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PRIVACY POLICY

SAMER AMES, S.A., a commercial entity organized as a public limited company, with taxpayer number 507740343 (hereinafter referred to as “CLÍNICA AEGER PRIMA”), in the course of its commercial activities on the website www.aegerprima.pt (hereinafter referred to as the “Website”), is committed to respecting your privacy and ensuring the protection of your personal data in its relationship with you as a client. As described throughout this Privacy Policy, CLÍNICA AEGER PRIMA processes Personal Data, meaning information relating to an identified or identifiable individual (“Data Subject(s)”). For this purpose, an individual is considered identifiable if they can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifiers, or one or more specific elements of their physical, physiological, genetic, mental, economic, cultural, or social identity (“Personal Data”).

The use of the Website by any user will be governed by the Terms and Conditions of use (“Terms and Conditions”), and its use implies acceptance of the same by the user. Should the user reject the Terms and Conditions, they must immediately cease using the Website.

CLÍNICA AEGER PRIMA acts as the “Data Controller,” thereby determining the purposes and means of processing Personal Data in compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and other applicable data protection and privacy legislation (“Data Protection Legislation”).

Under the Data Protection Legislation, CLÍNICA AEGER PRIMA strives to process Personal Data in accordance with all applicable principles, namely:
i) Principle of Lawfulness, Fairness, and Transparency;
ii) Principle of Purpose Limitation;
iii) Principle of Data Minimization;
iv) Principle of Accuracy;
v) Principle of Storage Limitation;
vi) Principle of Integrity and Confidentiality.

This Privacy Policy aims to explain how SAMER AMES processes your personal data and ensures the privacy of Website users.

LEGAL BASES AND PURPOSES OF DATA PROCESSING

The Personal Data of Data Subjects will be processed by CLÍNICA AEGER PRIMA based on the following legal bases:

Legal Bases Description
Consent The Data Subject may consent to the processing by providing a free, specific, informed, and explicit declaration of intent, such as by written or oral declaration or unequivocal affirmative action (e.g., checking a box), to authorize the processing of their Personal Data.
Pre-contractual steps or contract execution Personal Data may be processed as necessary for performing a service agreement or product provision where the Data Subject is a party or for taking pre-contractual steps at their request.
Compliance with a legal obligation Personal Data may be processed to ensure and guarantee compliance with legal obligations to which the entity is subject under Member State or EU law.
Vital interests Personal Data may be processed to protect the vital interests of the Data Subject, such as when processing is essential to their life.
Legitimate Interests CLÍNICA AEGER PRIMA or third parties may process Personal Data provided that such processing does not override the rights and freedoms of the Data Subject.

Given the above, the collection of Personal Data based on the stated legal bases is primarily for purposes related to the business activities of CLÍNICA AEGER PRIMA, as well as for the execution of contracts and legal obligations. Failure to collect Personal Data will prevent the execution of the purposes for which Personal Data is processed.

PERSONAL DATA PROCESSING ON THE WEBSITE

CLÍNICA AEGER PRIMA processes the Data Subject’s Personal Data as follows:

Purpose Processing Activities Legal Basis Retention Period
Website management by CLÍNICA AEGER PRIMA Analysis and processing of web navigation data Contract execution under the Website Terms and Conditions Up to 3 months after the last website visit. During the duration of the website registration period.
Contact Services upon request Responding to contact requests Consent For the time necessary to fulfill the contact request.
Commercial and Marketing Activities Sending Information Consent Up to 1 year after the last contact.

PERSONAL DATA PROCESSED ON THE WEBSITE

For the purposes mentioned, CLÍNICA AEGER PRIMA processes the following Personal Data:

Purpose Personal Data
Website Management Personal Identification Data, Contact Data, Authentication and Access Data, and/or Web Navigation Data (electronic identifier, connection start/end date/time, origin location, URL visited, social media address, social media interaction history, or hostname).
Commercial Activities Personal Identification Data and Contact Data.
Contact Services upon request Personal Identification Data, Telephone Contact Data, and Email Address.

DATA PROCESSING METHODS

The processing of Personal Data will be carried out both automatically and manually using IT tools, applying logic strictly related to the purposes, and, in any case, promoting the security and confidentiality of Personal Data.

DISCLOSURE AND TRANSMISSION OF PERSONAL DATA

Employees of CLÍNICA AEGER PRIMA will process the Data Subjects’ Personal Data for the execution of their professional duties and exclusively as specified in this Privacy Policy.

Personal Data may be made available to third parties contracted to provide services to CLÍNICA AEGER PRIMA (“Processors”), bound by a written contract, and will process the data solely under the terms of this Privacy Policy, not for their purposes or those of third parties.

Data Subjects have the right to obtain a complete and updated list of Processors (if any) contracted by CLÍNICA AEGER PRIMA by submitting a specific request as specified in this Privacy Policy.

INTERNATIONAL TRANSFERS

CLÍNICA AEGER PRIMA may transfer the Data Subject’s Personal Data outside the European Economic Area (EEA) to locations that may not guarantee the same level of protection.

DATA SUBJECTS’ RIGHTS

Under the Data Protection Legislation, Data Subjects have the right to access, rectify, restrict, port, erase, and object to the processing of Personal Data.

Rights of Data Subjects

Rights Description
Right to Information The Data Subject has the right to obtain clear, transparent, and easily understandable information about how CLÍNICA AEGER PRIMA uses their Personal Data and their rights. This is why CLÍNICA AEGER PRIMA provides all this information in this Privacy Policy.
Right of Access The Data Subject has the right to obtain information about which Personal Data CLÍNICA AEGER PRIMA processes (if any) and certain details (similar to those provided in this Privacy Policy) about how those Data are processed. This right allows the Data Subject to be informed and confirm that their Data are processed in accordance with Data Protection Legislation. CLÍNICA AEGER PRIMA may refuse to provide the requested information if it would reveal Personal Data of another person or negatively affect the rights of another person.
Right to Rectification If the Data Subject’s Personal Data are incorrect or incomplete (e.g., if their name or address is wrong), they can request CLÍNICA AEGER PRIMA to take reasonable measures to correct them.
Right to Erasure (Right to be Forgotten) This right allows the Data Subject to request the deletion or removal of their Personal Data, provided there are no valid reasons for CLÍNICA AEGER PRIMA to continue processing them or if their use is unlawful. It is not a general right to erasure as there are exceptions (e.g., if the Data are necessary for the defense of a legal claim).
Right to Restriction of Processing The Data Subject has the right to “block” or suppress the further use of their Personal Data while CLÍNICA AEGER PRIMA assesses a rectification request or as an alternative to erasure. When processing is restricted, CLÍNICA AEGER PRIMA may still store the data but will not use them further. CLÍNICA AEGER PRIMA maintains a list of Data Subjects who requested “restriction” to ensure compliance.
Right to Data Portability The Data Subject has the right to obtain and reuse certain Personal Data for their own purposes across different organizations. This right applies only to the Data provided by the Data Subject to CLÍNICA AEGER PRIMA and processed with consent or automated means.
Right to Object The Data Subject has the right to object to certain types of processing, for reasons related to their particular situation, at any time during that processing for the purposes of CLÍNICA AEGER PRIMA’s or third parties’ legitimate interests. CLÍNICA AEGER PRIMA may continue processing such Data if it can demonstrate “overriding legitimate grounds” or if the Data are necessary for legal claims.
Right to Lodge a Complaint The Data Subject has the right to lodge a complaint with the competent supervisory authority, the National Data Protection Commission (CNPD), if they believe that the processing of their Personal Data violates their rights and/or the Data Protection Legislation.

If the legal basis for processing your personal data is consent or legitimate interest, you may withdraw your consent or object to the processing at any time without adverse consequences. However, this does not affect the lawfulness of processing carried out before withdrawal or objection. Upon withdrawal of consent or explicit objection, CLÍNICA AEGER PRIMA will immediately cease processing your data for the stated purpose, unless required for legal and/or contractual obligations.

You may exercise your rights at any time, in writing, under Data Protection Legislation and other applicable laws, by contacting us.

Security and Confidentiality

To ensure the security and confidentiality of Personal Data, protected databases are used, including appropriate firewalls and passwords, in accordance with the provisions of Data Protection Legislation. Access to Personal Data is restricted to authorized employees who have a genuine need to use the data in accordance with security and confidentiality principles. Violations of this Privacy Policy by employees of CLÍNICA AEGER PRIMA may result in disciplinary action. Compliance with CLÍNICA AEGER PRIMA’s policies and procedures is regularly monitored and verified.

Cookies

Regarding the processing of Personal Data through the use of cookies, please refer to the Cookies Policy of CLÍNICA AEGER PRIMA and customize your settings according to your preferences.

How to Contact CLÍNICA AEGER PRIMA Regarding Privacy and Data Protection Matters

Data Subjects may exercise their rights by contacting CLÍNICA AEGER PRIMA via email.

Data Subjects may also contact CLÍNICA AEGER PRIMA’s Data Protection Officer by sending an email.