Skip to main content

Personal Data Policy

The protection of your personal information is a fundamental priority for us.

This Privacy Notice aims to inform you how and for what purposes we process the personal data provided by our clients. The processing of your Personal Data is carried out in accordance with the applicable law.

We highly value the privacy and confidentiality of your personal information; therefore, its protection is one of our main priorities.

1. The Liable Party

In compliance with Law 1581 of 2012 and Regulatory Decree 1377 of 2013, which regulate the protection of personal data in Colombia, SUBLIME PLASTIC SURGERY GROUP S.A.S., identified with NIT: 901222929-8, as the entity responsible for the processing and protection of the personal data of its patients, affiliates, employees, providers, partners, users, and other stakeholders, has collected, stored, and used information containing personal data. For the development of its corporate purpose, it intends to continue such processing in the future.

For this purpose, all data subjects are informed about the adoption of the following policies on the collection, processing, and use of personal information, which will be mandatory for SUBLIME PLASTIC SURGERY GROUP S.A.S., its employees, as well as third parties who, by legal obligation or company mandate, act as data processors or have access to such data.

2. Legal Framework

This policy is based on:

Colombia:

    • Law 1581 of 2012 (Personal Data Protection).
    • Regulatory Decree 1377 of 2013.
    • Law 23 of 1981 (Medical Ethics Standards).
    • Resolution 1995 of 1999 (Medical Records).

United States (Miami, Florida):

    • HIPAA (Health Insurance Portability and Accountability Act).
    • Florida state law on medical records retention (minimum 7 years).
    • California Consumer Privacy Act (CCPA), when applicable.
    • Rules established by The Campaign Registry (TCR) for SMS/MMS communications.

3. Scope

This policy applies to all personal information collected, stored, used, or processed by SUBLIME PLASTIC SURGERY GROUP S.A.S., within the framework of its administrative, commercial, healthcare, and promotional activities.

4. Purposes of Processing

The personal and sensitive data collected by SUBLIME PLASTIC SURGERY GROUP S.A.S., identified with NIT 901222929-8, will be used exclusively for the following purposes:

Medical assessment and preparation of estimates:

    • Collecting contact details and basic background information from patients through forms.
    • Requesting clinical photographs (including images of the partially nude body), which will be handled with strict confidentiality and used only for diagnosis, medical assessment, and preparation of surgical and non-surgical procedure estimates.

Patient communication:

    • Contacting data subjects to provide information about procedures, estimates, appointment scheduling, and follow-up.

Administrative and contractual management:

    • Complying with legal, contractual, and administrative obligations related to the provision of healthcare and wellness services.

Commercial and promotional activities:

    • Sending information about services, promotions, or campaigns, provided the data subject has authorized it.

5. Protection of Sensitive Data

As part of providing medical and aesthetic services, SUBLIME PLASTIC SURGERY GROUP S.A.S. may request the submission of clinical photographs of the body, which may, in some cases, include images of body parts without clothing.

These are classified as sensitive data under Colombian law and will be processed under the following guidelines:

    • The submission of photographs is voluntary and requires the express authorization of the data subject.
    • Such images will be used exclusively for medical assessment, diagnosis, and preparation of estimates.
    • Information will be stored under technical, human, and administrative security measures designed to prevent loss, misuse, alteration, unauthorized, or improper access.
    • Photographs will not be shared with third parties, except where legally required or with the express authorization of the data subject.

According to applicable regulations:

    • In Colombia, medical records must be retained for no less than ten (10) years from the date of the last medical care.
    • In the United States (Florida – Miami), medical records must be retained for no less than seven (7) years from the last service date, in accordance with state law and HIPAA provisions.

Therefore, photographs and other data forming part of the medical record cannot be deleted at the request of the data subject, except in cases expressly permitted by law.

6. Rights of Data Subjects

Under Law 1581 of 2012 and other applicable regulations, data subjects have the right to:

    • Know, consult, and access their personal data.
    • Update, rectify, or correct their information.
    • Request the deletion of data not forming part of the medical record and not required by law.
    • Revoke consent granted for data processing, when applicable.
    • File complaints with the Superintendence of Industry and Commerce (SIC) in Colombia or with the competent authorities in the United States in case of non-compliance.

7. Contact Channels

Data subjects may exercise their rights through the following channels:

Cartagena – Colombia

Miami – United States

8. Responsibility

Compliance with this policy is mandatory for all employees, contractors, and third parties who, by legal or contractual requirement, have access to the personal data processed by SUBLIME PLASTIC SURGERY GROUP S.A.S.

9. Validity

This policy is effective as of its publication and will remain valid as long as SUBLIME PLASTIC SURGERY GROUP S.A.S. engages in activities related to personal data processing and medical record retention.

 

Close Menu