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​Terms of Use and Privacy Policy

Revised on: 01/31/2024



INTRODUCTION

CLINICA DR. EDUARDO DALL'ACQUA S/S LTDA UNIPESSOAL, hereinafter Clínica Dr. Eduardo Dall'Acqua, is committed to protecting the privacy and confidentiality of information, as well as the protection of data and personal information that is shared by its users, in accordance with applicable laws and regulations. This policy defines which data is collected and how it is protected in all processing activities (collection, registration, storage, use, sharing, enrichment and deletion). Our goal is to process personal information responsibly and securely in accordance with Law No. 13,709/2018 (General Data Protection Law).


We recommend that you read this document carefully.


DEFINITIONS

To help you understand our Privacy Policy, we have provided some information below:

PERSONAL DATA: Brazilian law defines "personal data" as any data that refers to an identified or identifiable individual. In practice, the term includes any data that allows a person to be identified, such as: name, CPF, ID number, photograph, etc. In addition, personal data may or may not be sensitive.

SENSITIVE PERSONAL DATA: Sensitive personal data is data that refers to racial or ethnic origin, religious beliefs, political opinions, membership in a union or organization of a religious, philosophical or political nature, data related to health or sexual life, genetic or biometric data, when linked to an individual.

USER: an individual who interacts with us in situations where they have the possibility of providing their personal data. Examples: people who browse the website, portals, social networks, patients, students, teachers, employees, third parties or service providers, among others.

DATA SUBJECT: the person to whom the data refers. You, the user, are the owner of your personal data and sensitive personal data.

COOKIES: These are information files that are stored on your computer or mobile device through the internet browser. These files allow a website to “remember” the actions and preferences registered on behalf of the User for a period of time. Cookies are used so that the User, when returning to a website that they have already visited, does not, in principle, have to indicate their browsing preferences again (language, font, display format, etc.). Cookies can be persistent or session cookies.

PERSISTENT COOKIES: remain on the user's computer even after closing the session or until they are deleted.

SESSION COOKIES: expire when the user closes the browser.

DATA PROCESSING: refers to any action that can be carried out with personal data, for example, access, collection, processing, storage and deletion.

ANONYMIZATION: is a technical procedure used to de-identify personal data, that is, to prevent certain data from being related to a specific person. Anonymized data under the terms of the LGPD is not considered personal data.

SUBCONTRACTOR: companies that support diagnostics (such as international healthcare reference institutions, doctors hired by legal entities, among others).

COLLECTION OF PERSONAL DATA

The collection of personal data is necessary for us to offer services and features that are appropriate to the needs of users, as well as to personalize services, making their experience as comfortable and satisfactory as possible.

The data provided by the user (or legal representative) and/or obtained as a result of the services provided by us may be personal data, for example: name, CPF, identity number, address, e-mail, bank details or sensitive personal data, such as: data relating to health or sexual life, religious beliefs, genetic and biometric data.

The use of any and all websites and/or applications developed by Clínica Dr. Eduardo Dall'Acqua implies the collection of browsing data (IP address or mobileID – identification of the mobile device), however, does not necessarily imply the provision of personal data. However, if the user intends to contact us for any type of request, their data will be requested.

In face-to-face consultations, in order to submit requests and receive services, it is also necessary to provide personal data, which will be collected by a responsible attendant, who will record the information in a registration system.

The personal data requested must be provided so that it is possible to proceed with your request or service. Other personal data and sensitive personal data may be requested later, according to the service selected.

When the data collected is from minors, it is essential to obtain the unequivocal and informed consent of one of the parents and the data in question will be protected and will meet the child's need for privacy.


PURPOSE OF PROCESSING PERSONAL DATA

Clinica Dr. Eduardo Dall'Acqua is the entity responsible for processing the personal data of its users or for forwarding them to designated subcontracted entities. All data is processed for specific and legitimate purposes.

The personal data of its users collected, including those directly or indirectly related to their health, will be processed for the purposes of providing integrated health care, including management of systems and other services, auditing and continuous improvement thereof, and may be related to data from other health units that have the same purpose.

Clinica Dr. Eduardo Dall'Acqua may process the personal data collected from its users to carry out prior and subsequent negotiations in relation to the provision of contracted services, as well as to comply with legal or regulatory obligations, since the provision of health services is subject to its own regulations, which may even determine retention periods for documents and surgical/telephone recordings.

In addition, Clínica Dr. Eduardo Dall'Acqua may process personal data collected from its users in the event of defense in administrative, judicial or arbitration proceedings, including responses to official letters and complaints registered with its customer service department (SAC) and regulatory bodies (PROCON, MP, police stations and others).

Other cases of processing personal data of its users would be for investigation and prevention of fraud, infractions or irregularities; in conducting audit processes; for the development and improvement of resources, functionalities of Clínica Dr. Eduardo Dall'Acqua's websites and applications, products and services, aiming to provide a better experience to its users; in the event of legitimate interest when authorized by law and for lawful purposes aligned with Clínica Dr. Eduardo Dall'Acqua's needs. Furthermore, to ensure and protect life, Clínica Dr. Eduardo Dall'Acqua may process sensitive personal data of its users, based on health protection, as well as for the purposes provided for in informed consent when applicable, such as procedures performed by health professionals and health services, communications relevant to the promotion of your health, satisfaction surveys to improve our services, among others.


PROCESSING OF CHILDREN'S AND ADOLESCENTS' DATA

Under the terms of the General Data Protection Law, the processing of personal data of children and adolescents must be carried out in their best interests, and the processing of data must be carried out with specific and highlighted consent from at least one of the parents or their legal representative. Therefore, Clínica Dr. Eduardo Dall'Acqua will process the personal data entrusted to it in strict compliance with the rules provided for in Law 13.709/2018 (LGPD).


SHARING OF PERSONAL DATA

Personal data will be transmitted and communicated between the departments of Clínica Dr. Eduardo Dall'Acqua, with access by designated employees, whenever necessary, to enable the best experience and meet the user's needs.

Clínica Dr. Eduardo Dall'Acqua may also transmit your data to contracted entities that in some way need to collaborate to improve your experience and provide the best service, such as professional associations, educational institutions, medical institutions of excellence located outside Brazil, and laboratories ratifying the commitment to require their contractors to comply with applicable regulations.

We may also transmit users' personal data to third parties when such data communications become necessary or appropriate (i) in light of applicable law, (ii) in compliance with legal obligations/court orders, (iii) by order of the National Data Protection Authority or other competent supervisory authority, or (iv) to respond to requests from public or government authorities.

To guarantee privacy and security in the transmission of personal data, we will use SSL (Secure Sockets Layer) encryption for all information exchanged via the internet.


INTERNATIONAL DATA TRANSFER

Dr. Eduardo Dall'Acqua Clinic does not rent, sell or release data to third parties for the purpose of allowing any commercialization of its services, but informs that your data may be transferred and kept in an environment outside your municipality, state or country, where data protection laws may be different from those in force in Brazil, but ensure a level of protection of personal data appropriate to that provided for in the General Data Protection Law.

We will take all reasonably necessary measures to ensure that your data is treated reliably, securely and in accordance with this Privacy Policy.


RETENTION OF PERSONAL DATA

The data is kept for the period strictly necessary for each of the purposes described above and/or in accordance with current legal deadlines. In the event of pending litigation, the data may be kept until the decision is final and binding.

Additionally, Clínica Dr. Eduardo Dall'Acqua states that it will maintain all technical means within its reach to prevent the loss, misuse, alteration, unauthorized access and misappropriation of the personal data of its users, patients and clients. In any case, it should be noted that, since data circulates on an open internet network, it is not possible to completely eliminate the risk of unauthorized access and use, and therefore the user must implement appropriate security measures for browsing the website.


COOKIES AND SIMILAR TECHNOLOGIES

Dr. Eduardo Dall'Acqua Clinic receives and stores data from its users through the use of cookies.

Most browsers are set to automatically accept cookies, although it is possible to configure the browser to refuse all cookies, or to indicate when a cookie will be sent. Once the cookie is accepted, the next time you visit the Dr. Eduardo Dall'Acqua Clinic website or application, the Internet server will recognize the user's computer or mobile device.

The website uses persistent and session cookies. Persistent cookies can be removed by following the instructions in the help file of the user's Internet browser.


Purpose of use of Cookies:

Analytics: statistical analysis of browsing, with the aim of improving the user's browsing experience.

Advertising: analysis of users' browsing habits and preferences, with the aim of showing them advertising exclusively related to their browsing profile.


TRACEABILITY TECHNOLOGIES – WEB BEACONS

We use a software technology called web beacons (also known as web bugs, clear gifs or pixels) to help us understand which content is effective, for example, by counting the number of Users who have visited certain pages.

Web beacons consist of small graphics with a unique identifier, which function similarly to cookies, and which are used to determine whether certain content is viewed. Unlike cookies, which are stored on the User's computer, web beacons are invisibly embedded in web pages. Clínica Dr. Eduardo Dall'Acqua can thus correlate the data collected by web beacons with other data already collected.


USER RIGHTS

The LGPD guarantees you, the user, the exercise of rights regarding your personal data, which are:

Confirmation of whether your data is being processed and access to the data that is being processed;

Correction of data that is incomplete, inaccurate or outdated;

Anonymize, block or delete data that is unnecessary, excessive or processed in non-compliance with the proposed purpose and applicable laws;

Request the portability of your data;

Request the deletion of data, except in cases of legal storage or as provided for in specific regulations;

Obtain information about public and private entities with which the data is shared, except for the exceptions provided for by law;

Obtain information about the possibility of not providing your consent, when applicable, and possible consequences of refusal, as well as the possibility of revoking it;

Exercising this right is a freedom for every user and the fulfillment of the request by Clínica Dr. Eduardo Dall'Acqua will always take into account the applicable laws and regulations and, in the event that it is not possible to fulfill the request, the responses will be duly justified. The user may exercise these rights by sending a written request to the email dpo@dreduardodallacqua.com.br.


THIRD PARTY PAGES AND APPLICATIONS

Dr. Eduardo Dall'Acqua Clinic, through its website and applications, provides links to third party websites, which are subject to independent Privacy Policies. This Data Privacy and Use of Cookies Policy does not apply to such websites and we are not responsible for the way in which user data is handled by said third parties.


WEBSITE/APPLICATION CONTENT AND ITS USE

All content on www.dreduardodallacqua.com.br and applications made available by Dr. Eduardo Dall'Acqua Clinic is the property of CLINICA DR. EDUARDO DALL'ACQUA S/S LTDA UNIPESSOAL and its reproduction – in whole or in part – for commercial or editorial use or republication on the internet must be done with authorization and must necessarily cite the source and include the website link to the original content (Law No. 9,610/98 and other applicable related legislation). The use of the content for school work is permitted, as long as it is not republished in any media.


COMPLAINTS AND QUESTIONS

If you have any questions regarding the processing of your personal data and the rights granted to you by applicable legislation and, in particular, those referred to in this Policy, you may contact Clínica Dr. Eduardo Dall'Acqua via email: dpo@dreduardodallacqua.com.br.


CHANGES TO THE PRIVACY AND COOKIES POLICY

We may change this Data Privacy and Cookies Policy at any time. These changes will be duly made available and, if they represent a substantial change in the way your data will be processed, Clínica Dr. Eduardo Dall'Acqua will contact you using the information provided.

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