Privacy Policy

Confidentiality and security are INSTITUTO CLAVEL core values and we therefore undertake to ensure the User’s privacy at all times and not to gather any unnecessary information. Below we provide all the information necessary regarding our Privacy Policy in relation to the personal data collected, explaining: 

  • Who controls your personal data. 
  • The purpose for which we gather the data requested. 
  • The legal grounds for treatment of your data. 
  • The length of time we store the data. 
  • Who your data may be shared with. 
  • What your rights are. 

 

1. Data controller:

INSTITUTO CLAVEL, S.L.P. (B65134819)  institutoclavel@institutoclavel.com 

INSTITUTO CLAVEL centers (hereinafter, IC, or our Centers): 

 

- Instituto Clavel Barcelona

Hospital QuirónSalud Barcelona 

Plaça d’Alfonso Comín, nº 5 – 7, 08023 Barcelona (SPAIN) 

Ground floor (Consulting rooms 016 – 020)  barcelona@institutoclavel.com 

 

- Instituto Clavel Madrid:  

Hospital San Francisco de Asís 

Calle de Joaquín Costa, nº 28, 28002 Madrid (SPAIN) 

1st floor madrid@institutoclavel.com 

 

- IC Rehabilitation:

Carrer del Rosselló, nº 283, 08037, Barcelona (SPAIN)  

 

Data Protection Officer: 

Lant Abogados (Lant Advisors, S.L.P.) 
Contact details: clavel@delegado-datos.com 

 

2. PURPOSES, LEGAL GROUNDS, AND STORAGE OF THE DATA PROCESSING SENT VIA THE: 
 

CONTACT FORM 

Purposes: 

  1. Depending on the type of consultation you select: 

  1. To provide a means for you to contact us so that we may answer your requests for information; 

  1. To provide a means for you to request an appointment at one of our Centers, process your request, schedule the visit online or in person and confirm the day and time, as well as, where appropriate, send appointment confirmations or reminders, including through electronic means; 

  1. To make a first clinical evaluation of your case to make a diagnosis, register you in our systems, and present our proposal of service, as well as to follow-up, which implies the treatment of health data and data related to your clinical history. 

  1. If you check the Patient Portal box: To create an account and register you as a user of the Patient Portal. 

  1. If you check the box consenting to receipt of commercial and other information: To send you our newsletter and other information and communication, including advertising, about the products, services and activities of INSTITUTO CLAVEL and its foundation (FUNDACIÓN CLAVEL) that are of interest to you, including by electronic means. 

 

Legal grounds: 

  1. a) The USER’s consent indicated by requesting information through our contact form. 

I. b) The USER’s consent indicated by requesting an appointment at one of our Centers through our contact form 

I. c) Compliance with the pre-agreement for care and necessary treatment for purposes of medical diagnosis, provision of care or healthcare treatment to fulfill the request for evaluation of the case, as well as compliance with the Law on Patient Autonomy and Rights and Obligations regarding clinical information and documentation. 

  1. The USER’s consent indicated by marking the Patient Portal box and compliance with the agreement for the person registered in the Patient Portal.  

  1. The USER’s consent indicated by marking the acceptance box for sending of information from INSTITUTO CLAVEL and FUNDACIÓN CLAVEL.  

Storage: 

  1. a) Until the USER’s request submitted by web form has been processed or their email has been answered, if it has not generated a new data treatment. 

  1. b) For the time needed to handle your request for an appointment and until your request has been answered. 

After the appointment, while the evaluation of the case is ongoing and during the legally established deadlines and according to the requirements of the Patient Autonomy Law. 

If the first appointment does not take place, if the person is not a patient of the Center, the data will be deleted after 1 year, if a new data treatment has not been generated. 

I. c) For the duration of the evaluation of the case and/or validity of the care agreement and, in any case, according to the requirements for the conservation of clinical documentation according to the Law regulating patient autonomy and rights and obligations in terms of clinical information and documentation. 

  1. For the duration of time the USER is registered in the Patient Portal for management of data by this electronic means, as long as they do not request elimination from the Portal.  

  1. In the case where the USER has agreed to receive commercial communications from IC and its Foundation, until such time as the USER requests cancellation of the same. 

 

PATIENT PORTAL REGISTRATION FORM AND MANAGEMENT 

Purposes: To create an account and register you as a user of the Patient Portal, send you the access codes to the private area by email, and provide you with access to the space and services reserved for patients registered in our Portal to assess your case and provide the requested health care, as well as managing the exchange of diagnostic tests and medical information, managing your Clinical History and allowing you access to it in digital format, managing the relationship, communication, response to requests and questions by electronic means, and other administrative procedures deriving from the provision of care and, where appropriate, from the surgical procedure and rehabilitation sessions. 

Legal grounds: Fulfillment of the agreement with the person registered in the Patient Portal, attention to the request, and compliance with the pre-agreement for care and/or execution of the contract for the provision of services between the health center and the patient.    

Storage: For as long as the person is registered in the Patient Portal (to manage the relationship through this electronic means) and does not request removal from the Portal. 

If applicable, for the duration of the evaluation of the case and/or validity of the care agreement, and as long as needed to guarantee the provision of healthcare requested by the patient. Once the relationship has ended, for the legally established periods and according to the requirements for the preservation of clinical documentation of the law regulating patient autonomy. 

 

REGISTRATION FORM “JOIN OUR MEDICAL COMMUNITY” 

Purposes: To inscribe you as a registered user and allow you access to the services reserved for people registered on our website, as well as to inform you of our activities, products and services, and send you commercial communications from INSTITUTO CLAVEL and its foundation (FUNDACIÓN CLAVEL) that are of interest to you, including by electronic means. 

Legal grounds: USER’s consent indicated by registering as a member of our community and by marking the acceptance box for sending of information from INSTITUTO CLAVEL and FUNDACIÓN CLAVEL.    

Storage: Until the inscribed user requests their withdrawal and later during the legally established periods. In case the user has have agreed to receive commercial communication, until the user requests their cancellation. 

 

SUBSCRIPTION TO OUR NEWSLETTER 

Purposes: To send you our newsletter, information and advertising regarding products, services and activities of INSTITUTO CLAVEL and its foundation (FUNDACIÓN CLAVEL) which may be of interest to you, including by electronic means. 

Legal grounds: The user’s consent when subscribing to the business communications and/or newsletters of INSTITUTO CLAVEL and its FOUNDATION. 

Recipients: FUNDACIÓN CLAVEL, to inform you of the products, services, and activities of FUNDACIÓN CLAVEL.  

Storage: Until the interested party revokes their consent and requests they be unsubscribed from the service. 

  

SENDING A CURRICULUM VITAE 

Purposes: To have your curriculum so you may participate in current or future personnel selection processes and to check the references presented. 

Legal grounds: The user’s (candidate’s) consent when they send us their personal information and curriculum for our personnel selection processes. 

Storage: Throughout the personnel selection processes and for a maximum of 1 year for future selection processes 

 

QUESTIONS OR REQUESTS FOR INFORMATION SENT BY EMAIL, TELEPHONE OR OTHER ELECTRONIC MEANS. 

Purposes: To provide you with answers to your questions and requests for information. 

Legal grounds: The user’s consent when requesting information via our email address or any other means available. 

Storage:  Until your request or questions have been answered by email or other means, if no new processing has been generated. 
 

APPOINTMENT REQUEST FORMS 

Purposes: To provide you with the means to request an appointment at one of our Centers (by phone, in person, by email, through forms and/or through the hospital), manage your request, schedule the visit (online or in person) and confirm the day and the time, as well as, where appropriate, send appointment confirmations or reminders, including through electronic means. 

Legal grounds: The consent of the user/patient given when requesting an appointment online or in person at one of our Centers. Where applicable, fulfillment of the agreement with the hospital. 

Storage: For the time needed to handle your request for an appointment and until your request has been answered. 

After the appointment, while the evaluation of the case is ongoing and during the legally established deadlines and according to the requirements of the Patient Autonomy Law. 

If the first appointment does not take place, if the person is not a patient of the Center, the data will be deleted after 1 year, if a new data treatment has not been generated. 

 

CALL RECORDING (INCOMING AND OUTGOING) 

The interested party may object to recording of our calls by contacting  clavel@delegado-datos.com 

Purposes: To handle the request and provide the requested assistance, as well as to verify the quality of the service and of the incoming and outgoing calls, and as a guarantee of the requests or other procedures conducted by telephone through our call service desk. 

The recordings will be used internally and only for the time necessary for the indicated purpose. 

Legal grounds: Legitimate interest of the company to verify the quality of the services provided and to monitor quality of care for users and patients, as well as to have a temporary record of requests made by patients. 

Storage:  

  1. Quality checks: maximum of 6 months from the time of recording, except where a longer legal period exists. 

  1. Provision of care, verification of contracts, agreements, claims and complaints: maximum of 5 years to address possible legal responsibilities, except where a longer legal period exists. 


Obligation to provide your personal data and the consequences of failure to do so. 

The supply of personal data requires a minimum age of 14 years, or, if applicable, sufficient legal capacity to enter into a contract. 

The personal data requested are necessary to manage your requests and/or render the services that can be contracted and therefore any failure to do so signifies we cannot attend you correctly nor provide the service requested.  

The personal data requested in order to evaluate your case is necessary to manage your request, so if you do not provide it to us, we will not be able to attend you correctly or provide you with the service or carry out the requested evaluation. Said data treatment is necessary for the purposes of medical diagnosis, provision of care or treatment of a medical nature 
 

3. RECIPIENTS OF THE DATA 

Your data are confidential, will be used solely internally for the purposes described, and will not be transferred to third parties unless legally required, and in the following cases. 

  • Subscription to a newsletter and/or consent to receive business information and advertising: Personal data will be stored in a joint database and will be accessible by INSTITUTO CLAVEL, SLP (B65134819) and FUNDACIÓN CLAVEL (G66109109 - www.fundacionclavel.org/)   for sending the joint corporate newsletter of IC and its Foundation and informative and advertising communications on the products, services and activities of both entities. 
     

4. RIGHTS IN RELATION TO YOUR PERSONAL DATA 

Any person may withdraw their consent at any time after granting it for the processing of their data. Under no circumstance does withdrawal of consent affect the execution of the subscription contract or the relations established previously. 

Likewise, you may also exercise the following rights: 

  • Request access to your personal data or rectification of same when inaccurate. 
  • Request their deletion when, amongst other reasons, they are no longer necessary for the purpose for which they were collected. 
  • Request the limitation of processing in certain circumstances. 
  • Request opposition to the processing of your data due to your particular situation. 
  • Request data portability when so provided in law.  
  • Other rights recognized in applicable law. 

Where and how to exercise your Rights: By writing to the Data Controller at their postal or electronic address, indicating the reference “Personal Data”, specifying the right to be exercised and with regard to which personal data: 

  • Plaça d’Alfonso Comín, 5-7, Pl.0 (Consultation rooms 016 – 020), 08023 Barcelona (Spain) 
  • clavel@delegado-datos.com 

In the event of any dispute with the company with regard to the processing of your data you may lodge a claim with the Data Protection Authority (www.aepd.es). 
 

5. COOKIES 

This webpage uses own and third-party technical, customization, analysis, and advertising cookies which do not process personal data in any case, but capture user browsing habits and/or connection and/or device data for statistical and advertising purposes. 

Therefore, when accessing our website, in compliance with article 22 of the Information Society Services Law, when dealing with the aforementioned cookies, we have requested your consent for their use and provided information about them. 

For more information you can consult our Cookie Policy
 

6. SECURITY OF YOUR PERSONAL DATA 

In order to safeguard the security of your personal data, we inform you that we have adopted all the necessary measures of a technical and organizational nature to ensure the security of your personal data against alteration, loss and non-authorized processing and access. 
 

7. UPDATING YOUR DATA 

In order to maintain your personal data updated, it is important you inform us whenever there have been any changes; otherwise, we cannot be liable for the accuracy of your data. 

We shall not be liable for the privacy policy regarding the personal data you may supply to third parties via the links on our website. 

This Privacy Policy may be modified to adapt it to any changes on our website, as well as for any legal or jurisprudential modifications regarding personal data which may arise. Therefore, we request that you read this policy every time you supply your data through this website. 

 

Consent to the use of cookies.

For our website to function properly we use cookies. To obtain your valid consent for the use and storage of cookies in the browser you use to access our website and to properly document this we use a consent management platform: CookieFirst. This technology is provided by Digital Data Solutions BV, Plantage Middenlaan 42a, 1018 DH, Amsterdam, The Netherlands. Website: https://cookiefirst.com referred to as CookieFirst.

When you access our website, a connection is established with CookieFirst’s server to give us the possibility to obtain valid consent from you to the use of certain cookies. CookieFirst then stores a cookie in your browser in order to be able to activate only those cookies to which you have consented and to properly document this. The data processed is stored until the predefined storage period expires or you request to delete the data. Certain mandatory legal storage periods may apply notwithstanding the aforementioned.

CookieFirst is used to obtain the legally required consent for the use of cookies. The legal basis for this is article 6(1)(c) of the General Data Protection Regulation (GDPR).

Data processing agreement

We have concluded a data processing agreement with CookieFirst. This is a contract required by data protection law, which ensures that data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

Server log files

Our website and CookieFirst automatically collect and store information in so-called server log files, which your browser automatically transmits to us. The following data is collected:

  • Your consent status or the withdrawal of consent
  • Your anonymised IP address
  • Information about your Browser
  • Information about your Device
  • The date and time you have visited our website
  • The webpage url where you saved or updated your consent preferences
  • The approximate location of the user that saved their consent preference
  • A universally unique identifier (UUID) of the website visitor that clicked the cookie banner
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