INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA BY

Integra Medical Services SA

 

In accordance with the provisions of the European Regulation no. 679/2016 (hereinafter referred to as "GDPR"), in force as of May 25, 2018, Integra Medical Services SA ("Life Dental Spa") is obliged to process personal data, in secure conditions, for the general purposes specified in this information, in the context of providing medical services that you receive in the Life Dental Spa clinics.

 

1. PREAMBLE

 

Life Dental Spa is committed to providing a GDPR-compliant level of confidentiality, availability and integrity of personal data relating to any data subject through the processing activities carried out, including our service or marketing activities.

With this information we want to explain how your personal data is processed by Life Dental Spa.

Personal data (representing any kind of information that may lead to the identification, directly or indirectly, of a natural person) are detailed in section 6 below, being defined in consideration of the applicable legal provisions.

In order to fulfill the purposes of this information, we inform you that Life Dental Spa is a controller of personal data, as defined by GDPR.

 

2. THE IDENTITY AND CONTACT DETAILS OF THE OPERATOR

 

Name: name: Integra Medical Services SA

Registered office: 39, Martha Bibescu Street, Balotesti, Ilfov

C.U.I. 24144100

ORC Nr.: J23/6312/2022

Phone: 0318282274

E-mail: office@lifedentalspa.ro

 

3. CONTACT DETAILS OF THE DATA PROTECTION OFFICER (DPO)

 

The contact details of the person responsible for data protection (also called "DPO", en. Data Protection Officer) within Life Dental Spa that you can contact in relation to any issues concerning the protection of your personal data:

E-mail: office@lifedentalspa.ro

 

4. THE PURPOSES FOR WHICH YOUR PERSONAL DATA ARE PROCESSED

 

The processing and storage of personal data is done under optimal security conditions and for legitimate purposes mainly related to the performance of the activity of providing medical services or related to human resources activity, for advertising, marketing, publicity, statistics, or scientific. Whenever we request the collection, further processing and possible transfer of personal data, the use will be made only for the purposes mentioned, for other purposes you must give your consent or be informed in accordance with the GDPR.

Your personal data indicated in section 6 below will be processed for the following purposes:

1. Provision of medical services: providing medical services requested by you, establishing a medical diagnosis, providing medical care or medical treatment or managing health systems and services, recording medical services provided, communicating with you about the medical services provided, informing you about the medical services provided, scheduling appointments, identifying you and the services accessed.
2. Marketing: periodical information of a medical nature or regarding Life Dental Spa services, promotions, etc. Processing for this purpose will be carried out only if you have given your written consent and only for as long as you maintain this consent. You can withdraw this consent at any time by clicking on the "Unsubscribe" link in the footer of any e-mail you receive from us or by contacting us at office@lifedentlspa.ro
3. Medical statistics or scientific purpose: Processing for this purpose will be carried out only at the written request of the institutions of the statute with attributions in the field of statistics, respectively for scientific purposes. Your personal data will remain secure and confidential and will not be disclosed to third parties.
4. Fulfillment of legal obligations: processing in order to fulfill the various legal obligations of Life Dental Spa (such as: in the field of health, security, accounting, record keeping or other obligations imposed by applicable laws).
5. Improving services and resolving complaints: identifying problems or possible relevant issues related to existing services in order to improve them, implementing new services or improvements to existing ones, resolving your complaints.
6. Video surveillance: Life Dental Spa processes personal data by means of video surveillance, the purpose of the processing is to ensure the security of persons and property, as well as the security and protection of property, real estate, valuables, without prejudice to your fundamental rights and freedoms or your interest. The processing of personal data through the use of video surveillance systems takes into account the following rules: video surveillance cameras shall be located in visible, signposted places, and data subjects shall be informed of their existence by means of an information board made for that purpose; no personal data relating to racial or ethnic origin, political, religious or philosophical beliefs, trade union membership, state of health or sex life shall be processed by means of video surveillance; video surveillance cameras shall not be installed inside offices or in spaces where the privacy of individuals is required or which are not intended for the performance of work tasks, such as: Locker rooms, shower rooms, restrooms and other similar locations.
7. Financial record keeping: Issuance of financial-accounting documents to you (for example: receipts or tax invoices), collection of payments for services you receive, recovery of debts from you (which may also involve the involvement of third parties for debt recovery), refund of money to you, sending notifications related to the financial situation / payment status, drafting various reports or statements related to financial records.
8. Dispute Resolution: formulating various requests / opinions in the event of disputes arising in connection with the services provided to you and / or relating to the relationship established between you and Life Dental Spa.
9. Internal and external audit activity management: conducting external and internal audit activity to verify operational activities.

 

Life Dental Spa mentions that there is no automated decision-making process (including profiling) based on your personal data and we assume responsibility and ensure security only for that information, personal data and special categories of personal data (health data; genetic data; if applicable) that are provided and processed by Life Dental Spa staff (including doctors and nurses) exclusively and by the accumulation of the following coordinates:

1. in Life Dental Spa clinics;
2. in computerized and/or electronic systems/instruments/devices, hardware and software, Life Dental Spa records;
3. within the working hours of Life Dental Spa clinics.

Life Dental Spa is not responsible for the processing carried out, in any form whatsoever, outside the above-mentioned coordinates (including through the exchange/recording of personal information/data in the context of conversations between doctors and patients).

 

5. LEGAL BASIS FOR PROCESSING PERSONAL DATA

 

The legal grounds for the personal data processing operations carried out by Life Dental Spa are:

1. Grounds for the processing of personal data that do not fall into special categories of personal data (according to art. 6 of GDPR).

Personal data that do not comprise special categories of personal data (as defined under Article 9 of GDPR) are processed by Life Dental Spa on the following legal grounds:

1. to offer or to execute a contract concluded by Life Dental Spa with you (having as object the medical services provided by Life Dental Spa);
2. in marketing communications, we will process your personal data based on your express consent (this consent is requested either by filling out a form in one of the Life Dental Spa clinics which can be done either upon initial registration in the database or later upon registration in the forms on the website; participation in events, etc.), as detailed above;
3. for the purpose of continuous improvement of medical services, your personal data is processed on the basis of your prior consent;
4. fulfilling the legal obligations of Life Dental Spa (including archiving, health, security, record keeping, public authority request and other obligations that the legislation imposes);
5. in certain situations, we will process personal data on the basis of a legitimate interest of Life Dental Spa or a third party (such as: drawing up the records of medical services; keeping records of appointments in the software system; dealing with requests and complaints received from patients; concluding and executing contracts for the provision of medical services with partners and collaborators who provide medical services for Life Dental Spa; surveillance by the video camera system to ensure the security of goods and persons - if there is no legal obligation to do so; management of internal and external audit activity, transmission within the group of which Life Dental Spa is part).

2. Processing of personal data that fall into special categories of personal data (according to art. 9 of GDPR).

In consideration of the specificity of the medical activity/services provided by Life Dental Spa, we will process personal data that fall into the category of special data (as defined under art. 9 of the GDPR) on the following legal grounds (grounds that will apply in addition to the grounds detailed in art. 6 of the GDPR):

1. in order to establish a medical diagnosis, to provide healthcare or medical treatment, or to manage health systems and/or services;
2. in consideration of certain situations in which you may find yourself (physically or legally) and which may make it difficult for you to give your consent to the processing (for example: emergency situations), personal data will be processed in order to protect the vital interests of you or another natural person;
3. the processing is necessary for reasons of public interest in the field of public health (such as: protection against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicines or medical devices, under European Union or national law); and/or
4. the processing is necessary for the establishment, exercise or defense of a right in a court of law, given that, during the relationship established with Life Dental Spa, it cannot be excluded that such situations may arise in the context of the services provided (to the extent that such disputes are referred to the courts).

 

6. THE CATEGORIES OF PERSONAL DATA CONCERNED. CONSEQUENCES OF REFUSAL TO PROVIDE PERSONAL DATA

 

The personal data that will be processed by Life Dental Spa are:

1. data obtained directly from you in the context of the services provided or
2. data / results obtained as a result of the services provided by Life Dental Spa.

The personal information that you provide when making an appointment by phone, e-mail or in clinics (name, surname, telephone, e-mail, date of birth, symptoms, data on the tests and investigations performed or that you wish to have performed, CNP) are recorded and processed by Life Dental Spa only to the extent that this information has been provided by you without any constraint and with prior information. Life Dental Spa assumes no responsibility for inaccurate, incorrect information/data/documents that you provide to us. It is your obligation to inform us of any changes to your personal data so that it is always accurate and up-to-date. If Life Dental Spa has suspicions about the authenticity of the documents or information made available, it is entitled to notify the authorities/public institutions with powers of investigation, supervision and control.

Personal data includes the following categories of data:

1. contact data, such as: name and surname, home/residence address, telephone number (landline and/or mobile) and/or fax number, e-mail address, correspondence address;
2. personal data, such as: date of birth; gender; age; information about tobacco, alcohol, caffeine or drug use; information about environment and lifestyle; identity card number; personal identification number (CNP); other information included in the identity card; video images (obtained from video recordings made in the Life Dental Spa premises, where video surveillance cameras are installed); signature;
3. medical data (belonging to the special categories of personal data), such as: health data related to the medical services provided (such as: the medical services you access in the Life Dental Spa clinics; diagnosis; the results of the tests we perform on you or that you provide us with; the treatment we prescribe or administer; the doctor we or you have consulted; medical recommendations; symptoms; medical history; previous illnesses; blood group; information you give us about your family members, if any); physical characteristics (various diseases); genetic data;; dental impression, dental technical work related to the dental impression; imaging and any other medical information you provide us with or resulting from the services provided by Life Dental Spa;

 

4. data on the professional situation, such as: employer; occupation;
5. data relating to your insured status, such as: your status as insured/uninsured; the insurer; the insurance policy number;
6. payment data, such as: billing details; bank account number; amounts paid and/or to be paid; payment status;
7. data relating to your relationship with Life Dental Spa, such as: the history of your relationship with Life Dental Spa; any suggestions or other such opinions that you may transmit to us, either directly or through other means of communication (which may include social networks or other public communication channels).

In principle, there is no obligation for you to provide us with your personal data indicated in this Information Notice. However, please note that, to the extent that you do not provide us with the personal data described, we will not be able to provide you with some of the services. E.g., if you withdraw your consent, we will not be able to provide you with the requested medical services and/or you will not be able to benefit from all the facilities that Life Dental Spa offers you (for example: not providing your telephone number / e-mail address will not allow us to communicate with you regarding the confirmation / possible changes of appointments). In the event that, in the context of the services that Life Dental Spa provides to you, you provide us with personal data about persons other than yourself (such as: possible medical conditions that have been encountered in your family), we inform you that we will treat this information as confidential and will use it only for the purpose of providing medical services to you. At the same time, we would like to assure you that we will take all the necessary measures to ensure the protection of this information properly, taking into account Life Dental Spa's obligation to maintain professional/medical secrecy.

 

 

 

 

7. THE RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA

 

As a general rule, your personal data will be processed by Life Dental Spa. Taking into account the complexity of the services made available to you by Life Dental Spa, its belonging to a group of companies that provide medical services similar or complementary to those provided by Life Dental Spa, as well as the need for Life Dental Spa to call on certain external partners that provide support in the performance of its activities, we wish to inform you that your personal data may be transmitted to other natural or legal persons, to be processed for the purposes detailed in this Information Notice.

In this regard, personal data may be transmitted to:

1. collaborating physicians and medical service providers, accredited partners, partner clinics. In this regard, we inform you that data/information on your health status, dental impression or biological samples, regardless of their content or volume, may be communicated to accredited health care providers, in accordance with applicable legal provisions. Life Dental Spa makes every effort to ensure that collaborating physicians and other accredited medical service providers comply with the provisions of the legislation on the protection of personal data;
2. judicial, investigative, supervisory and control institutions and/or authorities, to the extent that, in accordance with the legal provisions in force, personal data/information are requested by Life Dental Spa by various bodies and/or institutions (for example: criminal investigation bodies, police, financial, fiscal control bodies and institutions, courts of law, the National Health Insurance House and any other supervisory and control institutions and/or authorities), in which sense Life Dental Spa is obliged to provide the requested data/information, without asking for your prior consent, including in the event that you object or do not express your point of view. In addition, it is possible that, in certain situations, such data/information may need to be made available without prior request from these institutions, bodies and/or authorities, in which case Life Dental Spa will provide the necessary data/information in accordance with the legal requirements;
3. other companies in the Life Dental Spa group;
4. other recipients such as: providers of IT support services or technical and organizational services in connection with activities related to the maintenance of medical equipment, providers of marketing services, payment services, archiving services, legal consultants, auditors, financial-accounting consultants or to other consultants of the Company and/or of entities within the Life Dental Spa group, in connection with extraordinary business operations (for example, in the case of mergers, acquisitions and the like), in which case confidentiality agreements will be concluded. Personal data may also be transmitted to other individuals or legal entities in Romania or abroad in the context necessary for the establishment, exercise and / or defense of a right of Life Dental Spa or another entity within the Life Dental Spa group in court.

In the event that the processing of personal data will be carried out by Life Dental Spa through its authorized persons, Life Dental Spa will ensure compliance with the specific requirements imposed by the provisions of art. 28 of the GDPR, ensuring, among other things, that (i) the respective personal data processing operations are carried out on the basis of a contract addressing the specific issues of the controller-trustee relationship, as required by the GDPR, and (ii) the processor will carry out the processing of personal data on the basis of Life Dental Spa's instructions.

 

8. TRANSFER TO THIRD COUNTRIES

 

In certain specific situations, your personal data will be transferred to entities located in other countries within the European Union and/or the European Economic Area, in order to perform various analyses or obtain specialized medical opinions in the context of the services provided by Life Dental Spa to you. In such cases we will ensure that adequate safeguards are in place to allow the transfer to be properly carried out in accordance with the requirements of the GDPR and personal data protection legislation (safeguards may include: the application of standard contractual data protection clauses or the existence of a European Commission decision adopted in this regard). In each case and with a view to carrying out the actual transfer, the patient is made aware of and asked to express his/her consent/assent to the situation imposed by the medical service in question, health condition, etc.

 

9. THE PERIOD FOR WHICH PERSONAL DATA WILL BE STORED

 

We will store your personal data for the entire period of the relationship established with you, but also for a certain period of time thereafter, in consideration of the applicable legal provisions. Thus, personal data will be kept for:

1. a period of between 1 and 30 years (the extended retention period being applicable, in principle, to medical documents which must be kept for such periods) and
2. during the lifetime of the medical computer system in terms of result slips for laboratory analysis, in accordance with the legislation in the field, under conditions of maximum security.

To the extent that certain personal data is included in or related to certain accounting records of Life Dental Spa, for which a specific retention period must be observed (e.g. 5 or 10 years), such personal data will be retained for those applicable periods.

With regard to images obtained by video surveillance, they will be kept for a maximum of 30 calendar days from the date of recording, except in duly justified cases or when a longer period is allowed or required by applicable law.

 

10. YOUR RIGHTS CONCERNING YOUR PERSONAL DATA

 

In accordance with the applicable provisions regarding personal data, we inform you that you have the following main rights:

1. The right of access to the personal data processed, meaning your right to obtain from Life Dental Spa a confirmation as to whether or not personal data concerning you are processed and, if so, access to the data and the conditions under which they are processed (including the purpose of processing, the categories of data processed, the recipients of the data).
2. The right to request the rectification of personal data, meaning your right to ask us to rectify inaccurate personal data, which are no longer up to date or to complete incomplete data.
3. The right to erasure of personal data, including: where the personal data are no longer necessary in relation to the purposes of the processing; where the data subject objects to the processing and there are no other legitimate interests prevailing for the processing; where the personal data have been processed unlawfully.
4. Right to request restriction of processing, meaning your right to obtain from Life Dental Spa the restriction of processing in the following cases: (i) you contest the accuracy of the data (the restriction will last as long as it is necessary for Life Dental Spa to verify the accuracy of the personal data); (ii) the processing is unlawful and you object to the deletion of the data by requesting instead the restriction of its use; (iii) Life Dental Spa no longer needs the personal data for the above-mentioned purposes, but you request the personal data for the establishment, exercise or defense of a legal claim; or (iv) you have objected to the processing, for the time during which Life Dental Spa verifies whether Life Dental Spa's legitimate rights prevail over your rights.
5. The right to object to processing, meaning your right to object to processing on grounds relating to your particular situation where the processing (i) is based on the legitimate interests of Life Dental Spa or a third party, including in the case of profiling activities based on this ground or (ii) to the extent applicable, is carried out for the purpose of direct marketing communications, involving the creation of profiles.
6. The right to withdraw your consent at any time if the processing is based on consent, without affecting the lawfulness of the processing carried out on the basis of consent prior to the withdrawal of consent;
7. The right not to be subject to an automated decision, which means that, as a user of our services, you will not be subject to a decision by us based solely on automated processing of your data (including profiling) that produces legal effects concerning you or similarly affects you to a significant extent.
8. The right to data portability, meaning your right to request the moving, copying or transfer of your personal data existing in the Life Dental Spa database to another database, in a structured, commonly used and machine-readable format, where the processing is based on consent or on a contract and is carried out by automated means.
9. The right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (Bucharest, Bd. General Gheorghe Magheru 28-30, sector 1, postal code 010336, Bucuresti, Romania, telephone : 031 805 92 11, e-mail anspdcp@dataprotection.ro) and to address the competent courts.

The rights mentioned in pct. A-I above may be exercised through a written request, signed and registered at Life Dental Spa, using the following channels of communication (for the attention of the Data Protection Officer - DPO): (i) at the e-mail address office@lifedentalspa.ro (ii) at the Life Dental Spa clinics or (iii) by sending the request by post to Life Dental Spa CLINIC S.A. in Bucharest, 15 Aviatorilor Boulevard, Sector 1.

In your request, you have the opportunity to indicate whether you want the information to be communicated to you at a specific address (which may be an e-mail address) or by a courier service which ensures that delivery will be personal.

Communication of the requested information will be made within 1 (one) month from the date of receipt of the request, respecting your possible communication options.

If it is not possible to meet the deadline mentioned above, you will be informed of the reason for postponing the reply, and you will also be informed of the procedure envisaged for solving your request, as well as the estimated deadline.