1. DATA CONTROLLER
PROVIDER information:
EUCALYPTUS AR S.A.S. CUIT: 30-71875904-4 Registered office: Avenida Congreso 2277, Piso 6, Departamento "A", C.P. 1428, Ciudad Autónoma de Buenos Aires, República Argentina Contact email: info@dentu.com.ar
When Eucalyptus.AR processes personal data on behalf of and on the instructions of the customer laboratory that uses the Platform (for example, data of patients, dentists, employees or third parties uploaded by the laboratory), Eucalyptus.AR acts as data processor in accordance with section 25 of Ley 25.326. In such cases, the customer laboratory is the data controller vis-à-vis the data subjects, as detailed in clause ten of the SaaS Services Agreement signed between the parties (hereinafter, the "Master Agreement").
2. DATA WE COLLECT
2.1. Data voluntarily provided by the User
When a User completes a form on the Site (for example, a demo or commercial contact request), we collect: first and last name, email address, name of the laboratory, telephone or WhatsApp, free-form message and any other information that the User decides to provide.
When a User registers and uses the Platform, we collect account information (name, email, encrypted password, assigned role), billing information (tax details, CUIT, VAT status, payment methods) and data uploaded during the operation of the Service.
2.2. Data uploaded by the User about third parties
Through the Platform, the User may upload personal data of third parties, including dentists, patients and employees. This data may include name, contact details, information about the requested prosthesis and other data related to the dental work. Eucalyptus.AR processes this data exclusively on behalf of and on the instructions of the User, in its capacity as data processor.
Health-related data constitutes sensitive data under section 2 of Ley 25.326 and section 8 of Ley 26.529 on Patient Rights. The User is responsible for having the legal bases and consents required for its processing, as well as for informing the data subjects under section 6 of Ley 25.326.
2.3. Automatically collected data
When the Site is browsed, technical information is automatically collected, including IP address, browser type and operating system, pages visited, date and time of access, referring site and interaction data. This information is obtained through cookies and similar technologies, in accordance with section 6.
3. PURPOSES OF THE PROCESSING
Eucalyptus.AR processes personal data for the following purposes: to handle demo, quote and commercial contact requests; to send operational communications about the Service (technical notices, contractual changes, security notifications, payment reminders); to provide, maintain and improve the Platform and associated services; to manage billing, collection and compliance with tax obligations (Ley 11.683, Tax Code of CABA and concordant rules); to comply with legal, regulatory, judicial or administrative obligations; to prevent fraud, abuse and unlawful use of the Service; to carry out statistical, aggregated and de-identified analyses to improve the product; to send commercial communications about new features, product news or content of interest, provided that the User has given consent or there is a pre-existing commercial relationship that enables it.
The data will not be processed for purposes different from or incompatible with those reported herein, except with new consent of the data subject or the existence of another enabling legal basis.
4. LEGAL BASES OF THE PROCESSING
The processing of personal data is based on one of the following grounds provided for by Ley 25.326: (a) free, express and informed consent of the data subject (section 5); (b) performance of a contractual or pre-contractual relationship (including the Master Agreement between Eucalyptus.AR and the User); (c) compliance with legal obligations incumbent on Eucalyptus.AR; (d) legitimate interest of the PROVIDER, provided that the fundamental rights of the data subject do not prevail; (e) exceptions expressly provided for by Ley 25.326, in particular those set forth in section 5 subsection 2.
5. RECIPIENTS AND TRANSFERS
5.1. Subprocessors
Personal data may be shared with technology service providers acting as data processors of the PROVIDER (cloud hosting, email delivery, payment processing, support, analytics, lead management and CRM, electronic invoicing), who access the data exclusively to provide their services and under contractual confidentiality and security obligations equivalent to those assumed herein.
Eucalyptus.AR uses, among others: Google Analytics (Google LLC) for Site analytics; HubSpot, Inc. for management of contact forms and CRM; and cloud infrastructure providers (hyperscalers such as Amazon Web Services, Microsoft Azure, Google Cloud Platform or others). The updated list of subprocessors applicable to the operation of the Service for contracting customers is detailed in the Technical Annex of the Master Agreement. The User expressly authorizes the engagement of these subprocessors.
5.2. Public authorities and corporate reorganizations
The data may be shared with public, judicial or administrative authorities when there is a valid legal request, and with third parties in the framework of a possible corporate reorganization, merger, acquisition or transfer of going concern of Eucalyptus.AR, in which case the data shall be transferred under the same protection conditions.
5.3. International transfers
Some of the providers and subprocessors mentioned are located outside the República Argentina. International data transfers are made respecting the provisions of section 12 of Ley 25.326. Argentina maintains the status of adequate country before the European Union (revalidated by the European Commission in January 2024). Eucalyptus.AR assesses that its providers offer adequate levels of protection or, failing that, executes contractual clauses ensuring the protection of the data.
6. COOKIES AND SIMILAR TECHNOLOGIES
The Site uses first-party and third-party cookies for the following purposes: (a) strictly necessary cookies, indispensable for the operation of the Site; (b) analytical cookies, which collect statistical information about the use of the Site (Google Analytics); (c) functionality and marketing cookies linked to tools such as HubSpot.
The User may configure their browser to reject or delete cookies. Deactivating cookies may limit the operation of the Site.
7. RIGHTS OF THE DATA SUBJECT
In accordance with Ley 25.326 and the Constitución Nacional (section 43, third paragraph), the data subject has the following rights:
Right of access: to know whether their data is being processed and, where appropriate, to obtain information about the processing (section 14).
Right of rectification, updating or deletion: to request the correction of inaccurate data, its updating or deletion when appropriate (section 16).
Right to confidentiality: to have their data processed confidentially (section 10).
Right to object: to object to the processing in the cases legally provided for.
Right to withdraw consent at any time, without retroactive effect.
To exercise these rights, the data subject may contact info@dentu.com.ar attaching identification that allows verification of their identity. Eucalyptus.AR shall respond within the timeframes provided by the regulations in force: ten (10) calendar days for access, and five (5) business days for rectification, updating or deletion, in accordance with sections 14 and 16 of Ley 25.326.
When the data has been uploaded to the Platform by a customer laboratory (for example, data of a patient uploaded by the laboratory that serves them), the data subject must address their request to the laboratory, in its capacity as data controller. Eucalyptus.AR, as data processor, shall reasonably cooperate with the laboratory to handle the request, to the extent provided for in clause ten of the Master Agreement.
8. SUPERVISORY AUTHORITY
The Agencia de Acceso a la Información Pública (AAIP), created by Ley 27.275, is the supervisory body for Ley 25.326 and has powers to handle complaints and claims from personal data subjects.
AAIP contact details: Av. Pte. Gral. Julio A. Roca 710, piso 3°, Ciudad Autónoma de Buenos Aires. Website: https://www.argentina.gob.ar/aaip
In the Ciudad Autónoma de Buenos Aires there is also Ley 1.845 on Personal Data Protection, the enforcement authority of which is the Defensoría del Pueblo de la Ciudad, competent with respect to public and private sector databases located in the jurisdiction of CABA.
9. DATA RETENTION
Eucalyptus.AR retains personal data for the time necessary to fulfill the purposes for which it was collected and as long as the relationship with the User or the data subject subsists.
Upon termination of the Master Agreement, Eucalyptus.AR shall make the processed personal data available to the User for a period of thirty (30) calendar days, after which it shall be securely deleted, except for any legal retention obligation.
Once the applicable retention period has expired, the data shall be deleted or anonymized, unless it must be kept due to a legal, tax, contractual obligation or because it is necessary for the exercise or defense of possible claims.
10. INFORMATION SECURITY
Eucalyptus.AR implements reasonable technical and organizational measures to protect personal data against loss, unauthorized access, alteration or improper disclosure, in accordance with the standards provided for in Resolución AAIP 47/2018 (Recommended Security Measures) and industry best practices. These measures include, among others, encryption in transit (TLS), per-user and per-role access control, periodic backups, environment segregation and provider review.
Without prejudice to the backup policies that Eucalyptus.AR may implement, the User assumes the obligation to maintain their own export and backup policies for data whose integrity and availability are critical to them, in accordance with clause ten of the Master Agreement.
No system is invulnerable. In the event that a security incident that could compromise personal data under processing is detected, Eucalyptus.AR shall notify the User within a reasonable timeframe in accordance with the magnitude and characteristics of the event, reasonably cooperating in its management, and shall involve the competent authorities when appropriate under applicable regulations.
11. MINORS
The Site and the Platform are not directed to persons under 18 years of age. We do not knowingly collect personal data of minors. If a parent, guardian or legal representative detects that a minor has provided data to Eucalyptus.AR, they may request its deletion by writing to info@dentu.com.ar.
12. COMMERCIAL COMMUNICATIONS
When we send commercial communications by email, in accordance with Disposición DNPDP 4/2009 and concordant rules, we include a simple and free mechanism so that the recipient can request to opt out of receiving them. Eucalyptus.AR unsubscribes those who so request within the timeframes provided by the regulations.
13. MODIFICATIONS OF THIS POLICY
This Policy may be modified by Eucalyptus.AR at any time. The updated version shall be published on the Site with its last updated date. When the changes are substantial, registered Users shall be notified by email at least thirty (30) calendar days in advance of their entry into force.
14. CONTACT
For inquiries, claims or the exercise of rights related to this Policy:
EUCALYPTUS AR S.A.S. CUIT: 30-71875904-4 Address: Avenida Congreso 2277, Piso 6, Departamento "A", C.P. 1428, Ciudad Autónoma de Buenos Aires, República Argentina Email: info@dentu.com.ar
The data subject may file complaints or claims with the Agencia de Acceso a la Información Pública (AAIP) when they consider that their request was not properly addressed.