Your Healthcare Partner
in the Caribbean

MCI Latam S.R.L hereinafter referred to as MCI Latam, in its commitment to the Protection of Confidentiality and Privacy of Personal Data, has adapted all its business processes and especially those involving the processing of personal data, to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), adapting them to the new regulatory requirements and implementing the necessary security measures, determined by the results obtained from the risk analysis carried out, which guarantee the integrity, availability and security of personal data.

This Privacy Policy describes what personal information we may collect, how we collect it, why we use it and generally the processes and ways in which we may treat it, as well as your rights. By providing us with your personal information, you expressly acknowledge that we may use it in the manner set out in this Privacy Policy. Your consent to all processing will enable us to provide you with a service that is as tailored to your needs as possible. However, we inform you that you may choose to limit the processing operations of your choice, provided that these are not necessary for the performance of the contract, that a legitimate interest of the data controller prevails or that they are required by law.

If you provide personal information about other people for any of our services or if you are a contact person for a Company and you are providing personal information about employees and/or alternative contacts, you must ensure that you have communicated this Privacy Policy to them and that you have their permission to share their information with us. From time to time, we may need to make changes to the Privacy Policy, for example, as a result of new legal regulation, new case law, the adaptation of new technology or other developments in Personal Data Protection rules or privacy in general. We advise you to check our website periodically for the most up-to-date Privacy Policy.

 

1.- RESPONSIBLE FOR PROCESSING YOUR DATA

The entity responsible for the processing of your data is:

MCI Latam.
Building A8-B, Puerto Plata Free Zones Industrial Park Puerto Plata 57000, Dominican Republic.

• Contact e-mail address for personal data: protecciondedatos@mcimanager.com
• Contact with the Data Protection Officer: dpo@mcimanager.com

 

2.- FROM WHOM DO WE COLLECT YOUR PERSONAL INFORMATION?

We may collect personal information:

• FROM YOU OR YOUR REPRESENTATIVE (by filling in forms or questionnaires, communicating with us by post, telephone, e-mail or otherwise)
• THIRD PARTY, (for example, when it is the company to which you belong or the insurance company whose insurance policy you have taken out that provides your contact information, etc.).

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All information provided to us must be truthful, taking responsibility for all the data communicated to us and must keep the information fully updated so that it corresponds, at all times, to the real situation. In all cases, the person providing the information shall be solely responsible for any false or inaccurate statements made and for any damage caused to MCI Latam. or third parties as a result of the information provided.

If you provide us with information about other people, you must obtain their consent. If you provide us with details of other people, you are confirming that you have their permission and that they have understood how the information will be used.

 

3.- BY WHAT MEANS DO WE COLLECT YOUR PERSONAL INFORMATION?

We may collect your personal information through:

• Our web page
• By telephone
• By email
• Forms or questionnaires

 

4.- WHAT PERSONAL INFORMATION DO WE COLLECT?

We only request for the information that is necessary for us to perform the service you request from us. Where we need to collect personal information from you by law or under the terms of a contract and you do not provide that information when requested, we may not be able to perform the contract we have entered into or are seeking to enter into with you. In such a case, we may not be able to enter into the contract you wish to enter into or we may have to cancel a service you have contracted for, although we will notify you accordingly. The personal information we collect includes, but is not limited to, the following:

SERVICES OF THIS WEBSITE

 1.- Any information you provide to us when you use our contact forms (e.g. “Contact”). The provision of your personal information via the contact forms is not a mandatory or contractual requirement. However, the fields marked with an asterisk are mandatory because we need this information to fulfil or respond to your request.

2.- For the purposes of technical security and system diagnostics, in anonymised or pseudonymised form, MCI Latam  may record the IP address (Internet access identification number of the device, which enables devices, systems and servers to recognise and communicate with each other). This information may be used for web performance analytics purposes.

PROVISION OF SERVICES TO CLIENTS

In accordance with our functions as our clients’ Data Processors and in relation to the claims whose attention, processing and follow-up we have been assigned by virtue of a Contract, we will ask you: your name, surname, contact details (telephone, contact email or similar), age, sex, date of birth, place of birth, marital status, family, mother tongue, nationality, details of the insurance policy, details of the claim, the place where it took place, health details and any other type of information that may be related to the claim and which is essential to manage the appropriate health care for the insured.

 

5.- PURPOSES OF THE PROCESSING OF PERSONAL DATA

Personal data provided voluntarily by any means will be included in the records of processing activities owned by MCI Latam for the following purposes:

SERVICES OF THIS WEBSITE

• • The processing and management of the request for information and/or advice via this website, by telephone or by e-mail.

• • To provide the services included on the website and/or provide the information requested, either via the website, by e-mail or by telephone.

• • To carry out studies to analyse the website for statistical purposes, with the aim of improving the information offered through it.

PROVISION OF SERVICES TO CLIENTS

• • Managing the contractual relationship established between MCI Latam and Clients.

• • Arranging international medical Assistance for insured persons through medical providers within the relevant national and international territory.

• • Validation that the treatment required is covered by the insurance policy.

• • Management of the required medical treatment.

• • Control that the medical treatment and its cost is reasonable and within the normal parameters of the usual market.

• • Management and validation of invoices and payments.

• • Sending periodic informative reports.

• • Managing the fulfilment of contractual or extra-contractual obligations assumed by MCI Latam.

• • Carrying out statistical studies for the purpose of improving MCI Latam S.R.L. own services.

We will only use your personal information for the purposes for which it was collected, unless we reasonably believe that we should use it for some other reason and that reason is compatible with the original purpose. In the event that we need to use your personal information for unrelated purposes, we will notify you in good time and explain the legal basis for allowing us to do so.

Prior to sending personal data through any form on the website, you must expressly accept the processing of your personal data in accordance with this Privacy Policy, which for legal purposes means that you have given your unequivocal, free, specific and informed consent to the processing of your personal data for the purposes indicated.

 

6.- LEGAL BASES FOR PROCESSING

Each purpose for which we process your personal data has a legal basis that justifies why we are using your personal data. These legal bases are set out below:

SERVICES OF THIS WEBSITE

• • You have given your consent to request information through the Contact form. You are free to withdraw your consent by contacting us at any time. However, withdrawal of this consent may affect our ability to provide the requested service.

PROVISION OF SERVICES TO CLIENTS

• • The data owner has provided his or her personal data in the context of a contractual or pre-contractual relationship. The processing is necessary for the conclusion and/or performance of a contract.

• • The data owner has given his or her consent to be treated by our network of medical providers, hospitals, clinics or other medical professionals and, therefore, for such centres or professionals to communicate relevant information to us for the purposes of insurance guarantee and appropriate health care. The request for withdrawal of consent does not have retroactive effect.

There may also be cases where processing is necessary for compliance with a legal obligation to which we are subject or is necessary for the performance of a task carried out in the public interest.

 

7.- WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

MCI Latam does not disclose your personal information to third parties, except when:

• • Disclosure is required by law or by a Government Body with authority over us or you, such as where there is a court order, legal obligation, etc.

• • We believe that such disclosure is necessary to Spain in the prevention or detection of any criminal action (including fraud) or in the public interest. However, in relation to the processing of data as Processors for our Customers, international healthcare involves the exchange of personal data, including health data with our network of healthcare and medical transport providers.

These third parties are subject to contractual and legal obligations necessary to preserve data confidentiality and protect privacy, act under our strict instructions and only have access to data necessary for the performance of their functions.

 

8.- RETENTION OF YOUR PERSONAL DATA

We will keep your personal data only for as long as is necessary and for the purpose for which it was originally collected, according to the legal basis for the processing authorizing it and in accordance with applicable law.

Thus, we will keep your personal information for as long as there is a contractual relationship with you or as long as you do not exercise your right to erasure, cancellation and/or restriction of processing of your data.

We shall also retain information for as long as it may be necessary for the exercise or defence of claims or as long as any legal, judicial or contractual liability may arise from its processing or where we are required to retain your personal data for legal or regulatory reasons.

However, the data will remain blocked for the periods of time determined by the aforementioned regulations, in order to be able to attend to any liabilities that may arise. Once these periods have elapsed, the data will be deleted, unless the data owner has authorized its processing for specific purposes for a longer period of time.

Finally, in some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without notice.

 

9.- INTERNATIONAL TRANSFERS

PROVISION OF SERVICES TO CLIENTS

International medical care of our clients’ insured persons or employees requires the international exchange of data when the insured person or employee, who is outside the European Union, requires medical care from our medical/healthcare providers.

Therefore, such international transfer is covered by the provisions of Article 49(b), (c) and (f) of the GDPR, which includes the following cases:

• • – (b) the transfer is necessary for the performance of a contract between the data owner and the controller or for the performance of pre-contractual measures taken at the data owner’s request.

• • – (c) the transfer is necessary for the conclusion or performance of a contract in the interest of the data owner between the controller and another natural or legal person.

• • – “(f) the transfer is necessary for the protection of the vital interests of the data owner or of other persons, where the data subject is physically or legally incapable of giving consent.”

However, MCI Latam  ensures that your personal information is afforded a level of protection appropriate to the type of data processed by putting in place appropriate procedures with third parties with whom we exchange your personal data to ensure that such third parties process such personal information in a manner consistent with data protection legislation and that they respect and protect it to the appropriate legal standard.

 

10.- PERSONAL DATA SECURITY MEASURES

We have implemented appropriate technical and organizational security measures to prevent your personal data from being lost, accidentally used or accessed in an unauthorized manner, modified or disclosed, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data, as well as any applicable national legislation. In order to protect personal data, MCI Latam implements technical and organizational measures appropriate to the state of the art taking into account the scope, context and purposes of the processing, the nature of the data, as well as the risks to the rights and freedoms of data subjects, while seeking to ensure the confidentiality, integrity and availability of the information. We have also implemented procedures to deal with any suspected breach of personal data security. In the event of such a breach, we will notify you and any relevant regulatory body (Spanish Data Protection Agency – AEPD). Our Information Security Policies and Procedures are regularly reviewed and updated to meet the needs of our business, technological changes and regulatory requirements. However, while we strive to protect your personal information, the nature of the Internet means that it is not possible to guarantee 100% information security. With this in mind, any data transmission over the Internet is at your own risk and we urge you to take every precaution to protect your personal information while online.

 

11.- YOUR RIGHTS

You may exercise, free of charge, your Rights of Access, Rectification, Deletion, Opposition and Limitation to the processing of your data, as well as the right to data portability and the right not to be subject to a decision based solely on automated processing, including profiling. Specifically, you have the right to:

• • Provide you with further details about our use of your personal data / special category of data.

• • Provide you with access to your personal data, including obtaining a copy of the personal information you have provided to us.

• • Update any inaccuracies in your personal data.

• • Delete any categories of personal data that no longer have a lawful basis for their use.

• • Where the processing is based on consent, withdraw your consent given (without retroactive effect) in order for us to cease processing based on that consent.

• • Object to any processing based on legitimate interest, unless our reasons for carrying out that processing outweigh any prejudice to your Data Protection Rights.

• • Restrict how we use your personal data while a complaint is being investigated.

In certain circumstances, we may be obliged to restrict the above rights to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

The exercise of the Rights is free of charge. However, we may charge you a reasonable fee if your request is clearly unfounded, repetitive or excessive.

The exercise of the Rights is very personal, so in order to exercise them you must prove your identity or that of his/her Legal Representative.

In the event that you do not duly accredit your identity or there are doubts about the exercised Right, we will contact you to clarify these issues.

We try to respond to all legitimate requests within one month. Occasionally, it may take longer than one month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you accordingly.

If you wish to exercise any of the rights set out above, please contact us at:

• • Email to protecciondedatos@mcimanager.com

• • Written communication addressed to:

MCI Latam S.R.L.
Building A8-B, Puerto Plata Free Zones Industrial Park Puerto Plata 57000, Dominican Republic

In said communication you must state as subject “Personal Data Protection”, indicate your name and surname, attach a photocopy of your ID card or supporting document and determine an address for the purpose of notifications and the reasoned request in which the request is made, date and signature.

Likewise, if you have any questions/issues regarding this Privacy Policy or in relation to our use/processing of your personal data, you may contact our Data Protection Officer at dpo@mcimanager.com.

In the event that you are not satisfied with the use we make of your personal data or with our response to any request you make, you may file a complaint with the SPANISH DATA PROTECTION AGENCY (www.aepd.es)