Data Privacy Policy

Last updated: September 15, 2025

Affinity Health and Wellness Corporation (“Affinity,” “we,” “our,” or “us”) is the owner of the Affinity Dental Clinics® trademark, along with Affinity Medical, Affinity Vaccines, and Affinity Pharmacy. As a healthcare organization, we are committed to protecting the privacy and personal information of our patients, clients, and partners in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and issuances of the National Privacy Commission (NPC).

This Privacy Policy explains what information we collect, how we use and protect it, your rights as a data subject, and how you may exercise those rights.

1. Personal Information We Collect

We collect both personal information and sensitive personal information, including:

  • Identity details (name, date of birth, gender, civil status, nationality)
  • Contact details (address, telephone number, email)
  • Government-issued IDs (e.g., SSS, PhilHealth, driver’s license, passport)
  • Health and dental information (medical history, diagnostic results, x-rays, treatment records, prescriptions)
  • Insurance and payment information (health insurance, billing records, payment method)
  • Technical information (IP address, device type, geo-location, cookies, web analytics)
  • Emergency contact and next of kin details

For patients who are children or minors, we collect health and personal information only with the consent of a parent or legal guardian.

2. Purpose of Collection and Lawful Bases

Your information is collected and processed for the following purposes:

  • To provide safe, effective, and appropriate dental and medical treatment
  • To manage appointments, reminders, and patient records
  • To process payments, receipts, insurance claims, and benefits
  • To comply with legal and regulatory requirements
  • To perform diagnostics, laboratory, and imaging services
  • To improve patient care, services, and clinic operations
  • To send marketing or promotional communications, only with your prior consent

We process data under lawful bases recognized by the Data Privacy Act, including:

  • Consent (freely given, informed, and explicit)
  • Contractual necessity (for treatment or services you requested)
  • Legal obligation (compliance with laws, regulations, and reporting)
  • Vital interests (to protect life and health in emergencies)
  • Legitimate interests (to improve services and maintain records, subject to your rights)

3. Sharing and Disclosure

We share personal information only as needed and in line with applicable law:

  • Affinity dentists, specialists, staff, and health professionals directly involved in your care
  • Insurance providers, HMOs, and government agencies for claims and compliance
  • Accredited third-party providers (e.g., dental laboratories, diagnostics, IT support) under binding confidentiality and data protection agreements
  • Regulatory authorities and law enforcement, but only when legally required

We do not sell, rent, or trade your information.

If data must be transferred outside the Philippines, we ensure adequate safeguards are in place (e.g., contractual clauses, secure hosting).

4. Data Protection and Security

Affinity Health and Wellness Corporation implements organizational, physical, and technical safeguards, including:

  • Restricted access and role-based permissions for personal data
  • Password protection, encryption, firewalls, and secure servers
  • Secure disposal of records through shredding, deletion, or anonymization
  • Staff training on data privacy and confidentiality
  • Regular audits and reviews of IT and security systems

In case of a personal data breach, we will notify the NPC and affected individuals in accordance with the law.

5. Retention of Data

We retain your personal information only as long as necessary:

  • Medical and dental records: at least 15 years from the last consultation or as required by law
  • Financial and billing records: in accordance with BIR regulations (10 years)
  • Marketing records: until you withdraw consent
  • Other personal data: only as long as necessary for legal or business purposes

After retention, data is securely deleted, anonymized, or destroyed.

6. Your Rights as a Data Subject

Under the Data Privacy Act, you have the right to:

  • Be informed about how your data is collected and processed
  • Access the personal information we hold about you
  • Rectify or correct inaccuracies in your data
  • Withdraw consent to processing, where applicable
  • Object to processing, such as for marketing
  • Request data portability of certain information
  • Request blocking, deletion, or destruction of data no longer necessary
  • Recover damages in case of violation of your rights

Requests may be made in writing and will be addressed in accordance with the law and subject to verification of identity.

7. Cookies and Website Analytics

Our website may use cookies and analytics tools to improve user experience:

  • Essential cookies: required for site functionality
  • Analytics cookies: to understand site usage and improve services
  • Marketing cookies: used only with your consent

You can manage or disable cookies through your browser settings.

8. Children’s Privacy

For patients under 18 years old, data collection and processing require the consent of a parent or legal guardian.

9. Updates to this Policy

We may update this Privacy Policy from time to time to comply with new laws, regulations, or operational needs. Updates will be published on our website with the effective date shown.

10. Contact Us

If you have questions, concerns, or wish to exercise your data subject rights, you may contact our Data Protection Officer (DPO):

Data Protection Officer Affinity Health and Wellness Corporation 6th Floor, Angelus Plaza, 104 V.A. Rufino Street, Legaspi Village, Makati City, 1229 Philippines 📩 DPO@affinity.com.ph

You may also file a complaint with the National Privacy Commission at www.privacy.gov.ph.

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