INFORMATION NOTICE REGARDING THE PROCESSING OF PERSONAL DATA BY L&L DENTAL LUXURY S.R.L.

In accordance with the provisions of the European Regulation no. 679/2016 (hereinafter also referred to as “GDPR”), effective from May 25, 2018, L&L DENTAL LUXURY S.R.L. (“Lucilla Dental Clinic”) has the obligation to process personal data securely, for the general purposes specified in this notice, in the context of providing the medical services you receive within Lucilla Dental Clinic.

1. PREAMBLE

Lucilla Dental Clinic commits to providing an adequate level of GDPR compliance regarding confidentiality, availability, and integrity of personal data related to any data subject through processing activities performed, including our service delivery and marketing actions.

This notice aims to explain how your personal data is processed by Lucilla Dental Clinic.

Personal data (meaning any information that can lead to the direct or indirect identification of a natural person) is detailed in section 6 below, defined according to applicable legal provisions.

For the purposes of this notice, we inform you that Lucilla Dental Clinic is the personal data controller as defined under GDPR.

2. IDENTITY AND CONTACT DETAILS OF THE CONTROLLER

• Name: L & L DENTAL LUXURY S.R.L.
• Registered Office: Snagov, Ilfov County, Șos. Snagov, No. 104
• Tax ID (CUI): 46925226
• Trade Registry Number: J23/6669/2022
• Phone: 0773 882 882
• Email: contact@lucilla.dental

3. CONTACT DETAILS OF THE DATA PROTECTION OFFICER (DPO)

Contact details of the person responsible for data protection (also called “DPO”) at Lucilla Dental Clinic, whom you may contact regarding any issues related to your personal data protection:

• Email: contact@lucilla.dental

4. PURPOSES FOR WHICH YOUR PERSONAL DATA IS PROCESSED

The processing and storage of personal data are done securely and for legitimate purposes mainly related to providing medical services, human resources activities, marketing, advertising, statistics, or scientific purposes. When we request collection, processing, and possible transfer of personal data, usage will only be for the stated purpose; any other purpose will require your consent or you will be informed according to GDPR provisions.

Your personal data (listed in section 6) will be processed for the following purposes:

• Medical services provision: Providing medical services you request, establishing a medical diagnosis, offering medical assistance or treatment, managing health systems and services, recording medical services provided, communication with you about medical services, informing you about services, scheduling appointments, identification of you and accessed services.
• Marketing: Periodic information regarding medical matters, Lucilla Dental Clinic services, promotions, etc. This processing will only occur with your explicit written consent and only as long as you maintain this consent. You may withdraw this consent anytime by clicking the “Unsubscribe” link at the bottom of any email from us or by contacting us at contact@lucilla.dental.
• Medical statistics or scientific purposes: Processing will only occur at the written request of competent state institutions in statistics or scientific research. Your data remain secure and confidential, not disclosed to third parties.
• Legal obligations compliance: Processing to fulfill various legal obligations of Lucilla Dental Clinic (e.g., health, safety, accounting, archive retention, or other legal requirements).
• Service improvement and complaints resolution: Identifying issues or relevant matters regarding existing services to improve them, implement new or improved services, and resolve your complaints.
• Video surveillance: Lucilla Dental Clinic processes personal data through video surveillance means for security of persons and property, guarding assets, without prejudicing fundamental rights and freedoms or your interests. Cameras are visibly placed and signposted; sensitive data such as racial/ethnic origin, political beliefs, health, etc., are not processed; no cameras in private spaces like changing rooms or toilets.
• Financial records: Issuance of financial-accounting documents (e.g., receipts, invoices), collecting payments for services, debt recovery (possibly involving third parties), refunds, sending financial notifications, and preparing financial reports.
• Dispute resolution: Handling requests or opinions in case of disputes related to services provided or the relationship with Lucilla Dental Clinic.
• Audit management: Conducting internal and external audits to verify operational activities.

Lucilla Dental Clinic confirms no automated decision-making (including profiling) based on your personal data and assumes responsibility and ensures security only for personal and special categories of data (health data, genetic data, if applicable) provided and processed exclusively by Lucilla Dental Clinic staff (doctors, nurses) within:

• Lucilla Dental Clinic premises;
• Lucilla Dental Clinic’s IT systems and medical records;
• During working hours at Lucilla Dental Clinic.

Lucilla Dental Clinic is not responsible for any data processing performed outside these coordinates (including exchanges of personal data during conversations between doctors and patients).

5. LEGAL BASIS FOR PERSONAL DATA PROCESSING

The legal bases for processing personal data by Lucilla Dental Clinic are:

• For non-special categories of personal data (according to Article 6 GDPR):
  • To offer or execute a contract with you regarding medical services;
  • For marketing communications based on your explicit consent (via forms filled in clinics or online, events, etc.);
  • For ongoing improvement of medical services based on your prior consent;
  • To comply with legal obligations (archiving, health, security, records, public authority requests);
  • For legitimate interests of Lucilla Dental Clinic or third parties (medical service records, appointment system, complaints, contracts with partners, security surveillance, audit management).
• For special categories of personal data (according to Article 9 GDPR):
  • For establishing medical diagnosis, providing medical assistance or treatment, or managing health systems/services;
  • To protect vital interests in emergency or when you cannot consent;
  • For public health interests under EU or national law;
  • For establishing, exercising, or defending legal claims in court.

6. CATEGORIES OF PERSONAL DATA PROCESSED AND CONSEQUENCES OF REFUSING TO PROVIDE DATA

Personal data processed include:

• Data obtained directly from you in the context of services provided;
• Data/results obtained following medical services provided by Lucilla Dental Clinic.

Personal data you provide during phone scheduling, email, or clinics (name, phone, email, birth date, symptoms, analysis results, personal numeric code, etc.) are recorded and processed only if given voluntarily and after prior information. Lucilla Dental Clinic is not responsible for inaccurate or incorrect data provided by you. You must update your personal data to keep them accurate. Suspicion of falsification may be reported to authorities.

Categories of personal data include:

• Contact data (name, address, phone, email, correspondence address);
• Personal data (birth date, gender, lifestyle, ID details, video recordings from surveillance cameras, signature);
• Medical data (health data related to services, diagnosis, test results, treatment, recommendations, symptoms, medical history, genetic data, dental impressions, imaging, etc.);
• Professional data (employer, occupation);
• Insurance data (insured status, insurer, policy number);
• Payment data (billing details, bank account, payments status);
• Relationship data with Lucilla Dental Clinic (history, suggestions, opinions, including via social media).

You are not obliged to provide all personal data but refusal may limit your access to services (e.g., communication on appointment changes).

If you provide data about third parties (family health info), these will be treated confidentially and used only for service provision.

7. RECIPIENTS OR CATEGORIES OF PERSONAL DATA RECIPIENTS

Generally, your data is processed by Lucilla Dental Clinic. Due to service complexity, group affiliation, or need for external partners, data may be transferred to:

• Partner doctors and accredited medical service providers;
• Judicial, research, supervisory authorities as legally required;
• Other companies in the Lucilla Dental Clinic group;
• Other recipients such as IT support, technical services, marketing, payment, archiving, legal consultants, auditors, financial consultants, or entities in business operations (mergers, acquisitions), under confidentiality agreements.

Lucilla Dental Clinic ensures compliance with GDPR requirements regarding processing by data processors.

8. TRANSFERS TO THIRD COUNTRIES

Your data may be transferred to entities in other EU/EEA countries for specialized analysis or opinions. Transfers are safeguarded by appropriate guarantees, such as standard contractual clauses or EU Commission decisions. You will be informed and asked for consent regarding such transfers.

9. DATA RETENTION PERIOD

Data is stored for the duration of the relationship plus a reasonable time according to legal requirements:

• Between 1 and 30 years (extended retention for medical documents);
• For the lifespan of the medical IT system regarding lab results;
• Accounting-related data retained per legal retention periods (e.g., 5 or 10 years);
• Video surveillance footage kept for a maximum of 30 calendar days unless legally justified otherwise.

10. YOUR RIGHTS REGARDING PERSONAL DATA

You have the following rights:

• Access to your personal data and information about processing;
• Rectification of inaccurate or incomplete data;
• Erasure of data when no longer necessary, if unlawful, or if you object without overriding legitimate interests;
• Restriction of processing under certain conditions;
• Objection to processing for reasons related to your particular situation or direct marketing;
• Withdrawal of consent at any time without affecting prior processing legality;
• Not being subject to solely automated decisions including profiling;
• Data portability under conditions of consent or contract and automated processing;
• Complaint to the National Supervisory Authority for Personal Data Processing and competent courts.

Requests can be made in writing to Lucilla Dental Clinic (Attention: Data Protection Officer) via:

• Email: contact@lucilla.dental
• At Lucilla Dental Clinic locations
• Mail to: L & L DENTAL LUXURY S.R.L., Șos. Snagov, Nr. 104, Snagov, Ilfov

You may specify preferred communication means (email, postal address, etc.).

Responses will be provided within one month, with notifications if delays occur.