update and rectify your personal data in front of the company Clínica Nacional de Prótesis Dental S.A.S. in its capacity as data controller. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or data whose processing is expressly prohibited or has not been authorized.

2. Be informed by Clínica Nacional de Prótesis Dental S.A.S., upon request, regarding the use that has been given to your personal data.

 

3. Submit a complaint to the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and the other regulations that modify, add or complement it, once the claim process has been exhausted before the person responsible or in charge of processing the data. personal information.

 

4. Revoke the authorization and/or request the deletion of the data when the Processing does not respect constitutional and legal principles, rights and guarantees.

 

5. Access free of charge to your personal data that has been processed, at least once every calendar month, and each time there are substantial modifications to this policy that motivate new queries.

 

6. Know the entity's data processing policy and, through it, the use or purpose that will be given to your personal data.

 

7. The others indicated by article 8 of Law 1581 of 2012.

RIGHTS OF CHILDREN AND ADOLESCENTS.

In the processing of personal data, respect for the prevailing rights of minors will be ensured. The processing of personal data of minors is prohibited, except for those data that are public in nature, and in this case the processing must comply with the following parameters: a. Respond to and respect the best interests of minors. b. Ensure respect for the fundamental rights of minors.

DUTIES OF CLÍNICA NACIONAL DE PROTESIS DENTAL S.A.S.

As responsible and in charge of data processing, the company undertakes to comply with the following duties, without prejudice to the other provisions provided for by law, in the provisions that refer to the processing of personal data:

 

1. Guarantee to the Holder, at all times, the full and effective exercise of the right of habeas data;

 

2. Request and keep, under the conditions provided in this law, a copy of the respective authorization granted by the Owner;

 

3. Duly inform the owner about the purpose of the collection and the rights granted to him by virtue of the authorization granted;

 

4. Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access;

 

5. Guarantee that the information provided to the data processor is true, complete, accurate, updated, verifiable and understandable;

 

6. Update the information, communicating in a timely manner to the Data Processor, all the news regarding the data that you have previously provided and adopt the other necessary measures so that the information provided to it remains updated;

 

7. Rectify the information when it is incorrect and communicate the pertinent information to the Data Processor;

 

8. Provide the person in charge of processing, as the case may be, only data whose Processing is previously authorized in accordance with the provisions of this law.

 

9. Demand that the data processor at all times respect the security and privacy conditions of the owner's information;

 

10. Process queries and claims made in the terms indicated in this law;

 

11. Adopt an internal manual of policies and procedures to guarantee adequate compliance with the law and, especially, to respond to queries and complaints;

 

12. Inform the data processor when certain information is under discussion by the owner, once the claim has been submitted and the respective process has not been completed;

 

13. Inform at the request of the Owner about the use given to their data;

 

14. Inform the data protection authority when violations of security codes occur and there are risks in the administration of the Owners' information.

 

15. Comply with the instructions and requirements issued by the Superintendence of Industry and Commerce.

 

16. Only use data whose processing is previously authorized in accordance with the provisions of Law 1581 of 2012.

 

17. Allow access to information only to people who can have access to it.

 

18. Use the personal data of the owner only for those purposes for which it is duly authorized and respecting in all cases the current regulations on the protection of personal data.

AUTHORIZATION AND CONSENT OF THE OWNER.

In data processing, the prior and informed authorization of the owner is required, as established in article 9 of law 1581 of 2012, therefore, the company will require the free, prior, express and informed consent of the data owner. personal for their treatment.

Manifestation of authorization for the use of data by individuals to the company:

 

1. The owner, who must prove his/her identity sufficiently by the different means made available to him/her.

2. The successors in title of the owner, who must prove such quality.

 

3. The representative and/or attorney-in-fact of the owner, after accreditation of the representation or power of attorney.

 

Authorization will not be required from the data owners in the following cases, which are excepted and authorized by law:

 

1. Information required by a public or administrative entity in the exercise of its legal functions or by court order.

 

2. Data of a public nature.

 

3. Cases of medical or health emergency.

 

4. Processing of information authorized by law for historical, statistical or scientific purposes.

 

5. Data related to the Civil Registry of Persons.

MEANS TO GRANT AUTHORIZATION.

Clínica Nacional de Prótesis Dental S.A.S., will obtain authorization through different means, including physical document, electronic document, data message, Internet, Websites, or in any other format that in any case allows obtaining consent through unequivocal conduct through from which it is concluded that if it had not been supplied by the owner or the person authorized to do so, the data would not have been stored or captured in the database.

Authorization will be requested by our company prior to processing personal data.

PROOF OF AUTHORIZATION. The company will retain proof of the authorization granted by the owners of the personal data for its processing, for which it will use the mechanisms currently available to it as well as adopt the necessary actions to maintain the record of the form and date and in which he obtained this. Consequently, the company may establish physical files or electronic repositories made directly or through third parties hired for this purpose.

REVOCATION OF AUTHORIZATION. The owners of personal data may at any time revoke the authorization granted to the company for the processing of their personal data or request its deletion, as long as it is not prevented by a legal or contractual provision.

National Dental Prosthesis Clinic S.A.S. will establish simple and free mechanisms that allow the owner to revoke their authorization or request the deletion of their personal data, at least by the same means by which it was granted. For the above, it must be taken into account that the revocation of consent can be expressed, on the one hand, entirely in relation to the authorized purposes, and therefore the company must cease any data processing activity; and on the other hand partially in relation to certain types of processing, in which case these will be the ones on which the processing activities will cease, such as for advertising purposes, among others.

In the latter case, the company may continue processing personal data for those purposes in relation to which the owner has not revoked his or her consent.

It is necessary to remember that the information recorded in the medical records, referred to in Resolution No. 1995 of 1999 of the Ministry of Health, cannot be deleted, not even at the request of its owner by law. Nor the data that make up the records and/or data of the Individual Registry of Provision of Health Services (RIPS), regulated by Resolution 3374 of 2000 of the Min Salud. TREATMENT TO WHICH THE DATA WILL BE SUBJECTED AND PURPOSE OF THE SAME.

 

1. Data processing and purposes thereof.

 

2. Make security videos; taking into account that it is for the well-being of patients, workers, service providers and other people who enter the facilities, always understanding that my data and images will be treated privately and respectfully in accordance with the provisions of this document. With respect to the images collected by security cameras, they will be used solely for security purposes, and internal company purposes such as reducing incidents of insecurity, improving the effectiveness of the company's workers and increasing the benefit for the company. company. In eventual cases, security videos may be used to contribute to judicial proceedings.

 

3. compliance with the contractual commitments signed between the Clínica Nacional de Prótesis Dental S.A.S. and the data owners.

 

4. Processes for updating, scheduling and confirming agendas and appointments.

 

5. Sending information about our promotions on treatments and products.

 

6. offer you new services and products related to our activity in the dental field.

 

7. sending information about events and oral health campaigns, promotions and offers.

 

8. inform about changes to our products and/or services, so that the owners of the information are updated about our service offering.

 

9. Conduct surveys related to the services or goods of the company Clínica Nacional de Prótesis Dental S.A.S. in order to improve the attention and quality of the services provided by the company.

 

10. capture of the image of the users, for the purposes of distribution, reproduction and public communication through the photos and videos taken by the photography and video team of the company Clínica Nacional de Prótesis Dental S.A.S., image that will be captured during the carrying out the dental procedures that are performed or after that, with prior authorization from the users or owners of the data, making it completely clear to the owners of the data that since it is sensitive data they can refrain from issuing said authorization, since it does not You are obliged to grant it, this, so that the company can use the image to advertise its services or products on its social networks, website or company offices. as long as the patient previously authorizes the use of their image data for this purpose.

 

11. Regarding the data of contractors and suppliers, their data will be processed in order to meet the obligations that arise from the corresponding contracts. They will be processed for the purpose of verifying references, evaluating their performance, as well as carrying out statistical analysis.

 

12. Regarding the contracts of the company's collaborators or workers, it is considered that the activities necessary to fulfill its purpose include the processing of financial data for the purposes of payment and social security obligations, as well as inclusion in the company's benefits program, performance evaluations and training programs.

 

13. Information regarding patient health data strictly related to their oral health, with the purpose of keeping control of the dental procedures contracted by users. Data that will be recorded in the medical records. 1. Biometric information (audio, video and/or photography).

The information that is collected by the company in relation to video, audio, and/or photography will be processed for the following purposes.

1. Have a security scheme that allows easy access for users, fully identify through video surveillance, the security of the assets of Clínica Nacional de Prótesis Dental S.A.S., its clients, suppliers and visitors. The collection and treatment will be optional and requires written authorization from the owner, with the exception of the information obtained through the video surveillance scheme, for which a privacy notice located in the company's headquarters facilities will be sufficient, which must inform attendees of the presence and purpose of the cameras.

2. In relation to users who have been previously informed and after they issue their authorization, their image will be captured for the purposes of distribution, reproduction and public communication through the photos and videos taken by the photography team and video of the company Clínica Nacional de Prótesis Dental S.A.S., image that will be captured during the performance of the dental procedures that are performed or after it, prior authorization from the users or owners of the data, making it completely clear to the owners of the data Since it is sensitive data, they may refrain from issuing said authorization, since they are not obliged to grant it. The collection of this data will be used by the company with the purpose of showing to the general public testimonials and results obtained by users after the provision of the dental service, based on real testimonies and images, and will also have the purpose of advertising the services or company products on social networks, website or company offices. NOTICE OF PRIVACY.

The Privacy Notice is the physical, electronic or any other format document made available to the owner to inform them about the processing of their personal data. Through this document, the owner is informed of the information related to the existence of the company's information processing policies and that they will be applicable, the way to access them and the characteristics of the treatment that is intended to be given to the data. collected personal data. The privacy notice must contain, at a minimum, the following information:

1. The identity, address and contact information of the person responsible for the treatment.

2. The type of processing to which the data will be subjected and its purpose.

3. The rights of the owner.

4. The general mechanisms established by the person responsible so that the owner is aware of the information processing policy and the substantial changes that occur in it. In all cases, you must inform the owner how to access or consult the information processing policy.

5. The optional nature of the response regarding questions about sensitive data. GUARANTEES OF THE RIGHT OF ACCESS TO DATA.

To guarantee the right of access of the data owner, Clínica Nacional de Prótesis Dental S.A.S. will make available to the latter, after accreditation of their identity, legitimacy, or personality of their representative, at no cost or expense, in a detailed and detailed manner, the respective personal data through all types of media, including electronic media that allow the owner's direct access to them. Said access must be offered without any limit and must allow the owner the possibility of knowing and updating them online.

PROCEDURE FOR CONSULTATION ABOUT THE PROCESSING OF DATA BY ITS OWNERS.

National Dental Prosthesis Clinic S.A.S. provides the appropriate means for the holders of personal data to consult about the processing of their data, which will be informed within the personal data collection forms.

PROCEDURE TO CORRECT, UPDATE, RECTIFY OR DELETE THE DATA.

National Dental Prosthesis Clinic S.A.S. In compliance with the General Personal Data Protection Regime, it will proceed to correct, update, rectify or delete personal data at the request of the owner or his representative, in the terms indicated in the law.

PROCEDURE FOR DELETION OF DATA.

The owner of personal data has the right to request the company to delete it in any of the following events:

 

1. Consider that they are not being treated in accordance with the principles, duties and obligations provided for in current regulations.

 

2. They have ceased to be necessary or relevant for the purpose for which they were collected.

 

3. The period necessary to fulfill the purposes for which they were collected has been exceeded.

This deletion implies the total or partial elimination of personal information in accordance with what is requested by the owner in the records, files, databases or treatments carried out by Clínica Nacional de Prótesis Dental S.A.S. However, this right of the owner is not absolute and consequently Clínica Nacional de Prótesis Dental S.A.S. may deny the exercise of the same when:

a) The owner has a legal or contractual duty to remain in the database.

b) The deletion of data hinders judicial or administrative actions linked to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.

c) The data is necessary to protect the legally protected interests of the owner; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the owner.

 

RESPONSIBLE AND IN CHARGE OF THE PROCESSING OF PERSONAL DATA. National Dental Prosthesis Clinic S.A.S. acts as RESPONSIBLE for the processing of personal data by virtue of the collection it carries out directly of the data of its patients, clients, employees, ambassadors, suppliers, business allies and in general any natural or legal person who has a relationship with our company, in addition acts as PROCESSOR of the processing of personal data by virtue of the agreements and agreements to share personal data that it signs with third parties for the purpose of making offers of commercial services, as well as to carry out the entrusted work.

National Dental Prosthesis Clinic S.A.S. As the person responsible or in charge of the processing of personal data, you may enter into alliances or agreements for the offer of commercial services, for which you have obtained the prior, informed and express consent of the data owners and those responsible for the processing of personal data, thus guaranteeing the rights to data protection.

DATA TRANSFERS FOR PROCESSING BY NATIONAL AND INTERNATIONAL THIRD PARTIES.

National Dental Prosthesis Clinic S.A.S. may transmit or transfer personal data partially or totally to third parties in the country or abroad, in the development of its corporate purpose, for which I previously request authorization from its owner and implement the necessary actions to comply with the legal precepts. of Colombia, through the signing of agreements and agreements to share personal data for the offer of commercial services.

VALIDITY OF THE POLICY.

This policy takes effect from the date of its publication and leaves without effect any other institutional provisions that are contrary to it. Anything not provided for in this manual will be regulated in accordance with the General Personal Data Protection Regime in force in Colombia.

 

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