INSTITUTO CLAVEL, S.L.P., with CIF B65134819 and registered office at Plaza Alfonso Comín, 5-7 (Consultations 016-020, Main Floor) 08023 Barcelona (SPAIN), and registered in the Barcelona Mercantile Registry, Volume 41434, Folio 101, Sheet B 384792, Entry No. 1 (hereinafter, INSTITUTO CLAVEL), is responsible for this platform (hereinafter, the Platform or the Patient Portal).

This Platform is operated by CONSULTORÍA INFORMÁTICA Y ELECTRÓNICA ISALUS, S.L. (hereinafter, iSalus), which acts as the provider and data processor of INSTITUTO CLAVEL and, under no circumstances, will process the data for its own purposes.

For any questions or suggestions, please contact us by calling +34 936 09 07 77 or by email at institutoclavel@institutoclavel.com.

We also have a Data Protection Officer at your disposal who will not only oversee all data processing carried out by our entity but will also be able to assist you with any questions related to the processing of your personal data. The contact details for our Data Protection Officer are: Lant Abogados (Lant Advisors, S.L.P.) – clavel@delegado-datos.com.

This platform is governed by the regulations exclusively applicable in Spain, and both Spanish and foreign users are subject to them.

Access to the Platform by those interested in making an appointment at one of our centers (Potential Patients) and/or previously registered INSTITUTO CLAVEL patients (Patients) (hereinafter, jointly and indistinctly, Users) is free of charge, and its use is governed by the terms of use in force at the time of access, which we ask you to read carefully. If Users do not agree with these terms of use, they should refrain from using this Patient Portal and operating through it. They may contact us to resolve any questions regarding them.

The provision of personal data through the Platform requires a minimum age of 16 years or, where applicable, sufficient legal capacity to enter into a contract.

At any time, we may modify the presentation and configuration of the Platform, expand or reduce services, and even remove it from the Network, as well as the services and content provided.

A. INTELLECTUAL PROPERTY

All content, text, images, and source code are the property of INSTITUTO CLAVEL, iSalus, or third parties from whom their exploitation rights have been acquired, and are protected by intellectual and industrial property rights.

Users are only entitled to private use of these materials within the scope of the contracted healthcare provision and the management of the relationship with INSTITUTO CLAVEL. They are prohibited from using them for commercial or profit-making purposes, and require express authorization to modify, reproduce, exploit, distribute, or exercise any right belonging to the owner.

INSTITUTO CLAVEL, S.L.P. is a registered trademark, and any reproduction, imitation, use, or insertion of this trademark without our due authorization is prohibited.

The establishment of links to the Platform does not confer any rights over it. Furthermore, the mere fact of establishing a link to the Platform does not entitle you to become a collaborator or partner.

Any imitation, whether total or partial, of the Platform or the establishment of links to the Portal without prior authorization from INSTITUTO CLAVEL and iSalus is strictly prohibited.

B. CONDITIONS OF ACCESS AND USE

Access to and use of the Platform is free. However, to access the features and services offered therein, Users must register on the Portal, either in person at one of our centers or by contacting us by phone, or by registering directly using the form available on our website.

Consequently, access to the Platform's content and the services offered therein is restricted to previously registered individuals, and their subsequent identification and authentication is restricted to their personal access codes (username and password), which may be individual for a single profile or combined for several associated profiles.

Furthermore, the Platform's features and services will be available only under the conditions described below in these clauses for Potential Patients, Patients, or, where applicable, those holding parental authority over said Patients (Authorized Persons) or persons expressly authorized by Patients to access and manage their profile (Authorized Persons).

By registering for the Platform or submitting personal data through the registration form on our website (www.institutoclavel.com), Users expressly accept our Privacy Policy.

All Users must access and use the Platform and all its services and features in accordance with good faith, public order regulations, current legislation, and these Terms of Use, without violating current laws or infringing the rights of third parties.

Users accessing the Platform have the right to private use of the Patient Portal's documentation and services and, where applicable, must provide proof of authorization or express authorization to operate through it on behalf of Patients, as well as to exercise any rights belonging to its owner. Access to and use of the Platform is carried out under the sole and exclusive responsibility of Users, who will be liable for any damages this may cause to third parties or to us.

Users are expressly prohibited from using and obtaining the services and content offered on the Platform through procedures other than those stipulated in these terms of use.

Users are prohibited from any type of action on the Portal that causes excessive overload to our computer systems, as well as from introducing viruses, installing bots, or software that disrupts the normal operation of the Platform or, ultimately, may cause damage to our computer systems.

INSTITUTO CLAVEL reserves the right to terminate Users who the organization believes have violated the conditions governing the use of the Platform. It also reserves the right to take appropriate legal action against those who violate these general terms of use.

User Profiles and assignment of associated profiles

Patients can have an individual profile to access their own information and procedures (Individual Profile), or, through the same profile and with the same access keys, also access the profiles of other Patients (Associated Profiles).

Access to Associated Profiles and the ability to operate jointly through the Portal by accessing a single profile must be requested and processed directly at one of INSTITUO CLAVEL's centers, providing proof of eligibility or after the interested party signs the corresponding authorization.

Specifically, access to Associated Profiles may be enabled or authorized in the following cases:

• Qualified persons:: Holders of parental authority over minor patients.
• Authorized persons: Persons expressly authorized by Patients to access and operate through the Patient Portal on their behalf, upon prior signature of the corresponding authorization by the interested party and accreditation of this fact before INSTITUTO CLAVEL.

In any case, to access the Patient Portal, a prior registration process must have been completed and, where applicable, the status of an authorized or qualified person must have been duly requested and/or accredited. Users must also be identified using access codes (username and password).

C. PRIVACY POLICY

1. Purposes: Register the interested party as a user of our Portal, create an account, and send the access keys to the private area by email.

Once you have completed your registration and are registered as a user, we will facilitate access to the Portal and reserved services, as well as manage your relationship, communications, and respond to requests, queries, and other administrative procedures electronically, according to your profile: 

• Potential patients: Provide you with a means to request an appointment at one of our Centers, manage your request, schedule an initial visit at the selected INSTITUTO CLAVEL center, as well as send appointment confirmations or reminders, including via electronic means.
• Patients:  Provide a means to request appointments and manage appointment schedules, as well as exchange reports, diagnostic tests, and medical information, allowing access to them in digital format, managing the relationship, and managing the requested care.

IMPORTANT: Authorized or authorized persons to access Patient Profiles, as well as Users with access to associated Profiles, may operate and carry out procedures under the same conditions as Patients.

2. Legitimation: Consent of the data subject and compliance with the agreement with the person registered in the Patient Portal. Processing requests and fulfilling the pre-agreement for care and/or executing the service provision contract between the healthcare center and its patients.

Where applicable, compliance with the authorization issued by the interested party (the Patient) in favor of a person authorized to access and/or manage their profile.

3. Recipients of your data: The transfer of data to third parties is not planned, except as provided for by law.
4. Conservation:  For the duration of the relationship and the individual is registered in the Patient Portal and/or enabled or authorized to access it, and no deregistration is requested. Once the relationship has ended, for the legally established timeframes to address potential liabilities.

• Potential patients: If you miss your first appointment, your data will be deleted after one year if no new treatment has been generated.
• Patients: During the term of the healthcare agreement and as long as necessary to guarantee the provision of healthcare requested by the patient.

Once the relationship has ended, for the legally established periods and in accordance with the clinical documentation retention requirements of the Law Regulating Patient Autonomy.

5. Rights in relation to your personal data

Every person has the right to withdraw their consent at any time, once it has been granted for the processing of their data. Under no circumstances does the withdrawal of this consent affect the execution of the subscription contract or any previously established relationships.

You may also exercise your rights of access, rectification, erasure, portability, restriction of processing, and objection by contacting clavel@delegado-datos.com. In the event of a dispute, you may file a complaint with the Data Protection Agency (www.aepd.es).

6. Security of your personal data

In order to safeguard the security of your personal data, we inform you that we have adopted all necessary technical and organizational measures to guarantee the security of the personal data provided against alteration, loss, and unauthorized processing or access.

7. Updating your data

It is important that you inform us whenever there has been any change in your personal information so that we can keep it up to date. Otherwise, we cannot be held responsible for its accuracy.

We are not responsible for the privacy policy regarding personal data you may provide to third parties through the links available on our website.

D. COOKIES

This platform only uses technical and session customization cookies. These cookies do not process personal data or collect browsing habits for statistical or advertising purposes. Therefore, pursuant to Article 22 of the Information Society Services Act, your consent is not required for their temporary installation during your browsing session.

E. RESPONSIBILITIES

By making this Platform available to Users, we aim to offer a quality service, using the utmost diligence in providing the service and in using the technological means employed. However, INSTITUTO CLAVEL does not guarantee that the service will be continuously and uninterruptedly available due to circumstances arising from internet network problems, computer device failures, or other unforeseen circumstances. Users therefore agree to tolerate these circumstances, within reasonable limits.

Everything related to the Platform is governed exclusively by Spanish law. In the event of any discrepancy or dispute between the parties regarding the interpretation and content of this Platform, all parties submit to the corresponding courts and tribunals.

F. VALIDITY OF THE GENERAL CONDITIONS OF ACCESS

This Privacy Policy and Terms of Use were modified on May 19, 2023. We may modify them at any time to adapt them to changes occurring on the Platform, as well as legislative or jurisprudential modifications regarding personal data that may arise. Therefore, please check the issue date each time you log in to the Platform to ensure that no changes have been made that affect you.