With this document, the Orthodontic Clinic ORTO-DENT as the administrator of your personal data aims to inform you on what grounds, for what purposes, within what periods and by what means it processes your personal data when providing dental services in the clinic, as well as when you visit our website https://orthoclinic.bg/ and what are your rights as a data subject. We strictly adhere to the applicable data protection regulations in each operation of personal data processing. The General Data Protection Regulation 2016/679 ("GDPR"), Data protection act and all applicable provisions of the national and European legislation.

1. Introduction
   In this Personal Data Protection Policy, ORTHO DENT CLINIC, “we”, “us” or “our” shall mean “ORTHO-DENT AIPPDP” Ltd. , and “you”, “your” and “user” shall mean visitors to our website – https://orthoclinic.bg/.

This Personal Data Protection Policy shall explain and govern:

• how and when we collect your personal data, and what information we collect
• how and why we use your personal data; and
• your rights to control your personal data.

Please carefully read this Personal Data Protection Policy. By accessing and using our website and services, you confirm that you have had an opportunity to read this Policy, that you understand it and that you agree to be bound by it. If you fail to do so, you must immediately cease using our website and any services provided by us.

We may amend this Policy from time to time in order to comply with applicable laws and regulations. You are encouraged to periodically review this page for the latest information on our privacy practices and amendments to our Personal Data Protection Policy.

2. Who we are?

"ORTO-DENT-AIPDP" Ltd., UIC  202348986 is an individual practice for outpatient dental care, diagnostics, holistic dental treatment, orthodontics, consultations, prophylaxis.

3. How can you contact us?

ORTHO DENT CLINIC is situated in the City of Sofia, District “Studentski”, ul. "Prof. Hristo Danov" 15. You can contact us by visiting us at the Company’s address specified above and on our website: https://orthoclinic.bg/.

4. Who can I contact about my data protection questions?

For all questions concerning the protection of your personal data you may use the following contact details: hello@orthoclinic.bg, mobile phone: 0883364095

5. Type, purpose and grounds of processing of personal data collected by ORTHO DENT CLINIC:

Personal Data	Purpose	Grounds
Name, father’s name and surname, Telephone, address, E-mail	Making contact with the patient; Schedule an appointment by phone call and/or visiting the clinic website; Providing dental services and responding to inquiries, signals, complaints, troubleshooting and other feedback regarding dental services used;	Taking steps at the request of the data subject before entering into a contract; Conclusion/ performance of an agreement for dental service;
Name, father’s name and surname, date of birth, PIN, address	preparation of primary accounting documents (invoices) for dental services rendered;	Legal obligation;
Name, father’s name and surname, age, date of birth, PIN, address, X-rays, photos, diagnostic models, dental impressions, health data, concomitant diseases and allergies	Analysis, preliminary study and preparation of a treatment plan; Conduct and follow up the treatment; Мaintain patient's personal record in archive;	Taking steps at the request of the data subject before entering into a contract; Conclusion/ performance of an agreement for dental service; Legal obligation;
Information about visits to and use of our website (IP address) collected through cookies, including operations and usage history when visiting our website)	Analyzing traffic and improving site functionality; Customize content and ads, including through social media;	Consent

 

Your personal data will be processed by ORTHO DENT CLINIC only in accordance with the applicable data protection regulations. When you communicate with us through any of the communication channels, you acknowledge that the data you have provided are accurate, correct and up-to-date.

We should inform you that any consent to processing your personal data may be withdrawn at any time by submitting a request in writing to the Company’s office situated in the City of Sofia, District “Studentski”, ul. "Prof. Hristo Danov" 15 and/or by sending an e-mail to hello@orthoclinic.bg . Withdrawal of your consent to the processing of your data will in no way adversely affect your dental care services.

6. For how long will my personal data be stored?

Personal data shall be stored for the time periods required to achieve the purposes for which they have been collected. After achieving the purposes for which personal data have been collected, we will destroy them immediately.

ORTHO DENT CLINIC shall take all necessary technical and organizational measures for the destruction of data that are no longer necessary, except in cases where there are legitimate grounds for ORTHO DENT CLINIC to process them for a longer period of time; when you make a request for restricting processing in accordance with your rights detailed below; or with a view to or compatible with the original purpose for processing of which you will be informed in a timely manner.

ORTHO DENT CLINIC shall store collected personal data within the following periods:

1. a) where data are processed on the basis of an agreement for dental services - for a period of 10 years, which period shall commence on the date of termination of the agreement. The patient's medical record is kept for a period of 10 years after completion of the treatment.
2. b) where data are processed on the basis of consent – until the explicit withdrawal of the consent;
3. c) where data are processed for the protection of implementation of the Company’s rights and interests, which reasonably override the interests of natural persons – until the right is extinguished and/or interest no longer exists.

After the expiration of the said time periods, if there are no other grounds for the processing of the data, they will be erased. For the purpose of obtaining and analyzing information related to the services used by you, and improving customer service, the Company may erase only part of the data. In such cases, it shall continue to store such part of the data that does not allow natural persons to be subsequently identified.

7. Will my personal data be accessible to third parties?

The following categories of persons, that may be processors on the grounds of contracts entered into with the Company, may also have access to your personal data, namely:

-  persons who maintain the Company's information systems and website and third parties who assist and help us to provide IT services, such as platform providers, hosting services, maintaining and supporting our databases and our software and applications that may contain data about you (such services sometimes involve accessing your personal data to perform these tasks);

-  persons who are assigned actions and activities related to assisting with patient care, hygiene, completion and storage of medical records;

-  couriers;

- advertising, marketing, digital and social media agencies to assist us in organizing advertising and marketing campaigns, analyzing their effectiveness;

The Company is obliged to provide personal data on its customers to competent authorities and institutions pursuant to applicable law and when such data are lawfully requested.

ORTHO DENT CLINIC does not transfer personal data to a third country or international organization outside the European Union, except in the case of your assignment and with your consent when it is necessary in connection with your dental treatment plan.

8. How we protect your personal data?

To ensure adequate protection of the data of the Company and our customers, we apply all necessary organisational and technical measures provided for in the Personal Data Protection Act and the General Data Protection Regulation.

9. When visiting thе website https://orthoclinic.bg/, ORTHO DENT CLINIC shall process your personal data using cookies. Please become familiar with our Cookie Policy.
10. Your Rights

Provision of personal data is voluntary – it is necessary for the conclusion of a contract for dental service with the Company. In the event that data are not provided, the Company will not be able to provide a product or service.

ORTHO DENT CLINIC shall meet your requests without delay, within 30 calendar days after submitting them. By our decision, we provide or refuse access and/or information requested by the applicant, but we always justify our response. For the purpose of the website of the Company, there is a link to this Policy published on a clearly visible and accessible position.

Applications concerning the exercise of your rights shall be submitted:

-    in person or by a proxy who has been expressly authorized by you through a notarized power of attorney at the Company’s office situated in the City of Sofia, District “Studentski”, ul. "Prof. Hristo Danov" 15. The notarized power of attorney through which a request for erasure is submitted should contain the following power: “To represent me before ORTHO DENT CLINIC EOOD, having the right to submit on my behalf a request for exercise of personal data protection rights”;

-    executed as an electronic document signed by your electronic signature to: hello@orthoclinic.bg .

The exercise of rights shall be free and cover all structured and unstructured data, and all databases supported by the Company.

Where the data subject submits a request by electronic means, the information shall be provided, where possible, by electronic means, unless the data subject has not requested otherwise.

Where the Company has reasonable concerns in relation to the identity of the natural person who submits a request for the exercise of their rights under this section, we may ask you for further information and/or action, including a personal visit to the clinic address.

You should also consider that the withdrawal of consents provided does not affect the lawfulness of the processing of your personal data before such withdrawal. Despite the withdrawn consent, your personal data may be processed by the Company, if there are grounds for processing the data other than those referred to above.

You shall have the following rights:

a. Right to be informed

As a data subject, you shall have a right to obtain information on important features of the processing of your personal data, including, but not limited to its purpose, period and grounds, on the recipients and the categories of recipients of the personal data, etc.

b. Right of access

You may request information on what personal data concerning you we process, and whether we process such. You may request access to such data.

We will provide you with a statement of personal data that are being processed. For additional statements we may adopt a reasonable fee on the basis of administrative costs. When you submit a request through electronic means, we will provide the information, where possible, in a widely used electronic form unless you have requested otherwise.

c. Right to rectification

If we process incomplete or incorrect personal data concerning you, you have the right to have such data rectified or completed at any time.

d. Right to erasure

You may request to have your personal data erased in the following cases:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw your consent on which the processing is based and there is no other legitimate grounds for the processing;
• you consider that the personal data have been unlawfully processed.

Please note that there may be other reasons that can thwart the immediate erasure of your data, such as statutory obligations for storage, pending proceedings, the establishment, exercise or defence of legal claims, etc.

e. Right to restriction of processing

You have the right to obtain restriction of processing, if:

• you contest the accuracy of the personal data for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful, but you do not want the personal data to be erased and request the restriction of their use instead;
• we no longer need the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims
• you have objected to processing pending the verification whether the legitimate grounds of the Company for processing of the data override your grounds.

If you request restriction of processing, we will inform you prior to revoking the restriction of processing.

f. Right to data portability

You may request from us to provide you with the personal data concerning you that we process in a structured, commonly used and machine-readable format and which can be transmitted to another institution. This shall apply, provided that

• оthe processing of the particular data is based on your consent or is in relation to conclusion and performance of a contract for service; and
• the processing is carried out by automated means.

g. Right to object

You have the right, at any time and on grounds relating to your particular situation, to object to processing of your personal data, which is based on legitimate interest – grounds are indicated in the table above, including profiling based on such grounds.

When you have given your consent to the processing of data for the purposes of direct marketing, you have the right at any time to object to the processing of personal data without having to specify any grounds.

h. Right to lodge a complaint

Please contact us if you think that we have violated any applicable law on the protection of personal data in the processing of your data and as a result we have affected your rights. Surely, you also have the right to lodge a complaint with the Personal Data Protection Commission, which is a supervisory authority in respect of personal data protection, to the following address: City of Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., tel. 02/91-53-518, e-mail: kzld@cpdp.bg .

All requests and additional explanations and information related to the exercise of your rights may be directly submitted to/requested from ORTHO DENT CLINIC, by contacting us via the contact details referred above.