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Privacy Policy

1. Data protection policy

  • Introduction

  • Who is the controller of the processing of your personal data?

  • For what purpose do we process your data and what is the legitimate basis?

  • What data do we process and from what source are they obtained?

  • To whom is your data communicated?

  • How long will we keep your data?

  • What are your rights?

Introduction.

This Data Protection Policy is specifically adapted to the HLA Hospital Group website (www.grupohla.com), as well as to the applications and other products and services of which the owner of the personal data may make use through the aforementioned website (collectively referred to as 'Services').


This Data Protection Policy may be modified by HLA LAVINIA SALUD, S.L.U, prior communication to the owner of the data through the website or by other means so that you can know it and continue using our Services. The fact of continuing to enjoy our Services after having communicated the aforementioned modifications will mean that you agree with them, unless express consent is required.


Who is responsible for the processing of your personal data?

The data controller will be the company HLA LAVINIA SALUD, S.LU. (hereinafter, HLA), with Tax Identification Code B87316139, and with registered office at C/ Juan Ignacio Luca de Tena, 12, 28027, Madrid.


For the proper management of the processing of your personal data, HLA has designated a Data Protection Officer to whom you can turn to resolve any questions you may have, and who can be contacted via email at DPO@grupohla.com.


For what purpose do we process your data and what is the legitimate basis?

At HLA we may process the personal data collected from the data subject for the following purposes:


1. Contact: on the basis of consent or the existing legal and/or contractual relationship with the interested party, manage the data of interested parties who contact HLA through the forms that HLA makes available to the user. Also, your data will be processed in order to manage the queries that you send us through the channels provided for this purpose on our website, as well as for the management of appointments for the provision of health care


2. Work with us: Based on the consent or the request for the application of pre-contractual measures, depending on how the selection process is initiated, the processing of your data is aimed at being able to develop the selection process, which involves the analysis of your professional profile through the information contained in your CV, as well as that provided during the development of the selection process through interviews, group dynamics and emails exchanged.


3. Access to 'Patient Portal': on the basis of the existing legal and/or contractual relationship with the patient, manage your registration in 'The Patient Portal', as well as subsequent data that could be generated through the aforementioned channel, in order to carry out the general administration of your account, maintenance, compliance, development, control and management of the requests that you register through the Patient Portal, as well as the management of your relationship with HLA.


4. Advertising of proprietary products and services: To send the patient, based on HLA's legitimate interest in promoting its products and services, information related to new benefits and care improvements offered, as well as to assess the degree of patient satisfaction in relation to the care provided. Where appropriate, this purpose may also be based on the patient's vital interest


5. Attention of requests for information based on pre-contractual measures, complaint, suggestion (due to the existence of a legitimate interest in maintaining appropriate quality standards and offering a better service), claim or exercise of data protection rights (in compliance with a legal obligation). In these cases, your data will be processed for the purpose of managing and processing the request, by any means, including telephone and/or electronic communications


6. Sending of newsletters: if you explicitly consent, your data may be used for sending, by electronic means, the newsletters you have subscribed to.


7. Compliance with legal obligations: it may be necessary to process personal data in order to comply with applicable legal requirements. In particular, in order to comply with data protection, tax or health legislation.


What data do we process and from what source are they obtained?

  • Data provided by the interested party, through the completion of the forms provided for this purpose and the relationship with HLA

  • The data processed for the development of the selection process that are provided by the candidate through the sending of his/her CV, or obtained during the selection process.

  • Data obtained from marketing studies in which the data subject has agreed to participate and has given consent to be used.

  • Depending on the service, the data processed comprises the following typology:

  • Identifying data (e.g., first name, last name, ID card, postal address, e-mail address, telephone number).

  • Socio-economic data (e.g. economic, financial and insurance).

  • Transaction data for goods and services (e.g. payments for services performed).

  • Commercial information data (e.g. interests in products or services).

  • Health data.

To whom is your data communicated?

The following data communications are intended to guarantee the correct development of the contractual relationship, as well as to comply with legal obligations that require the aforementioned communications to be made:


  • Public bodies and administrations in the exercise of a legal obligation.

  • Professionals (medical and administrative) and institutions that accredit legitimate and necessary interest for prevention, medical diagnosis, provision of health care, medical treatment, management of health services or monitoring of the clinical process and administrative management.

  • Professional liability insurance company for the purposes strictly necessary for the processing and management of the claims covered by the coverage of the policy contracted with them.

  • Insurance companies for the purposes strictly necessary for the processing and coverage of the expenses incurred and covered in the contracted policy.

  • Entities holding information services files on solvency and creditworthiness, both for consultation in the legally established cases and in the event of non-compliance with their monetary obligations

How long will we keep your data?

Personal data will be kept for the time necessary to provide the service. The data will be deleted in accordance with the provisions of the data protection regulations, which implies its blocking, being available only at the request of Judges and courts, Ombudsman, Public Prosecutor or the competent Public Administrations during the limitation period of the actions that may arise and, after this, it will proceed to its complete elimination


What are your rights?

The General Data Protection Regulation, provides that you may exercise the following rights:


  • Right of access: access to your data in order to know the processing of the data subject's personal data carried out by HLA.

  • Right of rectification: request the rectification of your data when they are incorrect or inaccurate.

  • Right of deletion: request the deletion of your personal data when you consider it.

  • Right of restriction: request the restriction of the processing of your personal data to the data controller to implement measures on those data, to prevent their modification or deletion.

  • Right of portability: to request the forwarding of personal data concerning him/her that he/she has provided to HLA. This data shall be provided to the data subject in a structured, commonly used, machine-readable format.

  • Right of opposition: oppose the processing of your data in certain circumstances and for reasons related to your particular situation, in which case, HLA would stop processing them, except for compelling legitimate reasons or for the exercise or defense of possible claims.

  • Right not to be subject to automated decisions: you have the right not to be subject to automated decisions (without human intervention in the process) that may have negative legal effects.

At any time the interested party may withdraw their consent on those purposes that have this as a legitimate basis. In addition, you may object to the sending of advertising by electronic means sent by HLA


Likewise, the interested party may exercise the rights described above, by means of a written request addressed to HLA LAVINIA SALUD, S.L.U. at the postal address calle Juan Ignacio Luca de Tena number 12, 28027, Madrid, or by sending an email to the address DPO@grupohla.com, indicating in both cases 'Data Protection Policy.'


Finally, the data subject may file a complaint with the Spanish Data Protection Agency, especially when he/she has not obtained satisfaction in the exercise of his/her rights.


*Access the following link to consult the data of the Data Controller of the corresponding center:
https://www.grupohla.com/es/hospitales-clinicas