1. GENERAL

Taking into account the provisions of the Political Constitution of Colombia, PREMIUM IMPLANT NETWORK, as a provider of general and specialized dentistry services, is committed to making known and complying with the personal data treatment policies directly or through its different allies, associates or any natural or legal person with whom it has a business relationship or link of some nature, guaranteeing that they are handled in accordance with this Policy and the law.

PREMIUM IMPLANT NETWORK In developing its corporate purpose, it will be responsible for data processing, in accordance with the Constitutional guarantee of Habeas Data and in compliance with Law 1581 of 2012 that dictates the constitutional right that everyone has to: “Know, update and rectify the information that has been collected about them in databases or files, and the other rights, freedoms and constitutional guarantees referred to in article 15 of the Political Constitution; as well as the right to information enshrined in article 20 thereof ”.

2. OBJECTIVE

The fundamental objective of this Policy is to guarantee the protection of the personal data of any person whose PREMIUM IMPLANT NETWORK has obtained any information or personal data, as stipulated by Law 1581 of 2012.   

In PREMIUM IMPLANT NETWORK We are committed to comply strictly and in a mandatory way in order to protect the privacy of any person who provides information personally or through the website, email, phone call, current physical or electronic means or those that are developed, as well as all the information sent through third parties with whom there is a commercial or legal relationship.

3. SCOPE

This policy applies to all personal information registered in the databases of PREMIUM IMPLANT NETWORK, who acts as the person responsible for the processing of personal data.

4. DEFINITIONS

For purposes of compliance with the law and this policy, it is understood by:

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

Database: Organized set of personal data that is subject to Treatment.

Personal information: Any information linked or that may be associated with one or more specific or determinable natural persons.

Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, carries out the Processing of personal data on behalf of the Responsible for the Treatment.

Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the database and the Data Processing.

Headline: Natural person whose personal data is subject to Treatment.

Treatment: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or deletion.

5. PRINCIPLES   

The following principles will be used by PREMIUM IMPLANT NETWORK in the processes of collection, treatment and use of all Personal Data, in accordance with the provisions of the law:

Principle of legality regarding data processing: The Treatment referred to in this law is a regulated activity that must be subject to what is established in it and in the other provisions that develop it.

Purpose principle: The Treatment must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Holder.

Principle of freedom: The Treatment can only be exercised with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that relieves consent.

Principle of truthfulness or quality: The information subject to Treatment must be truthful, complete, exact, updated, verifiable and understandable. Processing of partial, incomplete, fractioned or misleading data is prohibited.

Principle of transparency: In the Treatment, the right of the Holder to obtain from the Treatment Manager or the Treatment Manager, at any time and without restrictions, information about the existence of data concerning him or her must be guaranteed.

Principle of access and restricted circulation: The Treatment is subject to the limits that derive from the nature of the personal data, the provisions of this law and the Constitution. In this sense, the Treatment can only be done by persons authorized by the Holder and / or by the persons provided for in this law. Personal data, except for public information, may not be available on the Internet or other means of dissemination or mass communication, unless the access is technically controllable to provide restricted knowledge only to the Holders or authorized third parties in accordance with this law.

Safety principle: The information subject to Treatment by the Treatment Manager or Person in Charge of Treatment referred to in this law, 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 persons who intervene in the Processing of personal data that are not public are obliged to guarantee the reservation of the information, even after the end of their relationship with any of the tasks that the Treatment comprises, being able to only supply or communicate of personal data when this corresponds to the development of the activities authorized in the law and in the terms of the same.

6. AUTHORIZATION

The collection, storage, use, circulation and, in general, the Treatment of Personal Data found in the Databases of PREMIUM IMPLANT NETWORK require the free, prior, express and informed consent of the holders thereof. As the person responsible for the Processing of Personal Data, PREMIUM IMPLANT NETWORK It has the necessary mechanisms in place to obtain the Authorization of the Data Holders, prior to its collection. The personal data of the Holders will be kept in the Databases of PREMIUM IMPLANT NETWORK during the time that they are used for the authorized purposes, unless the Holder requests their elimination.

FORM AND MECHANISMS TO GRANT AUTHORIZATION

The Authorization of Personal Data Processing can be done through a physical or electronic document, data message, Internet, website or also verbally or by telephone or in any other format. It can also be provided through an unequivocal conduct of the Holder that allows to conclude that he granted the authorization; or through a suitable technical or technological mechanism through which it can be unequivocally concluded that, had the Owner's consent not been obtained, the data would never have been collected and stored in the Database.

With the consented Authorization, it is guaranteed that the Holder of the Personal Data has been made aware that their information will be collected and used for specific and known purposes in accordance with this Policy. In any case, the Holder has the right to request access, updating, rectification and elimination of their Personal Data at any time, through the mechanisms made available to them by PREMIUM IMPLANT NETWORK.

The Authorization is a statement that informs the Owner of the Personal Data about:

1. 1. Who collects your personal information.
   2. What data does it collect?
   3. What do you collect the data for?
   4. How to exercise rights of access, correction, updating or deletion of the Personal Data provided.
   5. Inform the Holder that because it is Sensitive Data, if applicable, he is not obliged to authorize its Treatment.

PROOF OF AUTHORIZATION

PREMIUM IMPLANT NETWORK will adopt the necessary measures to maintain records or suitable technical or technological mechanisms of when and how it obtained the Authorization on the part of the holders of Personal Data for the Treatment of the same.

AUTHORIZATION FOR THE PROCESSING OF PERSONAL DATA COLLECTED BEFORE JUNE 27, 2013

For this purpose PREMIUM IMPLANT NETWORK will proceed in accordance with the provisions of article 2.2.2.25.2.7 of Decree 1074 of 2015.

CASES THAT DO NOT REQUIRE THE HOLDER'S AUTHORIZATION

1. 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. Treatment of information authorized by law for historical, statistical or scientific purposes.
   5. Data related to the Civil Registry of Persons.

The foregoing in accordance with the provisions of article 10 of Law 1581 of 2012.

7. PRIVACY NOTICE

The Privacy Notice is the physical document, electronic or in any other format, provided for the Holder informing about the Treatment that their Personal Data will have by  PREMIUM IMPLANT NETWORK, prior to the moment that the collection of Personal Data is authorized. 

Through this document, the Owner is informed of the existence of the Information Treatment Policies that will be applicable, the way to access them and the characteristics of the Treatment that is intended to be given to Personal Data.

MINIMUM CONTENT OF THE PRIVACY NOTICE

The Privacy Notice, at a minimum, must contain the following information:

1. 1. The identity, address and contact details of the Data Controller.
   2. The type of Treatment to which the data will be submitted and the purpose thereof, as well as the rights of the Holder.
   3. The general mechanisms provided by the Responsible Party so that the Holder knows the information Treatment policy and the substantial changes that occur in it or in the corresponding Privacy Notice. In all cases, you must inform the Owner how to access or consult the Information Processing policy.
   4. When Sensitive Personal Data is collected, the Privacy Notice will expressly indicate the optional nature of the answer to the questions that relate to this type of data.

PRIVACY NOTICE AND INFORMATION PROCESSING POLICIES

PREMIUM IMPLANT NETWORK will keep the model of the Privacy Notice that was transmitted to the Holders while the Personal Data Processing is carried out and the obligations derived from it remain. For model storage, PREMIUM IMPLANT NETWORK You may use computer, electronic or any other technology.

8. RIGHTS AND DUTIES

RIGHTS OF THE INFORMATION HOLDER

1. 1. Know, update and rectify your personal data in front of the Treatment Managers or Treatment Managers. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose Treatment is expressly prohibited or has not been authorized.
   2. Request proof of the authorization granted to the Responsible for the Treatment except when expressly excepted as a requirement for the Treatment, in accordance with the provisions of article 10 of the aforementioned law.
   3. Be informed by the Treatment Manager or the Treatment Manager, upon request, regarding the use that has been given to your personal data.
   4. Present before the Superintendency of Industry and Commerce complaints for infractions to the provisions of this law and the other regulations that modify, add or complement it.
   5. Revoke the authorization and / or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the Treatment. The revocation and / or deletion will proceed when the Superintendency of Industry and Commerce has determined that in the Treatment the Responsible or Person in Charge have incurred in conduct contrary to this law and the Constitution.
   6. Free access to your personal data that have been subject to Treatment. In the processing of personal data, in any case, the prior and informed authorization of the Holder is required, which must be obtained by any means that may be subject to subsequent consultation.

SENSITIVE DATA

Sensitive data is understood to be: those that affect the privacy of the Holder or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership of trade unions, social organizations , human rights or that promotes the interests of any political party or that guarantees the rights and guarantees of opposition political parties as well as data related to health, sexual life and biometric data

TREATMENT OF SENSITIVE DATA

The treatment of sensitive data is prohibited, except when:

1. 1. The Holder has given his explicit authorization to said Treatment, except in cases where the granting of said authorization is not required by law.
   2. The Treatment is necessary to safeguard the vital interest of the Holder and he is physically or legally incapacitated. In these events, the legal representatives must grant their authorization.
   3. The Treatment is carried out in the course of legitimate activities and with due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or union, provided that they refer exclusively to its members or to people who maintain regular contact by reason of its purpose. In these events, the data may not be provided to third parties without the authorization of the Owner.
   4. The Treatment refers to data that are necessary for the recognition, exercise or defense of a right in a judicial process.
   5. The Treatment has a historical, statistical or scientific purpose. In this event, the measures leading to the suppression of the identity of the Holders must be adopted.

RIGHTS OF CHILDREN, GIRLS AND ADOLESCENTS

In the Treatment, respect for the prevailing rights of children and adolescents will be ensured. The processing of personal data of children and adolescents is prohibited, except for those data that are of a public nature. It is the task of the State and educational entities of all kinds to provide information and train legal representatives and guardians on the possible risks that children and adolescents face regarding the improper treatment of their personal data, and provide knowledge about responsible and safe use by children and adolescents of their personal data, their right to privacy and protection of their personal information and that of others.

PREMIUM IMPLANT NETWORK, You may use and process the personal data of children and adolescents only when these are of a public nature, in any case the processing of personal data of children and adolescents must always respond and respect the best interests of the minor and thus ensure the respect for their fundamental rights. In this case, authorization must be obtained from the legal representative of the minor, if only this is sufficient, since it is always necessary to listen to the opinion of the minor and this must be valued taking into account their maturity, autonomy and ability to understand the process of authorization of use. of personal data.

In any case PREMIUM IMPLANT NETWORK, reserves the right to prioritize the life or health of girls, boys and adolescents in those cases in which they may be violated, thus giving prevalence to the fundamental rights of minors (Sentence T / 587 of October 20, 1998 ). In the event of a collision between the fundamental rights of life or health and the right to privacy of the personal data of minors, the right to life or health will always prevail. In any case, adequate legal treatment must be given to said data.

HEALTH DATA: CLINICAL HISTORY

In accordance with the provisions of Resolution 1995 of 1999 of the Ministry of Health, Article 15 modified by Article 2 of Resolution 1715 of 2005 of the Ministry of Social Protection The medical record must be kept for a minimum period of ten (10) years, counted from the date of the last care. A minimum of three (3) years in the management file of the health service provider, and a minimum of seven (7) years in the central file. Once the conservation term has elapsed, the medical record may be destroyed, thus being the legal conservation period of twenty (20) years from the date of its last entry, which is why, after said period of time, PREMIUM IMPLANT NETWORK in its process of conserving said information, it takes advantage of such time.

The foregoing because by legal provision in the framework of the provision of the service PREMIUM IMPLANT NETWORK must prepare the clinical history of their patients within which information on various aspects of the patient, their family and their municipality is contemplated, so the owner must give express and written authorization for the collection and processing of data from them, on the which PREMIUM IMPLANT NETWORK It must guarantee the security and confidentiality measures of the information so that the integrity, custody and treatment of sensitive data is guaranteed.

DUTIES OF THOSE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

1. 1. Guarantee the Holder, at all times, the full and effective exercise of the right to habeas data;
   2. Request and keep, under the conditions set forth in this law, a copy of the respective authorization granted by the Holder;
   3. Properly inform the Holder about the purpose of the collection and the rights that assist him by virtue of the authorization granted;
   4. Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;
   5. Guarantee that the information provided to the Person in Charge of Treatment is true, complete, exact, updated, verifiable and understandable;
   6. Update the information, communicating in a timely manner to the Person in Charge of Treatment, all the news regarding the data that you have previously provided and adopt the other necessary measures so that the information provided to it is kept up-to-date;
   7. Rectify the information when it is incorrect and communicate the pertinent to the Person in Charge of Treatment;
   8. Provide the Treatment Manager, as the case may be, only data whose Treatment is previously authorized in accordance with the provisions of this law;
   9. Require the Treatment Manager, at all times, to respect the security and privacy conditions of the Owner's information;
   10. Process the queries and claims formulated in the terms indicated in this law;
   11. Adopt an internal manual of policies and procedures to guarantee adequate compliance with this law and especially, for the attention of queries and complaints;
   12. Inform the Treatment Manager when certain information is under discussion by the Holder, 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 there are violations of the security codes and there are risks in the administration of the information of the Holders.
   15. Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

DUTIES OF DATA PROCESSORS

1. 1. Guarantee the Holder, at all times, the full and effective exercise of the right to habeas data;
   2. Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access;
   3. Timely update, rectify or delete the data in the terms of this law;
   4. Update the information reported by the Data Controllers within five (5) business days from its receipt;
   5. Process the queries and claims made by the Holders in the terms indicated in this law;
   6. Adopt an internal manual of policies and procedures to guarantee adequate compliance with this law and, especially, for the attention of queries and claims by the Holders;
   7. Register in the database the legend "claim in process" in the manner in which it is regulated in this law;
   8. Insert in the database the legend "information in judicial discussion" once notified by the competent authority about judicial processes related to the quality of personal data;
   9. Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendency of Industry and Commerce;
   10. Allow access to information only to people who can have access to it;
   11. Inform the Superintendency of Industry and Commerce when there are violations of the security codes and there are risks in the administration of the information of the Holders;
   12. Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

PREMIUM IMPLANT NETWORK You may have the quality of MANAGER and / or RESPONSIBLE FOR THE TREATMENT, in which case the identification data is the following:

NAME OR SOCIAL REASON: PREMIUM IMPLANT NETWORK

ADDRESS: Calle 90 #19A-49 Office 202 and Calle 83 # 19-36 Office 301 and 302

CITY OF ADDRESS: Bogota DC

TELEPHONE: 3155523611 and 3224041241

EMAIL: info@old.pinimplant.com

WEB PAGE: www.premiumimplantnetwork.com

9. METHOD OF PROCEEDING WITH REGARD TO THE INQUIRIES AND REQUESTS MADE BY THE DATA HOLDERS

Every owner of personal data has the right to make inquiries and submit requests to the company regarding the handling and treatment given to their information.

PROCEDURE FOR THE PROCESSING OF CLAIMS, APPLICATIONS OR INQUIRIES

Any request, request, complaint or claim (PQR) that is submitted to PREMIUM IMPLANT NETWORK It will be processed and responded to within fifteen (15) business days of receipt.

In accordance with the provisions of article 14 of Law 1581 of 2012 and article 21 of Decree 1377 of 2013, the Holders or their successors in title may consult the personal information of the Holder that resides in any Database. Consequently, PREMIUM IMPLANT NETWORK will guarantee the right of consultation, providing the Holders with all the information contained in the individual record or that is linked to the identification of the Holder, under the following rules:

1. 1. The Holder will be able to consult his personal data free of charge and whenever there are substantial modifications to the Information Treatment policies that motivate new consultations.
   2. The right of consultation may be exercised by: (i) The Holder or his successors in title, after proof of their identity, or through electronic instruments that allow them to identify themselves. (ii) By the representative and / or attorney-in-fact of the Holder, prior accreditation of the representation or power of attorney. (iii) By stipulation in favor of another or for another. (iv) The rights of children or adolescents shall be exercised by the persons who are empowered to represent them. When the request is made by a person other than the Owner and it is not proven that it acts on his behalf, it will be deemed not submitted.
   3. Minimum information (i) The name and address of the Holder or any other means to receive the response. (ii) The documents that prove the identity or personality of its representative. (iii) The clear and precise description of the Personal Data with respect to which the Holder seeks to exercise any of the rights. (iv) Where appropriate, other elements or documents that facilitate the location of the Personal Data.
   4. In any case, regardless of the mechanism implemented to attend to consultation requests, they will be attended to within a maximum term of ten (10) business days from the date of receipt. When it is not possible to answer the query within said term, the interested party will be informed before the expiration of ten (10) days, stating the reasons for the delay and indicating the date on which the query will be attended, which in no case may exceed five (5) business days following the expiration of the first term.
   5. The means of communication that have been enabled for the attention of petitions, inquiries and claims against habeas data must be used, such as: at Calle 90 # 19A-49 or Calle 83 # 19-36 in Bogotá, DC, by mail email: info@old.pinimplant.com, or by phone or whatsapp: 3155523611 or 3224041241.

10. PURPOSES OF THE PROCESSING OF PERSONAL DATA

PREMIUM IMPLANT NETWORK collects, stores, uses, circulates, transmits and transfers Personal Data of its customers, suppliers, employees, potential customers, potential employees and potential suppliers for the purposes of control, security, establishment of commercial or legal relationships, judicial processes, requirements of administrative authorities and for future reference, inside and outside of Colombia, you may process personal data for the following purposes:

1. Perform permanent analysis of information on the population served, and delivery of RIPS to state control and surveillance bodies of the Health sector –Resolutions 1403 of 2006 and 3374 of 2000-; research and epidemiological studies.
2. In processes of updating, scheduling and confirming agendas and attending appointments.
3. Sending information to the subscriber about: events, promotions and advertising campaigns or information of interest about oral health, changes or news, and offers of treatments or products, through the different physical and virtual channels, telephone calls, messages through virtual platforms, chat, social networks or newsletter, according to the information provided by the Owner.
4. Evaluation of the quality of the treatments and services provided.
5. Virtual monitoring of the evolution of dental treatments.
6. Comply with the legal and / or contractual obligations of the Authorized Entities, due to the development of their civil and commercial activity. Manage data related to human resources, selection processes, organizational analysis, development and management of performance reports of employment contracts, management of labor relations, processing, management, payroll and compliance with legal obligations. Manage internal affairs including, but not limited to, accounting, financial and management reports, calculation, presentation and payment of taxes, other records and compliance reports, internal or external audit processes.
7. Carry out the Customer or Supplier Due diligence process, which consists of the set of procedures for the identification and acceptance of customers and suppliers.
8. Achieve efficient communication with the owner of the information, through any means of contact, related to our products, services, promotions, alliances, studies, contests, events, content, advertising and marketing campaigns, benefits, conditions or applicable policies , service channels, social networks, newsletters, as well as those of the Authorized Entities.
9. Inform about changes to our products or services or regarding new ones that are related to it or those contracted or acquired.
10. Comply with obligations contracted with our clients, suppliers and employees.   
11. The information may be anonymized in order to prepare statistics, studies and marketing or consumer analysis that may be used by Authorized Entities and / or third parties, who may dispose of all the information at their discretion.
12. For the purposes of security, prevention, investigation and prosecution of fraud.

In relation to the Data considered as Sensitive, in the terms of Law 1581 of 2012, the Holder is not obliged to authorize its Treatment. Regarding Personal Data of Boys, Girls and Adolescents, when they are collected, they will be treated in accordance with the provisions of article 7 of Law 1581 of 2013 and article 12 of Decree 1377 of 2013, and according to the purposes established in the Notice Privacy as they may be applicable.

11. INFORMATION SECURITY

In development of the security principle established in Law 1581 of 2012, PREMIUM IMPLANT NETWORK will adopt the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access. The Database Administrator will ensure the security of the Databases and will oversee the proper application of the Privacy Policy.

12. FINAL PROVISIONS

The area of Habeas Data is in charge of fulfilling the Personal Data protection function. The aforementioned area will process the requests of the Holders, for the exercise of the rights of access, consultation, rectification, updating, deletion and revocation referred to in Law 1581 of 2012. The above, if necessary, will be done with the support of the Patient Service area.   

VALIDITY

This Policy for the Treatment of Personal Data governs from the July 12, 2021, which consolidates any previously published version.

The databases in which the personal data will be recorded will have a validity equal to the time in which the information is kept and used for the purposes described in this policy. Once that purpose is fulfilled and as long as there is no legal or contractual duty to keep your information, your data will be deleted from our databases.