CONFIDENTIALITY POLICY

CONFIDENTIALITY POLICY FOR DR. LEAHU DENTAL CLINICS WEBSITE

INFORMATION NOTE REGARDING THE PROCESSING

OF PERSONAL DATA

 

Through this information note, we would like to explain to you the way in which the web page intended for the dental tourism (https://cliniciledrleahu.ro/en/accent-travel-events-incoming-travel-romania/) processes your personal data within the website www.cliniciledrleahu.ro. The site is hosted and operated in/from Romania.

According to the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), the Dr. Leahu Dental Clinics Group, being the Controller of personal data, processes in safe conditions, for the specified purposes, the personal data you provide us about yourself. At the end of this information note, you will find the identification details related to the companies that are part of the Dr. Leahu Dental Clinics Group.

Dr. Leahu Dental Clinics collaborates with Accent Travel & Events in order to facilitate the access of people who do not live in Romania to the dental services offered by Dr. Leahu Dental Clinics and also to offer them the opportunity to combine dental care with a pleasant holiday in Romania by helping them to organize their trip.

Also, in this information note, details are presented regarding the processing of your personal data by Accent Travel & Events, as the processor used by Dr Leahu Dental Clinics. Here is the identification data of Accent Travel & Events: registered seat in Bucharest, Mihai Bravu Street, no. 215, District 2, registered at the Trade Registry under registration no. J40/7734/1999, sole registration number R 12097170.

Dr. Leahu Dental Clinics Group applies technical and organizational measures to protect your personal data against accidental or illegal destruction, loss, modification, disclosure or unauthorized access. Through this information note, we would like to inform you that we comply with the data privacy laws and regulations. The personal data relating to you that we will process through this web page are the data obtained directly from you or resulting from accessing the web page. The processed data may include the following categories of data:

Personal details: name and surname, country of origin; image data (photographs/dental x-rays).Contact details: phone number; email address;Medical data (sensitive data): symptoms; previous illnesses; analyzes and drugs administered; blood group; services you access through us; the doctor you consulted; medical recommendations; data from the medical file, dental x-rays. Our web page dedicated to dental tourism can collect the following data, depending on your options and the permissions you grant us: In order to make an online appointment, in the appointment form, we will ask for your identification (name, surname) and contact data (mobile phone number and email address), country of origin, to  register the appointment and to be contacted by a call center operator. If you choose to also upload a dental x-ray, your patient file will be partially prepared. When you access the web page, as well as the Newsletter section, we collect your IP, the type of equipment and the operating system used. By collecting them, we cannot identify you, the extraction of the IP can only be done under the conditions of the law.Regarding your activity within the web page, we inform you that we use necessary cookies, without which certain sections of the web page cannot function and cannot be deactivated in our systems.We collect your email address and IP address to send you marketing materials (messages presenting news or promotional offers) if you have given your consent for this purpose. We will not send you marketing materials if you didn’t give your consent to receive information about our products and services. You can choose to stop receiving these materials at any time by accessing the “Unsubscribe” link at the end of each newsletter. You can also unsubscribe by accessing the “Unsubscribe” section of the web page. Regarding your personal data that we may process when you acces the site https://cliniciledrleahu.ro, please consult the site’s Privacy Policy (https://cliniciledrleahu.ro/en/privacy-policy/) Regarding the source from which we receive personal data, we would like to inform you that most of the information we receive directly from you, when you access the website and when you choose to make an online appointment.The personal data that we receive directly from you through the web page, we process as a result of your decisions, such as: selected details, appointments made (for example: name, surname, phone number, email address, country of origin, x-ray). We use cookie technology in statistical reporting on the website. A cookie is a piece of information sent by a web page, saved by your computer’s browser on your hard drive. It retains information that a web page would need to personalize your experience (for example, dynamic images on the web page) and gather statistical information about the web page, such as web pages visited, downloads made, domain name of the internet service provider Internet and country of origin of visitors and addresses of pages visited immediately before and after entering our site. The information in the cookies allows us to trace the “clicks” you have made (more precisely, the paths followed by visitors to reach our page as they move from one page to another).We also use standard web server log files that help us count visitors to find out how many people visit the site and to evaluate the technical capacity of our site. This information helps us to arrange the pages in an attractive way for users, to have a page that is easy to use in the browser and to provide visitors with useful pages. We record information about page traffic, but not information about individual visitors to our page.

We use Google Analytics to help us measure the effectiveness of our advertising and how visitors use the web page. The “help” part of the toolbar of most browsers shows you how to block the acceptance of new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. But don’t forget that without cookies you may not be able to fully benefit from all the features of our website. Grounds based on which we process your personal data other than special data can be the following: to be able to conclude an agreement with you, at your request, to fulfill archiving obligations, to fulfill obligations to communicate to public authorities certain information if they request so, based on our legitimate interest. In the case of marketing communications, we process your data based on your consent for this purpose.

 

Grounds based on which we process your sensitive personal data. Considering the fact that our activity consists in providing dental medical services, we process your sensitive personal data if you decide to upload the dental x-ray in the “Appointment Form” in order to establish an appointment and partially prepare your patient file. We process your personal data based on our legitimate interest, for example, considering the multitude of our clinics, to facilitate access to our dental services.

The purposes for which we process your personal data through the web page dedicated to dental tourism are the following: Providing information about the dental medical services offered by  Dr. Leahu Dental Clinics.

Facilitating the access of people who do not live in Romania to the dental services offered by Dr. Leahu Dental Clinics.

Regarding Dr. Leahu Dental Clinics colaboration with Accent Travel & Events, the purpose of processing your personal data is to offer you the opportunity to combine your dental care with a pleasant holiday in Romania and to help you organize your trip.

Granting access to the online appointment service in order to set up an appointment at your request and if you choose to send us the dental x-ray, the partial preparation of your patient file.

Managing our communication and IT systems, managing our IT security, issuing reports to the competent institutions in the field of cyber security, repairing system errors, performing security audits on our IT networks.

Fulfilling our legal obligations regarding the registration of information and the keeping of records, archiving and other obligations that the legislation imposes on us. Communicating with you by any means, such as: phone, email, phone messages, about the news regarding the dental medical services offered by us, newsletter subscription.

Formulation of requests and defenses before public authorities and other entities that resolve disputes.

The collection of statistical information about the web page, such as the number of visitors to the web page, the web pages visited, the downloads made, the domain name of the Internet provider and the country of origin of the visitors, as well as the addresses of the pages visited immediately before and after entering our web page.

Identifying the aspects that can be improved and the ways in which we can do it, testing the improvements made to our services or new services, solving your complaints.

It is possible that in the future we will process your personal data in the context of M&A transactions.

In certain situations, it is possible to disclose your personal data to other natural or legal persons. The categories of such recipients can be the following:Accent Travel & Events SRL, Regarding he collaboration between Dr. Leahu Dental Clinics and Accent Travel & Events SRL, we will disclose to Accent Travel & Events the following data: name, surname, email address, telephone number, country of origin, name of the dental services you will benefit from Dr. Leahu Dental Clinics and their duration. Thus, Accent Travel & Events can contact you to make you a personalized travel offer depending on the dental services you will benefit from at Dr. Leahu Dental Clinics and their duration. Accent Travel & Events  keeps your data confidential, according to the data privacy law and according to the agreement concluded with Dr. Leahu Dental Clinics.  The companies that are part of Dr. Leahu Dental Clinic Group, having as a legitimate interest, the unified access to dental medical services by all patients. Their list can be found at the end of this information note.Doctors from Dr. Leahu Dental Clinics. They can be employees of  Dr. Leahu Dental Clinics or they can be collaborating doctors based on a service agreement. Each doctor keeps your data confidential, according to the data privacy law and according to the agreement concluded with Dr. Leahu Dental Clinics.Public authorities, from Romania or abroad, such as: the National Health Insurance House, the Ministry of Health, etc., under the conditions of the legislation applicable in Romania and the European Union.Insurers from Romania or other countries, in connection with the services you benefited from in the Dr. Leahu Dental Clinics, at your request.Accountants, auditors, lawyers and other external professional consultants of ours or of another company from Dr. Leahu Dental Clinics Group, from Romania or from abroad. They will keep your data confidential, according to the privacy law or according to the agreement concluded with us or with another company from Dr. Leahu Dental Clinics Group.Natural or legal persons who act as authorized persons for Dr. Leahu Dental Clinics, in various fields, providing certain services for us, such as: IT services, payment services, debt recovery services, marketing and communication, etc., which will comply with the requirements of the privacy law that protects your rights.Any relevant person, agency or court in Romania or in another country, to the extent necessary to establish, exercise or defend a right of ours or another company in Dr. Leahu Dental Clinics Group, in court.Any purchasers or possible relevant purchasers from the dental medical field or from other fields, from Romania or from another country, in the event that we sell or transfer all or part of our social shares, our assets or our business (including in the case of reorganization, or of our dissolution or liquidation), they will keep your data confidential.Our partners, with whom we are in contractual relations, such as service providers in the field of IT, marketing and communication.When we use a natural or legal person as the authorized person for the processing of your personal data, we will conclude with him a written act by which he assumes, among other obligations that the privacy law on personal data provides, the obligations to process the personal data according to our written instructions and to implement measures to protect confidentiality and ensure the security of personal data. Regarding the collaboration between Dr. Leahu Dental Clinics and Accent Travel & Events, concerning processing of your personal data, we inform you that Accent Travel & Events has the status of processor. The country in which your personal data is processed is Romania. At this moment, we do not transfer and do not intend to transfer your personal data to third countries or to international organizations. If it will be necessary to transfer your data to third countries or to international organizations, we will inform you in advance and ensure that such transfers will be carried out in compliance with the applicable privacy law, including, if necessary, your explicit consent The storage period of your personal data is between 6 months and 100 years in the case of medical documents. To store your data (in electronic format), we use our own servers or those of other companies specialized in electronic archiving.The identification data – name, surname, are accessories to the data regarding the patient’s state of health, and are therefore kept for the entire medical data storage period.The contact data – surname, first name, email address, telephone number, country of origin, completed in the appointment form are kept for the necessary period for which the purposes they are processed are fulfilled and in compliance with the data retention procedures, including the applicable archiving regulations.The persistence of Cookies can be found in the Cookie Policy https://cliniciledrleahu.ro/en/cookie-policy-travel-romania/ Minors under the age of 16 should not submit any personal data to the website without the permission (consent or approval) of their legal guardian. Our website will never knowingly collect personal data from persons that it is aware that they are minors (under 16 years of age), nor will it use or disclose it to any unauthorized third party without the express consent of the legal guardian in such a case. Security of personal data. In order to protect the personal data we process from unauthorized access, modification, disclosure or unauthorized destruction, we apply the following technical and organizational measures to ensure the security and confidentiality of personal data:Procedures and policies for processing personal data, as well as physical and electronic security measures, to protect our systems from unauthorized access. We also check the application of the personal data protection policies and the compliance with data protection legislation.At the same time, we inform you that your personal data that we process are limited to those that are necessary, relevant and appropriate for the purposes stated in this information note and that the employees and collaborators of Dr. Leahu Dental Clinics are trained on the legislation and practices in the field of personal data processing.If it is possible and appropriate to our activity, we anonymize/pseudonymize the personal data we process, as an additional protection measure.In the case of agreements with service providers who process personal data for us or together with us (for example, processors) we introduce clauses or annexes in these agreements to ensure the protection of the data we process. By completing the appointment form and submitting the data, you become aware of the collaboration between Dr Leahu Dental Clinics and Accent Travel & Events in the matter of dental tourism, as well as the quality of processor in the data processing of Accent Travel & Events and that you agree with the transmission of your personal data mentioned in this information note to Accent Travel & Events.You benefit from the following rights related to the processing of your personal data that we carry out:
·         The right of access: you can obtain from us confirmation that we are processing your personal data, as well as information regarding the specifics of the processing such as: the purpose, the categories of personal data processed, the recipients of the data, the period for which the data are kept.
·         The right to rectification of data: you can ask us to modify your incorrect personal data or, as the case may be, to complete data that is incomplete.
·         The right to deletion: you can request the deletion of your personal data when: they are no longer necessary for the purposes for which we collected and process them; you have withdrawn your consent for the processing of personal data and we can no longer process them on other legal grounds; personal data are processed contrary to the law, respectively personal data must be deleted according to the relevant legislation.
·         Withdraw consent: you can withdraw your consent at any time regarding the processing of personal data processed on the basis of consent.
·         The right to object: In certain circumstances you have the right to object to the processing of your data by us or on our behalf. Thus, we will no longer process your personal data, unless: (a) we can prove legitimate and compelling reasons that justify the processing and that prevail over your interests, rights and freedoms, or (b), if the purpose is establishing, exercising or defending a right in court. You can always object to the processing of your personal data for marketing purposes. Whatever your reason is, you can withdraw your consent.
·         The right to restriction of processing: you can request the restriction of the processing of your personal data if: you dispute the correctness of the personal data for a period that allows us to verify the accuracy of the data in question; the processing is illegal, and you oppose the deletion of personal data, requesting instead the restriction of their use; the data are no longer necessary for our processing, but you request them for a court action; in case you objected to the processing, for the period of time in which it is checked whether the legitimate rights of Dr. Leahu Dental Clinics as a Controller prevail over your rights as a data subject.
·         The right to portability: to the extent that we process personal data by automatic means, you can request us, within the law, to provide your personal data in a structured, frequently used form that can be read automatically. If you request this from us, we can transmit your personal data to another entity, if this is possible from a technical point of view.
·         The right to file a complaint with the Supervisory Authority: you have the right to file a complaint with the Data Processing Supervisory Authority if you believe that your rights have been violated (The National Supervisory Authority for Personal Data Processing – G-ral Gheorghe Magheru Bd, no. 28-30, District 1, zip code 010336, Bucharest, Romania, anspdcp@dataprotection.ro).To exercise these rights, you can send a written, dated and signed request to Dr. Leahu Dental Clinics, at the office in Bucharest, Chindei Street no. 4, District 4, Bucharest, with the mention “to the attention of the Data Protection Officer” and/or by email to the email address: dpo@drleahu.ro.Under the current conditions, you will not be subject to a decision based exclusively on the automatic processing of your data (including the creation of profiles) that will produce legal effects regarding you or that will affect you in a similar way, to a significant extent.We may change this information note from time to time. In these cases, we will not reduce the level of protection, nor will we reduce the rights you have over your personal data. We attach the utmost importance to privacy issues and intend to remain fully compliant with legal provisions regarding privacy policy and personal data protection. Thus, we inform you that we will periodically update the privacy policy and will display the new ones on our web page.
Remember that when you use a link to get from our web page to another web page, this privacy policy no longer applies. Your browsing and interaction on another web page, including any page that has a link to thisweb page, is subject to that page’s rules and policies. We encourage you to read the rules and policies of the pages you visit to better understand their procedures for collecting, using and disclosing personal data. This webpage uses cookies. For more information on how these files are used, please visit the following link: https://cliniciledrleahu.ro/en/cookie-policy-travel-romania/ The terms used in this information note mean the following: The supervisory authority for the processing of personal data: an independent public authority which, according to the law, has powers related to the supervision of compliance with the data privacy law. In Romania, this supervisory authority for the processing of personal data is The National Supervisory Authority for Personal Data Processing (ANSPDCP).Personal data: any information regarding an identified or identifiable natural person (referred to as “data subject”). A natural person is identifiable if he can be identified, directly or indirectly, in particular by reference to an identification element, for example: name, identification number, location data, online identifier, one/more specific elements, specific to the physical identity, physiological, genetic, psychological, economic, cultural or social of that person. Thus, for example, the notion of personal data includes the following: name and surname; country of origin; email address; phone number;. The categories of personal data we process are listed above in this information note.Sensitive personal data: personal data that: reveal racial or ethnic origin, political opinions, religious confession or philosophical beliefs or trade union membership; genetic data; biometric data for the unique identification of a natural person; data regarding the health, sex life or sexual orientation of a natural person.Controller: natural or legal person who decides why (for what purpose) and how (by what means) personal data are processed. According to the law, the responsibility for compliance with the legislation regarding personal data rests primarily with the controller. In relation to you, we are the Controller, and you are the data subject.Processor: any natural or legal person who processes personal data on behalf of the controller, other than the controllers employees.Data subject: the natural person to whom certain personal data “belong”. In the relationship with us, you are the data subject.Processing of personal data: any operation / set of operations performed on personal data or sets of personal data, with or without the use of automated means; for example: collecting, recording, organizing, structuring, storing, adapting or modifying, extracting, consulting, using, divulging through transmission, disseminating or making available in any other way, aligning or combining, restricting, deleting or destroying that personal data.Third country: a country outside the European Union and the European Economic Area. Companies that are part of Dr. Leahu Dental Clinics Group:

 

IMPLANT EXPERT S.A. with its registered seat in 41 Nicolae Caramfil Bd, room 2, ground floor, District 1, Bucharest, Romania, registered with Bucharest Trade Registry under registration number J40/94/2011, sole registration number 27878713.

IMPLANT EXPERT PITESTI S.R.L. with its registered seat Doaga Street no.11, Arges County, Pitesti, Romania, registered with the Trade Registry under registration number J3/354/2018, sole registration number 38878344.

IMPLANT EXPERT ORADEA S.R.L. with its registered seat in Motilor Street, no.3, Bihor County, Oradea, Romania, registered with the Trade Registry under registration number J5/2077/2019, sole registration number 41557549.

IMPLANT EXPERT IASI S.R.L. with its registered seat in Ignat Street no. 7, Iasi County, Iasi, Romania, registered with the Trade Registry under registration number J22/940/2020, sole registration number 42458586.

CORIDENT PRO S.R.L. with its registered seat in, Cristian Street, no. 18, room 1, Sibiu County, Sibiu, Romania, registered with the Trade Registry under registration number J32/1674/2018, sole registration number 40189236.

IMPLANT EXPERT PLOIESTI S.R.L. with its registered seat in Gheorghe Grigore Cantacuzino Street, no. 90, Prahova County, Ploiesti, Romania, registered with the Trade Registry under registration number J29/2023/2020, sole registration number 43265362.

IMPLANT EXPERT GALATI S.R.L. with its registered seat in  Chindiei Street, no. 4, room 1, District 4, Bucharest, Romania, registered with Bucharest Trade Registry under registration number J40/5795/2021, sole registration number 44020212.

IMPLANT EXPERT BRASOV S.R.L. with its registered seat in Eroilor Bd., no.3, Brasov, registered with the Trade Registry under registration number J18/2316/2021, sole registration number 44753850.

IMPLANT EXPERT DSO S.A., with its registered seat în Nicolae Caramfil Bd. , no. 41, room 5, District 1, Bucharest, Romania, registered with Bucharest Trade Registry under registration number J40/5004/2019, sole registration number  40969355.

IMPLANT EXPERT SERVICES S.R.L. with its registered seat in Chindiei Street, no. 4, room 3, District 4, Bucharest, Romania, registered with Bucharest Trade Registry under registration number J40/14902/2016, sole registration number 36732791.

IMPLANT EXPERT DENTAL LAB S.R.L. with its registered seat in Chindiei Street, no. 4, District 4, Bucharest, Romania, registered with Bucharest Trade Registry under registration number J40/14837/2016, sole registration number 36727884

 

 

 

Dr. Leahu Dental Clinics

021 9777