Privacy -

PERSONAL DATA PROCESSING POLICY DRA JOHANNA CALDERÓN

I. General

The legal regulations in force in Colombia stipulate the right of all persons to know, update and rectify the information that exists about them in databases or files of public or private entities. Likewise, it orders those who have Personal Data of third parties to respect the rights and guarantees provided for in the Constitution when collecting, processing and circulating this type of information.

Constitutionally, the right of every person to information is enshrined, so that they receive truthful and impartial information.

DRA JOHANNA ANDREA CALDERÓN BOHORQUEZ (hereinafter DRA JOHANNA CALDERON) is committed to full compliance with the regulations on the protection of Personal Data, implementing due respect for the rights of the Holders of the information. For the above, it adopts this Personal Data Processing Policy (hereinafter, “The Policy”) is mandatory and applicable in all activities that, within the fulfillment of its corporate purpose, involve the Processing of Personal Data and is mandatory for DRA JOHANNA CALDERON, its Administrators, Collaborators and any third party with whom it has a contractual or commercial relationship.

DRA JOHANNA CALDERON, within the development of its corporate purpose, receives, transmits and processes Personal Data on a daily basis, so it is essential to have this policy and strictly comply with it, especially when it comes to sensitive and legally confidential Data, such as information related to health conditions, reflected in medical history.

II. Objective

The objective of this Policy is to ensure due and optimal compliance with Statutory Law 1581 of 2012 and Decree 1377 of 2013, as well as the definition of the guidelines for the reception, attention to queries and complaints of the Holders of Personal Data on which DRA JOHANNA CALDERON carries out some type of Treatment.

The implementation of this policy aims to ensure the confidentiality of information and the security of the treatment that will be given to it to all patients, employees, suppliers and third parties from whom DRA JOHANNA CALDERON has legally obtained information and personal data in accordance with the guidelines established by the law regulating the right to Habeas Data.

III. Scope

This Policy is mandatory and strictly enforceable by DRA JOHANNA CALDERON, its directors, administrators, collaborators and other third parties who represent it or act on its behalf, or with whom DRA JOHANNA CALDERON has any type of link, whether legal, commercial or conventional.

Without exception, all DRA JOHANNA CALDERON Collaborators must observe, respect, comply with and enforce this Policy in the performance of their duties.

IV. Definitions

For the purposes of interpretation and application of this policy, the following concepts must be taken into account:

Authorization: consent that the owner of any personal data issues in advance, expressly and in an informed manner so that DRA JOHANNA CALDERON can carry out the processing of his/her personal data.
Privacy Policy: Physical, electronic document generated by the data controller that is made available to the owner with information regarding the existence of information processing policies that will be applicable to him/her, the way to access them and the characteristics of the Processing that is intended to be given to the personal data.
Database: It is the organized set of Personal Data that is subject to Processing, electronic or not, whatever the modality of its formation, storage, organization and access.
Query: Request from the data owner or persons authorized by him or her or by law to know the information stored about him or her in databases or files.
Personal data: Any information that directly or indirectly refers to a natural person and that allows him or her to be identified. Some examples of personal data are: name, citizen identification number, postal address, email address, telephone number, marital status, health data, fingerprint, salary, assets, financial statements, etc.
Private Personal Data: means data that, due to its intimate or reserved nature, is only relevant to the Data Subject. For example: papers or books of merchants and private documents.
Public Personal Data: means data classified as such according to the mandates of the law or the Political Constitution and all data that are not semi-private, private or sensitive. For example: data contained in public documents, public records, official gazettes and bulletins and duly executed court rulings that are not subject to reservation, data relating to the civil status of persons, their profession or trade and their status as merchant or public servant. Personal Data existing in the commercial register of the Chambers of Commerce are public (Article 26 of the C.Co.).

Likewise, public data is data that, by virtue of a decision by the Owner or a legal mandate, is found in freely accessible and consultable files. This data can be obtained and offered without reservation and regardless of whether it refers to general, private or personal information.

Semi-private personal data: means data that is not of an intimate, reserved or public nature and whose knowledge or disclosure may be of interest not only to its Owner but also to a certain sector or group of people, or to society in general. For example: data relating to the fulfillment and non-fulfillment of financial obligations or data relating to relations with social security entities.
Sensitive personal data: means data that affects a person's privacy or whose misuse may lead to discrimination. For example: data that reveals racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, human rights organizations or that promotes the interests of any political party or that guarantees the rights and guarantees of opposition political parties, data relating to health, sexual life and biometric data (fingerprints), among others.
Responsible for the treatment: Person who decides on the collection and purposes of processing, among others. This may be, for example, the company that owns the databases or information system that contains personal data.
Claim: means the request of the Data Owner or the persons authorized by him or her or by law to correct, update or delete his or her Personal Data or when they notice that there is an alleged breach of the data protection regime, according to Article Art. 15 of Law 1581 of 2012.
Data owner: It is the natural person to whom the data refers.
Treatment: Any operation or set of operations on personal data such as, among others, the collection, storage, use, circulation or deletion of such information.
Transfer: Sending of personal data carried out by the Controller or the Processor from Colombia to a Controller located within (national transfer) or outside the country (international transfer).
Transmission:: Processing of personal data that involves the communication of the same within (national transmission) or outside Colombia (international transmission) and that has as its object the performance of a treatment by the Person in Charge on behalf of the Person in Charge.
In charge: means the natural or legal person who carries out the Data Processing on behalf of the Data Controller.
Authorized: It means all persons who, under the responsibility of DRA JOHANNA CALDERON or its Managers, may carry out Personal Data Processing by virtue of the Authorization granted by the Owner.
Controller: Natural or legal person, public or private, that by itself or in association with others, decides on the database and / or the Treatment of the data.
Procedural requirement: prior step that the Data Subject must take before filing a complaint with the Superintendence of Industry and Commerce. This consists of a direct claim to the Person in Charge or Responsible for his/her Personal Data.

V. Principles for the Processing of Personal Data

In the development, interpretation and application of this Policy, the following principles will be applied in a harmonious and comprehensive manner:

1. Related to the Collection of Personal Data.

a. Principle of Liberty: Unless otherwise provided by law, data collection may only be carried out with the prior, express and informed consent of the Data Subject. Personal Data may not be obtained or disclosed without the prior consent of the Data Subject, or in the absence of a legal or judicial mandate waiving consent.

The Data Subject must be informed in a clear, sufficient and prior manner about the purpose of the information provided and therefore, data may not be collected without a clear specification of the purpose thereof.

b. Principle of Collection Limitation: Only the Personal Data that is strictly necessary for the fulfillment of the purposes of the Processing should be collected, so that the recording and disclosure of data that is not closely related to the purpose of the Processing is prohibited. Consequently, everything reasonably possible should be done to limit the processing of Personal Data to the minimum necessary. That is, the data must be: (i) adequate, (ii) relevant and (iii) consistent with the purposes for which they were intended.

2. Related to the Use of Personal Data.

a. Principle of purpose: The processing must be for a legitimate purpose in accordance with the Constitution and the Law, which must be communicated to the Owner in advance, clearly and sufficiently. Data may not be collected without a specific purpose.

b. Principle of Temporality: Personal Data will be retained only for a reasonable period of time necessary to fulfil the purpose of the Processing and the legal requirements or instructions of the supervisory and control authorities or other competent authorities. The data will be retained when it is necessary for the fulfilment of a legal or contractual obligation. To determine the term of the Processing, the regulations applicable to each purpose and the administrative, accounting, fiscal, legal and historical aspects of the information will be considered.

3. Related to Information Quality.

a. Principle of Truth or Quality: The information subject to processing must be true, complete, accurate, up-to-date, verifiable and understandable. The processing of partial, incomplete, fractional or misleading data is prohibited. Reasonable measures must be taken to ensure that the data is accurate and sufficient and, when requested by the Owner or when Dr. Johanna Calderon determines, be updated, rectified or deleted if appropriate.

4. Related to the Protection, Access and Circulation of Personal Data.

a. Safety Principle: Each person linked to Dr. Johanna Calderon, must comply with the technical, human and administrative measures established by it to ensure the security of Personal Data, avoiding its adulteration, loss, consultation, use or unauthorized or fraudulent access.

b. Transparency Principle: In the Treatment, the right of the Owner to obtain, at any time and without restrictions, information about the existence of data that concerns him or her must be guaranteed.

c. Principle of Restricted Access and Circulation: Only the following persons will be permitted access to Personal Data:

I. To the Data Owner.

II. To persons authorized by the Data Owner.

III. To persons who by legal mandate or court order are authorized to know the information of the Data Owner. given.

d. Confidentiality Principle: All persons involved in the Processing of Personal Data that are not public in nature are obliged to guarantee the confidentiality of the information, even after their relationship with any of the tasks that comprise the Processing has ended, and may only provide or communicate Personal Data when this corresponds to the development of the activities authorized by law.

VI. Processing to which the Personal Data will be subjected and the purpose thereof

DRA JOHANNA CALDERON will process the Personal Data in accordance with the conditions established by the Owner, the law or public entities for the fulfillment of the activities inherent to its corporate purpose, such as the provision of dental services, contracting, execution and marketing of the goods and services it offers.

The processing of personal data may be carried out through physical, automated or digital means according to the type and form of information collection.

DRA JOHANNA CALDERON may also process the Personal Data, among others, for the following purposes:

Exercise your right to sufficiently know the Owner with whom you intend to establish relations, provide services, and assess the present or future risk of the same relations and services. Carry out the relevant procedures for the development of the pre-contractual, contractual and post-contractual stage with DRA JOHANNA CALDERON, with respect to any of the products or services offered by it, which you have or have not acquired or with respect to any underlying business relationship you have with it, as well as comply with Colombian or foreign law and the orders of judicial or administrative authorities;

Carry out marketing, sales and promotional activities, telemarketing (telephone marketing), customer service, brand activation activities, prizes and promotions, directly or through third parties derived from commercial alliances or any link;

Implement relationship strategies with patients, suppliers, shareholders and other third parties with whom the Company has contractual or legal relationships;

Make invitations to events, improve products and services or offer new products, and all those activities associated with the commercial relationship or existing link with DRA JOHANNA CALDERON, or any other that may arise;

Manage procedures (requests, complaints, claims), carry out satisfaction surveys regarding the services offered by DRA JOHANNA CALDERON, or related companies and its business partners;

Disclose, transfer and/or transmit Personal Data within and outside the country to the parent companies of DRA JOHANNA CALDERON or to third parties as a result of a contract, law or lawful link that so requires or to implement cloud computing services.

The data collected or stored about DRA JOHANNA CALDERON employees by filling out forms, by telephone, or by submitting documents (CVs, attachments) will be processed for all matters related to legal or contractual labor issues. In accordance with the above, DRA JOHANNA CALDERON will use the Personal Data for the following purposes: (1) To comply with laws such as, among others, labor law, social security, pensions, professional risks, family compensation funds (Comprehensive Social Security System) and taxes; (2) To comply with the instructions of the competent judicial and administrative authorities; (3) To implement labor and organizational policies and strategies.

Sort, catalogue, classify, divide or separate the information provided by the Data Holders. Verify, corroborate, check, validate, investigate or compare the information provided by the Data Holders, with any information legitimately available, such as business relationships. Access, consult, compare and evaluate all the information about the Holder that is stored in the databases of any credit, financial, judicial or security background check center, of a state or private, national or foreign nature, or any commercial or service database, that allows to establish in a comprehensive and complete historical manner, the behavior as a debtor, user, client, guarantor, endorser, affiliate, beneficiary, subscriber, taxpayer and/or as Holder of financial, commercial or any other type of services.

For security purposes, to improve our service and the experience at DRA JOHANNA CALDERON facilities, Personal Data may be used, among others, as evidence in any type of process, regarding the data (i) collected directly at security points, (ii) taken from the documents that people provide to security personnel and (iii) obtained from video recordings made inside or outside the facilities of DRA JOHANNA CALDERON.

Know, store and process all the information provided by the Data Owners in one or more databases, in the format deemed most convenient.

Carry out all tax, accounting, fiscal and billing procedures.

The validity of the database will be the reasonable and necessary time to fulfill the purposes of the Treatment in each case, taking into account the provisions of Article 11 of Decree 1377 of 2013.

VII. Rights of Data Subjects

Holders of personal data have the right to:

To know, update and rectify your Personal Data in front of the Data Controllers or Data Processors. This right may be exercised, among others, in the case of partial, inaccurate, incomplete, fragmented data that may lead to error, or data whose processing is expressly prohibited or has not been authorized. For this purpose, it is necessary to previously establish the identification of the person to prevent unauthorized third parties from accessing the Owner's data.
Request proof of authorization granted to Dr. Johanna Calderon, unless it is one of the cases in which authorization is not necessary, in accordance with the provisions of Article 10 of Law 1581 of 2012.
be informed by Dr. Johanna Calderon, upon request, regarding the use that has been given to your Personal Data.
Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of the law and other regulations that modify, add to or complement it.
Revoke the authorization and/or request the deletion of the data when the Processing does not respect the constitutional and legal principles, rights and guarantees. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the Processing the Controller or Manager has engaged in conduct contrary to this law and the Constitution.
The request for deletion of information and revocation of authorization will not proceed when the Owner has a legal or contractual obligation to remain in the database of the Controller or Processor.
Access free of charge to your Personal Data that have been subject to Processing.

VIII. Duties of DRA JOHANNA CALDERON when acting as Controller.

DRA JOHANNA CALDERON is obliged to comply with the duties imposed by law. Therefore, she must act in such a way that she complies with the following duties:

1. Regarding the Data Owner.

a. Guarantee the Owner, at all times, the full and effective exercise of the rights mentioned in section VII of this Policy.

2. Regarding the quality, security and confidentiality of Personal Data.

a. Observe the principles of truthfulness, quality, security and confidentiality in the terms established in this Policy.

b. CKeep the information under the security conditions necessary to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.

c. Update information when necessary.

d. Rectify Personal Data when appropriate.

3. Regarding Processing through a Processor.

a. Provide the Data Processor only with Personal Data whose processing has been previously authorized.

b. Ensure that the information provided to the Data Processor is true, complete, accurate, up-to-date, verifiable and understandable.

c. Communicate in a timely manner to the Data Processor any new developments regarding the data that you have previously provided and adopt any other measures necessary to ensure that the information provided to the Data Processor remains up to date.

d. Inform the Data Processor in a timely manner of any corrections made to Personal Data so that the Data Processor may proceed to make the relevant adjustments.

e. Demand that the Data Processor at all times respect the security and privacy conditions of the Owner's information.

f. Inform the Treatment Manager when certain information is under discussion by the Holder, once the claim has been submitted and the respective procedure has not been completed.

4. Regarding the Superintendence of Industry and Commerce.

a. Inform you when security code violations occur and there are risks in the management of the information of the Holders.

b. Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

IX. Duties of DRA JOHANNA CALDERON when acting as Manager.

In the event of data processing on behalf of another entity or organization that is the Data Controller, DRA JOHANNA CALDERON must comply with the following duties:

Guarantee the Holder, at all times, the full and effective exercise of the right to habeas data.
Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
Carry out the updating, rectification or deletion of data in a timely manner.
Update the information reported by the Data Controllers within five (5) business days from receipt.
Process queries and complaints made by the Owners in the terms indicated in this Policy.
Refrain from circulating information that is being controversial by the Holder and whose blocking has been ordered by the Superintendency of Industry and Commerce.
Allow access to the information only to persons authorized by the Owner or empowered by law for such purpose.
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.
Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.

X. From the authorization

1. Authorization for Data Processing.

Those required to comply with this policy must obtain prior, express and informed authorization from the Owner to collect and process their Personal Data. This obligation is not necessary when dealing with data of a public nature.

To obtain authorization, it is necessary to inform the Data Subject clearly and expressly of the following:

a. The Processing to which your Personal Data will be subjected and the purpose thereof;

b. The optional nature of the response to the questions asked, when these relate to sensitive data or the data of girls, boys and adolescents;

c. The rights that you have as Owner provided for in Article 8 of Law 1581 of 2012;

d. The identification, physical or electronic address of Dr. Johanna Calderon.

The Authorization of the Holder must be obtained through any means that can be subject to subsequent consultation, such as the website, forms, formats, activities, contests, in person or on social networks, PQR format, data messages or Apps.

In all cases, proof of compliance with the above points must be left.

Authorization may also be obtained from unequivocal conduct by the Data Subject that reasonably allows us to conclude that he/she has given his/her consent to the Processing. Such conduct(s) must be very clear so as not to allow for any doubt or mistake regarding the will to authorize the Processing.

2. Authorization for processing sensitive data.

When collecting sensitive data, the following requirements must be met:

a. The authorization must be explicit;

b. The Owner must be informed that he/she is not obliged to authorize the Processing of said information;

c. The Data Subject must be informed explicitly and in advance which of the data to be processed are sensitive and the purpose thereof.

3. Authorization for processing data of children and adolescents (NNA).

When it comes to the collection and processing of data from children and adolescents, the following requirements must be met:

a. Authorization must be granted by persons who are authorized to represent the children and adolescents. The representative of the children and adolescents must guarantee the children and adolescents' right to be heard and assess their opinion on the Treatment, taking into account the children and adolescents' maturity, autonomy and capacity to understand the matter.

b. It should be reported that it is optional to answer questions about data on children and adolescents.

c. Dr. Johanna Calderon must ensure that the Processing of Personal Data of Children and Adolescents will be carried out respecting their rights, which is why, in the commercial and marketing activities that it carries out, it must have the prior, express and informed authorization of the father or mother or the legal representative of the Children and Adolescents.

XI. National or international transfers of Personal Data

DRA JOHANNA CALDERON may transfer data to other Data Controllers when authorized by the Data Owner, by law or by an administrative or judicial order.

XII. National or international transmissions of Personal Data

DRA JOHANNA CALDERON may send or transmit data to one or more Managers located within or outside the territory of the Republic of Colombia in the following cases:

When you have authorization from the Owner.
When there is a data transmission contract between the Controller and the Processor without authorization.

XIII. Procedure for Holders to exercise their rights

For the full and effective exercise of the rights that assist the Holders of Personal Data, or the persons authorized by law for this purpose, DRA JOHANNA CALDERON has the email address ppgad@pucrs.br through which they may submit all queries, complaints and/or claims associated with the right to Habeas Data.

All requests made by persons entitled to know the Personal Data held by DRA JOHANNA CALDERON will be channeled through the aforementioned email address, which will include the date of receipt of the query and the identity of the applicant.

The claim must be addressed to DRA JOHANNA CALDERON. and contain at least the following information:

Name and identification of the data owner or authorized person.
Accurate and complete description of the facts giving rise to the claim.
Physical or electronic address to send the response and inform about the status of the procedure.
Documents and other relevant evidence that you wish to present.

Once the request has been received, the identity of the petitioner or his legitimacy for this purpose will be verified. The response to the query must be communicated to the applicant within a maximum period of ten (10) business days from the date of receipt of the same. When it is not possible to respond to the query within this period, the interested party must be informed of the reasons for the delay and the date on which his query will be responded to, which in no case may exceed five (5) business days following the expiration of the first period.

If the application or claim is incomplete, the interested party will be required within five (5) days of receipt to correct the deficiencies. After two (2) months from the date of the request, if the applicant does not submit the required information, it will be understood that he has withdrawn the claim.

XIV. Person or area responsible for the protection of Personal Data

The Personal Data Protection Officer is the person in charge of the data protection function, who can be contacted via email ppgad@pucrs.br

XV. Video surveillance

Dr. Johanna Calderon uses various video surveillance means installed in different internal and external locations of its facilities or offices. For this reason, it informs the general public about the existence of these mechanisms by disseminating video surveillance announcements in visible locations.

The information collected through this mechanism is used for security purposes, to improve our service and the experience at the DRA JOHANNA CALDERON facilities, as well as as evidence in any type of process before any type of authority or organization, however, the recording reservation time will at no time exceed eight (8) days.

DRA JOHANNA CALDERON does not deliver video recordings obtained to any third party, unless there is a court order or a competent authority or the law allows it.

XVI. Data of the Data Controller

Company name: DRA JOHANNA CALDERON

NIT: 1.110.461.261

Address: Torreón Empresarial Building, office 907, Ibagué – Colombia

Email: ppgad@pucrs.br

Phone: (314) 602-4619

Website: www.periodoncistajohannacalderon.com

XVII. Information security policies

DRA JOHANNA CALDERON will adopt the technical, administrative and human measures necessary to ensure the security of the Personal Data that it processes, protecting its confidentiality, integrity, use, and unauthorized and/or fraudulent access. To this end, it has implemented security protocols that are mandatory for all Personnel who have access to this data and/or the information systems.

The internal security policies under which the Owner's information is kept to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access are included in the Comprehensive Personal Data Management Program of DRA JOHANNA CALDERON.

The Processing of Personal Data will be from the beginning of the Event until the day DRA JOHANNA CALDERON is dissolved and liquidated or until the purpose for which the Personal Data was collected is completed.

XVIII. Adjustments to the Personal Data Processing Policy

In order to maintain the validity of the policy, DRA JOHANNA CALDERON may adjust and modify it, indicating the date of the update on the website or by using other means, such as data messages, physical materials at points of sale, etc.

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