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PRIVACY POLICY AND PROCESSING OF PERSONAL DATA

INTRODUCTION

UNILASER in development of its principles: responsibility, respect, transparency and fairness, determine the information of its employees, clients, patients and suppliers as one of the most important assets; therefore, it declares the importance of proper treatment of your information, using the regulatory framework that regulates it in Colombia.

SCOPE

This privacy policy is a binding document for UNILASER as the person responsible for the data to be processed, in accordance with the regulations in force in Colombia.

Data of the person in charge: UNILASER ODONTOLOGIA ESPECIALIZADA SAS and/or JUAN FIDEL DIEZ MEJIA with main domicile in the city of Medellín, at calle 7 NO. 39-197 suite 902, communication through phone number 57 (4) 4440881, or email [email protected]

Information we collect and store from our patients: Depending on the owner’s relationship with UNILASER or the treating dentist, the information collected or stored may include the following:

Public data:it is the data that is not private or sensitive. For example: number and type of identity document, information contained in public documents, marital status, trade or profession, corporate phone and email.​

Private data: are those that due to their intimate or reserved nature are only relevant to the owner. For example: work information, preferences in social networks, consumption habits, as well as contact information such as address, telephone and personal email.​

Private data: are those that due to their intimate or reserved nature are only relevant to the owner. For example: work information, preferences in social networks, consumption habits, as well as contact information such as address, telephone and personal email.​

GENERAL GUIDELINES

Treatment to which personal data will be subjected: UNILASER or the treating dentist will use the personal information of their patients for the purposes authorized and informed to the owner and those indicated in this policy, provided that the treatment obeys a legitimate purpose and is proportional according to the patient’s relationship, particularly for what is necessary for the provision of the services ordered. The authorization to process sensitive data is optional.

Purposes for which the data will be processed: in order to obtain a better service for employees, patients or providers, you authorize UNILASER and/or JUAN FIDEL DIEZ MEJIA and/or the treating dentist, as the person responsible, to process your data, even those of health, that are sensitive, being able or not to use cloud computing, for the following activities:

Purposes inherent to the contractual object or authorized by regulations:

1. Share information with strategic allies, for the contracting of products and services and commercial management.

2. Consult and obtain a copy of the clinical history or clinical data, which are sensitive data, in order to evaluate and manage risks that may affect health, well being and quality of life.

3. Transmit and/or transfer personal data in order to attract, value, retain, capture and/or study market behavior and patient care.

4. Provide the health service and carry out a quality audit.

5. Carry out scientific research, committing to disclose the results anonymously.

Other purposes:

1. Deliver or receive information with dental entities or associations or others, in order to develop activities and projects in the health sector.

2. Facilitate comprehensive knowledge and elaboration of value proposals based on the use of databases that contain both private and sensitive data.

3. Be contacted for the delivery of commercial offers and advertising information.

4. Study digital behavior (social networks, web pages, applications), to carry out comprehensive advice on products and services, and prepare a profile of consumer interests and habits.

Rights of the holders: in accordance with the provisions of Law 1581 of 2012, the holders have the right to authorize the processing of their personal data, revoke the authorization, know the data being processed, update it, rectify it when it is considered that there is a deficiency in its capacity, and finally request the deletion of data as long as there is no legal or contractual obligation to continue with the treatment (article 2.2.2.25.2.8 Decree 1074 of 2015), for example in the case of the purposes that are inherent to the contracted object and without which its execution is not possible.

Exercise of rights over personal data: the holders of the information may exercise their rights at any time, for which they may contact line 57 (4) 4440881, send an email to [email protected]  or establish contact at through social networks.

General principles that are accepted to guarantee the protection of personal data: they are established as general principles for the treatment of information, in development of those already present in Law 1581 of 2012 and chapter 25 of Decree 1074 of 2015, and others applicable standards, the following:

Principle of legality:there will be no treatment of personal information of clients or patients without observing the rules established in the current regulations.​

Principle of purpose:the incorporation of data into the physical or digital bases must obey a legitimate purpose, which will be duly informed to the owner in the authorization clause for treatment and in the privacy policy.

Principle of freedom: the treatment of personal data of clients or patients will be carried out when they have their authorization or when, as a rule, there is a power to do so, under the terms of art. 3rd literal a) and 6th literal a) of Law 1581 of 2012, as well as section II of chapter 25 of Decree 1074 of 2015.​

Principle of veracity and quality:it will be ensured that the information of its clients or patients is truthful and up-to-date, for which it will have efficient means for updating and rectifying personal data.

Principle of transparency: within the mechanisms established for the exercise of the rights of the holders of personal information, the owner and his successors in title, as well as third parties authorized by it, will be guaranteed access to information on personal data that concern you.

Principle of restricted access and circulation: we are committed to ensuring that only authorized persons can access personal information. Likewise, its circulation will be limited to the exercise of the purposes authorized by the user or by regulations. Contractual means will be available to guarantee the confidentiality and restricted circulation of the information.

Security principle:all technical, administrative and human measures will be taken to guarantee that the personal information of the holders, stored in physical or digital databases, does not circulate or is accessed by unauthorized persons.

Principle of confidentiality: all persons involved in the processing of personal data that are not public in nature are obliged to guarantee the reservation of the information, even after the end of their relationship with any of the tasks involved in the treatment, being able to only make provision or communication of personal data when it corresponds to the development of activities authorized by law and in the terms thereof.

Delivery of personal information to service providers: it is possible that to comply with the provision of services, the information of the client or patient is delivered or shared with providers or other providers of dental services for the purposes authorized by the owner or those provided in the law and in order to properly pay attention. Whenever your information is delivered or shared with third parties, we will ensure that we establish conditions that link the provider or third party to their privacy and information security policies so that the personal information of the owners is protected. Likewise, confidentiality agreements will be established for the handling of the information and responsible-responsible obligations when the type of delivery warrants it.

Validity of data processing:  the information provided by the owners will remain stored for the time that is determined by the owner or that is indicated by law for the fulfillment of the purposes for which it was incorporated.

Modifications to the privacy policy and treatment of personal data: we reserve the right to modify the rules of confidentiality and data protection in order to adapt them to new requirements of a legal, jurisprudential, technical nature and, in general, when necessary to provide better service.

Acceptance of this privacy policy: the owner of the information accepts the treatment of your personal data, in accordance with the terms of this privacy policy, when you provide the data through our channels, networks or service points and when you acquire or use any of our services.