PRIVACY POLICY AND DATA PROTECTION

In compliance with applicable legislation, Marina Bejenar, Precision and Integrative Medicine (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy complies with current Spanish and European regulations on the protection of personal data online. Specifically, it adheres to the following standards:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
• Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD) — Spanish legislation applicable to processing activities carried out in Spain.
• Royal Decree 1720/2007 of 21 December, approving the Regulation implementing Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).
• Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller for personal data collected by Dr. Marina Bejenar, Precision and Integrative Medicine is: Dr. Marina Bejenar (hereinafter, the Data Controller). Contact details are as follows:

Address: Calle Inocencio Rodríguez Guanche nr. 8, Puerta 38, 38350 Tacoronte, Santa Cruz de Tenerife

Contact telephone: +34 922 200 079

Contact email: administracion@medicosantiagomarrero.com

Registration of personal data

In accordance with the GDPR and the Spanish Data Protection Act (LOPD-GDD), we inform you that the personal data collected by Dr. Marina Bejenar, Precision and Integrative Medicine through the forms on its website will be incorporated into and processed in our records in order to facilitate, expedite and fulfil the commitments established between Dr. Marina Bejenar, Precision and Integrative Medicine and the User, or to maintain the relationship established through the forms completed by the User, or to respond to a request or query from the User.

Furthermore, in accordance with the GDPR and the LOPD-GDD, unless the exception provided for in Article 30(5) of the GDPR applies, a record of processing activities is maintained, specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

1. Principles applicable to the processing of personal data

The processing of the User's personal data shall be subject to the following principles set out in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User's consent will be required at all times, following completely transparent information about the purposes for which personal data are collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
• Principle of data minimisation: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and kept up to date.
• Principle of storage limitation: personal data will be kept in a form that permits identification of the User for no longer than is necessary for the purposes for which the personal data are processed.
• Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
• Principle of accountability: the Data Controller will be responsible for ensuring compliance with the above principles.

2. Categories of personal data

The categories of data processed at Dr. Marina Bejenar, Precision and Integrative Medicine include both identification data (name, surname, contact details) and special categories of personal data within the meaning of Article 9 of the GDPR, in particular health data, collected in the context of the provision of medical services.

Special categories of personal data include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

For the processing of special categories of personal data, the User's explicit consent will be required in all cases for one or more specific purposes.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Marina Bejenar, Precision and Integrative Medicine undertakes to obtain the User's express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. Withdrawal of consent shall be as easy as giving it. As a general rule, withdrawal of consent will not affect use of the Website.

Where the User must or may provide their data through forms in order to make enquiries, request information or for reasons related to the content of the Website, they will be informed if completion of any of these is mandatory, as it is essential for the correct execution of the operation performed.

4. Purposes for which personal data are processed

Personal data are collected and managed by Marina Bejenar, Precision and Integrative Medicine in order to facilitate, expedite and fulfil the commitments established between the Site and the User, or to maintain the relationship established in the forms completed by the User, or to respond to a request or query from the User.

Data may also be used for commercial purposes such as personalisation, operational and statistical analysis, and activities related to the corporate purpose of Marina Bejenar, Precision and Integrative Medicine, as well as for data extraction, storage and marketing studies to adapt the content offered to the User and to improve the quality, performance and navigation of the Website.

At the time personal data are obtained, the User will be informed of the specific purpose or purposes for which the personal data will be processed; that is, the use or uses to which the information collected will be put.

5. Personal data retention periods

Personal data will be retained only for the minimum period necessary for their processing and, in any event, only for the following period: 1 year, or until the User requests their deletion.

At the time personal data are obtained, the User will be informed of the period for which personal data will be stored or, where that is not possible, the criteria used to determine that period.

6. Recipients of personal data

The User's personal data will not be shared with third parties.

In any event, at the time personal data are obtained, the User will be informed of the recipients or categories of recipients of the personal data.

Where the Data Controller intends to transfer personal data to a third country or international organisation, the User will be informed at the time personal data are obtained of the third country or international organisation to which the data are intended to be transferred, and of the existence or absence of an adequacy decision by the Commission.

7. Personal data of minors

In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights, only persons aged 14 and over may lawfully consent to the processing of their personal data by Marina Bejenar, Precision and Integrative Medicine. For persons under the age of 14, the consent of their parents or guardians will be required for processing, and such processing will be considered lawful only to the extent that parents or guardians have authorised it.

8. Confidentiality and security of personal data

Marina Bejenar, Precision and Integrative Medicine undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and prevent their accidental or unlawful destruction, loss or alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.

However, since Marina Bejenar, Precision and Integrative Medicine cannot guarantee the impenetrability of the internet or the complete absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach is defined as a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Personal data will be treated with confidentiality by the Data Controller, who undertakes to inform and guarantee by means of a legal or contractual obligation that such confidentiality is respected by their employees, associates and any person to whom the information is made accessible.

9. Rights arising from the processing of personal data

The User has rights against Marina Bejenar, Precision and Integrative Medicine and may therefore exercise the following rights against the Data Controller, as recognised in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights:

Right of access: This is the User's right to obtain confirmation as to whether or not Marina Bejenar, Precision and Integrative Medicine is processing their personal data and, if so, to obtain information about their specific personal data and the processing carried out or being carried out by Dr. Marina Bejenar, Precision and Integrative Medicine, including, among other things, information available on the origin of those data and the recipients of communications made or planned.

Right to rectification: This is the User's right to request the modification of their personal data that are inaccurate or, taking into account the purposes of the processing, incomplete.

Right to erasure ("the right to be forgotten"): This is the User's right, unless applicable legislation provides otherwise, to obtain the erasure of their personal data where they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there are no other legitimate grounds to continue it; the personal data have been unlawfully processed; the personal data must be erased for compliance with a legal obligation; or the personal data were obtained as a result of a direct offer of information society services to a child under 14 years of age.

Right to restriction of processing: This is the User's right to restrict the processing of their personal data. The User is entitled to obtain restriction of processing where they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs them for the establishment, exercise or defence of legal claims; and where the User has objected to processing.

Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format and to transmit those data to another controller. Where technically feasible, the Data Controller will transmit the data directly to that other controller.

Right to object: This is the User's right to prevent the processing of their personal data or to request the cessation of such processing by Dr. Marina Bejenar, Precision and Integrative Medicine.

Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless applicable legislation provides otherwise.

The User may therefore exercise their rights by sending a written communication to the Data Controller with the reference "GDPR - https://marinabejenar.com", specifying:

• The User's name and surname and a copy of their national identity document.
• Request with the specific reasons for the application or the information to which access is sought.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document evidencing the request made.

This request and any other attached documents may be sent to the following address and/or email:

Postal address: Calle Inocencio Rodríguez Guanche nr.8, Puerta 38, 38350 Tacoronte, Santa Cruz de Tenerife

Email: administracion@medicosantiagomarrero.com

10. Virtual assistant (Chat AI)

Our Website includes a virtual assistant powered by a third-party artificial intelligence service (OpenAI, L.L.C., USA). Messages you send through the chat may be processed on OpenAI servers located in the United States of America, constituting an international transfer of data pursuant to Art. 46 of the GDPR, covered by the Standard Contractual Clauses adopted by the European Commission.

Please do not transmit sensitive medical data, detailed personal data or confidential information through the chat. Conversations are not permanently stored on our servers. For further information, please consult the OpenAI privacy policy.

11. Reviews section

Our Website includes a reviews section where users may leave ratings and comments regarding medical services. Data provided in this context (name, review text) are collected on the basis of the user's explicit consent and are stored on our servers. The User may request deletion of their review at any time by contacting us at the email address indicated in the contact section.

12. Blog

Our Website includes a blog with medical information articles. Visiting blog pages does not entail the collection of personal data beyond those mentioned in the cookies section (technical session data). No identifying data of blog readers are collected.

13. Links to third-party websites

The Website may include hyperlinks or links that allow access to websites of third parties other than Dr. Marina Bejenar, Precision and Integrative Medicine, and which are therefore not operated by Dr. Marina Bejenar, Precision and Integrative Medicine. The owners of those websites will have their own data protection policies and will themselves be responsible, in each case, for their own files and their own privacy practices.

14. Complaints to the supervisory authority

Where the User considers that there is a problem or infringement of the applicable regulations concerning the processing of their personal data, they have the right to an effective judicial remedy and to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).