Privacy Policy

1. INTRODUCTION

Apogei Medical Center for Specialized Outpatient Care – Dr. Angelov, Sie SD understands that privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this online store/link to website/and we collect and use your personal data only as described in this Privacy Policy. Any personal data we collect will be used only in the manner permitted by Bulgarian and European law.

Information about us:

Our online store is owned and managed by “Medical Center for Specialized Outpatient Care Apogei – Dr. Angelov, Co.” LLC, UIC: 817031403.

Headquarters and registration address: 2 Kukush Str., Gabrovo, 5300.

Manager: Dr. Hristofor Hristov Angelov

Correspondence email:info@apogeymedical.com

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT BASIS DO WE PROCESS IT?

According to Regulation (EU) 2016/679 (GDPR), “personal data” means any information relating to an identified natural person or to an identifiable natural person, directly or indirectly.

Medical Center for Specialized Outpatient Care “Apogei – Dr. Angelov, SIE” JSC understands that privacy is important to you and that you care about how your personal data is used. We respect and protect the privacy of all visitors to our website and collect and use your personal data only in accordance with this Privacy Policy.

All personal data is processed in accordance with applicable Bulgarian and European legislation, including Regulation (EU) 2016/679 (GDPR).

Our website provides the opportunity to book appointments and pay for medical services online.

The website does not collect or process data related to the health status of patients..

We may process the following categories of personal data about you:

• Communication data– This includes any communication you send to us, whether via our online store contact form, email or any other communication. We process this data for the purpose of communicating with you, for record keeping and for the establishment, exercise or defence of legal claims. Our lawful basis for this processing is our legitimate interest.
• Client/Patient Data– includes data necessary to make a reservation for a medical service, namely: name, surname, telephone number, email address, as well as date, time and type of the selected service. The processing of this data is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
• User data– This includes data about how you use our online store. We process this data to manage and administer our online store and ensure that you are provided with appropriate content, to ensure the security of our online store, to maintain backups, etc. Our lawful basis for processing is our legitimate interests, which in this case are to allow us to properly administer our site and our business.
• Technical data– This includes data about your use of our online store and online services, such as your IP address, your login details, your browser details, the length of time you spend on individual pages, page views and other technologies on the devices you use to access our website. Our lawful basis for this processing is our legitimate interests, which in this case are to allow us to properly administer our website/online store and business, to develop our business and to determine our marketing strategy.

Payment information

We do not collect or store your payment card details. Payments made through our website are processed securely through DSK Bank AD as our payment service provider.

When you choose a payment method through DSK Bank, the information necessary to process the transaction is collected and processed directly by the bank, in accordance with its own privacy policies and applicable payment service security requirements.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect personal data when you:

• You use our website to book an appointment;
• You are making a payment for a service;
• Contact us by email or via contact form.

We also automatically collect technical data through cookies and similar technologies when you use the website.

4. MARKETING COMMUNICATIONS

Our legal basis for processing your personal data for the purpose of sending marketing messages is your consent and/or our legitimate interest, namely the development and promotion of our services.

We may send you marketing messages if you have made a reservation for a medical service or have expressed interest in our services, including by requesting information.

We will not share your personal data with third parties for their own marketing purposes without your express prior consent.

You have the right to opt out of receiving marketing communications at any time by using the unsubscribe link included in each communication or by contacting us at:info@apogeymedical.com

If you opt out of marketing communications, this will not affect your receipt of service-related communications, including appointment confirmations, reminders, or administrative notifications.

5. DISCLOSURE OF YOUR PERSONAL DATA

We may need to disclose or share your personal data with the following categories of recipients:

• Companies from our group that provide services related to the administration and operation of our business;
• Service providers, including information technology providers, hosting, website maintenance and system administration;
• Payment service providers – DSK Bank AD, for the purposes of processing payments and making bank transfers. The Bank acts as an independent controller of personal data in accordance with applicable data protection legislation;
• Professional consultants, including lawyers, accountants, auditors, banks and insurers;
• Competent government and regulatory authorities, when required by law or in connection with the fulfillment of our legal obligations;
• Third parties to whom we may sell, transfer or merge some or all of our assets or business.

We require all third parties to whom we provide your personal data to maintain data security and to process it in accordance with applicable data protection legislation. We permit them to process personal data only for specific purposes and in accordance with our instructions, except where they act as independent data controllers (for example, payment service providers who process payments, in accordance with their own privacy policies).

6. INTERNATIONAL TRANSFERS

We may need to transfer your personal data outside the European Economic Area (EEA) by using the services of external providers or when data processing is related to international banking operations.

This may include, but is not limited to, information technology providers, hosting services and other technical or support systems, as well as participants in the payment infrastructure, including banks and financial institutions involved in processing payments through DSK Bank.

When your personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place in accordance with applicable data protection legislation. These measures may include:

• Transfer to countries for which an adequate level of data protection solution is in place;
• Use of standard contractual clauses approved by the European Commission or the relevant supervisory authority;
• Additional technical and organizational measures for data protection.

You can contact us if you would like further information regarding international transfers of your personal data and the safeguards we use.

7. DATA SECURITY

We implement appropriate technical and organizational security measures to protect your personal data from accidental or unlawful loss, use, alteration, unauthorized disclosure or access.

Access to your personal data is granted only to employees, associates and partners who need to process it to perform their duties. These persons process personal data only on our instructions and are bound by an obligation of confidentiality.

To protect personal data, we implement a number of information security measures, including:

• Using SSL (Secure Socket Layer) encryption for secure communication;
• Data encryption, where applicable;
• Regular data backup for disaster recovery purposes;
• Email protection through filtering and anti-spam systems;
• Antivirus protection and regular system scanning;
• Access control to information systems.

We also have procedures in place to manage incidents related to the security of personal data. In the event of a security breach that poses a risk to the rights and freedoms of natural persons, we will notify the relevant supervisory authority and the individuals affected, where required by applicable law.

8. DATA STORAGE

We store your personal data only for the period necessary to fulfill the purposes for which it was collected, including the purposes of fulfilling legal, accounting and reporting obligations.

When determining the appropriate retention period for personal data, we consider the following factors:

• The volume, nature and sensitivity of the data;
• The potential risk of time from unauthorized use or disclosure;
• The purposes for which we process the data and the possibility of achieving these purposes in an alternative manner;
• Applicable legal, regulatory and contractual requirements.

For tax and accounting purposes, we store basic customer information, including contact details, identification data, financial data and transaction data, for a period of up to 10 (ten) years, when required by the accounting and tax legislation of the Republic of Bulgaria, and in other cases – up to 6 (six) years after the last service provided or transaction performed.

In certain cases, we may anonymize your personal data for statistical, analytical or research purposes. In such cases, the information no longer allows your identification and may be used for an indefinite period of time without further notice.

9. YOUR LEGAL RIGHTS

According to Bulgarian and European data protection legislation, you have the following rights, which we are obliged to observe and respect:

• Right to information– to be informed about the collection and use of your personal data. This Privacy Policy aims to provide you with this information. If necessary, you can contact us at:info@apogeymedical.com.
• Right of access– to receive confirmation whether we are processing your personal data and, if so, to gain access to it.
• Right to rectification– to request correction of inaccurate or incomplete personal data.
• Right to erasure(“the right to be forgotten”) – to request the deletion of your personal data under the conditions provided for by law.
• Right to restriction of processing– to request restriction of the processing of your personal data in certain cases.
• Right to object– to object to the processing of your personal data when it is based on legitimate interest or is used for certain purposes.
• Right to withdraw consent– where processing is based on consent, you have the right to withdraw it at any time, without affecting the lawfulness of the processing before the withdrawal.
• Right to data portability– where applicable, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transfer them to another controller.
• Rights in relation to automated decision-making and profiling– we do not use your personal data for automated decision-making or profiling.

For more information about exercising your rights or the processing of your personal data, you can contact us at:info@apogeymedical.com.

It is important that your personal data is accurate and up-to-date. Please notify us promptly if the data you have provided changes.

10. LINKS TO THIRD PARTIES

Our website may contain links to websites, plug-ins and applications operated by third parties.

When using such links or functionalities, third parties may collect or share data about you.

We do not control these third-party websites and are not responsible for their privacy policies or practices. We encourage you to review the privacy policy of any external website you visit after you leave our website.

11. COOKIES

You can set your browser to refuse all or some cookies or to notify you when websites set or access cookies.

If you disable or refuse the use of cookies, please note that some website functionalities may become unavailable or may not work properly.

What is a cookie?

A “cookie” is information that is stored on your computer’s hard drive, if you consent to it. It records how you navigate a website so that when you visit it again, it can offer you personalized options based on the information stored from your last visit. Cookies can also be used for traffic analysis, as well as for advertising and marketing purposes.

Cookies are used by almost all websites and do not harm your system.

We are required to obtain your consent for all non-essential (necessary) cookies used on our website. You may block cookies at any time by activating the settings on your browser that allow you to refuse the placement of all or some cookies. However, if you use your browser settings to block essential cookies, you may not be able to access all or parts of the site.

How do we use cookies?

We use cookies to track the use of our website. This allows us to understand how you use the site and track patterns in your behavior. This helps us develop and improve our website, as well as our products/services, according to your needs and preferences.

Cookies come in two types:

• Session cookies: They are stored on your computer only during your internet session and are automatically deleted when you close your browser. They do not collect personal data from your computer.
• Persistent cookies: They are stored as a file on your computer and remain there even after you close your browser. They can be read by the website (online store) that created them when you visit it again. We use persistent cookies for Google Analytics.

Cookies can be classified as follows:

• Strictly necessary cookies:They are essential for you to be able to use the website effectively, for example when purchasing a product and/or service. Without these cookies, the services available on our site cannot be provided. These cookies do not collect information about you that could be used for marketing purposes or to track your online behavior.
• Performance cookies:They allow us to monitor and improve the performance of the website. For example, they allow us to count visits, identify traffic sources, and see which parts of the site are most popular.
• Functional cookies:They allow our website to remember choices you make and provide enhanced features. For example, they can provide you with news or updates related to the services you use. The information collected by these cookies is usually anonymous.
• Targeting cookies:They record your visit to our website, the pages you have visited, and the links you have followed. We will use this information to make the website and the advertising on it more relevant to your interests.
• First-party and third-party cookies: First-party cookies are those that are set by our website. Third-party cookies are those on our website that are set by a site other than ours, for example, when we have advertisements on our site or use Facebook pixels so that we can show you relevant content from us when you are on Facebook.

More detailed information about the individual cookies we use, as well as the purposes for which we use them, can be found in the table below:

You can change your cookie settings at any time by changing the settings in our cookie consent tool. Please refresh the page to ensure the new settings have taken effect.

In case the cookie consent tool does not appear on our website, please open our site in a new window in incognito mode.

You can also control cookie settings through your web browser.

If you have any questions about the cookies we use, please do not hesitate to contact us at:info@apogeymedical.com

12. CHANGES TO THIS PRIVACY POLICY

We may update or change this Privacy Policy from time to time. This may be necessary, for example, if applicable law changes or if there are changes in the way we process personal data in connection with our business.

Any changes to the Privacy Policy will be posted on our website in a timely manner. The updated version will be effective from the time of its posting, unless otherwise stated.

Continued use of our website after the posting of amendments is deemed acceptance of the updated Privacy Policy.

We recommend that you periodically review this page to be informed of any changes.