PRIVACY POLICY

DEAR CLIENT, USER, MEMBER, SUPPLIER, ASSOCIATES AND RELATED PARTIES:

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1. LEGAL FRAMEWORK

This notice is prepared and made available to you in accordance with the provisions of the “Federal Law on the Protection of Personal Data Held by Private Parties”, in line with the provisions of the General Health Law; the Regulations of the General Health Law on the Provision of Medical Care Services; the Regulations of the General Health Law on Health Research; the Regulations of the General Health Law on Advertising; the Official Mexican Standard NOM-004-SSA3-2012, Clinical Records; the Official Mexican Standard NOM-012-SSA3-2012, Establishing criteria for the execution of health research projects in human beings; the Official Mexican Standard NOM-017-SSA2-1994, Epidemiological Surveillance; related and applicable laws and regulations, and in compliance with the obligation of “DENTAL HOLBEIN” and its Registered Trademarks, responsible for protecting the personal data of its patients, clients, members, affiliates, beneficiaries, suppliers, users, service providers, employees, and all associates and related parties, provided in connection with the consumption, search, access, or benefit of any of the products, services, memberships, including records, databases, and templates belonging to the business and related activities under the trade name “DENTAL HOLBEIN”, and registered trademarks, owned by SBD Salud y Bienestar Dental S.C.

In compliance with current regulations, we hereby inform you of the following:

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PRIVACY NOTICE

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II. GENERAL PROVISIONS

1. CONTENT OF PERSONAL DATA AND DEFINITIONS

In accordance with the “Federal Law on the Protection of Personal Data Held by Private Parties”, the following terms will be understood as follows for the purposes of this notice:

• NOTICE: The content of this Privacy Notice.

• LAW: Unless otherwise specifically referred to, the “Federal Law on the Protection of Personal Data Held by Private Parties.”

• USERS: Any natural or legal person, including but not limited to patients, clients, members, affiliates, beneficiaries, suppliers, users, service providers, employees, associates and related parties, who use, acquire, enter, access, enjoy, or benefit from any product or service offered by “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., in accordance with the specificities of its professional medical activity and specialties of its parties, and who, in any stage, process, or form, provide their PERSONAL DATA.

• PERSONAL DATA: Any information concerning an identified or identifiable individual. For the purposes of this Privacy Notice:

 

By way of example, but not limited to, the following shall be considered Personal Data, depending on their specification:

GENERAL DATA

 

First and last name, date of birth, gender, marital status, existence or not of children, address, home and office landline numbers, mobile phone number, email address, among other similar related personal data.

 

DATA RELATED TO STAFF RECRUITMENT

Personal Data provided in job boards, calls for applications, databases, and recruitment templates of “DENTAL HOLBEIN” and/or SBD

Salud y Bienestar Dental S.C.

 

In addition to general data, Personal Data will also include information such as educational level, work experience, and any information related to résumés and professional experience collected.

 

APPOINTMENTS, MAGAZINES, NEWSLETTERS, BILLING, AND ONLINE TRANSACTIONS

When subscribing to receive any products from “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks (such as company magazines, electronic magazines, electronic newsletters, brochures, among others), and when electronic transactions are carried out for the acquisition of products or services, electronic invoicing, or appointment scheduling on any digital platforms (including the use of mobile devices such as iPhone®, iPad® or Android® devices, as well as websites and microsites).

 

Data required for tax invoicing, such as RFC (Tax ID), Tax Address, Name, corporate or trade name, are required by official provisions and are considered public documents, and therefore are not subject to this privacy notice, but will be safeguarded in the necessary databases.

 

In addition to general data, Personal Data will also include those related to bank cards, such as cardholder name, card number, expiration date, card type, and security code, as well as product delivery address and any other information necessary for subscription or online transaction.

 

The Personal Data referred to in this section will be subject only to the Purposes of Processing established later in this Privacy Notice, for as long as the commercial transaction lasts; that is, once the transaction and its effects are concluded, the Personal Data referred to in this section will be deleted from our databases.

 

SOCIAL MEDIA

Known “social networks,” such as Facebook® and Instagram®, among others, constitute a form of communication and interconnection between digital platforms of different users, and are external to “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C. and its Registered Trademarks, and therefore are not under their responsibility.

 

For this reason, in adherence to data privacy dynamics, their use and management will be limited without requesting or collecting, for any reason, personal data publicly (openly) from anyone, always respecting the social platform’s policy in question, except in cases of personal requests via email, private messages, or “inbox.”

 

Information provided within “social networks” where “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks participate as users does not constitute nor form part of the Personal Data subject to protection under this Privacy Notice, being the responsibility of the platform provider and of the individual who publishes it.

 

DATABASES AND PHYSICAL AND ELECTRONIC CLINICAL RECORDS, DIGITAL MEDIA

Databases. “DATABASES” shall be understood as the data records contained and backed up in tables, electronic files, and security records generated after the collection of data either physically or electronically, in the different templates made available according to their specific relation with the activity, product, or service to which one wishes to gain access, which shall register and compile the personal data of all users who make use of them.

 

Digital Media. The storage and backup media and devices, known as “Servers,” in addition to computer equipment interconnected on the “Intranet” of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and devices containing backup files, and which are under the safekeeping of authorized personnel within the facilities, shall comprise the “DIGITAL MEDIA.”

 

Clinical Records. Given the specific activities related to the Provision of Professional Medical Services, private sector dental offices provided by “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., different templates and formats, both physical and electronic, that make up the body known as the “CLINICAL RECORD,” will be made available to users who specifically access this type of service, regulated both by the General Health Law and the Regulations of the General Health Law on the Provision of Medical Care Services, as well as the Official Mexican Standard NOM-004-SSA3-2012, Clinical Record.

 

Said formats involve the collection of data related to specialized medical activity, and will include, in addition to general data, those specific such as personal medical history, non-pathological personal history, family medical history, photographic sessions, diagnostic test results, imaging and laboratory studies, among other similar, annexed, and related data concerning a person’s medical care.

The data referred to in this section shall be subject to the management and safekeeping measures contained in this Privacy Notice, in accordance with the Federal Law on the Protection of Personal Data Held by Private Parties, the principles of Professional Ethics, and the purposes of Diagnosis, Treatment, and follow-up of users, for the superior benefit of health.

 

COOKIES

Cookies are text files that are automatically downloaded and stored on a user’s computer hard drive when browsing a given internet page, and that allow the internet server to remember certain user data. Through this Privacy Notice we inform that “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C. and its Registered Trademarks DO NOT USE cookies.

 

CLINICAL CASE

A Clinical Case shall be understood as those medical care activities which, due to their magnitude, importance, reference, circumstances, findings, evolution, or factors that involve notable interest, are referenced as an example of the evolution of Medicine, of the Lex Artis, of the Medical Act, both internally and externally, for the benefit of the advancement of medical science.

 

For both collection and management, the data of “Clinical Cases” will be presented as the references and specific medical circumstances involving the indication of an illness or health condition, as well as its evolution, treatment, follow-up, and results, but whose presentation will never include General Data, nor any indication that reveals the identity of the user.

 

FORMS OF COLLECTION

The data referred to in this section will be compiled through the completion of printed physical forms as well as through the collection of information or documentation required by “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, whether in person or electronically on any of the websites of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, present or future (“Websites of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C. and its Registered Trademarks”), among which is highlighted: www.dental-holbein.com

Ownership of the rights over the websites may correspond to “DENTAL HOLBEIN” and/or to SBD Salud y Bienestar Dental S.C. and its Registered Trademarks.

 

The collection of Data relating to medical care, for the compilation of “Clinical Records” as well as for the management of “Clinical Cases,” will be obtained under two forms of collection:

 

DIRECT PHYSICAL COLLECTION: those which, in their own handwriting, users provide in the “Medical History” forms, “Data Sheets,” Daily Patient Records, and other documents necessary for medical care, as considered by the General Health Law as well as its Regulations and official standards in the matter.

 

INDIRECT PHYSICAL COLLECTION: those entered into databases, even as backup of those obtained directly; those entered into formats, paperwork, and electronic media in the presence of the user, through interview or questioning; the inclusion of data and references from inter-consultations; and those necessary for the evolution of clinical management, such as diagnostic studies and photographic sessions.

 

All data contained and collected, by any of the forms described, shall have the same treatment and adherence to this Privacy Notice.

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REGISTERS OF PARTICIPANTS, MEMBERS, ASSOCIATES, AFFILIATES

The data recorded in the various lists, participation records, logbooks, and other documents in which the data of members, partners, associates, and participants of both “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., as well as of the various congresses, lectures, courses, informational sessions, meetings, and events, whether public, social, or private, organized by the same, are entered.

 

In addition to what has been stated in previous paragraphs, information related to institutions and educational level, work and professional service addresses, and any information related to the provision of specialized medical and professional services will be handled under these parameters.

 

COMMERCIAL ACTS, TRANSACTIONS, AND OPERATIONS

Commercial acts, transactions, and operations shall be understood as those operations carried out with the purpose of buying or selling a product or providing a service, and the respective transfer of goods in exchange for another of equal value, whether in goods, services, or national or foreign currency.

 

Those related to identification data, including of legal entities, as well as of their legal representatives, in the nature of the respective products, goods, or services that are acquired or transferred, and which are kept under the custody of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., shall be treated in adherence to this Privacy Notice.

 

RESPONSIBLE PARTY FOR PERSONAL DATA

The natural person responsible for personal data, in this act, as well as in representation of past and/or future acts, is SBD Salud y Bienestar Dental S.C., duly designated and authorized, in full exercise of its faculties and in accordance with the responsibility implied in the management of the contents of this Notice and its implications, for all legal purposes, the processing, attention, all references, or obligations established by the Federal Law on the Protection of Personal Data Held by Private Parties.

For the purposes of what is established in section I of article 16 of said Law, the domicile of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C.” is designated as: Av. San Antonio #350, locales 23 y 24, Colonia Santa María Nonoalco, Delegación Benito Juárez, CDMX, C.P. 03700

 

PROCESSING OF PERSONAL DATA

In accordance with the provisions of the Law, the processing of Personal Data (“Processing of Personal Data”) is considered the collection, use, disclosure, or storage of Personal Data, by any means. Use includes any action of access, management, utilization, transfer, or disposition of personal data.

 

The Processing of Personal Data by “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks shall be limited to compliance with the Processing Purposes set forth in this Privacy Notice and shall be subject to the following:

In the event that your Personal Data is to be processed for a purpose other than those set forth in this Privacy Notice, “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C.” and its Registered Trademarks shall be required to obtain your consent for such purpose again.

 

Such processing shall be that which is necessary, adequate, and relevant for the purposes described in this Privacy Notice.

PURPOSES OF THE PROCESSING OF PERSONAL DATA

 

Through this Privacy Notice, “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks declare that the purposes of the processing of your Personal Data shall be the following:

 

Purposes of the Processing:

COMMERCIAL PURPOSES.

For the purpose of informing you about the products, services, promotions, and commercial information of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., among which are highlighted those related to promotions, information about new products, birthday greetings, electronic magazines, changes in products, requests for evaluation of service quality, conducting internal studies on consumption habits, and any other promotional or related matters concerning the products and/or services that form part of the commercial concept known as “DENTAL HOLBEIN.”

ONLINE PAYMENTS, ACCOUNTS PAYABLE, AND RECOVERY OF OUTSTANDING ACCOUNTS.

For the purpose of making economic charges to bank cards for products acquired by clients of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, derived from subscriptions and/or the purchase of products or services of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks.

 

If, due to delays in payments, cancellation or changes in the payment method, rejection of credit instruments or bank charges, or due to refusal to comply with payment for the acquisition of any product or service offered by “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C. and its Registered Trademarks, the Personal Data may be used for the issuance of reminders, collection follow-up, as well as for transfer to third parties for the recovery of overdue accounts, and for the exercise of legal actions related to criminal conduct.

DELIVERY OF PRODUCTS AND SERVICES. COMPLIANCE WITH OBLIGATIONS WITH USERS.

To comply with the obligations that may exist or arise from the acquisition of the products and services offered, subscriptions, including electronic transactions, the follow-up of the delivery of prizes derived from promotions, trivia, or raffles of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C. and its Registered Trademarks, the Personal Data will be used to contact the user or send products, provide domiciled services, refer attention in the event of user immobility, and deliver correspondence.

RECRUITMENT AND SELECTION OF PERSONNEL

With the objective that applicants and candidates receive timely information about job offers or vacancies that arise in “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks and affiliated companies.

CLINICAL MANAGEMENT

 

Shall be understood under the following concepts:

 

Internal. In the case of activities related to the application of medical acts within the medical facilities owned by “DENTAL HOLBEIN,” property of SBD Salud y Bienestar Dental S.C., this shall include, but not be limited to, studies, diagnoses, treatment plans, treatments, evolution, updating of the clinical record, and other related matters annexed and connected, which imply knowledge by the specialized medical and technical staff of the establishment, contained in the Clinical Records, medical histories, and other notes related to the clinical record, in accordance with the provisions of the Official Mexican Standard “NOM-004-SSA3-2012, Clinical Record.”

 

All clinical records shall be handled as Clinical Cases, which would imply the management of information related to treatment, follow-up, application, and evolution of one or several clinical conditions, including photographic sessions, electronic, magnetic, electromagnetic, optical, and digital records, diagnostic study results and correlated data, and shall be managed under the custody of identification data and identity, provided that the patient so states within the section made available for the handling of clinical cases for Clinical Research purposes, for which personal consent shall be collected for these specific cases, and will be included and managed as “Clinical Case.” If no physical authorization exists, it shall adhere to the provisions of Section 6. “Acceptance of the processing of personal data.”

 

External. Those related to activities concerning the application of medical acts performed outside the establishment by medical personnel and referred to the patient, in which case they shall be treated as an internal clinical case; or under presentation within studies, lectures, courses, and the dissemination of data for teaching purposes, in which case, contemplated under the aforementioned provisions and applied for any purpose, including advertising purposes, the same shall be carried out in strict adherence to safeguarding personal attributes and identity, concealing any data that may reveal them.

 

In the case of persons participating in congresses, public events, lectures, classes, courses, and other related activities, “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks shall not be responsible for activities that only involve the logistics and organization of the event, but not the collection of consents nor the handling of clinical cases of other health professionals; however, they shall be urged, to the extent possible, to safeguard the same information of their associated patients, clients, and related parties.

 

Clinical cases handled for clinical research purposes shall be subject to the following:

 

Information related to any research delivered to the Ministry of Health shall be classified as confidential. The Health Research Committees of the institutions or establishments where research is carried out must maintain complete confidentiality regarding the reports and documentation received from the principal investigator, particularly when the research results may be subject to patent or commercial development and exploitation.

 

Members of the Health Research Committees created within “DENTAL HOLBEIN,” property of SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, must maintain complete confidentiality regarding the reports and documentation received from the principal investigator, especially when the research results may be subject to patent or commercial development and exploitation.

The principal investigator and the Health Research Committees of “DENTAL HOLBEIN,” property of SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, shall protect the identity and personal data of users subject to research, whether during the course of an investigation or during the publication or dissemination phases of the results thereof, adhering to the specific applicable legislation in the matter.

 

Due to the nature of the provision of professional medical services provided by “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, by regulation, records of Infectious and Contagious Diseases of Mandatory Notification must be kept, compiled, and delivered to the National Epidemiological Surveillance System (SINAVE). All information related to and generated for these purposes is for epidemiological, statistical, and public health use; therefore, its management must observe the principles of confidentiality and reserve. This regulatory compliance, due to its mandatory nature, cannot be subject to refusal of handling, so any request in this regard submitted under Section 8.2. “REQUEST FOR ACCESS, RECTIFICATION, CANCELLATION, OR OPPOSITION” of this Notice shall be dismissed.

 

STORAGE AND BACKUP

With the objective of safeguarding information related to the execution, monitoring, and recording of various relationships, operations, and commercial acts, service provision, medical acts, and clinical cases, the backup of information shall comply with the periods established by the Regulation of the General Health Law in Matters of the Provision of Medical Care Services, as well as the Federal Fiscal Code, as applicable.

 

CONSENT FOR MINORS

In the event that the holder of the personal data is a minor, authorization for the use, processing, and storage of their data must be provided by their mother, father, or legal guardian, who must prove such representation at the time the information is provided.

 

ACCEPTANCE OF THE PROCESSING OF PERSONAL DATA

For "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks to be able to carry out the processing of personal data, users who hold such personal data must provide either express or tacit acceptance for such processing, which may be carried out by any of the following means:

 

ACCEPTANCE THROUGH ELECTRONIC MEANS

Publication on websites.

"DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, in addition to making the Privacy Notice known through references in emails, will publish this Privacy Notice on its websites so that, once users have reviewed its content, they may grant or deny their consent and the processing of personal data may proceed.

 

Emails.

Based on the information provided, "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will send the link containing this Privacy Notice via email, so that once the user has reviewed its content, they may grant or deny their consent, always personally, so that the processing of personal data may take place.

 

ACCEPTANCE OR REJECTION OF THE PRIVACY NOTICE BY ELECTRONIC MEANS

Acceptance or rejection of the Privacy Notice of "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks through electronic means will be carried out as follows:

"DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will send to the email address registered in the user’s name the following information:

 

The statement that there exists a Privacy Notice of "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, or the modifications or changes made to such Notice, as the case may be.

The content of the Privacy Notice and, where applicable, the updates or amendments made to it.

The protocol or electronic link through which the Privacy Notice, or any changes thereto, may be accepted or not accepted.

Once you have read and become aware of the content of the Privacy Notice, or of the changes made to it, you will have the following options:

1. Accept. By accepting, you grant consent and authorization for "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks to use your personal data according to the purposes of processing established in the Privacy Notice.

2. Do not accept. By not accepting the content of the Privacy Notice or its modifications, you deny or cancel your consent and authorization for "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., under the trade name “Dental Holbein,” and its Registered Trademarks to use your personal data.

 

In this case, "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will cancel and cease to use your personal data for the purposes of processing established in the Privacy Notice. The refusal regarding the handling and use of personal data and the present notice made electronically must be carried out according to the following protocol:

Sending an email to the following address: gerente.dentalholbein@outlook.com

The email must specify the user’s full first and last name(s).

A sufficiently clear and specific statement expressing total intent of refusal.

The email must be addressed to the person designated as responsible in section 2, “THE PERSON RESPONSIBLE FOR PERSONAL DATA.”

It must comply with and adhere to the provisions set forth in section 8.2, “REQUEST FOR ACCESS, RECTIFICATION, CANCELLATION, OR OPPOSITION.”

 

PERSONAL ACCEPTANCE

When personal data is obtained directly from the holder, involves management as a clinical case of notable interest or follow-up, which due to its nature, use, and scope, or because the user’s identity so warrants, "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will provide the acceptance form for this Privacy Notice at the moment the personal data is collected, in a clear and verifiable manner, through the forms that "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks use or may use for such purpose.

 

Furthermore, through said forms, "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will collect the holder’s acceptance or denial of consent to subject such data to the purposes of processing established in this Privacy Notice.

 

TACIT ACCEPTANCE

Based on Article 35 of the Law, the content of this Privacy Notice, as well as any modification or addition thereto, will be communicated by any of the means established in sections 6.1, “ACCEPTANCE THROUGH ELECTRONIC MEANS”and 6.2, “ACCEPTANCE OR REJECTION OF THE PRIVACY NOTICE BY ELECTRONIC MEANS” above, and if no objection is expressed to their content and scope within a period of 2 months, counted from the date on which "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks inform about the Privacy Notice or its modifications, establish contact through different means, collect records showing awareness of its existence, or initiate a relationship with the user, it shall be understood that tacit consent has been granted for "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks to process the personal data based on the purposes of processing established in the Privacy Notice. Refusal must be expressed in writing at the signing of contracts and agreements that "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks issue for the subscription, contracting, and acquisition of their various products and/or services.

 

This shall also apply in cases where, for any reason, "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks do not have the user’s email address, or when the personal data is incorrect or outdated and does not allow the user to be located and/or is returned due to incorrect addressing.

 

RETROACTIVE ACCEPTANCE

For all users who, prior to the notification or publication of this Privacy Notice, provided their personal data—whether through the completion of clinical records, digital media, or any other means by which "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks collected such data, or by any other form or medium—the Privacy Notice will be communicated to them according to the provisions of sections 6.1, “ACCEPTANCE THROUGH ELECTRONIC MEANS” and 6.2, “ACCEPTANCE OR REJECTION OF THE PRIVACY NOTICE BY ELECTRONIC MEANS” above, so that they may grant or deny their consent, whether express or tacit, for "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks to continue or not with the processing of personal data based on the purposes of processing established in the Privacy Notice.

 

LIMITATION OF THE USE OR DISCLOSURE OF PERSONAL DATA

Actions to prevent unauthorized use or disclosure

In order to guarantee the protection of personal data and limit its unauthorized use or disclosure, "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks continuously carry out and will carry out the following actions:

 

Confidentiality of information.

"DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will maintain confidentiality regarding collected personal data, which will remain in effect even after the end of its commercial or other relationships with the user or holder of such data.

 

Confidentiality notice.

In the event that, for any reason, "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks need to provide your personal data to third parties, under the terms provided in the Law or in this Privacy Notice, such third parties will be notified of the obligation to comply with the provisions of the Law and the confidentiality of personal data.

 

Database administration.

Personal data is managed and safeguarded through the use of databases, which are administered only by individuals designated by "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks for such purpose, without allowing their use, consultation, handling, or access by unauthorized individuals.

 

Computer and IT systems.

The databases are protected by firewalls and computer and/or IT systems aimed at preventing and avoiding access to personal data by persons outside of or unauthorized by "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks.

 

Personnel policies and relationships with third parties.

For the protection of personal data, "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will implement mandatory data protection policies for all personnel in their employment relationships or with third parties who may have knowledge of, contact with, or handle personal data. These policies will entail the assignment of responsibilities and the exercise of legal actions in the event of improper handling. All third parties will be urged to acknowledge, comply with, and expressly recognize the handling of data protection and security policies, as well as awareness of the contents of this Privacy Notice, insofar as it relates to their services.

 

In the case of relationships with third parties, "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., whose service contracts or request forms are expressly authorized for this purpose, will responsibly and invariably require the proper privacy notice under which they operate, as applicable, to ensure that such third party complies with general guidelines and federal regulatory laws; and, in turn, will present and request third-party signatures acknowledging this Privacy Notice.

 

REQUESTS TO LIMIT USE OR DISCLOSURE

In the event that you wish to limit the use or disclosure of personal data in relation to one or more of the purposes of personal data processing—for example, promotional emails, birthday greetings, job offers, prize distribution, among others—you may submit the corresponding request according to the procedure established in section 8, “RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION, OR OPPOSITION,” of this Privacy Notice, or through the links published or to be published on the websites of "DENTAL HOLBEIN" and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, or in the promotional information we send you.

 

 

RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION OR OPPOSITION

 

Exercise of ARCO Rights
You may exercise your ARCO rights (Access, Rectification, Cancellation, or Opposition) by sending a request to the email: gerente.dentalholbein@outlook.com
Y

our request must include:

1. Full name and means of contact

2. Documents proving your identity or that of your legal representative

3. A clear description of the right you wish to exercise

4. Any documents that may help locate your data

5. Specification of the modifications or limitations requested

6. Documentation supporting your request

 

In accordance with the provisions of the Law, you have the right to access, rectify, cancel, or oppose the Processing of Personal Data, for which “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks offer the following procedure:

 

PERSONAL DATA DEPARTMENT

“DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks have designated a department in charge of the custody of Personal Data, which will handle requests and promote the protection of Personal Data within “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks.

 

For this purpose, the Personal Data Department makes available the following contact information and means for receiving information and documentation:
Email: gerente.dentalholbein@outlook.com
Address: Av. San Antonio #350, locales 23 y 24, Colonia Nonoalco, Delegación Benito Juárez, CDMX.
C.P. 03700
Attention: Personal Data Officer
Responsible Party: Dr. Grecia Scull Viyella

 

REQUEST FOR ACCESS, RECTIFICATION, CANCELLATION OR OPPOSITION
As the holder of Personal Data, you may submit or send to the Personal Data Department a request for access, rectification, cancellation, or opposition regarding the handling of your Personal Data.

 

Such request must be made in writing and must include:

1. Full name and address of the holder of the Personal Data, or another means to communicate the response to your request

2. A simple copy of documents proving the identity or legal representation of the holder of the Personal Data

3. A clear and precise description of the Personal Data for which you wish to exercise any of the aforementioned rights

4. Any other element or document that facilitates locating the Personal Data

5. Indication of the modifications to be made and/or the limitations on the use of Personal Data, as provided in section 7.2. “REQUESTS TO LIMIT THE USE OR DISCLOSURE” of this Privacy Notice

6. Documentation supporting the request

All personal data subject to the operations and relationships indicated herein must adhere to the provisions of this section, given the nature, purpose, and scope of the responsibilities that the handling of data implies, both for “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, and for the person responsible for handling them. Therefore, all requests that do not comply with the provisions set out herein will be dismissed.

 

RESOLUTION AND COMMUNICATION
“DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental, and its Registered Trademarks will communicate to the holder of the Personal Data the decision adopted, within no more than 20 business days from the date the request is received. This period may be extended once for an equal amount of time, provided that the circumstances of the case justify it.

 

Based on the above, and in accordance with the provisions of the Law, “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental, and its Registered Trademarks will inform the holder of the Personal Data of the outcome and reasoning of the decision, through the same means by which the request was made, and will accompany said decision with the relevant evidence, where applicable. When the request is appropriate, “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental, and its Registered Trademarks will enforce it within 15 business days following the communication of the adopted resolution.

 

The holder may file a data protection request with the competent authority in matters of transparency and data protection (Secretaría Anticorrupción y de Buen Gobierno, formerly INAI) if they receive an unsatisfactory response or no response at all from “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental, and its Registered Trademarks. Such request must be filed by the holder within 15 business days following the date the response was communicated by “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, and shall be subject to the provisions of the Law.

 

In the case of requests for access to Personal Data, it will be necessary for the applicant or their legal representative to first prove their identity.

 

The obligation to grant access to information will be fulfilled when “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks make the Personal Data available to the holder, or through the issuance of simple copies or electronic documents.

 

If a person requests access to Personal Data from “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, presuming that it is the responsible party, but it is not, it will suffice for “DENTAL HOLBEIN”and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks to so inform the holder by any means, to consider the request resolved.

 

The response to the request for access, rectification, cancellation, or opposition of Personal Data will be free of charge. Only justified shipping costs or reproduction costs in copies or other formats must be covered, which, when applicable, will be communicated by “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks to users who request it.

 

If the same person repeats the request for access, rectification, cancellation, or opposition of Personal Data within less than 12 months from the date of the last request, the response to such request may incur an additional cost set by “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks, in accordance with Article 35 of the Law.

 

DENIAL OF ACCESS TO PERSONAL DATA

“DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental, and its Registered Trademarks may deny total or partial access to Personal Data or the rectification, cancellation, or opposition to its processing in the following cases:

1. When the applicant is not the holder, or the legal representative is not duly authorized

2. When the Personal Data of the applicant cannot be found in the Database of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks

3. When the rights of a third party are compromised

4. When there is a legal impediment or resolution by an authority

5. When rectification, cancellation, or opposition has already been carried out, making the request unnecessary

 

CONSEQUENCES OF CANCELLATION
The cancellation of Personal Data will result in a blocking period after which “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will proceed with the deletion of the corresponding data. Once the relevant Personal Data has been canceled, “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will notify the holder.

 

After this, “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks may retain Personal Data exclusively for purposes related to the responsibilities arising from the processing referred to in this Privacy Notice.

 

When Personal Data has been transferred to third parties before its rectification or cancellation and is processed by those third parties, “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks must inform them of the request submitted by the holder, so that they may proceed to carry out such rectifications or cancellations.

 

“DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks will not be obliged to cancel Personal Data in the cases established under Article 26 of the Law.

 

Furthermore, when the information collected in the Personal Data is no longer necessary for the fulfillment of the purposes outlined in this Privacy Notice and applicable legal provisions, the Personal Data will be deleted from the Databases of “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks.

 

CHANGES TO THE PRIVACY NOTICE
“DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks reserve the right to make modifications or updates to this Privacy Notice at any time, in order to comply with legislative or jurisprudential changes, internal policies, new requirements for the provision or offering of their products and services, or for commercial practices.

 

Therefore, in the event that “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks modify the content of this Privacy Notice, they will notify you by any of the means set out in section 6. “ACCEPTANCE OF PERSONAL DATA PROCESSING” of this Notice.

 

TRANSFER OF PERSONAL DATA
In the event that “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks transfer Personal Data to any of its providers in order to carry out the Purposes of Processing established in this Privacy Notice, they will do so subject to confidentiality agreements and only if:

1. The provider or person to whom the data is transferred agrees to subject the processing of Personal Data to this Privacy Notice, and

2. It does not involve any of the cases established in Article 37 of the Law.

3. If, at the time of contracting, you do not state your opposition to your Personal Data being transferred to third parties, it will be understood that you have granted “DENTAL HOLBEIN” and/or SBD Salud y Bienestar Dental S.C., and its Registered Trademarks your consent to do so.

 

This Privacy Notice was last updated on June 23, 2025.

 

 

I DO NOT AUTHORIZE

Name: __________________
Date: __________________
Signature: __________________

 

 

I AUTHORIZE

Name: __________________
Date: __________________
Signature: __________________