Privacy Policy

Privacy Policy and Personal Data Processing Policy, under Colombian Law 1581 of 2012 and Decree 1377 of 2013.

1.Data Controller

The party responsible for processing your personal data (data controller) is [LEGAL NAME OF THE CLINIC], NIT [NIT / TAX ID], operating as Smiles by Julia Molina, with legal address at [LEGAL ADDRESS].

  • Privacy email: [PRIVACY CONTACT EMAIL]
  • WhatsApp: +57 316 824 7619
  • Clinics: Cl. 9 #48-81, Cali, Valle del Cauca · Cerritos Mall, Torre Medical Center, Piso 8, Consultorio 806A, Pereira

This policy is issued in compliance with Colombian Statutory Law 1581 of 2012, Decree 1377 of 2013 (compiled in Decree 1074 of 2015) and other applicable regulations.

2.Data We Collect

  • Identification and contact data: name, phone or WhatsApp number, email, country and city of residence.
  • Data you provide in the booking form and messages: treatment of interest, preferred dates, questions and comments.
  • Health data and images: photos of your smile and face, medical and dental history, X-rays, scans and clinical records.
  • Travel data needed to coordinate your visit: flight details, arrival dates and lodging preferences.
  • Payment data: transaction records. Card data is processed by the payment provider, not stored by us.
  • Browsing data: device, browser, pages visited and interactions, collected through cookies and similar technologies such as the Meta Pixel.

3.Purposes of Processing

We process your personal data for the following purposes:

  • Responding to your requests and providing the free virtual consultation.
  • Evaluating your case, preparing treatment plans and quotes, and providing dental care.
  • Creating and keeping your clinical record as required by Colombian health regulations.
  • Scheduling appointments, sending reminders and doing clinical follow-up and check-ups.
  • Coordinating dental tourism plans: airport pickup and drop-off, transportation, lodging, meals and, depending on the plan, tours.
  • Billing, payments and accounting and tax obligations.
  • Handling warranty requests, inquiries and claims.
  • With your separate prior authorization: publishing before and after photos, videos or testimonials.
  • With your consent: sending news, promotions and satisfaction surveys, and measuring the performance of our advertising.
  • Complying with legal obligations and requests from competent authorities.

4.Sensitive Data: Health Information and Photos

Health data, clinical records and photos or images of patients are sensitive data under Colombian law. We process them only with your prior, express and informed authorization, and only for the purposes described in this policy.

Providing sensitive data is optional: you are not required to authorize the processing of sensitive data or to answer questions about it. However, some of this information (for example, your medical history or photos) is necessary to evaluate your case and treat you safely, so without it we may not be able to provide certain services.

5.Your Rights as Data Subject

Under Article 8 of Law 1581 of 2012, you have the right to:

  • Know, update and rectify your personal data.
  • Request proof of the authorization you granted.
  • Be informed, upon request, about how your data has been used.
  • File complaints with the Superintendencia de Industria y Comercio (SIC) for violations of data protection law, after first contacting us.
  • Revoke your authorization and request deletion of your data when there is no legal or contractual duty to keep it.
  • Access your personal data free of charge.

6.Procedure for Queries and Claims

You, your successors or your authorized representative can submit requests by email to [PRIVACY CONTACT EMAIL] or via WhatsApp at +57 316 824 7619. Include your full name, contact details, a description of your request and any supporting documents.

Queries

Queries to know what data we hold about you will be answered within a maximum of ten (10) business days from receipt. If that is not possible, we will tell you why and answer within the following five (5) business days.

Claims

Claims to correct, update or delete data, or to report a breach, will be answered within a maximum of fifteen (15) business days from the day after receipt. If that is not possible, we will tell you why and answer within the following eight (8) business days. If the claim is incomplete, we will ask you to complete it within five (5) days; if you do not do so within two (2) months, the claim will be considered withdrawn.

7.International Transfer and Transmission of Data

Some providers we use to operate store or process data outside Colombia, including in the United States. This includes WhatsApp and Meta Platforms (messaging and advertising measurement), our website hosting provider [HOSTING PROVIDER], email and cloud storage tools, and the SMS service provider. By accepting this policy, you authorize this international transmission and transfer, which we carry out only with providers that offer adequate data protection levels or under contracts that protect your information.

When you submit our booking form, the information is sent to WhatsApp so our team can contact you. WhatsApp's own privacy policy also applies to communications on that platform.

8.Minors

Our website and services are aimed at adults. The data of children and adolescents is processed only with the authorization of their parents or legal guardians, respecting their best interests and fundamental rights, as required by Colombian law.

9.Security

We apply reasonable administrative, technical and physical measures to protect your data against loss, misuse, unauthorized access, alteration or destruction, including restricted access to clinical records and confidentiality commitments with staff and providers. No system is completely secure, so we cannot guarantee absolute security.

10.Data Retention

Clinical records, X-rays and other health data are kept for the period required by Colombian health regulations, even if you request deletion, because the law requires us to preserve them. Other personal data is kept while it is needed for the purposes described, and for [RETENTION PERIOD FOR NON-CLINICAL DATA], or for longer when required by legal, accounting or tax obligations.

11.Information for Visitors from the United States

Many of our patients travel from the United States. This section summarizes how we handle their information.

Categories collected and how we use them

We collect identifiers (name, phone, email), information you send us (messages, photos, medical history), travel details and internet activity (pages visited, interactions with our website). We use them to respond to you, provide the virtual consultation and treatment, coordinate your trip and measure our advertising, as described above.

No sale of personal information

We do not sell your personal information. We do not share your health information or photos for third-party advertising.

Cookies and Meta Pixel

Our website uses the Meta Pixel, a tool from Meta Platforms, Inc., to measure the effectiveness of our ads and show relevant ads to people who visited our site. The pixel may collect information such as pages visited, browser and device data and actions on the site. We also use your browser's local storage to remember your language preference. You can opt out or limit this by:

  • Blocking or deleting cookies and site data in your browser settings.
  • Adjusting your ad preferences in your Facebook or Instagram account settings (Accounts Center, Ad preferences).
  • Using industry opt-out tools such as the Digital Advertising Alliance (optout.aboutads.info).

Do Not Track

There is no common industry standard for Do Not Track browser signals, so our website does not currently respond to them. You can use the options above to limit tracking.

California residents

If you are a California resident, you may request to know what personal information we have collected about you and request its deletion, subject to legal exceptions (such as clinical records we must keep). We will not discriminate against you for exercising these rights. Send your request to [PRIVACY CONTACT EMAIL].

Note about HIPAA

Smiles by Julia Molina is located in Colombia and provides its services in Colombia. It is not a covered entity under the United States Health Insurance Portability and Accountability Act (HIPAA), and HIPAA does not apply to it. Even so, we treat your health information as confidential and protect it under Colombian health and data protection laws, with a level of care comparable to that expected by patients in the United States.

12.Text Messages (SMS)

If you opt in to receive text messages from us, your mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. See our SMS Privacy Policy and our SMS Terms and Conditions for details.

13.Validity and Changes

This policy is effective from [EFFECTIVE DATE]. Your data will be processed for as long as necessary for the purposes described and in accordance with the retention rules above. Substantial changes to this policy will be communicated through this website and, when required, we will request a new authorization.

14.Contact

[LEGAL NAME OF THE CLINIC] · NIT [NIT / TAX ID] · operating as Smiles by Julia Molina.

  • Legal address: [LEGAL ADDRESS]
  • Cali clinic: Cl. 9 #48-81, Cali, Valle del Cauca, Colombia
  • Pereira clinic: Cerritos Mall, Torre Medical Center, Piso 8, Consultorio 806A, Pereira, Colombia
  • WhatsApp: +57 316 824 7619
  • Email: [PRIVACY CONTACT EMAIL]
  • Website: drajuliamolina.com

Effective date: [EFFECTIVE DATE] · Last updated: [EFFECTIVE DATE]