We wish to reassure you that any processing of your personal data, as such processing is explained in the present Policy, will be carried out by Happy Tooth Clinic in compliance with applicable laws on the protection of personal data, to include Regulation (EU) 2016/679 (hereinafter the “GDPR”), Law 4624/2019, as well as any applicable legislation on the protection of privacy in the electronic communications sector, any decisions and guidelines of the Hellenic Data Protection Authority, as well as any relevant and more specific national or European legislation.
By visiting or using our Website, to include the services offered herein, it will be deemed that you have carefully reviewed, understood and agree to be bound by the present Policy, our Terms & Conditions of Use as well as our Cookies Policy.
The following terms shall have the meaning provided below, in accordance with the provisions of Regulation (EU) 2016/679 (GDPR):
a) “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) “Special categories of personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation, as well as data relating to criminal convictions and offences
c) “Data Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) “Data Controller” means a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. The data controller, regarding all personal data processing operations carried out through the present Website, is Eleftheria Papadopoulou, pediatric dentist, operating a dental clinic at 26 Andrea Papandreou Street, 166 75, Glyfada, Attica, Greece, tel.: 2108985581, email: firstname.lastname@example.org.
e) “Data Processor”: means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.
- Personal data collected
When you access our Website, use our services, communicate or enter into transactions with us, we collect information about you that allows your identification, either directly or indirectly in combination with other information (hereinafter the “Personal Data”). Such information may be collected when you willingly choose to provide same to us or simply by analyzing your behavior on our Website. In particular:
Data willingly provided by you: Data voluntarily provided by you when you interact with our Website (e.g. when you communicate with us through the “Contact Us” form available on our Website). Such data include your name, surname, email address, telephone number, as well as the contents of the message that you choose to send us.
Navigation data: As part of our Website’s normal operation, information about our Website users is collected, the transmission of which takes place automatically, through internet communication protocols. Although this information is not collected in order to be associated with a specific user, it is possible, in combination with other data held by third parties, to allow your identification. For this reason, such information constitutes, according to applicable law, “Personal Data” and it is being protected as such. Such information may include your Internet Protocol (IP) address, data collected through cookies, device data (domain name and type of device), as well as information about your activities’ history on our Website. Through this data we hope to improve the quality of our Website and services. Moreover, such data may be associated with other data that you choose to provide us, in order to offer you more personalized content, based on your interests. For more information, we invite you to check our Website’s Cookies Policy.
- Special categories of personal data
Through the operation of its Website, Happy Tooth Clinic does not seek to collect special categories of data. Special categories of data may, however, be processed to the extent that they are voluntarily provided by you when completing the online “Contact Us” form (namely, if you choose to include in your message and report health data, symptoms etc.).
- Scope and legal basis of processing
The personal data collected through our Website are used for the following purposes and their processing relies on the following legal bases:
- To process and respond to your requests, as well as to provide all other types of services that you may request through our Website. For the above purposes (hereinafter jointly “Provision of Services”) your consent to the processing of your personal data is not required, as such processing is necessary for the provision of the services that you have requested and, therefore, for the performance of an agreement to which you are a party or for the implementation of measures requested by you prior to entering into an agreement (GDPR article 6, para. 1.b). It is not mandatory for you to provide your personal data to us for the above purposes. However, if you fail to do so, we will not be able to respond to your requests or/and provide the services that you have requested.
iii. For compliance with legal obligations to which we are subject, such as the Code of Dental Ethics or compliance with tax, insurance obligations etc. Your consent is not required for such purpose (hereinafter “Compliance”), as such processing is necessary for compliance with a legal obligation to which Happy Tooth Clinic is subject (GDPR, article 6, para. 1.c).
- iv. To protect and defend the security of the systems and property of Happy Tooth Clinic, to include the prevention and detection of any misuse of our Website or any fraudulent activities taking place through the Website, as well as to defend our legitimate interests before the competent Courts and Authorities. The processing of your personal data for such purpose (hereinafter “Security/Legitimate Interests”) is necessary for Happy Tooth Clinic to pursue its legitimate interests (GDPR article 6, para. 1.f).
- Who has access to your personal data?
Happy Tooth Clinic does not sell, exchange, lease personal data to third parties, natural or legal persons. We may disclose personal data, to the extent necessary, as follows:
- To duly appointed external collaborators of Happy Tooth Clinic, acting on its behalf as data processors and assisting it with the operation of the Website (e.g. internet service providers, IT service providers).
- Selected individuals that have been authorized by us to process data necessary for the carrying out of activities relating to the operation of the Website, who are subject to an obligation of confidentiality (e.g. employees of Happy Tooth Clinic, legal advisors).
- Public authorities, bodies or offices, to the extent necessary in compliance with applicable law.
- Freud prevention and control organizations (e.g. Cybercrime Unit).
- Transfer of personal data outside the EU and provision of safeguards
In the event that our partners, service providers or authorities, as per term 6 above, are located outside the European Union/European Economic Area, your personal data may be transferred to a third country. We wish to reassure you that in the limited and necessary circumstances that your personal data will be transferred to a third country, Happy Tooth Clinic will put in place adequate measures and will provide appropriate safeguards, in order to ensure the privacy and security of your personal data. You may obtain additional information on the matter by emailing us at email@example.com.
- Data retention period
Happy Tooth Clinic retains your personal data strictly for as long as necessary, in order to fulfill the purposes for which such data were collected. The criteria used to determine our data retention periods include: (a) for as long as we have an ongoing relationship with you, (b) if the processing is based on your consent, from the moment that you provide such consent until the moment you withdraw same, unless if further retention is necessary for the protection of the rights of Happy Tooth Clinic, (c) for as long as necessary in light of a legal obligation to which we are subject, (d) for as long as necessary in light of our legal position (indicatively, to defend our rights before the Courts, to comply with regulatory controls etc.).
- Your rights
As a data subject, you have the following rights:
- To obtain confirmation on whether your personal data are being processed by us and, in the affirmative, access and obtain a copy of such data.
- To modify, update, or complete your personal data, where they may be inaccurate or incomplete.
- To request the erasure of your personal data, where the processing is unnecessary or unlawful.
- To request the restriction of processing of your personal data, when you feel that your personal data is inaccurate or that the processing is unnecessary or unlawful.
- To withdraw your consent to the processing of your personal data when such consent serves as the legal basis for processing.
- To request, under certain conditions, the portability of your personal data, namely, to obtain a copy of your personal data in a structured, commonly used and machine-readable format, as well as to request the transmission of your personal data to another data controller.
- To object to the processing of your personal data.
You also have the right to file a complaint with the Hellenic Data Protection Authority. For more information regarding the competency of the Authority and how to file a complaint, you may visit the Authority’s website (www.dpa.gr ® Citizen rights ® Complaint to the Hellenic DPA).
- Minors’ personal data
Happy Tooth Clinic does not purposely collect personal data concerning minors, through the operation of its Website. If minors willingly visit our Website, we assume no responsibility whatsoever. Parents/guardians can prevent a minor from accessing the Website, by using available, easily accessible programs that control access to the internet or to specific websites. If it comes to our attention that a user of our Website is a minor, we will not process or retain such personal data.
- Social media
Ηappy Tooth Clinic uses social media tools and applications (Facebook, Instagram). If you are connected to one of these networks, the network may match your user account with your visit to our Website. For this reason, if you do not wish to have any data retrieved from your visit to our Website linked to your social media account, you must be logged out of your account before logging in to our Website.
- Third party websites and links
Our Website may contain links, hyperlinks, advertising banners and references to websites, platforms, or third-party applications (jointly “third-party websites”), over which Happy Tooth Clinic has no control. Similarly, access to our Website may be achieved through links that you will find to third-party websites, over which we have no control. Note that third-party websites may collect your personal data for their own processing purposes. Happy Tooth Clinic does not guarantee the level and the quality of any website to which it links, nor does it assume any responsibility in connection with the content of the websites that do not belong to us. Following the above, we invite you to be very careful and to check the terms and policies that govern such third-party websites, as they may differ significantly from ours.
- Security of personal data
Happy Tooth Clinic has implemented appropriate technical and organizational measures for the protection of the personal data collected from this Website. All personal data that we collect are stored and processed in a way to minimize the risk of (accidental) loss, destruction, or breach. Happy Tooth Clinic cannot, however, guarantee complete security of your data from individuals who attempt to circumvent such security measures and/or prevent the transfer of data over the internet.
The present Policy applies only to our Website and does not cover websites, platforms or applications of third parties, to which the user may be redirected through links, hyperlinks, banner ads and reports that exist on our Website, which we do not control.
We reserve the right to modify this Policy from time to time. Any amendment will appear on our Website and there will be a clear indication of the date of the last update. Please check this Policy regularly to keep yourself posted on any modifications or updates thereto.
- Contact Us
If you have any request or query regarding this Policy and the personal data that Happy Tooth Clinic collects and processes through this Website or/and if you wish to exercise any of your rights, as set forth under term 9 above, you may contact us:
- By post: HAPPY TOOTH CLINIC, 26 Andrea Papandreou Street, 166 75, Glyfada, Attica, Greece
- By email: firstname.lastname@example.org
We will make every effort to respond to your query the soonest possible.