Contents
- Who we are
- What data we process
- Purposes and legal bases
- Booking form and WhatsApp
- Medical data
- Video surveillance
- Photos and social media
- Who we share data with
- Transfers outside the Republic of Moldova
- How long we keep data
- How we protect data
- Your rights
- Children’s data
- Cookies
- Changes to this policy
1. Who we are
The data controller is Apple Dent SRL, company ID (IDNO) 1020606002117, registered office: Soldanesti, 31 Pacii St., office 24, MD-7201, Republic of Moldova; clinic address: Soldanesti, 6 Testimiteanu St., MD-7201, Republic of Moldova (“Apple Dent”, “the clinic”, “we”).
Data protection contact:
Email: appledent.sd@gmail.com · Phone: +373 69 423 112 · Clinic address: Soldanesti, 6 Testimiteanu St., MD-7201, Republic of Moldova
We process personal data in accordance with the personal data protection legislation of the Republic of Moldova, healthcare legislation (including Law No. 263/2005 on patients’ rights and responsibilities) and, where applicable, Regulation (EU) 2016/679 (GDPR).
2. What data we process
- Identification and contact data: first and last name, phone number, email address (if you email us).
- Booking data: the service you want, your preferred date and the message you send us.
- Medical data: relevant dental and medical history, diagnosis, treatment plan and progress, X-rays and clinical photos — only if you become our patient.
- Technical data: IP address and browser information, processed automatically by our hosting provider in server logs for website security.
We do not use analytics or advertising tools and we do not build marketing profiles.
3. Purposes and legal bases
| Purpose | Data | Legal basis |
|---|---|---|
| Handling booking requests and answering questions | contact, booking | your consent and steps taken at your request before entering into a contract |
| Providing dental services and keeping medical records | identification, medical data | performance of the medical services contract and legal obligations in healthcare |
| Accounting and tax records | billing and payment data | legal obligation |
| Website security and defending the clinic’s rights | technical data, correspondence | the clinic’s legitimate interest |
4. Booking form and WhatsApp
The website form does not store data on our server. When you tap “Send via WhatsApp”, the details you entered are turned into a message that opens in the WhatsApp app, and you decide whether to send it to the clinic’s number +373 69 423 112.
WhatsApp is provided by WhatsApp Ireland Ltd. / Meta Platforms, which processes data under its own privacy policy. Messages are end-to-end encrypted. If you prefer not to use WhatsApp, you can call or email us instead.
Please do not send sensitive medical details through the form or messaging apps — we will discuss them confidentially during your consultation.
5. Medical data
Health data is a special category of personal data. We process it only for diagnosis and treatment, by medical staff bound by professional secrecy, on the basis of the medical services contract and our legal obligations. Before procedures that require it, we ask for your informed consent in accordance with patients’ rights legislation.
6. Video surveillance
For the safety of patients, staff and property, the clinic uses video surveillance in areas marked with warning signs (mainly the entrance and common areas). The legal basis is the clinic’s legitimate interest. Recordings are accessible only to authorised persons, kept for no more than 30 days and then deleted automatically, unless they are needed to investigate an incident or are requested by the authorities as provided by law.
7. Photos and social media
We never publish clinical photos, before/after images or any other images of patients on our website or social media without their explicit, separate written consent, which can be withdrawn at any time. If you message us on our Facebook page, the message is also processed by Meta Platforms Ireland Ltd. under its own policy.
8. Who we share data with
We never sell or rent your data. We may share it, strictly as needed, with:
- dental laboratories we work with to produce prosthetic work (only the data needed for the work);
- our accountant and advisers, who are bound by confidentiality;
- IT and communication service providers: website hosting, email (Google — Gmail), WhatsApp (Meta) and Viber (Rakuten Viber), when you contact us through these channels;
- public authorities and courts, where the law requires it.
9. Transfers outside the Republic of Moldova
Some providers (for example Meta/WhatsApp, Rakuten Viber and Google — for email and, only if you allow it, for the map) may process data in the European Union or other countries. In these cases we rely on the safeguards offered by these providers (standard contractual clauses or equivalent mechanisms), in line with applicable law.
10. How long we keep data
- Booking requests and correspondence — up to 12 months after the last interaction, if you do not become a patient.
- Medical records — for the period required by healthcare legislation.
- Accounting and sales documents — for the periods required by accounting and tax law; data needed for warranty purposes — at least for the warranty period.
- Video recordings — up to 30 days.
- Technical server logs — according to the hosting provider’s settings, usually up to 30 days.
When these periods expire, data is deleted or anonymised.
11. How we protect data
We apply appropriate technical and organisational measures: access limited to authorised staff, confidentiality obligations, secure storage of documents, an encrypted (HTTPS) connection on the website and strong passwords for the systems we use.
12. Your rights
Regarding your data, you have the right to:
- be informed and access the data we process;
- request rectification of inaccurate or incomplete data;
- request erasure, except for data we are legally required to keep (e.g. medical records);
- request restriction of processing and object to processing based on legitimate interest;
- receive the data you provided in a structured format (portability), where the law provides for it;
- withdraw your consent at any time, without affecting the lawfulness of earlier processing;
- lodge a complaint with the National Center for Personal Data Protection of the Republic of Moldova (datepersonale.md) or go to court.
To exercise your rights, email us at appledent.sd@gmail.com. We reply without undue delay and within the legal deadline. We may ask you to confirm your identity to protect your data.
13. Children’s data
Appointments and treatment for patients under 18 take place with the consent and in the presence of a parent or legal guardian, who exercises the rights regarding the minor’s data.
14. Cookies
The website only uses strictly necessary storage, and Google Maps loads only with your consent. See our Cookie Policy for details.
15. Changes to this policy
We may update this policy when the law or the way we work changes. The current version is always published on this page, with the date of the last update.
Contact
For any question about this document, you can contact us at appledent.sd@gmail.com · +373 69 423 112.