1. Mission and Commitment

The purpose of this policy is to define the general principles and rules to be applied by Startwell to the Personal Data it collects, taking into account the applicable norms, standards and legal requirements, and a specific, explicit and informed notification about the processing of your data, allowing the application of the legislation in force on Personal Data.

• Startwell ensures proper management of Personal Data in accordance with the applicable standards and legislation. It therefore develops tools and implements actions to guarantee and monitor the effectiveness of Personal Data protection.
• Startwell has several internal policies and procedures that raise awareness among its employees about the importance of protecting Personal Data, providing them with operational guidance on how to comply with Data Protection legislation and monitor Personal Data protection compliance.
• Startwell establishes in this document a Privacy Notice to the holders of Personal Data that complies with the requirements of the legislation in force and guarantees specific, explicit and informed notification to the Holders about the processing of their data. The responsibilities for notifying leaks of Personal Data to the competent Supervisory Authorities are also defined.
• Startwell has a training/communication program that raises awareness among its employees.
  Startwell has a Personal Data Protection Officer responsible for ensuring compliance with personal data protection rules.

2. General principles

Startwell collects and processes Personal Data in accordance with the following principles:

• Personal Data is processed legally, impartially and transparently (lawfulness, impartiality and transparency);
• Personal Data is collected and processed for specific, explicit and legitimate purposes arising from the legislation in force and is not further processed in a manner incompatible with those purposes (purpose limitation principle);
• Personal Data is kept adequate, relevant and limited to what is necessary taking into account the purposes for which it is processed (data minimization principle).
• Personal Data is accurate and, where necessary, rectified and updated (principle of accuracy).

Startwell defines appropriate technical and organizational security measures to effectively implement the principles of Personal Data protection, complying with current legislation and protecting the rights and freedoms of Data Subjects.
Startwell imposes the same level of Personal Data protection on all its Processors (service providers, suppliers, partners, etc.) through contracts.

3. Collection and Processing of Personal Data

Why and how Personal Data is collected

When you visit our website, you may provide us with your Personal Data.
In this context, Startwell is likely to collect your Personal Data through the following means:

• When you browse our website (i.e. technical information such as IP addresses or logs collected through cookies or similar technologies);
• When you contact customer service or click on contact us (complaints, suggestions or information) or through the “Chat with us” chat;
• When you establish a relationship with us in the context of providing services at our clinic;
• When you subscribe to the newsletter provided by Startwell;
• When you participate in a contest, marketing program, test or survey;
• When you apply for a job in the recruitment section in the contact us section;
• When you post comments or images on our social media pages; or
• When you otherwise send us personal information. The information collected in this context may be processed for the purposes of the relationship between Startwell and the Data Subject, in compliance with regulatory and/or legal obligations, to protect and defend the rights, interests, property and safety of StarWell, its employees or other persons with whom it collaborates.

Legal basis for data processing

The data processing operations carried out by Startwell with regard to customers’ Personal Data are based on:

• In its legitimate interest in carrying out its services, protecting its activities, better knowing the preferences of its customers in order to personalize offers and highlight articles, products and/or services that best correspond to the needs and desires of its customers;
• The need to execute the contracts entered into with its clients for the provision of services; and
• When data processing is required by applicable laws.

Startwell also has a legitimate interest in carrying out recruitment operations to manage its activities in the best possible way. In this regard, Startwell collects all necessary data about interested candidates.

Startwell only collects and processes Personal Data if, inter alia:

• You have given consent to the Processing of your Personal Data for one or more specific purposes (where required); or
• The data processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract; or
• The data processing is necessary for compliance with a legal obligation to which Startwell is subject; or
  Processing is necessary for the purposes of Starwell’s legitimate interests unless those interests are overridden by the interests or fundamental rights and freedoms of the Data Subject, which requires the protection of Personal Data, especially if the Data Subject is a child.

The personal data collected at the clinic, including those directly or indirectly related to your health, will be processed by StartWell for the provision of medical-dental services, namely for medical diagnosis and the provision of health care or treatment appropriate to your needs and audit, as well as for the management of administrative services, namely for scheduling appointments and complementary means of diagnosis or billing.

Data relating to your health will only be processed by professionals bound by confidentiality and to the extent necessary for the provision of health care. If you want the services provided by Startwell to be reimbursed by your insurance or health subsystem, the health data related to such services may be communicated to the insurance company and subsystem of which you are a beneficiary, which are also bound by confidentiality.

What is the Personal Data Retention Period?

Startwell keeps Personal Data in accordance with the retention periods imposed by the legislation in force, in particular taking into account its activities, never keeping Personal Data longer than is necessary in accordance with the purposes for which it was collected and is being processed, for: compliance with legal obligations (e.g. auditing, accounting and tax obligations), resolution of legal disputes and/or exercise of its legal rights. Circumstances may vary depending on the context and type of Personal Data.
The personal data necessary for the provision of medical and dental services will be kept in accordance with the legislation applicable to the archiving of hospital documentation and for the periods defined therein (Portaria 247/2000, de 8 de Maio, alterada pela Portaria nº 157/2014 de 19 de Agosto).

How Personal Data is shared

Startwell guarantees that:

• Personal Data is not provided to third parties without the prior consent of its owners;
• Personal data is not sold or provided free of charge to companies that use it for direct marketing purposes or to other entities that use mailing lists to advertise products and/or services;
• It transfers Personal Data to third parties when it receives the request from a judicial authority or public authority with legal powers to do so, in accordance with the legal rules in force.
  Ensures the confidentiality and security of Personal Data during transfer to the aforementioned recipients.

4. Security Measures

Startwell has all the appropriate technical and organizational measures in place to ensure a level of security of Personal Data appropriate to the risk and, in particular, to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.
The same level of protection is contractually imposed by Startwell on its Processors.
Any Startwell employee who, in the course of their work, has access to Personal Data agrees to keep it in the strictest confidence within the framework of the confidentiality agreements signed.

5. Right to access, rectify, update and delete data

In accordance with the applicable rules on the protection of Personal Data, if they so request, Data Subjects may exercise their right to obtain access to, rectify, delete and transfer their Personal Data and also to restrict and object to the Processing of their Personal Data.
When data processing is based on the authorization of the Data Subject, they have the right to withdraw their authorization at any time.
In their own interest, Data Subjects should endeavor to keep their data up to date. To this end, they can request that their data be updated on the Startwell website via the “Talk to Us” chat or contact the Data Protection Officer via email at info@startwell.pt.
Data Subjects have the right to lodge a complaint with the competent Supervisory Authority in the event of a breach of the rules applicable to the protection of Personal Data.

6. Privacy Notice

The purpose of the personal data collected and processed is solely and exclusively to comply with legal, contractual or Startwell interest requirements.

The provisions regarding the collection and processing of personal data are described in this Policy.
Personal data subjects may exercise their right to access, rectify, cancel, delete or oppose the use of their personal data at any time, including the revocation of consent. To do so, they must access the Startwell website and request that their data be updated on the website via the “Chat with Us” chat or contact the Data Protection Officer via email at info@startwell.pt.
Data Subjects have the right to lodge a complaint with the competent Supervisory Authority in the event of a breach of the rules applicable to the protection of Personal Data.

In the event of a proven leak of Personal Data, Startwell will report it to the competent Supervisory Authorities.

7. Changes to the Privacy Policy

The Personal Data Protection Policy may be amended by Startwell whenever there is a need or a change in the law, and a notice of such amendments will be published in a revised version of the current Policy, which will come into force when it is published.
Startwell will notify Data Subjects of any changes to the policy via the contact details provided by them.

8. Contact

If you have any questions about this Privacy Policy, please contact us at info@startwell.pt.