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Web implementation: privacy policy

A fin de mantener actualizadas las políticas de cumplimiento de la Ley 34/2002, de 11 de julio, de Servicios de la Sociedad de la Información y de Comercio Electrónico, que establece la regulación del régimen jurídico de los servicios de la sociedad de la información y de la contratación por vía electrónica, en lo referente a las obligaciones de los prestadores de servicios.

READ CAREFULLY THIS PRIVACY POLICY BEFORE USING THE SERVICES OF THE INTERNET PORTAL WWW.DENTOMO.COM AND ITS RELATED APPLICATIONS (HEREINAFTER, THE “WEBSITE” OR THE “PLATFORM”). BY CLICKING ON THE CHECKBOX OR ACCESSING AND USING DENTOMO’S SERVICES, YOU UNEQUIVOCALLY EXPRESS YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH WHAT IS DESCRIBED, YOU SHOULD REFRAIN FROM ACCESSING OR USING THE SERVICES OFFERED BY DENTOMO.

PRIVACY POLICY

1. DATA CONTROLLER OF DENTOMO

REGISTERED NAME:

MEDLAB MEDIA GROUP SL (MEDLAB)
NIF (FISCAL IDENTIFICATION NUMBER):B87354379
POSTAL ADDRESSCalle General Castaños 13, 1º izquierda, 28004 Madrid
ELECTRONIC ADDRESS:info@dentomo.com

DENTOMO is a web and desktop (API) platform for the interpretation of CBCT (Cone Beam Computed Tomography) images, utilizing technologies such as Artificial Intelligence (AI) and Machine Learning. Its objectives include:

  • Clinical Diagnosis Assistance: It aims to automate the detection of oral pathologies to aid in clinical diagnosis.
  • Management and Issuance of Clinical Reports: DENTOMO facilitates the generation of detailed clinical reports. These reports provide patients with a clear and accurate overview of their oral health.
  • Patient Management: The platform includes a database for effective management of patient records and histories.
  • Storage of Patient’s Supplementary Tests: DENTOMO allows the storage of additional tests conducted during various visits, creating a comprehensive historical record of the patient’s interactions with the dental office.

To enhance its performance, DENTOMO “learns” not only from data processing but also through a retraining model based on corrections and annotations provided by dental specialists. By accepting the Privacy Policy, users acknowledge MEDLAB’s exemption from any misuse of the AI tool.

In accordance with current data protection regulations, it is informed that user data will be incorporated into the processing system owned by MEDLAB. The following details the purposes, retention periods, legal bases, etc., for the processing of data within the DENTOMO platform by MEDLAB, in compliance with applicable data protection law.

2. SCOPE OF APPLICABILITY

This Privacy Policy applies to the DENTOMO platform accessed through the API or the web. DENTOMO is a tool whose main function is Diagnostic Assistance, and as such, it is intended for dental professionals. DENTOMO does not include any functionality for patients, and its use by this group is discouraged.

3. COMPILED INFORMATION BY DENTOMO

3.1. User-provided Information.

DENTOMO obtains the personal data provided by the User through the following means:

  1. When visiting or using the Website in browsing mode.
  2. Through the information provided by the User through different services offered on the platform.
  3. By requesting information or contact through the forms created for this purpose.
  4. By registering as a user on the API or platform, as an organization or dentist, for the use of the services offered through it.
  5. Creation of a patient database by the administrator user.
 

3.1.1. Data typology

Personal Data

DENTOMO will process personal data such as email, first and last name, contact phone number, ID, date of birth, gender, as well as other information such as avatar image and preferences like favourite equipment and banking data for billing.

Non-Personal Data

Professional data (registration number), professional contact information, tax identification number (NIF), company name, etc.

 

3.2. Platform-collected Information.

DENTOMO collects and stores personal information indirectly about the User through the following means:

  • Information is collected through simple navigation on the Platform, including the type of browser, device type, and its configuration. We also use cookies for which you can refer to our “Cookie Policy.”
  • Information gathered from searches performed and documents accessed, as well as interaction information with documents, such as marking as favourite, printing, adding notes, etc.
  • We automatically collect data related to the User’s use of the platform (including the API).
  •  

4. PURPOSE OF DATA PROCESSING

The personal data you provide through the platform will be included in a file owned by DENTOMO and will be used for the following purposes, which may vary depending on the use made of them:

  • Management and processing of obligations and duties arising from compliance with the regulations to which MEDLAB is subject.
  • Use or provision of services on the Platform, possibly after User registration, in accordance with the Terms of Use and the Contracting Conditions.
  • Data from the clinic or organization to which the dentist belongs.
  • Professional data of the dentist: name and surname, ID number, contact phone, registration number, as well as any required information.
  • Patient data: name and surname, date of birth, and gender.
  • CBCT images uploaded by users and pseudonymized for analysis by the DENTOMO artificial intelligence engine.
  • Responding to user inquiries or information requests.
  • Administrative management of the DENTOMO demonstration request.
  • Invoicing and collection of the platform’s service.
  • With the prior consent of the user, sending information about DENTOMO’s services, products, and activities, subscribing to the newsletter.
  • Conducting data analysis and generating reports for statistical purposes on the use of platform services, after subjecting them to a dissociation process. Dissociated data do not individually identify the user but allow for the analysis of patterns within groups of people.
  • Personalizing and improving the tools and functionalities of the platform.
  • Ensuring the technical functioning of the platform.
  • Using them for any other purpose required or permitted by applicable law or for which you have given your consent.

5. LEGITIMACY OF PROCESSING

The legal bases that legitimize the processing of data by MEDLAB are detailed as follows:

  • The legal basis for processing your data for the purposes mentioned above is specific, informed, unequivocal, and affirmative consent for the processing of your data, in accordance with Article 6.1 a) of the GDPR.
  • The legal basis for the aforementioned purposes is that the processing is necessary for the execution of the service contract of the DENTOMO Platform, in which the User is a party, in accordance with Article 6.1 b) of the GDPR.
  • The legal basis for processing your data for the aforementioned purposes for compliance with legal obligations, in accordance with Article 6.1 c) of the GDPR.
  • The legal basis for the processing of your data for the purpose mentioned in the previous section is MEDLAB’s legitimate interest in sending this type of information, in accordance with Article 6.1 f) of the GDPR, consisting of improving the performance of the Platform’s services.

6. DATA PRESERVATION

Your data will be retained for the duration specified in the Terms of Service. In the event of a user’s account termination, data will be deleted, unless it poses an impediment to the AI engine. However, due to potential legal obligations, your data may be kept after the commercial contract has ended.

7. DATA RECIPIENT

DENTOMO will not provide users personal data to third parties unless it has the express consent of the user for doing so, and it believes in good faith that it is allowed by law or that it is necessary to disclose it reasonably to comply with a judicial procedure, including, among others, citations for civil or criminal trials, court orders, or other mandatory disclosures.

The information uploaded to the platform for analysis through DENTOMO will be the responsibility of each user, as they have the authority to upload images of their patients and fulfill the duty to inform. MEDLAB is thereby exempted from any liability.

8. SECURITY MEASURES IN DENTOMO

MEDLAB has established all technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, and theft of data provided by the user through DENTOMO. 

MEDLAB states that the information provided by the user through the platform will be stored and processed while observing the duty of secrecy and confidentiality, in accordance with applicable regulations.

MEDLAB has a security certificate that is used by SSL CERTIFICATE to establish secure connections. 

Additionally, MEDLAB commits to adopting the necessary technical and organizational measures, in line with the level of risks associated with the treatments performed by them and indicated in the terms and conditions of use section. These measures are designed to ensure the integrity, confidentiality, and availability of the data.

9. INTERESTED PARTIES RIGHTS

MEDLAB informs users that they have the right to exercise various rights regarding the processing of their personal data. These rights include:

  • Right of Access: Users have the right to obtain information about their specific personal data and the processing carried out, as well as information about the origin of the data and any communications related to them.
  • Right of Rectification: Users can request the modification of inaccurate or incomplete data.
  • Right to Limitation of Processing: Users have the right to limit the original purposes of data processing.
  • Right of Erasure: Users can request the deletion of their personal data, except in cases specified by GDPR or other applicable regulations that determine the mandatory retention of data.
  • Right of Portability: Users have the right to receive their personal data in a structured, commonly used, and machine-readable format and transmit it to another data controller.
  • Right of Objection: Users can object to the processing of their personal data by the platform.

To exercise these rights, users must comply with the following requirements:

  • Submit a written request to the postal address provided at the top or via email to: info@dentomo.com. 
  • The written request must include the following legal requirements:
    • Name, surname of the interested party, and a copy of the ID/NIE or any identification document. In exceptional cases where representation is allowed, the identification of the person being represented, as well as the document proving the representation, will also be required by the same means. A photocopy of the ID card may be replaced, provided that identity is proven by any other legally valid means.
    • Clear specification of the request (e.g., access to information). If it doesn’t refer to a specific file, all available information with personal data will be provided. If it relates to a specific file, only information from that file will be provided.
    • Address for notifications.
    • Date and signature of the applicant.
    • Supporting documents for the request.
    • The interested party must use any means that allows proof of sending and receiving the request.

Finally, users have the right to file a complaint with the Spanish Data Protection Agency if they become aware of or believe that an event may constitute a breach of applicable data protection regulations.

MEDLAB commits to adopting the necessary technical and organizational measures, in accordance with the level of risks associated with the treatments indicated in the terms and conditions of use, to ensure the integrity, confidentiality, and availability of the data.

10. MODIFICATIONS

MEDLAB reserves the right to occasionally make modifications to this Privacy Policy as it deems necessary or as required by law. Any modifications will be promptly published on the platform, and it will be deemed that the User has accepted the modified Privacy Policy at the time they first use the platform after the corresponding modification. 

In the event of substantial changes to this Privacy Policy, MEDLAB will make reasonable efforts to inform users of the introduced changes. However, it is the User’s responsibility to periodically check for updates to this Privacy Policy. Each version of this Privacy Policy will have an effective date from which it takes effect, indicated at the end of the Privacy Policy.

LAST UPDATE: December of 2023