Privacy Policy

1. What Information Do We Collect?

Personal Information You Provide

In short: We collect personal information that you voluntarily provide to us.

We may collect personal information when you request information about our services, submit a consultation request, communicate with our team, arrange treatment, complete forms, or otherwise interact with ClinMedica.

The information you provide may include:

• Full name
• Email address
• Telephone or WhatsApp number
• Country of residence
• Consultation and appointment information
• Travel or reservation information where relevant
• Information contained in correspondence with our team

Sensitive and Health Information

Because ClinMedica provides healthcare-related and medical tourism services, you may provide health information that may be considered sensitive personal data under applicable privacy laws.

This may include information such as:

• Medical history
• Current health conditions
• Previous treatments or procedures
• Photographs submitted for medical assessment
• Medication or allergy information
• Other information necessary to evaluate a requested treatment

We process sensitive information only where necessary and where we have an appropriate legal basis, including your explicit consent when required.

You are responsible for ensuring that the information you provide is accurate and up to date.

Information Collected Automatically

When you visit our website, certain technical and usage information may be collected automatically.

This may include:

• Internet Protocol (IP) address
• Browser type and browser settings
• Operating system
• Device type and device identifiers
• Language preferences
• Referring and exit pages
• Pages viewed on our website
• Date and time of website activity
• General geographic or location information
• Technical error and performance information

We use this information primarily to operate, secure, monitor, analyze, and improve our website and services.

2. How Do We Use Your Information?

In short: We use your information to provide our services, communicate with you, improve our operations, maintain security, and comply with applicable law.

Depending on your interaction with ClinMedica, we may use personal information to:

• Respond to consultation and treatment enquiries.
• Provide information regarding procedures and services.
• Communicate with you before and after treatment.
• Arrange appointments, reservations, and related services.
• Provide customer service and aftercare support.
• Process and manage transactions where applicable.
• Send administrative messages and important service updates.
• Request feedback regarding our services.
• Improve the quality and functionality of our website.
• Analyze website traffic and user behavior.
• Identify and prevent fraudulent or unauthorized activity.
• Protect our website, personnel, patients, and users.
• Comply with regulatory and legal obligations.
• Establish, exercise, or defend legal claims.
• Send marketing communications where legally permitted.

Where marketing communications are based on consent, you can withdraw your consent or unsubscribe at any time.

3. Legal Bases for Processing Personal Information

The legal basis on which we process your personal information depends on your location, the type of information involved, and the purpose for which we process it.

European Economic Area and United Kingdom

Where the General Data Protection Regulation (GDPR) or UK GDPR applies, we may process personal data based on one or more of the following legal grounds:

• Consent: You have given us permission to process your personal information for a specific purpose.
• Contract: Processing is necessary to provide services you requested or to take steps before entering into an agreement with you.
• Legitimate interests: Processing is reasonably necessary for our legitimate business interests, provided those interests do not override your fundamental privacy rights.
• Legal obligation: Processing is required for us to comply with a legal or regulatory obligation.
• Vital interests: Processing is necessary to protect the vital interests of you or another individual.

Sensitive health information may require an additional lawful condition under applicable data protection legislation.

Canada

Where Canadian privacy law applies, we generally process personal information with your express or implied consent, depending on the nature and sensitivity of the information and applicable legal requirements.

In certain situations, applicable Canadian law may permit or require collection, use, or disclosure without consent, including fraud investigations, legal proceedings, emergencies, regulatory requirements, and certain business transactions.

4. When Do We Share Personal Information?

We do not sell personal information simply because you use our healthcare services. However, we may disclose personal information where reasonably necessary for legitimate business or healthcare purposes.

Information may be shared with:

• Authorized ClinMedica personnel.
• Healthcare professionals involved in your consultation or treatment.
• Hospitals, clinics, laboratories, or medical service providers where relevant.
• IT, hosting, security, communications, analytics, and website service providers.
• Payment or transaction providers where necessary.
• Professional advisers, including legal and accounting advisers.
• Public authorities or regulators where disclosure is legally required.

Business Transfers

If ClinMedica is involved in a merger, acquisition, reorganization, financing, sale of assets, or similar corporate transaction, personal information may be transferred as part of that transaction in accordance with applicable privacy law.

5. Cookies and Tracking Technologies

We may use cookies, pixels, web beacons, local storage, and similar technologies to operate our website, remember preferences, understand website usage, improve performance, and support marketing activities.

Cookies may be used for purposes including:

• Essential website functionality
• Website security
• Remembering user preferences
• Traffic and performance analysis
• Measuring marketing effectiveness
• Advertising and remarketing, where legally permitted

You may be able to manage your cookie preferences through our cookie consent tool or through your browser settings. Disabling certain cookies may affect the functionality of some parts of the website.

Google Analytics

We may use Google Analytics or similar analytics services to understand how visitors use our website. These services may collect information such as device information, approximate location, pages visited, session duration, and referral sources.

Google may also provide options that allow users to control advertising personalization or opt out of certain Analytics tracking.

For additional information about Google's privacy practices, please review Google's applicable privacy documentation and advertising settings.

6. How Long Do We Keep Your Information?

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including providing healthcare-related services, maintaining appropriate records, resolving disputes, and meeting legal, regulatory, tax, accounting, or reporting obligations.

Retention periods may vary depending on the type of information and applicable legal requirements.

When personal information is no longer required, we will take reasonable steps to delete, anonymize, or securely isolate it, except where continued retention is required or permitted by law.

7. How Do We Protect Your Information?

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure.

Security measures may include access restrictions, account controls, secure systems, staff procedures, and other safeguards appropriate to the sensitivity of the information.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure. You should therefore use appropriate care when submitting personal or sensitive information electronically.

8. Information About Minors

Our website and services are not intended to collect personal information directly from children without appropriate authorization from a parent or legal guardian where required by law.

If we become aware that personal information relating to a minor has been collected in a manner that does not comply with applicable law, we will take reasonable steps to address or delete the information.

Parents or legal guardians who believe that a child has provided information to us improperly may contact us using the details provided below.

9. Your Privacy Rights

Depending on your country, state, province, or region, privacy legislation may provide you with rights regarding your personal information.

These rights may include the right to:

• Request confirmation that we process your personal information.
• Access personal information we hold about you.
• Request correction of inaccurate or incomplete information.
• Request deletion of your personal information.
• Request restriction of certain processing activities.
• Object to certain types of processing.
• Withdraw consent where processing relies on your consent.
• Request data portability where applicable.
• Opt out of certain marketing communications.
• File a complaint with an appropriate data protection authority.

Withdrawing Consent

Where we rely on your consent to process personal information, you may withdraw that consent at any time.

Withdrawal will not generally affect the lawfulness of processing carried out before consent was withdrawn or processing that is permitted under another lawful basis.

Marketing Communications

You may unsubscribe from promotional emails by using the unsubscribe mechanism included in applicable marketing messages or by contacting us.

Even after opting out of marketing, we may continue to send non-promotional communications when necessary for consultations, treatment, transactions, legal notices, or other service-related purposes.

10. Do-Not-Track Controls

Some browsers and devices provide a Do-Not-Track ("DNT") feature or similar privacy preference.

Because there is not always a universally accepted standard for interpreting these signals, our website may not respond to every DNT signal in the same manner.

Where applicable law requires recognition of a legally valid browser-based opt-out preference, we will seek to comply with the relevant legal requirements.

11. United States Privacy Rights

Residents of certain U.S. states may have additional privacy rights under state consumer privacy legislation.

Depending on the law applicable to you, these rights may include:

• The right to know whether we process your personal information.
• The right to request access to personal information.
• The right to request correction or deletion.
• The right to obtain a portable copy of certain information.
• The right to opt out of certain targeted advertising.
• The right to opt out of certain sales or sharing of personal information.
• The right to limit certain uses of sensitive information where applicable.
• The right not to be unlawfully discriminated against for exercising privacy rights.

We may need to verify your identity before completing certain privacy requests. Where permitted by applicable law, an authorized agent may submit a request on your behalf, subject to appropriate verification.

12. Rights in Other Regions

European Economic Area and United Kingdom

Individuals located in the European Economic Area or United Kingdom may have rights under the GDPR or UK GDPR, including access, correction, deletion, restriction, objection, and data portability rights.

You may also have the right to lodge a complaint with the supervisory authority responsible for data protection in your country.

Switzerland

Individuals in Switzerland may have rights under applicable Swiss data protection legislation, including rights relating to access, correction, and other controls over personal information.

Canada

Individuals in Canada may have rights to access and correct personal information and to withdraw consent, subject to limitations and exceptions under applicable federal or provincial privacy law.

Other Countries

If you live in another jurisdiction, additional privacy rights may apply under local law. We will respond to valid privacy requests in accordance with applicable legal requirements.

13. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our services, technology, business practices, legal requirements, or regulatory guidance.

When we update this Privacy Policy, we may revise the "Last updated" date displayed at the top of this page.

Where required by law, we may provide additional notice regarding material changes.

We encourage you to review this page periodically to stay informed about how we handle personal information.

14. How Can You Contact Us?

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of personal information, you may contact ClinMedica using the details below.

15. How Can You Access, Update, or Delete Your Information?

If applicable privacy law gives you the right to access, correct, delete, restrict, or otherwise control your personal information, you may submit a request to us using the contact information provided above.

Please provide enough information for us to identify the relevant records and understand your request. We may need to request additional information to verify your identity and protect your personal information from unauthorized disclosure.

We will review verified requests and respond within the period required by applicable data protection law.

In some circumstances, we may be permitted or required to retain certain information or decline part of a request. If this occurs, we will provide an explanation where required by law.