This platform belongs to and is managed by MiioSmile Digital SRL, headquartered in Romania, Craiova, Calea București, no. 58 block of flats D2, entrance 5 floor 4 Ap.10, registered with the Trade Registry under no J16/1166/2018 and the unique identification number 39373080 and bearing the trade name miioSmile.
By using this platform you agree to the collection, processing and transfer of your personal data as described in this data processing policy.
The information collected through our platform is collected in the European Union and is subject to Regulation 679/2016.
We are happy to see more and more dental professionals using our application in order to facilitate patients' treatment as quickly as possible. To start with confidence our relationship, we want to provide you with some key information about protecting your personal data from your professional account in our platform.
What is personal data?
"Personal data" means any information relating to an identified or identifiable natural person (the data subject), for example, name, physical address, contact data, user ID, IP address, photo and video recordings, health data, etc.
How will we use personal and what is the flow?
Any personal data that you provide to us through our platform will only be used for the intended purpose of sending the data. In addition, we will use this data to update our database and send you, to the extent permitted by law, occasional information about products, services, and other items that may be of interest to you and relate to the activity deployed.
The information we collect
1. We collect information about you when you access our application through online identifiers (cookies, IPs), geo-location
The application automatically collects certain information and stores them in log files. This information includes the Internet Protocol (IP) address, the general location of your computer or device (at city-level).
We use this information to design our application in a way that is better adapted to the needs of our users. We may also use your IP address to help diagnose problems with our servers and administer our application, analyze trends, track user movements, and gather general demographic information to support us identifying user preferences. The basis of the processing is our legitimate interest in monitoring the activity in the application and ensuring the security of the site. The data is kept for two years from the date of the visit.
2. We collect information about you when using our contact addresses to match: name, surname, email, phone number, platform profile
We use this information to help you with the requests you address to our company. The basis of processing is your legitimate interest in having access to information about our platform. The data is retained for one year, unless there is a contract that intervenes between the parties or any other legal obligation.
3. We collect information about you when you create a profile on the platform and when you are using our services:
- name, surname, phone number, email address, city,
- professional quality: dentist or dental technician
- details about patients (name, surname, dental x-rays, tooth color, type of dental work performed / to be performed, patient name, job id, etc )
- details of the treatment schedule applied to the patient
- photographic images necessary / useful for the work
- details of the patient's health status
We use this information about you and your patient to help speed up and secure the transmission of information to the dental technician, so that dental work can be done in a shorter time. The legal basis for data processing in the context of account creation is the contract between the parties, which you can read in the Terms and Conditions section. In the context of this processing, personal data is retained until you decide to delete your account.
How do we use the information we collect?
Your data will be used to:
- improving contracts;
- using the application miioSmile
- transmission of personalized information / notices / notifications;
- solving platform issues
- customer support services;
- for the transmission of information messages on novelties of interest for dentists and dental technicians;
- to improve our services;
- defense of the legitimate interests of MiioSmile Digital S.R.L
Your information can be shared with third-party companies that have supplier status miioSmile. Likewise miioSmile may sometimes be required to disclose your information to external third parties such as local authorities, courts and tribunals, regulatory bodies and / or law enforcement agencies in order to comply with the applicable laws and regulations or in response to a legal procedure.
We will also share your personal information with third parties if we have your consent or to detect, prevent or otherwise address fraud, security breaches or technical issues, or to protect ourselves against breaching property rights or violating the safety of users, other candidates, employees and other individuals concerned, or in the cases provided by law.
The miioSmile application can collect information about minors in custody of parents who have agreed that their child's data either processed in the application. However, accessing and using the application is not intended to be used by minors. Also, if we find that a minor is entered into the app without the legal representative's approval, we will delete all personal data about the minor in question.
How do we share information with third parties?
We will disclose your personal data only for the purposes of those third parties, as described below. miioSmile will take the necessary steps to ensure that your personal data is processed, secured and transferred in accordance with the Law in force.
External service providers
Where necessary, we will instruct other companies and individuals to perform certain tasks that contribute to our services on our behalf. We may, for example, provide personal data to couriers, agents, contractors or partners for hosting our databases, for data processing services or to send you information you have requested. We will share or make available to external service providers that information to the extent necessary to process your requests. This information can not be used by them for any other purpose, especially for their own purposes or for third parties. External service providers miioSmile are bound by contract to respect the confidentiality of personal data.
Some of our external vendors who have access to your data are the companies that provide us with the database hosting, in this case Google Cloud.
We will only disclose your personal data to public authorities if this is required by law. For example, the Company will respond to requests from law enforcement, law enforcement agencies, regulatory agencies and other public and official authorities that may include such authorities outside of the country of residence.
In relation to any reorganization, restructuring, merger or sale or other transfer of assets (collectively "Business Transfer") we will transfer information, including personal information, to a reasonable scale and as necessary for the Transfer of Business and provided that the receiving party agrees to respect your personal data in a manner that complies with applicable data protection laws.
International transfers of personal data
Any transfers of personal data to countries other than those for which a decision has been made on the adequacy of the data protection level by the European Commission as listed on official websites is made on the basis of agreements contractual arrangements using the standard contractual clauses adopted by the European Commission or other appropriate safeguards, in accordance with the law in force.
Any transfers of personal data to the U.S. will be governed by the Privacy Shield rules and subsequent acts adopted by the European Commission.
For how long will we keep your personal information?
1. Unless you oppose the processing of our personal data and / or request the deletion of your personal data, the following retention periods apply in accordance with our data retention policy for the following categories of personal data:
If there is no contract between us, your data will be kept for 12 months.
2. During the existence of your account in our platform
3. We do not store personal data more than is necessary for the purpose for which we have retained it, or to comply with a statutory law or requirement
4. In the case of commercial contracts, personal data will be kept for at least 10 years under the Romanian Tax Code.
5. Browser and cookie data will be kept 24 months after the session.
6. Patient data from inactive accounts will be destroyed 6 months after account closure.
Are your personal data collected and processed by miioSmile safe?
We have physical, electronic and managerial security measures to protect and secure the information we collect and process.
We apply an appropriate level of security and therefore have implemented reasonable physical, electronic and administrative procedures to protect the information we collect from accidental or unlawful destruction, from unauthorized loss, alteration, disclosure or access to personal data transmitted, stored or otherwise processed. Our information security policies and procedures are closely aligned with widely accepted international standards and are periodically reviewed and updated as necessary to meet our business needs, technological change as well as regulated requirements. Access to personal data is granted only to those staff members, service providers with a need for knowledge driven by the business itself or who need it in order to perform its tasks.
Please note that, unfortunately, no data transmission is guaranteed with an accuracy of 100%.
You are responsible for your username and password: keep them safe!
If you suspect that the security or privacy of your data has been violated, please contact us immediately by email email@example.com
Your legal rights
As a target person, you have specific legal rights with respect to the personal data we collect from you. And miioSmile will respect your individual rights and will handle your interests properly.
Right of withdrawal of consent: You can withdraw your consent to the processing of personal data at any time when processing is based on consent
Right to rectification: You can get from us the rectification of your personal data. We make reasonable efforts to keep personal data that is being used continuously and in our possession or control - accurate, complete, current and relevant, based on the latest information available to us.
The right to restrict: You may obtain from us the personal data processing restriction if:
you dispute the correctness of personal data for the time we need to verify the accuracy,
processing is illegal and you require restriction of processing rather than deletion of personal data,
we no longer need your personal data, but you ask for it to be ascertained, exercised or defended, or
you oppose your processing while we are checking that our legitimate reasons are superior to yours.
Right of access: You can ask us for information about the personal data we hold about you, including information about which categories of personal data we have in our possession or control, what they are used for, where we collected them, are not collected directly from you and to whom it has been disclosed, if any. You may obtain a free copy from us containing the personal data we hold about you. We reserve the right to charge a reasonable fee for each additional copy that you may request.
The right to portability: Upon request, we will transfer your personal data to another operator, where technically possible, provided the processing is based on your consent or is required for the performance of a contract. Rather than receiving a copy of your personal information, you may request that we transfer your data directly to another operator, specified by you.
The right to delete:
- you can get from us the deletion of your personal data if:
- your personal data is no longer necessary for the purpose for which it was collected or otherwise processed
- you have the right to oppose further processing of personal data (see below) and to execute this right of objection to processing;
- personal data has been processed illegally;
Unless processing is required:
- in order to fulfill a legal obligation that requires our processing;
- in particular, for legal data retention requirements;
- for the establishment, exercise or defense of a right.
The right of opposition: You may object - at any time - to the processing of your personal data due to your special situation, provided the processing is not based on your consent but on our legitimate interests or those of a third party. In this case, we will no longer process personal data if we can not demonstrate good, legitimate, and a major interest in processing or in finding, exercising or defending a right. If you oppose your processing, please specify if you wish to delete your personal data or the restriction of our processing by us.
The right to file a complaint: In the case of an alleged violation of the privacy law in force, you can file a complaint with the data protection supervisor.
National Supervisory Authority for Personal Data Processing
Address: General Gheorghe Magheru Av., 28-30, Sector 1, postal code 010336, Bucharest, Romania
Time period: We will try to meet the request within 30 days. However, the period may be prolonged for specific reasons relating to the specific legal law or complexity of the request.
Restrict access: In some situations, we may not be able to grant you access to all or part of your personal data because of legal provisions. If we refuse your access request, we will inform you of the reason for which you were refused.
Impossibility of identification: In some cases, we may not be able to search for your personal data because of the identification elements provided in your application.
In such cases, where we can not identify you as the data subject, we are not able to comply with your request to exercise legal rights as described in this section unless you provide additional information to enable us to identify you.
Exercise your legal rights: In order to exercise your legal rights, please contact us by sending us a letter or by writing an email at firstname.lastname@example.org
An important note on patient data
The dentist is solely responsible for informing his or her patients about their use of the application miioSmile.
This version was updated on 25.03.2019