Privacy Policy

This Privacy Policy, based on the General Data Protection Regulation, GDPR, explains which personal data are collected in connection with our activities, how we process, use and protect such data, for which purposes we use them, as well as your rights relating to your personal data.

Privacy and the protection of personal data are fundamental principles of our business

The privacy of individuals and the protection of personal data are fundamental human rights. We have a duty to take care of the personal data we collect, process and store. Your personal data are our responsibility, and we collect and process them only when necessary, while ensuring appropriate security measures for their protection.

IMPLANT CENTRE MARTINKO d.o.o., a member of Adria Dental Group, the largest dental medicine group in the Adriatic region, follows the principles below in order to protect the privacy and personal data of its patients and all persons whose personal data we process:

• We do not collect more personal data than is necessary.
• We do not use personal data for purposes of which you have not been informed in a timely manner.
• We do not retain personal data when this is no longer necessary.
• We never sell, lend or distribute personal data.
• We do not send personal data to third parties without your knowledge and unless it is lawful to do so.
• We do not use any automated processing for decision-making or profiling.
• We continuously ensure that personal data are stored securely and protected.

It is important that you read this Privacy Policy, and we hope you will take the time to do so. We have made every effort to write it as clearly and understandably as possible, with the aim of maintaining your full trust in the way we handle your personal data.

If, after reading this Privacy Policy, you have any further questions about personal data protection at IMPLANT CENTRE MARTINKO, you may contact our Data Protection Officer at any time:

Igor Barlek, CIPP/E, Data Protection Officer of Adria Dental Group

• by email at bi@biconsult.hr or info@implant-centre-martinko.com
• by post at IMPLANT CENTRE MARTINKO d.o.o., Zagrebačka cesta 126, 10000 Zagreb, Croatia
• by post at Adria Dental Group, Ulica Josipa Marohnića 3, 10000 Zagreb, Croatia

We regularly improve our Privacy Policy in order to further enhance the protection of your data.

This Privacy Policy was updated on 22 April 2026.

1. Who we are

IMPLANT CENTRE MARTINKO d.o.o., Zagrebačka cesta 126, 10000 Zagreb, Croatia, is the controller of your personal data and determines the purposes and means of processing your personal data. It is also responsible for ensuring all security measures for the protection of your personal data.

In relation to patients’ personal data, IMPLANT CENTRE MARTINKO d.o.o. also acts as a joint controller together with affiliated companies, namely dental laboratories within Adria Dental Group and our group company ADRIA DENTAL GROUP d.o.o., Ulica Josipa Marohnića 3, 10000 Zagreb, Croatia.

2. What data we process, how and for how long

When potential patients book a free specialist examination

For this purpose, we require your basic personal data, such as your first and last name, as well as your contact details, including email address and telephone number. These data are necessary for effective communication, for a better understanding of your wishes and needs, and for arranging the date of your first examination.

Providing a dental scan or orthopantomogram is welcome, but only if you already have one and wish to share it with us. Such data are processed in accordance with the GDPR rules on health data as special categories of personal data, with the highest level of security in the processing of such personal data.

If you decide not to proceed with the free specialist examination, we will permanently delete all your personal data.

When providing dental medicine services to our patients

During the provision of dental medicine services, we are required to collect all data relating to your dental health and to keep a patient record. We also collect the necessary set of health-related personal data, such as the presence of chronic diseases, possible allergies, infections, specific circumstances related to receiving anaesthesia and similar information.

These data are necessary for providing dental services and protecting your health during individual specialist treatments and surgical procedures. They are processed in accordance with GDPR rules on health data as special categories of personal data and with the highest level of security.

During agreed treatments and multiple procedures, and for the purpose of monitoring the effectiveness of individual stages of treatment, we also collect photographs of patients’ dental condition. These photographs are stored exclusively in the patient record.

In your patient record, we retain all data relevant to ensuring the highest quality of your dental health. In accordance with legal regulations in the field of dental medicine, we are required to keep such data for ten years after treatment has been completed, while fully respecting patients’ rights to confidentiality regarding health-related data and the rules on professional secrecy. Older data are archived.

In your best interest and in order to ensure the highest quality of dental medicine services, we may refer you to another clinic within Adria Dental Group or use the services of dental laboratories that are members of Adria Dental Group. In doing so, in accordance with legal regulations in the field of dental medicine and the preservation of professional dental secrecy, we may also forward your medical documentation.

All members of our team are required to treat as professional secrecy everything they know about your health condition. Access to all your personal data is strictly limited. In accordance with the Healthcare Act, we are obliged to provide access to your personal data upon request by the competent ministry, other state administration bodies in accordance with special regulations, the Croatian Dental Chamber and competent judicial authorities.

For the purpose of issuing invoices for services, we retain the necessary set of basic personal data, including first name, last name, personal identification number, address and service provided, in accordance with accounting and tax regulations.

Video surveillance

Exclusively for the purpose of protecting the safety of our patients, employees and all persons covered by the lawful recording perimeter, as well as for the protection of property and prevention of unlawful acts against the clinic’s property, such as theft, robbery, burglary, violence, destruction and similar acts, we monitor only the acceptable area inside and around the clinic’s business premises.

This is carried out in accordance with our justified and documented legitimate interest. The recording perimeters are clearly marked with easily visible notices.

Video surveillance recordings are generally stored for up to eight days, depending on the amount of recorded material on the storage medium.

Recording of telephone conversations

The system for recording telephone conversations between patients and our agents is used for the purpose of analysing received complaints and proving their resolution, preventing fraud, ensuring compliance and improving communication with patients, in accordance with a valid legitimate interest.

Recordings of telephone conversations are retained in the system for the shortest period necessary to achieve the purpose, and for no longer than one year from the date the recording was made. After this period, they are permanently deleted.

Tracking of company vehicles

The GPS tracking system for our patient transport vehicles is used for the purpose of protecting property and people, as well as ensuring the optimal use of the vehicle fleet, in accordance with a valid legitimate interest.

Records of company vehicle movements are retained for a period of up to 12 months.

Selection of job candidates and employment

During recruitment and employment selection procedures, we collect basic candidate data with the intention of concluding an employment contract. These data include first and last name, residential address, email address, telephone number, education, work experience and other data you provide to us through your CV.

After the selection process has been completed, selected candidates are employed, and we collect all necessary data in accordance with legal obligations. Applications and personal data of candidates who are not selected are returned upon request or permanently destroyed. Based on your consent, we may retain them for possible future employment opportunities.

Personal data of job candidates are shared with our group company ADRIA DENTAL GROUP d.o.o., Ulica Josipa Marohnića 3, 10000 Zagreb, Croatia, as an affiliated company, based on a valid legitimate interest and in accordance with the provisions of the GDPR.

Consumer right to submit a complaint

Each of our patients has the right to submit a complaint or claim regarding the services provided. In such cases, we collect the necessary set of personal data of the person submitting the complaint and retain them for up to 12 months, in accordance with regulations in the field of consumer rights protection.

Use of your personal data for sending newsletters

We send newsletter updates about news from our clinic, our services and special offers based on your consent or a valid legitimate interest in using your email address for this purpose.

We use your email address for this purpose until you withdraw your consent or object and express your wish to stop receiving further notifications.

Collection of your personal data on our website

Although you may use our website without providing personal data, when you contact us through our contact form for the purpose of booking a free specialist examination or treatment, possible employment, establishing a business relationship or making an inquiry, we collect your first and last name and email address.

Information about your telephone number is particularly useful so that, by calling you back, we can more accurately determine your wishes and needs in the field of dental health.

As long as communication is ongoing in terms of establishing cooperation and arranging a first examination, we will collect your personal data. We delete such data when further communication ends, after the expiry of all legal obligations or when the lawful grounds under the GDPR for processing your personal data cease to exist.

Our website is not intended to provide services to minors under the age of 16. For this purpose, the consent of a parent or holder of parental responsibility must be provided before personal data are submitted through our contact form.

Our website also contains links to other websites and social networks, such as Facebook, Instagram and YouTube. This Privacy Policy does not apply to those websites or social networks. We recommend that you read the privacy terms of every website and social network you visit, especially where you provide your data.

Cookies

Our website uses small text files and places them on your computer or device in order to customise your web browser interface.

Cookies necessary for ensuring the functionality of our website cannot be disabled. They are usually set in response to your actions that include a request for services, such as cookie settings, login or filling in forms.

For the use of other cookies through which we would collect your personal data, your prior consent is required. Even if you do not provide your free consent, you may still fully use our website and have uninterrupted access to all of its content.

3. Who has access to your personal data

We cooperate exclusively with trusted business partners who help us provide and improve our services and make our direct communication with you more efficient.

We provide access to your personal data to authorised external processors for the purpose of processing personal data on our behalf and based on our explicit instructions, pursuant to concluded personal data processing agreements in accordance with Article 28 of the GDPR.

These partners are obliged to strictly comply with the obligation of confidentiality in accordance with this Privacy Policy, the agreements we have concluded with them and the obligations arising from the GDPR.

Our selected external processors are business partners who provide us with services related to contacting patients, staff selection, IT services, maintenance of business applications and systems, protection of property and people, and web and email hosting. Without these services, we would not be able to ensure the highest quality of our services.

For the purpose of arranging accommodation for our patients during their arrival for a first examination and treatment at our clinic, we share your necessary personal data with trusted business partners who provide transport and accommodation services, or with a partner travel agency.

4. Your rights

You are free to contact us at any time in order to exercise your rights in the field of personal data protection. Your rights are as follows:

Right of access to personal data

You have the right to access your personal data and to be informed about which data we process, in what way, for which purpose and for how long. We also provide you with the possibility to receive a copy of your personal data.

Right to rectification of personal data

You have the right to request the correction or completion of inaccurate or incomplete personal data that we have collected.

Right to erasure of personal data

You have the right to request that we delete your personal data when the data are no longer necessary for the purpose for which they were collected, when you submit a justified objection or when your personal data are being processed unlawfully.

Right to object

You have the right to object to certain processing of your personal data. For example, you may request that we stop processing your personal data for direct marketing purposes via newsletter.

Right to restriction of processing

You may request that we restrict the processing of your data, for example when deletion, correction or objection in relation to your personal data is pending, and/or when we do not have a valid basis for processing your data but you want us to retain them.

When processing is restricted, your data will be stored and will not be further processed. For example, if you dispute the accuracy of your data, the processing of such data will be restricted until it is ensured that the data are accurate.

Right to data portability

Where processing is carried out by automated means on the basis of a contract or consent, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and, at your own discretion, to transmit such data to third parties.

Right to withdraw consent

If you have previously given your freely given and explicit consent for the public publication of intraoral photographs, facial photographs or audio/video recordings on our websites or social media, you have the full right to withdraw your consent at any time. We will then delete our publications of your photographs or audio/video recordings.

If you wish to exercise any of the above rights, you may submit a request:

• by email at info@implant-centre-martinko.com
• by post at IMPLANT CENTRE MARTINKO d.o.o., Zagrebačka cesta 126, 10000 Zagreb, Croatia

We will respond to your request as soon as possible, and no later than one month from receiving your request. If we are unable to securely confirm your identity, we may request additional verification of the identity of the person submitting the request.

If you believe that our handling of your personal data is not lawful, you may at any time lodge a complaint directly with the competent supervisory authority:

Croatian Personal Data Protection Agency, AZOP
Ulica Metela Ožegovića 16, 10000 Zagreb, Croatia
Telephone: +385 1 4609 000
Email: azop@azop.hr

Improvement of this Privacy Policy

We reserve the right to occasionally adapt and improve the text of this Privacy Policy, primarily in order to comply with legal changes or in the event of changes in the purposes and methods of processing.

However, we will not restrict or reduce your rights arising from this Privacy Policy or from applicable legal regulations.

If any changes occur that may affect your rights, we will inform you in a timely and direct manner in an appropriate way.