TERMS OF USE OF THE AI ASSISTANT AND CONSENT TO DATA PROCESSING
Perfect Smile Dental Clinic
Data Controller: Private Medical Unitary Enterprise "Fabrika Ulybki", Taxpayer Identification Number (UNP) 190485787
Version: 1.0 dated October 22, 2026
Effective Date: October 22, 2026
1. What Is the AI Assistant?
1.1. The AI Assistant available on the Perfect Smile website (hereinafter referred to as the Chat) is an automated information service that helps visitors obtain general information about the Clinic, dental services, and administrative matters.
1.2. The Chat is not a medical professional and does not perform examinations or diagnostics, establish diagnoses, or prescribe treatments, medications, or medical procedures. Chat messages do not constitute a medical opinion, prescription, treatment plan, appointment confirmation, or agreement for the provision of medical services.
1.3. Responses are generated automatically and may contain errors, incomplete information, or outdated information. Medical decisions require consultation with a qualified specialist at the Clinic. In an emergency, users must seek emergency medical assistance rather than wait for an AI response.
1.4. The Clinic reserves the right to temporarily disable the Chat in the event of technical errors or an inability to comply with the necessary data protection requirements.
2. Rules of Use and Restrictions
2.1. The Chat is intended for adult users. Users may ask questions relating to general information about services, the Clinic's address, opening hours, and appointment booking procedures.
2.2. Do not submit diagnoses, medical images, laboratory test results, medical records, medical record numbers, passport details, comprehensive treatment information, third-party personal data, or other sensitive information through the Chat. If individual medical advice is required, please contact the Clinic through its designated communication channels to arrange an in-person consultation.
2.3. Free-text input in the Chat is technically processed: the warning in Section 2.2 does not prevent users from entering health-related information. If such information is submitted, it may be processed on the server and transmitted to external AI service providers.
2.4. Users must not attempt to circumvent the service's technical restrictions, extract confidential system information, or use the Chat to send automated messages in bulk. The Clinic reserves the right to impose request rate limits to protect the service.
3. Information Processed
3.1. When the user clicks the send button, the Clinic's server receives the text of the user's message and the context of the recent conversation. Under the current implementation, up to six most recent messages are used to generate a response. A technical input length limit is enforced by the server.
3.2. Technical information (such as IP addresses used for in-memory rate limiting) is processed to protect the service against excessive requests. The Data Controller does not use this processing for advertising or medical profiling.
3.3. Responses may incorporate information from the Clinic's knowledge base, which contains details about services, medical professionals, and other reference materials. The server generates system instructions before submitting requests. Visitor messages must not be added to the permanent administrative knowledge base.
3.4. The Chat does not request the uploading of medical images or files.
4. AI Services Used and Data Transfers
4.1. To generate responses, the Clinic's server communicates with OpenRouter as a request-routing service, which subsequently routes requests to the OpenAI GPT-4o mini model.
4.2. According to the latest documented configuration, the Clinic requires the following settings for requests:
- Azure OpenAI as the sole selected provider;
- Prevention of request routing to alternative providers;
- Data retention minimization and prohibition of data collection for the specified purposes;
4.3. These settings relate to technical request routing and do not mean that message content remains exclusively on the Clinic's server. Transmitted data is received by OpenRouter and the selected model provider's infrastructure for the purpose of processing the request. Actual retention periods and the obligations of the parties depend on the providers' applicable terms.
4.4. Recipients and Geographic Scope:
To provide the AI Assistant functionality, Private Medical Unitary Enterprise "Fabrika Ulybki" uses the following third-party services:
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OpenRouter, Inc. (United States) — an AI model request-routing service. Visitor messages and the necessary conversation context are transmitted through OpenRouter's infrastructure.
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Microsoft — Azure AI (Azure OpenAI) infrastructure — the provider of computing infrastructure used to process messages with the GPT-4o mini model developed by OpenAI.
Personal data is processed using infrastructure located outside the Republic of Belarus and may involve cross-border data transfers, including transfers to the United States of America, as well as processing in other countries in accordance with the applicable terms and infrastructure of the respective providers.
To deliver their services, providers may engage affiliated organizations and subcontractors, including cloud infrastructure, networking, and technical service providers. Current information about such entities is published in the respective providers' documentation.
The Clinic uses technical settings designed to ensure that requests are routed exclusively to the selected provider of the OpenAI model, prevent automatic fallback to alternative providers, prohibit data collection for model training, and require Zero Data Retention (ZDR).
Under the applicable terms, ZDR provides for the processing of messages to generate responses without subsequent retention of their content by the relevant AI provider. This arrangement does not eliminate the transfer of data itself and does not automatically apply to all categories of technical, account-related, or operational data.
The Clinic does not permanently store AI Assistant conversation histories in its own database. The retention and processing periods for technical information handled by external providers are governed by their applicable terms.
5. Data Retention and Deletion
5.1. According to the current technical description, conversation text is not stored in the Website's persistent database. Messages are processed by the server to generate responses. Request rate-limiting counters may remain in the application's memory until they are reset or the application is restarted.
5.2. The browser interface may display messages during the current session.
5.3. The Clinic must not record message content in server logs, error logs, or backups.
6. User Information and Consent
6.1. Before the first message is submitted, the Chat displays its main limitations and information about data transfers to OpenRouter/OpenAI. *
6.2. Where consent is used as the legal basis for processing, the Data Controller provides the following separate consent statement:
Consent to the Processing of AI Chat Messages. I hereby consent to Private Medical Unitary Enterprise "Fabrika Ulybki" collecting and processing the messages I submit and a limited amount of conversation context for the purpose of generating automated informational responses through the AI Assistant. I understand that, for this purpose, message content is transmitted through OpenRouter to the OpenAI GPT-4o mini model and may be processed outside the Republic of Belarus. Information about data recipients, countries, and applicable conditions is provided in Section 4. This consent covers the collection, temporary processing, and transfer of the specified data to the identified recipients, as well as the termination of processing in accordance with the established conditions. I have been informed of my rights, the procedure for withdrawing consent, and the consequences of refusing consent (the Chat will be unable to process my question, but other pages of the Website will remain accessible). I understand that the response does not constitute medical advice and that I should not provide health-related information.
6.3. If a user does not provide the required consent, their message will not be transmitted to the third-party provider. This does not restrict their ability to use the Clinic's standard contact form.