Privacy policy

What data Hexa Smile collects, why, who we share it with, how long we keep it and how you can exercise your rights.

  • 6 min read
  • 16 sections

Updated on

On this page
  1. 01Who we are
  2. 02What we collect
  3. 03Why we use it
  4. 04Health information
  5. 05Who we share it with
  6. 06HIPAA
  7. 07If you live in the United States
  8. 08If you live in the Dominican Republic
  9. 09If you live in the European Union
  10. 10If you live in Quebec
  11. 11Sending data to other countries
  12. 12How long we keep it
  13. 13Your rights
  14. 14Security and breaches
  15. 15Children
  16. 16Changes

Draft pending legal review. It may change before it is published.

Who we are

Hexa Smile coordinates dental implant treatment with partner clinics in the Dominican Republic. There are two today, the S.O.I. FACE clinic of Dr. Carlos Contreras Columna in Santo Domingo and Asenjo One Visit Dentistry of Dr. Miguel Asenjo in Punta Cana. We run the ads, this website, the WhatsApp chat, the first phone call, scheduling and the check-ins after surgery. The clinics examine you, treat you and bill you.

The company responsible for your data is por confirmar (legal name, country of incorporation and address). For privacy questions, write to por confirmar.

What we collect

When you fill in the 60-second questionnaire or message us, we keep your name, phone number, email, country and your answers.

If you move forward to an evaluation, the clinic or our team may ask for photos of your mouth, x-rays and the list of medicines you take. After surgery we keep your answers to the follow-up messages. All of this is health information, and we handle it with extra care, as explained below.

We also keep a record of your permission to receive messages and calls, with the date, the time and the exact wording you agreed to.

Why we use it

  • To answer you and call you, if you said yes to calls.
  • To see whether it makes sense to set up an evaluation with a doctor. Whether you are a candidate is always the clinic’s decision.
  • To arrange your appointment, your trip and your follow-up.
  • To count how many people come from each ad, without sending health information to the ad network.
  • To comply with the law and respond to legal claims.

We do not sell your data. No system makes decisions about you automatically.

Health information

Photos, x-rays, medicines and follow-up answers are stored encrypted. Only the person on our team or at the clinic who needs them to help you can see them, each with their own login. We do not send them to outside automated analysis services, and we never use them in ads.

Your questionnaire answers may say something about your teeth. That is why we do not share them with the ad network either.

Who we share it with

  • The partner clinic that will evaluate you, so it can care for you.
  • Companies that provide hosting, messaging and phone services to us, under contract and only for that purpose. The list and the country of each one are por confirmar.
  • Meta, which shows our ads on Facebook and Instagram. We only tell Meta that someone filled in the form, without your answers or any health information. Whether that signal includes an encrypted identifier of your email or phone is por confirmar.
  • Authorities, when the law requires it.

The clinics may pay Hexa Smile for coordination. The exact wording of this point is por confirmar.

HIPAA

HIPAA is the US federal law that protects health information held by certain health care providers and health plans, and by the companies that work for them. Our partner clinics are outside the United States. Whether HIPAA applies to Hexa Smile or to the clinics has not been determined yet por confirmar. So we do not claim to be HIPAA compliant. What we do is protect your health information as this page describes.

If you live in the United States

Several state laws protect your data. In Florida, section 501.171 of the Florida Statutes requires anyone who keeps personal information, including medical information, to take reasonable measures to protect it and to notify you of a breach. The Florida Digital Bill of Rights covers businesses with more than one billion dollars in yearly revenue, under the definition in section 501.702, so it does not reach us today. Whether other parts of that law still apply is por confirmar.

If you live in New York, New Jersey, Massachusetts, Pennsylvania or Connecticut, your rights depend on your state’s law. Which ones apply to Hexa Smile, given its size and the kind of data, is por confirmar. You can still send us any of the requests listed under your rights and we will answer.

If you live in the Dominican Republic

We handle your data under Law 172-13. For your health information we ask for express written consent, which you can give in the form or in the chat. You can ask for access to your data, a correction or deletion.

If you live in the European Union

If you are in France or another EU country, the General Data Protection Regulation applies. We use your contact details to answer you and arrange your appointment, and your health information only with your explicit consent. You can withdraw that consent at any time. You have the right to access, correct, erase and restrict your data, to object, and to take a copy with you. You can also complain to the data protection authority in your country, which in France is the CNIL. Our representative in the EU is por confirmar.

If you live in Quebec

Quebec’s law on the protection of personal information in the private sector applies, as amended by Law 25. The person in charge of protecting your information at Hexa Smile is por confirmar. You can ask for access and correction, and for a copy of your data in a commonly used format. Before your data leaves Quebec we carry out a privacy impact assessment. You can complain to the Commission d’accès à l’information.

Sending data to other countries

Your data may be stored in a country other than yours por confirmar, and the clinic receives it in the Dominican Republic. Where the law requires it, we do this with your consent or under a contract that protects your data.

How long we keep it

  • Contact details of people who did not move forward, por confirmar.
  • Health and follow-up information of patients, por confirmar, depending on what Dominican law requires of the clinic.
  • The record of your permission for messages and calls, por confirmar.

When the period ends, we delete the data or make it unreadable.

Your rights

You can ask to see your data, correct it, delete it, get a copy or stop receiving messages. Write to por confirmar. We answer within por confirmar days. Before we hand over any data, we check that you are who you say you are.

Security and breaches

We encrypt health information and limit who can see it. If a breach affects you, we will tell you within the time required by the law where you live.

Children

This website is for adults. We do not knowingly collect data from anyone under 18.

Changes

If we change this policy, we put the new date at the top and let you know when the change matters.

Sources

  1. 01Dominican Republic Law 172-13 on personal data protection (copy published by the Superintendencia de Bancos)sb.gob.do
  2. 02Florida Statutes 501.171, security of confidential personal informationflsenate.gov
  3. 03Florida Statutes 501.702, Florida Digital Bill of Rights definitionsflsenate.gov
  4. 04Regulation (EU) 2016/679, General Data Protection Regulationeur-lex.europa.eu
  5. 05Commission d'accès à l'information du Québec, main changes under Law 25cai.gouv.qc.ca

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