Controller and its contact information
1.1 Data controller is SIA “Molārs MG”, uniform registration No.50103456991, registered office: 6-27 Street Nakotnes, Kekava, LV-2123.
1.2 Contact information for inquiries regarding personal data processing: +371, 26618834, e-mail [email protected].
1.3 Contact information of SIA Molārs MG to let us know about potential data protection violations: +371, 26618834, e-mail [email protected].
General terms and conditions
2.1 Personal data is any information about an identified or identifiable natural person.
natural persons – SIA Molārs MG for customers of dental clinic Concordia (including potential, former and existing customers);
For visitors of SIA Molārs MG dental clinic Concordia, which are in the scope of video surveillance;
For visitors of website of SIA Molārs MG dental clinic Concordia;
persons whose data are processed in the social media in relation to marketing activities of SIA Molārs MG dental clinic Concordia (henceforth – Patients).
2.3. SIA Molārs MG respects privacy and personal data protection of its Patients, it respects Patients’ rights to legality of data processing under laws and regulations – Regulation of the European Parliament and of the Council 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, Data Processing Law, Law on Patients Rights and other applicable laws and regulations governing the privacy and data processing.
Purposes for personal data processing
3.1 SIA Molārs MG processes personal data for the following purposes:
3.1.1 To provide healthcare services:
to identify patient;
to schedule patient’s visit;
to prepare patient’s medical record according to statutory requirements;
to send remainders to patients about the scheduled visit at the specialist;
to perform medical exams;
to receive doctor’s consultations and medical manipulations;
to evaluate health condition of patients or other natural persons;
to identify capacity for work;
to administer settlements;
3.1.2 to recover debts;
3.1.3 to examine patient objections and control quality;
3.1.4 to promote patient loyalty, to measure satisfaction;
3.1.5 to prepare and sign the informed consent with patients;
3.1.6 to maintain website and improve its functions;
3.1.7 to plan business and perform analytics;
3.1.8 to provide information to state administration and operative subjects in cases and to an extent laid down in laws and regulations;
3.1.9 to ensure safety and property protection of SIA Molārs MG, and to evaluate staff service quality;
3.1.10 to enter information in the National Uniform Medical Information System (E-veselība).
Legal basis of personal data processing
4.1 SIA Molārs MG processes personal data of patients on the following legal bases:
for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of treatment (Article 9(2)(h) of the Regulation);
the processing shall take place in line with a consent from the data subject (patient) (Article 10(2)(a), Article 10(2) of the Law On the Rights of Patients;
to comply with laws and regulations – to comply with obligations stated in the laws and regulations binding on SIA Molārs MG (Article 9(2)(b) of the Regulation, Article 10 of the Law On the Rights of Patients);
processing is needed to exercise or defend the legal interests of SIA Molārs MG in courts (Article 9(2)(f) of the Regulation);
processing is necessary to ensure legitimate interests of SIA Molārs MG (to organise efficient provision of healthcare services, to ensure efficient scheduling and cancelling of visits, to receive a payment for provided healthcare services, to promote SIA Molārs MG in mass media and social networks).
processing is necessary to perform contracts with data subjects (patients) or to take measures at the request of data subject before entering into the contract (Article 6(1)(b) of the Regulation);
processing is necessary to protect vital interests of data subject (patient) or other natural person (Article 6(1)(d) of the Regulation).
Personal data processing
5.1 SIA Molārs G processes Patient data with modern technologies, considering existing privacy risks and organisational, financial and technical resources available to SIA Molārs MG.
5.2 SIA Molārs MG may take automated decisions regarding the Patient. Patient is privately notified about such acts of SIA Molārs MG according to laws and regulations.
5.3 Automated decision-making, which causes legal consequences to the Patient (for example, transfer to collection companies for debt recovery), may take place during performance of the informed consent between SIA Molārs and the Patient or on the basis of obvious consent of the Patient.
Personal data protection
6.1. SIA Molārs G protects Patient data with modern technologies, considering existing privacy risks and organisational, financial and technical resources available to SIA Molārs MG.
Transfer / disclosure of personal data
7.1. SIA Molārs MG does not disclose personal data to third parties, except:
in line with a written consent from the Patient;
to persons stipulated in laws and regulations (including institutions) at a reasonable request from them in accordance with the procedure and to the scope stated in such laws and regulations;
7.2. SIA Molārs MG does not disclose other personal data (which are not patient data) to third parties, except:
in line with a clear consent from the Patient;
to persons stipulated in laws and regulations at a reasonable request from them in accordance with procedure and to the scope stated in such laws and regulations;
To protect legal interests of SIA Molārs MG, for example, by bringing an action in the court or other public institutions against the person who has infringed the legal interests of SIA Molārs MG, and transferring the debts of natural persons for collecting.
Transfer of personal data
8.1 SIA Molārs MG transfers Personal data to third parties, ensuring that third parties retain personal data confidentiality and provide sufficient protection.
8.2 SIA Molārs MG is entitled to transfer Personal data to subcontractors of SIA Molārs MG, which allows performing its functions.
8.3 In case under Clause 8.2, the subcontractors of SIA Molārs MG receiving and processing personal data, are deemed to be data processors for the purpose of the Regulation, they are bound under a written contract where SIA Molārs MG demands data recipients to use the received information solely for the purposes they have been transferred, and according to the applicable laws and regulations in data processing and data regulation field.
Access to personal data by third country subjects
9.1 SIA Molārs MG does not transfer personal data to third countries (countries located outside the European Union and European Economic Area).
Duration of personal data storage
10.1 SIA Molārs MG stores and processes personal data of the Patients while at least one of the following criteria fulfils:
as long as the obligations arising from the informed Consent signed by SIA Molārs MG and the Patient are being performed or the Patient is receiving healthcare service;
as long as SIA Molārs MG has a statutory obligation to store the data;
as long as the Patient’s request/application is being reviewed and/or performed;
as long as the Patient’s consent for processing of relevant personal data is in force, unless there are other legal grounds for data processing.
Audio recordings where conversations of SIA Molārs MG staff with patients are recorded, when scheduling a visit with clinic specialists, are available not more than for 30 days since the audio recording;
10.2 Upon expiry of circumstances under Clause 10.1, the Patient’s personal data are deleted. Auditing records are stored for one year since their recording.
Access to personal data and other rights of the Patient
11.1 The Patient is entitled to receive statutory information regarding his or her data processing.
11.2 The Patient is statutory entitled to request from SIA Molārs MG an access to his or her personal data, and also request from SIA Molārs MG to supplement, edit or delete them, or to restrict their editing regarding the Patient, or rights to object to processing as well as rights to data portability. These rights are exercisable insofar as the data processing does not exceed the scope of obligations of SIA Molārs MG, imposed on it under applicable laws and regulations.
11.3 The Patient may submit a request on exercise of his or her rights:
in a written form when present in person at SIA Molārs MG dental clinic “Concordia” by presenting an ID document;
electronically by signing the letter with a safe digital signature and sending it to e-mail: [email protected].
by sending a written letter to SIA Molārs MG;
by phone or sending an e-mail letter to SIA Molārs MG to e-mail address: [email protected]at a request that the patient has coordinated his communication with SIA Molārs MG regarding the patient data via that particular e-mail address or phone number. Such consent must be written in person on-site (by presenting ID document) or signed with safe digital signature;
Audio recordings of conversations between the Patient and SIA Molārs MG dental clinic “Concordia” may be listened to or received on-site by presenting a valid ID document.
11.4 When receiving a request from the Patient on exercise of his or her rights, SIA Molārs MG verifies Patient’s identity, evaluates the request and performs it according to laws and regulations.
11.5 SIA Molārs MG provides a response to the Patient to an extent possible, taking into account the type of provision of answer specified by the Patient.
11.6 If the answer is sent in a registered mail, it is addressed to data subject (person whose personal data are requested). If the answer is sent electronically, it is signed with a safe digital signature (if the submitted application was signed with the safe digital signature).
11.7 SIA Molārs MG ensures meeting of data processing and protection requirements under the laws and regulations and in case of objections from the Patient takes reasonable steps to solve the objection. However, failing to do so entitles the Patient to the supervision authority – State Data Inspectorate.
11.8 The Patient is entitled to receive one copy of his or her personal data processed by SIA Molārs MG free of charge.
11.9 Receiving and/or use of information stated in Clause 11.8 hereunder may be restricted with an aim to prevent adverse effects on rights and freedoms of other persons (including employees of SIA Molārs MG).
11.10 SIA Molārs MG undertakes to ensure accuracy of Personal data and relies on its Patients, suppliers and other third parties delivering Personal data, making sure the completeness and accuracy of Persona data is in place.
Patient’s consent to data processing and right to withdraw it
12.1 The Patient gives a consent to personal data (which are deemed to be patient data for the purpose of the Law on Patient Rights) processing, legal basis of which is the consent, in person while at SIA Molārs MG dental clinic Concordia or by sending an e-mail signed with a safe digital signature.
12.2 The Patient provides consent for personal data (which are deemed to be patient data for the purpose of the Law on Patient Rights) processing, legal basis of which is the consent (for example, for sending commercial information) in person while at SIA Molārs MG dental clinic Concordia, by sending an e-mail signed with a safe digital signature, as well as by phone or in a regular e-mail, if SIA Molārs MG and Patient have agreed on use of relevant e-mail address and/or phone number for mutual communication.
12.3 The Patient is entitled to withdraw the given consent for data processing in the same way it was given, and in this case any further data processing based on previously given consent for this particular purpose will not be made.
12.4 Withdrawal of the consent does not affect data processing which were performed while the Patient’s consent was in force.
12.5 By withdrawing the consent, data processing may not be discontinued if such processing is based on other legal basis (for example, according to external laws and regulations or the Informed Consent signed between SIA Molārs MG and Patient).
13.1 Communication containing commercial information about services of SIA Molārs MG complies with the external laws and regulations or Patient consent.
13.2 Communication, including also commercial communication, can be provided by SIA Molārs MG also via automated calling devices.
13.3 The Patient may provide a written consent to receive commercial information during an on-site visit, at the website of SIA Molārs MG and mobile apps.
13.4 Patient’s consent to receive commercial communications is valid until revoked. The Patient may refuse from further reception of commercial information at any time in one of the following ways:
by sending an e-mail to address [email protected];
by calling to +371 26252539
during on-site visit to SIA Molārs MG dental clinic Concordia;
13.5 SIA Molārs MG discontinues sending of commercial information as soon as the Patient’s request is processed. Consent processing time may depend on technological possibilities, potentially up to three days.
13.6 When expressing his or her opinion in surveys and leaving the contact information (e-mail, phone), the Patient agrees that SIA Molārs MG may contact him or her via the provided contact information in relation to feedback provided by the Patient.
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