Privacy Policy

Sante Clinics Privacy Policy

Protecting your privacy is part of the way we understand medicine.

At Sante Clinics we treat our patients' personal information with the same commitment to confidentiality, rigor and responsibility with which we provide healthcare.

We know that, when a person visits a medical clinic, they entrust its professionals with more than personal data: they entrust their trust. For this reason, we guarantee that all the information you provide will be processed lawfully, fairly, transparently and confidentially, applying the technical and organizational measures necessary to protect it at all times.

This Privacy Policy explains how we collect, use, retain and protect your personal data when you visit our website, request information, book an appointment or receive healthcare at Sante Clinics.

The processing of your data is carried out in accordance with the Reglamento (UE) 2016/679, General de Protección de Datos (RGPD), the Ley Orgánica 3/2018, de Protección de Datos Personales y garantía de los derechos digitales (LOPDGDD), the Ley 41/2002, reguladora de la autonomía del paciente, the Ley 44/2003, de Ordenación de las Profesiones Sanitarias, as well as the rest of the applicable regulations.

1. Data controller

SANTE SALUD BARCELONA BRAND, S.L.

CIF: B56142987

Registered office: Avenida Diagonal 384, 08037 Barcelona (España)

Inquiries about data protection: legal@santeclinics.com

Telephone: +34 699 145 887

2. Scope of application

This Privacy Policy applies to all persons who interact with Sante Clinics through our website or any of our communication channels.

In particular, it affects those who:

• request information about our treatments;
• contact the Clinic through forms, email, telephone or WhatsApp;
• request or manage an appointment;
• receive healthcare;
• take part in personnel selection processes;
• subscribe to informative or commercial communications, where applicable;
• browse our website.

3. What personal data do we process?

The data processed will depend on the relationship you have with Sante Clinics and the services requested.

We may process the following categories of information:

Identification data

• first name and surnames;
• identification document when necessary;
• date of birth;
• sex.

Contact data

• email address;
• telephone;
• postal address, where applicable.

Financial data

When necessary for the contracting of services or the issuing of invoices, we may process the information essential to manage payments, collections and tax obligations.

Health-related data

In the event of receiving healthcare, we may process the information necessary to ensure adequate medical care, including, among others:

• personal and family medical history;
• previous illnesses;
• allergies;
• medication;
• relevant habits;
• examinations;
• diagnoses;
• treatments performed;
• clinical progress;
• informed consents;
• medical documentation provided by the patient.

Health-related data receives a reinforced level of protection in accordance with current regulations.

Clinical photographs

When necessary to document the progress of a treatment, clinical photographs may be taken which will become part of the patient's medical record.

These images will be used exclusively for care purposes, unless express and independent authorization is given for any other use.

Browsing data

When you visit our website, we may process certain technical information such as:

• IP address;
• browser type;
• operating system;
• language;
• device used;
• pages visited;
• date and time of access;
• information obtained through cookies in accordance with the configuration chosen by the user.

4. How do we obtain your data?

The personal data processed by Sante Clinics generally comes from the data subject.

The information may be provided when you:

• complete a contact form;
• request an appointment;
• contact the Clinic by telephone;
• write to us by email;
• use WhatsApp to communicate with us;
• attend a consultation;
• provide medical reports or clinical documentation;
• subscribe to our communications;
• browse our website.

In certain cases, and provided there is a legal basis that allows it, we may also receive information from other healthcare professionals, medical centers, insurance companies or legal representatives of the patient.

5. For what purposes do we process your data?

Personal data will be processed only for legitimate and specific purposes.

Depending on the relationship maintained with Sante Clinics, we may use your information to:

• respond to requests for information;
• answer inquiries made through any communication channel;
• manage medical appointments;
• provide healthcare;
• create and maintain the medical record;
• carry out the patient's medical follow-up;
• issue estimates;
• manage payments and invoicing;
• comply with legal, tax, healthcare and administrative obligations;
• respond to complaints or requests to exercise rights;
• improve the quality of our services;
• ensure the security of our systems;
• send communications related to the appointments or treatments contracted;
• send commercial information only when there is a legal basis that allows it.

Under no circumstances will we use your data for purposes incompatible with those for which they were obtained.

6. Legal basis for processing

The processing of personal data carried out by Sante Clinics is based on the legal grounds set out in article 6 of the Reglamento General de Protección de Datos and, in the case of health-related data, on the circumstances contemplated in article 9 of the same Reglamento.

Depending on each situation, the processing may rely on one or more of the following bases:

• the performance of pre-contractual measures requested by the data subject;
• the provision of healthcare and the management of the care relationship;
• compliance with legal obligations applicable to the Clinic;
• the consent of the data subject when legally required;
• the legitimate interest of Sante Clinics, provided the fundamental rights and freedoms of the data subject do not prevail.

When the processing is based on consent, this may be withdrawn at any time without affecting the lawfulness of the processing carried out beforehand.

7. Medical record and healthcare documentation

The medical record is the main instrument for guaranteeing continuous, safe and quality healthcare.

In accordance with current healthcare legislation, Sante Clinics will create and retain the medical record of those patients who receive medical care, incorporating only the information necessary to adequately document the care process.

The medical record may include, among others:

• the patient's identification data;
• relevant personal and family medical history;
• anamnesis and clinical examination;
• diagnoses;
• treatments performed;
• medical progress;
• diagnostic tests;
• clinical reports;
• medical recommendations;
• informed consents;
• clinical photographs when necessary to document the progress of the treatment.

Access to this information is restricted exclusively to the healthcare professionals and authorized personnel involved in the patient's care or who must access the documentation to comply with legal or administrative obligations.

All Sante Clinics staff are subject to the duty of confidentiality and professional secrecy with respect to the information to which they have access.

8. Informed consents

Before carrying out those procedures for which healthcare regulations require it, the patient will receive sufficient, understandable information adapted to the characteristics of the proposed treatment.

This information will include, among other aspects, the purpose of the procedure, its nature, the expected benefits, the foreseeable risks, the existing alternatives and the post-treatment recommendations.

Once the information has been received and any questions raised have been resolved, the patient may give their consent by signing the corresponding informed consent document.

These documents will form part of the medical record and will be retained for the legally established periods.

9. Clinical photographs

In certain aesthetic medicine treatments it may be necessary to obtain clinical photographs in order to objectively document the patient's progress and facilitate an adequate medical assessment.

Images taken for this purpose will be of an exclusively care-related nature and will become part of the medical record.

Access to them will be limited to authorized personnel and they will be subject to the same level of protection and confidentiality as the rest of the healthcare documentation.

Taking clinical photographs does not, under any circumstances, imply authorization for their use for purposes other than medical care.

Use of images for scientific, teaching or informative purposes

When Sante Clinics considers it of interest to use clinical images for scientific, teaching or professional training activities, it will adopt the measures necessary to preserve the patient's identity.

Whenever there is the possibility of direct or indirect identification, the express consent of the data subject will be requested beforehand.

Use of images for advertising purposes

The publication of photographs or videos of patients on the website, social media, advertising campaigns or any other means of dissemination will always require express, specific, independent and revocable authorization.

The patient's refusal to authorize such use will in no way affect the quality of the healthcare received or condition access to the treatments offered by the Clinic.

Consent may be withdrawn at any time with respect to future publications, without prejudice to the lawfulness of those carried out beforehand on the basis of validly granted consent.

10. Communications with patients

In order to ensure adequate continuity of care, Sante Clinics may contact patients through the communication channels provided during the care process.

These communications may be carried out, among other means, through:

• telephone call;
• email;
• SMS messages;
• WhatsApp or other messaging systems, when the patient uses them to communicate with the Clinic.

Their purpose will be exclusively care-related or administrative and will include, among other cases:

• appointment confirmations;
• schedule changes;
• treatment reminders;
• sending post-procedure recommendations;
• requests for documentation;
• responses to inquiries raised by the patient.

Particularly sensitive medical information will not be requested through channels that are not suitable for it, except when the patient themselves voluntarily decides to use such means and the information is necessary to ensure proper healthcare.

11. Commercial communications

Sante Clinics will only send commercial communications when there is a legal basis that allows it.

When regulations require the prior consent of the recipient, such communications will only be sent after having obtained valid authorization.

These communications may include information relating to:

• new treatments;
• the incorporation of new services;
• informative sessions;
• Clinic news;
• promotions and campaigns, when their sending is legally appropriate.

The recipient may revoke their consent or object to receiving these communications at any time, free of charge and easily, using the link provided in each mailing or by writing to legal@santeclinics.com.

12. With whom do we share your data?

Confidentiality is one of the essential principles of Sante Clinics' activity.

For this reason, our patients' personal data will not be sold, transferred or disclosed to third parties for commercial purposes.

Only those persons or entities whose involvement is necessary for the correct provision of our services, or when there is a legal obligation requiring it, may access the information.

Depending on each case, the data may be disclosed to:

• healthcare professionals involved in the patient's care;
• laboratories or partner centers when their involvement is necessary for the provision of the requested service;
• financial institutions responsible for managing collections or payments;
• legal, tax, labor or accounting advisors that provide services to the Clinic;
• technology providers that act as data processors for the maintenance of systems, web hosting, backups or IT support;
• insurance companies, when the patient has expressly requested the management of benefits covered by their policy;
• public administrations, judges, courts or competent authorities when there is a legal obligation to disclose.

All providers that access personal data on behalf of Sante Clinics will be subject to the corresponding data processor contracts and may only process the information following our instructions and applying the security measures required by current regulations.

13. International data transfers

In general, the personal data processed by Sante Clinics is stored and managed within the European Economic Area.

However, certain technology providers used for the provision of web hosting, email, storage, backup, analytics or IT management services could involve the processing of information from third countries.

When this occurs, Sante Clinics will ensure that such transfers are carried out only when there is a valid legal basis and the guarantees required by the Reglamento General de Protección de Datos have been adopted.

These guarantees may consist, among others, of adequacy decisions by the European Commission, standard contractual clauses or any other mechanism recognized by the applicable regulations.

14. Data retention period

We will retain personal data only for the time necessary to fulfill the purpose for which they were obtained and, subsequently, for the periods required by applicable legislation to address possible legal liabilities.

In general:

• The data provided to request information or make inquiries will be retained for the time necessary to address the request and, subsequently, for the applicable legal periods.
• The data derived from the provision of healthcare and the documentation that makes up the medical record will be retained for the periods established by current healthcare legislation.
• Accounting, tax and administrative documentation will be retained for the periods required by tax and commercial regulations.
• The data used to send commercial communications will be processed until the data subject withdraws their consent or exercises their right to object.

Once the retention periods have ended, the data will be deleted or, where appropriate, blocked in accordance with applicable legislation.

15. Rights of data subjects

Any person whose data is processed by Sante Clinics may exercise, under the terms provided by the regulations, the following rights:

• Right of access, to know whether we are processing your personal data and to obtain information about such processing.
• Right of rectification, to request the modification of data that is inaccurate, incomplete or outdated.
• Right of erasure, when the circumstances legally provided for apply, without prejudice to the retention obligations arising from healthcare regulations.
• Right to object, when the processing is based on the legitimate interest of Sante Clinics or on other circumstances provided for by law.
• Right to restriction of processing, in the cases established by the Reglamento General de Protección de Datos.
• Right to portability, when legally appropriate.
• Right to withdraw consent, at any time, with respect to processing based on such authorization.

The exercise of these rights is free of charge and will not affect the lawfulness of the processing carried out beforehand.

16. How can you exercise your rights?

You may exercise any of the rights recognized in this Policy by contacting:

SANTE SALUD BARCELONA BRAND, S.L.

Avenida Diagonal 384

08037 Barcelona (España)

or by email to:

legal@santeclinics.com

In order to protect the confidentiality of the information, we may request the documentation strictly necessary to verify the identity of the applicant when there are reasonable doubts about their identity.

Requests will be addressed within the periods established by current regulations.

17. Right to lodge a complaint

If you consider that the processing of your personal data does not comply with applicable regulations or you believe that your rights have not been duly addressed, you can lodge a complaint with the competent supervisory authority.

In Spain, the competent authority is the Agencia Española de Protección de Datos (AEPD).

However, before turning to the supervisory authority, we invite you to contact us through legal@santeclinics.com so that we can analyze your request and try to offer a quick and satisfactory solution.

18. Information security

Protecting information is a priority for Sante Clinics.

We apply appropriate technical and organizational measures to protect personal data against loss, destruction, alteration, disclosure or unauthorized access, taking into account the nature of the information processed, the state of the technology and the existing risks.

These measures are reviewed periodically to maintain an adequate level of security and to guarantee the confidentiality, integrity, availability and resilience of the systems used by the Clinic.

However, no technological system can guarantee absolute security, so, in the event of an incident that may significantly affect the rights and freedoms of individuals, we will act in accordance with the procedures established by current regulations.

19. Minors

The services offered by Sante Clinics are generally aimed at adults.

When, exceptionally and in accordance with healthcare legislation, the care of a minor is necessary, the processing of their personal data will be carried out respecting the guarantees provided by the applicable regulations and, where appropriate, with the involvement of those who hold parental authority or legal representation.

20. Social media

Sante Clinics has official profiles on various social media platforms in order to provide information about its services, activities and news.

Users' interaction with these profiles will be governed both by this Privacy Policy and by the conditions and policies established by each platform.

We recommend not publishing medical information or sensitive personal data through social media, as these are open environments whose management depends on third parties.

21. Modifications to this Policy

Sante Clinics may update this Privacy Policy when necessary to adapt it to legislative changes, criteria of the supervisory authorities, modifications to the processing carried out or improvements to our internal procedures.

The version in force will always be the one published on this website and will indicate the date of its last update.

Contact

If you have any inquiry related to the processing of your personal data or wish to exercise any of the rights recognized by data protection regulations, you can contact us through the following means:

SANTE SALUD BARCELONA BRAND, S.L.

Avenida Diagonal 384

08037 Barcelona (España)

legal@santeclinics.com

+34 699 145 887