1. Introduction

The Ardentis Group, i.e. any company owned by or affiliated with Ardentis Holding SA (hereinafter « Ardentis », « Nous », « Notre », « Nos ») provides services (hereinafter « Prestation(s)») to patients (hereinafter « Patient(s) », « Vous », « Votre », « Vos ») and operates the websites https://www.ardentis.ch/ et https://www.orthodontics-gouttieres.ch/ (hereinafter « Sites ») which offer their users (hereinafter “User(s)”) content relating to dental care and the Ardentis Clinics and which allow them to book appointments online. 

In order to provide Our Services and develop them, as well as to provide online content and services on Our Sites, We collect, use and communicate a certain amount of data concerning Patients and Users. When We talk about data, We refer to personal data. This is all information that allows Us to identify Patients and Users immediately or by combining it with other information. 

This privacy policy (hereinafter « Politique ») expose the conditions under which the Ardentis Clinics process data concerning Patients and Users, as well as the choices available to them regarding the collection, use and communication of this information in accordance with the Federal Data Protection Act. 

Les Terms and Conditions of Use of the Sites follow after this Privacy policy. Their clauses should be read together. 

2. Data controller 

The Ardentis Group is made up of several public limited companies, organised according to the following principles. 

Each clinic that provides Prestations is legally attached to a public limited company (see Table 2 in the Appendix). These public limited companies are primarily responsible for processing the data necessary to provide Prestations. 

These public limited companies work in close collaboration with SdC Services SA. The latter centralises various useful tasks for the proper functioning of the clinics (operational management at the level of the group Ardentis, operation of the Sites, marketing, invoicing of Prestations, making appointments, etc.). It is data controller for all these processes.

Given this collaboration, the public limited companies operating the clinics and SdC Services SA must be considered as joint data controllers. 

LDC Laboratoire Dentaire de Chauderon SA is a company of the Ardentis group which manuinvoices prostheses for patients on behalf of clinics. For the majority of the time, this company acts as a subcontractor for the public limited companies operating les cliniques. However, it sometimes happens that patients use the services of LDC Laboratoire Dentaire de Chauderon SA without going through a clinic. In this case, LDC Laboratoire Dentaire de Chauderon SA must be considered as the data controller of the processing, together with SdC Services SA.

3. Processing of Your data as part of the provision of Our Services 

3.1 Data that may be processed

3.1.1 Data communicated by the Patient

When You use Our Services, You will be asked to provide Us with a certain amount of data concerning You such as Your personal details, Your billing data, Your health data, Your data relating to Your health insurance or Your accident insurance, Your data arising from a disability insurance decision, etc. 

This personal data is generally collected using a form. Some of this data, including Your personal details, may also be communicated via the Sites ; in this case, the Patient is also considered as a User and the provisions of section 4 apply to them. 

You can also voluntarily provide us with other data. 

3.1.2 Data provided by Your doctor

When the use of Our Services is prescribed Your doctor, they communicate to Us a certain amount of data concerning You such as Your personal details, Your health data, Your data relating to Your health insurance or Your accident insurance, etc. 

3.1.3 Billing data

When using Our Services, We record Your data necessary for payment (e.g. surname, first name, billing address, telephone number, AVS number, e-mail address, IBAN number, bank account number, date of consultation) but also other data such as for example the name of Your health insurance or Your accident insurance.

3.1.4 Video recordings

When You enter one of our clinics, You may be filmed by video surveillance cameras. 

Video surveillance is limited to clinic entrances, as well as to areas distinguishable by stickers. 

3.2 Purpose of data use

3.2.1 Provision of Services

Your data is used to provide Our Services, interact with You and respond to Your requests. 

3.2.2 Marketing

Your data is used to send You information about Our Services, unless You object. You can inform Us at any time of Your wish to object to this processing. Your data may also be used as part of the development of Our Services in order to test Your interest in creating new Services. 

3.2.3 Pursuit of Our legitimate interests

Your data may also be used to pursue Our legitimate interests, which includes the safety of our employees and our patients, the detection of fraud, the collection of debts, as well as the study of any complaints that We may receive, from You or from third parties. Video surveillance images are only used for safety purposes.

3.2.4 Compliance with legal or regulatory obligations

Your data is used to meet Our legal and regulatory obligations, such as keeping accounting documents, keeping medical records or responding to requests from authorities. 

4. Processing of Site User’s data 

4.1 Introduction

When Users browse Our Sites and interact with them, automated data collection technologies are used to collect certain data about them to understand their actions (e.g. which links were clicked on, which pages were viewed), as well as other similar data and statistics (e.g. content response times, download errors, length of visit to certain pages, type of browser used or place of connection). This information is collected using automated technologies such as cookies.  

4.2 Cookies

Cookies are text files that can identify Users and store their personal preferences (e.g. their choice of language) as well as technical information (including click-type data and browsing-type data). 

We use cookies to facilitate access to the Sites and to analyse traffic and Users and identify malfunctions of the Sites. It also allows Us to improve the User experience as well as the design and content of the Sites. 

Furthermore, We may also utiliser des web beacons or ‘Clear GIFs’ or similar technologies which serve to verify how Users browse Our Sites and to see which pages of Our Sites they visit. Web beacons are short series of codes allowing delivery of graphic images to a web page for the purpose of transferring data such as the IP address (Internet Protocol) of the computer that downloaded the page on which the web beacons appear, the URL of the page on which the beacons appear, the time at which the page containing the beacons was viewed, the types of web browsers that retrieved the beacon and the identification number of any cookie previously stored on the computer by the server.

For the operation of the Sites, We may collaborate with other companies that place cookies or web beacons on the Sites (including Google Analytics). These companies help Us in the management of the Sites and offer additional products and services. The use of these technologies by these third parties is then subject to their own terms of personal data processing and is not covered by this Policy.

The use of cookies can be disabled by selecting the appropriate settings in the browser used. However, such disabling could prevent the use of certain features of the Sites. For more information on cookies https://allaboutcookies.org/fr : allaboutcookies.org/fr et youronlinechoices.com/fr.

Depending on the browser used, disabling Google Analytics is also possible by installing an add-on or by consulting this procedure. Users also have the option to consult the use of their personal data when using Google Analytics.

Users of the Sites may also at any time modify or withdraw their consent for non-essential cookies by clicking on this link : Manage cookie settings

4.3 Third-party social networks

When Users authorize a third-party social network (such as Facebook, YouTube, LinkedIn, etc.) to share with Our accounts, We may receive any data that Users share publicly on this social network and data that is part of their profile. This may include basic data relating to their account (e.g. first name, last name, e-mail address, gender, birthday, city of residence, profile photo, user ID, etc.) and any other data or activity that Users authorize the third-party social network to share. These social networks are governed by their own terms of use and privacy policies which We invite Users to read.

5. Data disclosure

5.1 Within the Ardentis group

The data (including those concerning health) communicated to one of the companies of the group Ardentis may be transmitted to all other companies of the group. These companies may process data in accordance with this Privacy policy for the purposes mentioned in section 3.2. 

The list of Ardentis group companies is shown in Table 1 in the Appendix. 

5.2 Subcontracting

We may use subcontractors and external service providers, to the extent necessary for the completion of the tasks entrusted to them, in particular providers to manage online appointment booking, provide applications for communicating with patients (for example WhatsApp business), set up a call center, manage and/or maintain the Sites, analyse traffic on the Sites, send messages on Our behalf, conduct research, monitor and analyse the status of Our network and the effectiveness of Our communication.

5.3 Disclosure to third parties

We may transmit the data of Patients and Users to third parties outside the Ardentis group (i) if this is necessary for the pursuit of the purposes for which Patients and Users have freely provided them to Us, (ii) if Patients and Users have previously consented ou (iii) if the law permits Us or requires Us to do so (p. ex. upon request of a judicial authority, to assert Our rights in court or to proceed with debt collection with the help of a collection service).

5.4 Transfer abroad

We collect, use and communicate a certain amount of data concerning Patients and Users. For Users and Patients, personal data will primarily be stored in Switzerland, Germany, Netherlands, Ireland and United Kingdom. 

For Users, only with regard to Google Analytics, personal data may also be stored in Belgium, Finland, Denmark, Poland and United States. 

The Company will comply with all applicable rules and will adopt all required and necessary measures prior to the transmission of data abroad.  

6. Data security and confidentiality

Although total security does not exist, security measures (of a technical and organisational nature) in accordance with best practices have been implemented, taking into account the risks involved to protect the data of Patients and Users against any accidental or intentional manipulation, loss, destruction, disclosure or against any unauthorized access.  

7. Jurisdiction and applicable law

This Policy and all questions arising from it or related to it, as well as to the use of Our Sites or the use of Our Services, are governed by Swiss law, excluding conflict of laws rules.  

Patients and Users accept the exclusive jurisdiction of the Courts of the registered office of SdC Services SA.

8. Updates to Our Policy

We may update this Policy from time to time without notice.  

We will seek to draw the attention of Our Patients to any significant change. If You have sent Us Your e-mail address, You will be informed by e-mail, if applicable of the new Policy. The new Policy will also be available on the Sites.  

Users are required to review the Policy and to stay informed of any changes. 

The use of Our Services after a change is an explicit acceptance des modifications, in the same way as the continued use of Our Sites.

9. Contact

Les Patients and Users can Nous contacter for any question regarding the Privacy Policy by sending Us an e-mail à legal@ardentis.ch or writing to Us at the address :

SdC Services SA

Route du Verney 7

1070 Puidoux

Annexe

Tableau 1 : structure of the group Ardentis

The Ardentis Group is constitué des following companies, wholly or majority owned par Ardentis Holding SA :

Dental Lab Ardentis SA

SdC Services SA

Ardentis Dental Clinic Chablais SA

Ardentis Dental Clinic Pully SA

Ardentis Dental Clinic Genève SA

Ardentis Centre Dentaire Bulle SA

Ardentis Dental Clinic Cossonay SA

Ardentis Dental Clinic Yverdon SA

Ardentis Dental Clinic Renens SA

Ardentis Dental Clinic Morges SA

Ardentis Dental Clinic Lausanne SA

Ardentis Dental Clinic Vevey SA

Centre Dentaire du Seyon SA

Tableau 2 : cliniques 

Les Ardentis clinics are attached to following companies :

Clinic	Société anonyme
Collombey	Ardentis Dental Clinic Chablais SA
Pully	Ardentis Dental Clinic Pully SA
Genève	Ardentis Dental Clinic Genève SA
Bulle	Ardentis Centre Dentaire Bulle SA
Cossonay	Ardentis Dental Clinic Cossonay SA
Yverdon	Ardentis Dental Clinic Yverdon SA
Renens	Ardentis Dental Clinic Renens SA
Morges – Gare	Ardentis Dental Clinic Morges SA
Ecublens – EPFL	Ardentis Dental Clinic Morges SA
Ardentis Experience Center	Ardentis Dental Clinic Morges SA
Lausanne – Benjamin-Constant	Ardentis Dental Clinic Lausanne SA
Lausanne – Chauderon	Ardentis Dental Clinic Lausanne SA
Lausanne – Flon	Ardentis Dental Clinic Lausanne SA
Vevey	Ardentis Dental Clinic Vevey SA
Villars	Ardentis Dental Clinic Vevey SA
Neuchâtel – Seyon	Centre Dentaire du Seyon SA