Protecting your personal data is an essential part of the trust you place in us. This policy explains what data we process, why, on what legal basis, and what rights you can exercise.

It is drawn up in accordance with the Swiss Federal Act on Data Protection (FADP, revised with effect from 1 September 2023) and its implementing ordinance (DPO), and with the General Data Protection Regulation (GDPR) where that applies, in particular in respect of individuals located in the European Union.

‍

1. Controller

Pure Clinic Group SA Place du Marché 3, CH-1860 Aigle, Switzerland UID: CHE-420.817.696 Email: info@pureclinic.ch

Each clinic in the network acts as controller for the data of its own patients.

[If applicable:] We have appointed a data protection adviser, who can be contacted at info@pureclinic.ch.

[If applicable, where an EU representative is required:] Our representative in the European Union within the meaning of Art. 27 GDPR is [NAME AND CONTACT DETAILS].

‍

2. Categories of data processed

2.1 Site visitors

• technical data: IP address (truncated where possible), browser and device type, operating system, pages viewed, date and time of access, referring site;
• audience measurement data and cookie preferences.

2.2 Appointment and contact requests

• identity: surname, first name, date of birth where applicable;
• contact details: postal address, email address, telephone number;
• subject of the request, chosen clinic, free-text message content;
• attachments you choose to send.

2.3 Patients

• administrative data: identity, contact details, AHV number where required, insurer, policy number, billing data;
• health data: medical history, diagnoses, treatment plans, procedures performed, imaging (X-rays, CBCT), medical correspondence, prescriptions, post-operative follow-up.

Health data constitutes sensitive personal data within the meaning of Art. 5(c) FADP and a special category of data within the meaning of Art. 9 GDPR. It is subject to enhanced protection.

2.4 Job applicants

• CV, covering letter, diplomas, references, career history, and any information you choose to send us.

‍

3. Purposes and legal bases

‍

4. Professional secrecy

Our doctors, dentists, hygienists and all our auxiliary staff are bound by professional secrecy within the meaning of Art. 321 of the Swiss Criminal Code. No health data is disclosed to a third party without your consent, save where required or permitted by law, or where secrecy is lifted by the competent authority.

‍

5. Recipients

Your data is neither sold nor rented. It may be disclosed to the following categories of recipient, strictly to the extent necessary:

• the Pure Clinic network clinics involved in your care;
• the Dental Practitioners' Fund (CMD) and, where applicable, your health or accident insurer;
• prosthetics laboratories and imaging providers;
• colleagues and institutions to whom you are referred, with your agreement;
• our IT processors: hosting, email, practice management software, appointment booking tool, audience measurement;
• our legal, fiduciary and audit advisers, who are bound by professional secrecy;
• the authorities, where the law requires it.

Our processors are bound by contracts imposing confidentiality, security and processing solely on our instructions.

‍

6. Transfers abroad

Some providers are established outside Switzerland, including in the United States. Such transfers take place only where the recipient country ensures adequate protection under the Federal Council's list, or subject to appropriate safeguards: standard contractual clauses recognised by the FDPIC and the European Commission, supplemented where necessary by additional technical and organisational measures.

Our patients' health data is hosted in Switzerland [to be confirmed and adapted to your practice management software].

‍

7. Retention periods

• Patient records: retained for at least 10 years after the last contact, in accordance with the applicable federal and cantonal legal requirements; certain cantons or situations require a longer period, up to 20 years.
• Accounting records and invoices: 10 years (Art. 958f CO).
• Contact and appointment requests not resulting in treatment: 12 months.
• Unsuccessful applications: 6 months after the process closes, unless you agree to longer retention.
• Audience measurement data: see our Cookie Policy.

On expiry, data is deleted or irreversibly anonymised.

‍

8. Security

We implement appropriate technical and organisational measures: encryption in transit (TLS), access control and logging, role-based permissions, regular backups, system segregation, staff awareness training and signed confidentiality undertakings.

No transmission over the internet is entirely secure, however. Please do not send us detailed health data by unencrypted email.

‍

9. Your rights

Subject to statutory conditions and exceptions, you have the following rights:

• Access: to obtain confirmation that processing is taking place and to receive a copy of the data (Art. 25 FADP; Art. 15 GDPR).
• Rectification of inaccurate data (Art. 32 FADP; Art. 16 GDPR).
• Erasure, where retention is no longer justified. This right does not apply to data subject to a statutory retention obligation, which is the case for the medical record.
• Restriction of processing and objection, in particular to processing based on legitimate interest (Art. 30 FADP; Art. 18 and 21 GDPR).
• Portability: to receive your data in a common, machine-readable format (Art. 28 FADP; Art. 20 GDPR).
• Withdrawal of consent at any time, without affecting the lawfulness of prior processing.
• Not to be subject to an automated individual decision producing legal effects. We carry out neither high-risk profiling nor automated decision-making in relation to care.

To exercise these rights, write to info@pureclinic.ch or to our registered office. We may ask for proof of identity to avoid disclosure to a third party. We will normally respond within 30 days.

‍

10. Complaints

You may lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch.

If you reside in the European Union, you may also contact the supervisory authority in your country of residence.

‍

11. Cookies

The use of cookies and similar technologies is described in our Cookie Policy. You can change your choices at any time via the "Cookie settings" link.

‍

12. Minors

Care provided to minors is given with the consent of the legal representative, subject to the patient's capacity of judgement. The Site is not intended to be used independently by children to submit personal data.

‍

13. Changes

This policy may be adapted to reflect legal, technical or organisational developments. The version in force is the one published on the Site, together with its update date.