In compliance with Law 1581 of 2012, by which provisions are issued for the protection of personal data, UNIDAD OPERADORA DE FRANQUICIAS ODONTOLOGIA DE MARLON BECERRA in its capacity as responsible for the processing of personal data, informs the general guidelines in this matter:

1. General Data

The responsible for the treatment of your personal data is UNIDAD OPERADORA DE FRANQUICIAS ODONTOLOGIA DE MARLON BECERRA identified with Nit: 830.088.051-5, with main office at Calle 93 # 13 – 45 Local 101 y 102. Bogotá D.C. Web Portal www.marlonbecerra.co

Contact: Through any of the Customer Service channels that UNIDAD OPERADORA DE FRANQUICIAS ODONTOLOGIA DE MARLON BECERRA has available.

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INFORMATION OF THE PERSON RESPONSIBLE FOR THE DATA PROCESSING:

FRANCHISE OPERATING UNIT
NIT: 900438367-3
93 Street # 13 – 45 Local 101 and 102. Bogotá D.C. (+57) (1) 7461111 protecdatos@marlonbecerra.co

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2. LEGAL FRAMEWORK

Constitution, Article 15.
Law 1266 of 2008
Law 1581 of 2012
Regulatory Decrees 1727 of 2009 and 2952 of 2010,
Partial Regulatory Decree 1377 of 2013
Rulings C – 1011 of 2008, and C – 748 of 2011, of the Constitutional Court.

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3. DATA PROCESSING POLICY

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT in compliance with its legal and regulatory duty, strives to make effective the constitutional guarantee of protection to the personal and family privacy of all citizens, establishing instruments and expeditious controls in order to give an adequate treatment to the information it administers.

The purpose of this Policy is to define the necessary guidelines to guarantee the exercise of the right to privacy of individuals, through the protection of personal data contained in the different databases of MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT so that they receive the treatment in accordance with the intended purposes. The Policy for the Treatment of Personal Data is applicable to the personal data contained in the databases that are under the responsibility of MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT and that are susceptible to any access or treatment by MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT, its personnel or any third party.

These terms and conditions apply to any registration of personal data made in person and/or virtually for the linking to any product, service or benefit of MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT. The data subject registers or submits his/her information freely and voluntarily and acknowledges that he/she has read and expressly accepts these terms and conditions. MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT. is directly responsible for the processing of Personal Data; however, it reserves the right to delegate such processing to a third party. MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT.

Similarly MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT reports that for several years of experience, for reasons of providing health services, has collected, retained and used information from individuals, to give the following treatments, directly or through third parties: consult, be subject to administrative procedures, send information, contact by telephone, request completion of survey, collect, store, use, circulate, delete, process, contact, survey, compile, exchange, publish, audit, update and / or dispose of the data provided by the holder to incorporate them in the various databases or databases, or in electronic or manual repositories of all kinds that MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT has. These treatments have been carried out for the purpose of providing health services, compliance with regulatory, scientific, commercial, promotional, informational, security, quality improvement and evaluation of the external positioning of the institution and its activities. The purposes listed below will be detailed according to the types of data handled. Other purposes that are not contemplated in this Policy, whose origin is not regulatory, must be expressly authorized by the owners of the data.

At present MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATOR UNIT wishes to continue with the treatment and collection of information for the purposes described in this Policy, and for this purpose requires authorization from the owners who provide information for their databases to give them treatment other than those authorized by the legal norms.

 

4. SCOPE OF APPLICATION

The present policy will be applicable to the personal data registered in any database of MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT whose owner is a natural or legal person.

 

5. DEFINITIONS

For the purposes of this policy and in accordance with current legislation on the protection of personal data, the following definitions shall be taken into account

 

Authorization:

Any free, specific, informed and explicit manifestation of will, in oral or written form, by means of which the Data Subject accepts, either by means of a statement or unequivocal conduct by means of which the granting of the processing of personal data concerning him/her can be reasonably inferred.

 

Treatment:

Any operation or set of operations, whether or not by means of automated procedures, applied to personal data, such as collection, recording, organization, storage, processing or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form that facilitates access to them, matching or interconnection, as well as their blocking, deletion, modification or destruction.

 

Privacy Notice:

Verbal or written communication generated by the Controller, addressed to the Data Subject for the processing of his/her personal data, by means of which he/she is informed about the existence of the information processing policies that will be applicable to him/her, the way to access them and the purposes of the processing that is intended to be given to the personal data.

 

Personal data processing policies:

A set of guidelines whose purpose is to inform and define both the rules for processing personal data in an organization and the guidelines for the holder to exercise his or her rights.

 

Responsible for the treatment:

Natural or legal person, public or private, who alone or in association with others, decides on the database and/or the processing of data.

 

Data Processor:

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 Controller.

 

Database:

Any structured set of personal data, accessible according to determined criteria.

 

Data owner:

Natural person owner of the information provided, which is the object of the treatment.

 

Delegate or responsible area:

Natural person or area of the Company delegated to: i) the implementation and proper functioning of the policies for the processing of personal data; ii) to process and respond to requests from the owner of the information; iii) Cooperate and provide timely response to requests from the supervisory authority.

 

Public data:

It is data that is not semi-private, private or sensitive. Public data includes, among others, data related to the marital status of individuals, their profession or trade, and their status as merchants or public servants. By their nature, public data may be contained, among others, in public records, public documents, official gazettes and bulletins and duly executed court rulings that are not subject to confidentiality.

 

Sensitive data:

Sensitive data are understood as those that affect the privacy of the Data Subject or whose improper use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations, human rights or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sex life, and biometric data.

 

Transfer:

The transfer of data takes place when the controller and/or processor of personal data, located in Colombia, sends the information or personal data to a recipient, which in turn is responsible for the processing and is located inside or outside the country.

 

Transmission:

processing of personal data that involves the communication of such data within or outside the territory of the Republic of Colombia when the purpose of the processing is to be carried out by the processor on behalf of the controller.

 

5. PRINCIPLES

In order to guarantee the protection of personal data, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT will apply in a harmonious and integral manner the following principles, in the light of which the treatment, transfer and transmission of personal data must be carried out

 

Principle of legality in data processing:

Data processing is a regulated activity, which shall be subject to the legal provisions in force and applicable to the subject.

 

Principle of finality:

The personal data processing activity carried out by MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT or to which it has access, will obey a legitimate purpose in accordance with the Political Constitution of Colombia, which must be informed to the respective owner of the personal data.

 

Principle of freedom:

The processing of personal data can only be carried out with the prior, express and informed consent of the Data Subject. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal, statutory, or judicial mandate that relieves consent.

 

Principle of veracity or quality:

The information subject to personal data processing must be truthful, complete, accurate, updated, verifiable and understandable. The processing of partial, incomplete, fractioned or misleading data is prohibited.

 

Principle of transparency:

In the treatment of personal data, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT will guarantee the Data Subject his right to obtain at any time and without restrictions, information about the existence of any type of information or personal data that is of his interest or ownership.

Principle of restricted access and circulation:

The processing of personal data is subject to the limits derived from the nature of the data, the provisions of the law and the Constitution. Consequently, the processing may only be carried out by persons authorized by the owner and/or by the persons provided for by law. Personal data, except for public information, may not be made available on the Internet or other means of mass dissemination or communication, unless access is technically controllable in order to provide restricted knowledge only to the owners or third parties authorized in accordance with the law. For these purposes the obligation of ODANQUICIAS ODONTOLOGIA DE MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT, will be medium.

 

Safety principle:

The information subject to treatment by MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT shall be handled with the technical, human and administrative measures that are necessary to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.

 

Principle of confidentiality:

All persons who in UNIDAD OPERADORA DE FRANQUICIAS ODONTOLOGIA DE MARLON BECERRA,, administer, manage, update or have access to information of any kind that is in databases, are obliged to ensure the confidentiality of the information, so they undertake to preserve and maintain strictly confidential and not disclose to third parties, all information that they come to know in the execution and exercise of their functions, except in the case of activities expressly authorized by the data protection law. This obligation persists and will be maintained even after the end of your relationship with any of the tasks that comprise the Processing.

 

6. RIGHTS OF THE HOLDER OF THE INFORMATION

In accordance with the provisions of the current applicable regulations on data protection, the following are the rights of the holders of personal data:

 

Holder

For the purposes of this Policy, holders of personal data shall be understood as natural or legal persons, including patients and users of the health service, providers, clients, benefactors, students, health professionals and employees in general.

 

Authorization

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT requires the prior informed and express authorization of the owner, which will be obtained by written means, either physical or electronic, in such a way that it may be subject to subsequent consultation.

When requesting the information to the Data Subject, the purpose for which the personal data is collected, the treatment to which the personal data may be subjected, their rights and the means through which they may exercise them and the power to authorize or not the treatment in case of sensitive data must be clearly informed.

Authorization of the Data Subject is not required when it concerns:

1. Respond to a court order or when requested by a public or administrative entity in the exercise of its legal functions;
2. personal data of a public nature;
3. cases of medical or sanitary emergency;
4. information authorized by law for historical, statistical or scientific purposes.
5. data related to the civil registry of persons.

Holder’s rights

The Holder shall have the right to know, rectify and update their personal data, request proof of authorization except in exceptional cases by law, be informed about the use given to their personal data, submit queries and file complaints, request revocation to MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT for non-compliance with the regulations and to access free of charge to the personal data that have been processed.

 

Duties of the holder

The Holder must guarantee the veracity of the information he/she provides to MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT and update his/her information in a timely manner. In case of falsehood in the information provided to MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT is exempt from any liability.

 

Duties of the person in charge

The Controller undertakes to proceed under the regulatory guidelines to ensure to the extent that it is entitled to the exercise of the rights of the Data Controllers of the personal data obtained in the performance of their duties.

 

7. TYPE OF INFORMATION RECORDED

To facilitate contact with Cardholders, we record and retain personal data or any linked information that can be associated with the individual. MARLON BECERRA DENTISTRY FRANQUICIA UNIDAD OPERATIVA obtains information through the following sources:

• When the patient or user voluntarily provides information.
• In health care processes.
• In service billing processes.
• Other sources, which provide information related to the service the user requires.
• In the process of commercial activities
• In the development of educational activities
• In the exercise of labor proceedings
• Name, addresses and telephone numbers
• Date and place of birth, as well as gender
• E-mail addresses.
• Information necessary to facilitate contact or other services, including contact information.
• family or work.
• Identity card number, passport, nationality and country of residence
• Identification, representation and existence in the case of legal persons
• Use of services.
• Personal information provided through surveys or other research methods.
• Personal information provided to the Customer Service office.
• Due to the nature of our health care institution, we also record basic data of the person responsible for the patient, as well as the health insurance company to which he/she is affiliated.

Información personal facilitada a la oficina de Atención al Cliente.

8. USE OF INFORMATION

In addition to the general purposes stated in the introductory part of this Policy, we have the following purposes, which are common to the data of all types of owners: Efficient communication related to services and partnerships through different means. Verify the veracity of the data provided. Provide information on campaigns, research, special programs. Inform and invite to marketing campaigns, promotion of services and user education. Conduct a service satisfaction survey. Response, management and follow-up to requests for improvement, petitions and suggestions.

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT according to the different relationships it has with the types of holders of personal data, may have special purposes in the processing of data, which are indicated below. The different types of holders may be: patients, collaborators, contractors or providers, representatives or collaborators of entities responsible for payment of health services or users in general.

8. PURPOSES FOR WHICH THE INFORMATION IS USED

Special purposes for the treatment of patient data: To obtain fundamental data for clinical and epidemiological research; To identify clinical, scientific and technological advances; To achieve efficient communication related to our services and partnerships; To provide information about special campaigns and programs. Report marketing activities and/or promotion of own services or with whom MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT has entered into alliances of health services; User education campaigns; To know the state of satisfaction of services and care provided.

 

Special purposes for the processing of personal data of collaborators:

Inform about calls and invitations to health events. Providing internal and external publications Opening and managing access and support to the organization’s own technological platforms Providing information to companies that request verification of employees’ labor data for authorization of loans or commercial credits. The above, after verification of the source and use of data, should focus on verification rather than on the provision of information. To be contacted directly in case of being required, due to their functions. Detect training needs Inform and shape election and internal promotion processes.

Special purposes for the processing of personal data of suppliers and contractors: Evaluation of goods and services provided by suppliers and contractors. Follow-up and management of the contractual relationship. Verify the suitability for the performance of the contracted services.

Special purposes of personal data of representatives or collaborators of entities responsible for the payment of health services: Sending calls and invitations to health events. Special purposes of personal data of visitors and other community users. Safety of patients, visitors, collaborators and the general community that are in the facilities of MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT

Besides using it to process, confirm and comply with the object of operation of ODANQUICIAS ODONTOLOGIA DE MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT or any other service requested by the Holder, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT may use this information for administrative and analytical purposes, such as administration of information systems, invoicing, accounting and audits, commercial relationship, processing and verification of payment methods, correspondence from our Customer Service area, and/or for the operation of promotional programs that may be implemented.

 

9. TRANSFER AND TRANSMISSION OF PERSONAL DATA

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT complies with the provisions of Article 26 of the Statutory Law 1581 of 2012 and refrains from transferring personal data of the Data Controllers to other countries that do not have equal or higher standards of protection. However, the following exceptions shall apply:

 

This prohibition shall not apply in the case of:

a) Information with respect to which the Data Subject has granted express and unequivocal authorization for the transfer.

b) Exchange of medical data, when so required by the Data Controller’s Treatment for reasons of public health or hygiene.

c) Bank or stock exchange transfers, in accordance with the applicable legislation.

d) Transfers agreed within the framework of international treaties to which the Republic of Colombia is a party, based on the principle of reciprocity.

e) Transfers necessary for the execution of a contract between the Data Subject and the Data Controller, or for the execution of pre-contractual measures, as long as the Data Subject’s authorization is obtained.

 

10. children’s and adolescents’ rights

In the processing of personal data, respect for the prevailing rights of minors shall be ensured. The processing of personal data of minors is prohibited, except for those data that are of a public nature, and in this case the processing must comply with the following parameters:

a. Respond to and respect the best interests of minors.
b. To ensure respect for the fundamental rights of minors.

It is the task of the State and educational entities of all types to provide information and train legal representatives and guardians on the possible risks faced by children and adolescents with respect to the improper processing of their personal data, and to provide knowledge about the 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.

11. REFUSAL TO PROCESS INFORMATION

If the user or patient considers that ODANQUICIAS ODONTOLOGIA DE MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT should not use or share his/her personal information for the purposes stated herein, or does not want to receive informative materials related to ODANQUICIAS ODONTOLOGIA DE MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT should write to the e-mail address protecdatos@marlonbecerra.co, expressing his/her refusal.

 

12. DUTIES OF MARLON BECERRA’S ODONTOLOGIA FRANCHISE OPERATING UNIT AS RESPONSIBLE AND LIABLE FOR THE PROCESSING OF PERSONAL DATA

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT recognizes the ownership of personal data held by individuals and consequently they exclusively can decide about them. Therefore, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT will use the personal data for the fulfillment of the purposes expressly authorized by the owner or by the regulations in force.

In the treatment and protection of personal data, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT shall have the following duties, without prejudice to others provided for in the provisions that regulate or come to regulate this matter:

a. Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
b. Request and keep a copy of the respective authorization granted by the holder for the processing of personal data.
c. Duly inform the owner about the purpose of the collection and the rights he/she has by virtue of the authorization granted.
d. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.
e. Ensure that the information is truthful, complete, accurate, up-to-date, verifiable and understandable.
f. To update the information in a timely manner, thus taking care of all the novelties with respect to the holder’s data. In addition, all necessary measures must be implemented to ensure that the information is kept up to date.
g. Rectify the information when it is incorrect and communicate the pertinent.
h. Respect the security and privacy conditions of the holder’s information.
i. To process the consultations and claims formulated in the terms established by law.
j. Identify when certain information is under discussion by the owner.
k. Informar a solicitud del titular sobre el uso dado a sus datos.
l. Inform the data protection authority when there are violations to the security codes and there are risks in the administration of the information of the owners.
m. Comply with the requirements and instructions issued by the Superintendence of Industry and Commerce on the particular subject.
n. Use only data whose processing is previously authorized in accordance with the provisions of Law 1581 of 2012.

o. Ensure the proper use of personal data of children and adolescents, in those cases in which the processing of their data is authorized.
p. Register in the database the legend “claim in process” in the manner regulated by law.

q. Insert in the database the legend “information under judicial discussion” once notified by the competent authority about judicial processes related to the quality of the personal data.
r. Refrain from circulating information that is being disputed by the owner and whose blocking has been ordered by the Superintendence of Industry and Commerce.

s. Allow access to information only to those who can access it.
t. Use the holder’s personal data only for those purposes for which it is duly authorized and respecting in any case the current regulations on personal data protection.

 

13. AUTHORIZATION AND CONSENT OF THE HOLDER

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT requires the free, prior, express and informed consent of the owner of the personal data for the processing of the same, except in cases expressly authorized by law, namely:

a. Information required by a public or administrative entity in the exercise of its legal functions or by court order.
b. Data of a public nature.
c. Cases of medical or sanitary emergency.

d. Processing of information authorized by law for historical, statistical or scientific purposes. e. Data related to the Civil Registry of Persons.

Manifestation of authorization
The authorization to MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT for the processing of personal data will be granted by:
– The holder, who must prove his identity sufficiently by the different means made available to him by UNIDAD ESTETICA DENTAL SAS.
– The holder’s representative and/or attorney-in-fact, upon proof of representation or power of attorney.
– Other in favor of or for which the holder has stipulated.

 

14. MEANS OF GRANTING AUTHORIZATION

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT will obtain the authorization through different means, among them the physical document, electronic, data message, Internet, Web Sites, or in any other format that in any case allows obtaining the consent through unequivocal conducts through which it is concluded that if the same had not been given by the holder or the person entitled to do so, the data would not have been stored or captured in the database. The authorization will be requested by MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT prior to the processing of personal data.

 

Proof of authorization

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT will keep the proof of the authorization granted by the owners of the personal data for its treatment, for which it will use the mechanisms available at present, as well as adopt the necessary actions to keep the record of the form and date in which it was obtained. Consequently, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT may establish physical files or electronic repositories made directly or through third parties contracted for such purpose.

 

15. processing to which the data will be subjected and the purpose of such processing

For the processing of personal data of children and adolescents, we will proceed in accordance with the provisions of this policy in the section related to the rights of children and adolescents.

Sensitive Data

In the case of sensitive personal data, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT may use and process them when:
a. The owner has given his explicit authorization, except in cases where the law does not require the granting of such authorization.

b. The processing is necessary to safeguard the vital interests of the Data Subject and the Data Subject is physically or legally incapacitated. In these events, the legal representatives must give their authorization.

c. The processing 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 trade union, provided that they relate exclusively to its members or to persons who maintain regular contacts by reason of their purpose. In these events, the data may not be provided to third parties without the owner’s authorization.

d. The Processing refers to data that are necessary for the recognition, exercise or defense of a right in a judicial process.

e. The processing 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.

Notwithstanding the exceptions provided by law, the processing of sensitive data requires the prior, express and informed authorization of the owner, which must be obtained by any means that may be subject to consultation and subsequent verification.

 

16. PRIVACY NOTICE

The Privacy Notice is the physical document, electronic or in any other format, made available to the holder to inform him/her about the processing of his/her personal data. Through this document, the holder is informed of the information related to the existence of the information processing policies of MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT and that will be applicable, how to access them and the characteristics of the treatment that is intended to be given to personal data.

The privacy notice shall contain, at a minimum, the following information:

a. The identity, address and contact details of the data controller.
b. The type of processing to which the data will be subjected and the purpose of such processing.
c. Holder’s rights
d. The general mechanisms provided by the responsible party so that the holder is aware of the information processing policy and the substantial changes that occur in it. In all cases, it must inform the holder how to access or consult the information processing policy. e. The optional nature of the response to questions about sensitive data.

 

17. guarantees of the right of access

In order to guarantee the data owner’s right of access, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT will make available to the owner, upon proof of identity, legitimacy, or personality of its representative, at no cost or expense, in a detailed and itemised manner, the respective personal data through all types of media, including electronic media that allow direct access to them by the owner. Such access must be provided without limit and must allow the holder the possibility of knowing and updating them online.

 

18. PROCEDURE FOR THE ATTENTION OF CLAIMS, REQUESTS FOR RECTIFICATION, UPDATING AND SUPPRESSION OF DATA.

a. Claims

The Holder who considers that the information contained in a database should be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in the law, may file a claim with MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT which will be processed under the following rules:

1. The Holder’s claim shall be formulated by means of a request addressed to MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT to the e-mail protecdatos@marlonbecerra.co. If the claim is incomplete, the interested party shall be required within five (5) days following the receipt of the claim to correct the faults. After two (2) months from the date of the request, if the applicant does not submit the required information, it will be understood that the claim has been abandoned. In the event that the person who receives the claim is not competent to resolve it, he/she will transfer it to the corresponding person within a maximum term of two (2) business days and will inform the interested party of the situation.
2. Once the completed claim is received, it will be labeled “claim in process” and the reason for the claim, within a term not to exceed two (2) business days. This label will be maintained until the claim is decided.
3. The maximum term to address the claim shall be fifteen (15) business days from the day following the date of its receipt. When it is not possible to attend the claim within said term, the interested party will be informed of the reasons for the delay and the date on which the claim will be attended, which in no case may exceed eight (8) working days following the expiration of the first term.

 

b. Request for update and/or rectification

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT will rectify and update, at the holder’s request, the information of the holder that turns out to be incomplete or inaccurate, in accordance with the procedure and terms indicated above, for which it will be taken into account:

1. The holder must send the request to the e-mail protecdatos@marlonbecerra.co.
2. MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT may enable mechanisms that facilitate the exercise of this right to the holder, as long as they benefit him/her. Consequently, electronic or other means may be enabled as deemed appropriate, which will be informed in the privacy notice and will be made available to interested parties on the website.

c. Request for deletion of data

The holder of the personal data has the right to request to MARLON’S ODONTOLOGY FRANCHISE OPERATOR UNIT Becerras suppression (deletion) in any of the following events:

1. Consider that they are not being treated in accordance with the principles, duties and obligations set forth in the regulations in force.
2. Are no longer necessary or relevant for the purpose for which they were collected.
3. The period necessary for the fulfillment of the purposes for which they were collected has been exceeded.

This suppression implies the total or partial elimination of personal information as requested by the holder in the records, files, databases or treatments carried out by DENTAL ESTHETIC UNIT SAS. However this right of the holder is not absolute and consequently MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT may deny the exercise of the same when:

a. The owner has a legal or contractual duty to remain in the database.
b. The deletion of data hinders judicial or administrative proceedings related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.
c. The data is necessary to protect the legally protected interests of the holder; to carry out an action in the public interest, or to comply with an obligation legally acquired by the holder.

19. NATIONAL DATABASE REGISTRY

MARLON’S ODONTOLOGY FRANCHISE OPERATOR UNIT Becerras reserves, in the events contemplated in the law and in its bylaws and internal regulations, the power to maintain and catalog certain information contained in its databases or data banks, as confidential in accordance with the rules in force, its bylaws and regulations.

MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT shall proceed in accordance with the regulations in force and the regulations issued by the National Government for such purpose, to register its databases with the National Registry of Databases (RNBD), which shall be administered by the Superintendence of Industry and Commerce. The RNBD is the public directory of the databases subject to processing operating in the country, which will be freely available for consultation by citizens, in accordance with the regulations issued by the National Government for such purpose.

 

20. INFORMATION SECURITY

In compliance with the security principle established in the current regulations, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT will adopt the technical, human and administrative measures necessary to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.

 

21. USE AND INTERNATIONAL TRANSFER OF PERSONAL DATA AND PERSONAL INFORMATION BY UNIDAD ESTETICA DENTAL SAS

In compliance with the institutional mission and the strategic development plan of ODANQUICIAS ODONTOLOGIA DE MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT and taking into account the nature of the permanent or occasional relationships that any person holding personal data may have with MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT, the latter may transfer and transmit, even internationally, all personal data, provided that the applicable legal requirements are met; and consequently the owners with the acceptance of this policy, expressly authorize to transfer and transmit, even internationally, personal data. The data will be transferred for all relationships that may be established with DENTAL ESTHETIC UNIT SAS.

For the international transfer of personal data of the owners, MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT will take the necessary measures so that third parties are aware of and agree to comply with this policy, with the understanding that the personal information they receive may only be used for matters directly related to MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT and only while it lasts and may not be used or intended for a different purpose or purpose. For the international transfer of personal data, the provisions of Article 26 of Law 1581 of 2012 shall be observed.

The international transmissions of personal data carried out by MARLON BECERRA’S ODONTOLOGY FRANCHISE OPERATING UNIT, will not require to be informed to the holder or have his consent when there is a contract for the transmission of personal data in accordance with Article 25 of Decree 1377 of 2013.

MARLON BECERRA DENTISTRY FRANCHISE OPERATING UNIT may also exchange personal information with governmental or other public authorities (including, but not limited to judicial or administrative authorities, tax authorities and criminal, civil, administrative, disciplinary and fiscal investigative agencies), and third parties involved in civil legal proceedings and their accountants, auditors, attorneys and other advisors and representatives, as necessary or appropriate: (a) to comply with applicable laws, including laws other than those of your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and governmental authorities, and to respond to requests from public and governmental authorities other than those of your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, yours or those of others; and (g) to obtain the applicable indemnities or limit the damages that may affect us.

22. PERSON IN CHARGE AND PERSON IN CHARGE OF THE PROCESSING OF PERSONAL DATA

UNIDAD OPERADORA DE FRANQUICIAS ODONTOLOGIA DE MARLON BECERRA will be responsible for the processing of personal data.

 

23. VALIDITY

This policy is effective from the date of its approval.