PERSONAL DATA PROCESSING POLICY
Private Medical Unitary Enterprise "Fabrika Ulybki"
Version: 1.0 dated October 22, 2026
Effective Date: October 22, 2026
1. General Provisions and Data Controller
1.1. This Policy establishes the procedures for processing and protecting personal data when using the Perfect Smile dental clinic website at https://perfectsmile.by (hereinafter referred to as the Website), including the processing of appointment requests, reviews, and inquiries submitted through the Website.
1.2. The Personal Data Controller is Private Medical Unitary Enterprise "Fabrika Ulybki", Taxpayer Identification Number (UNP) 190485787 (hereinafter referred to as the Clinic or the Data Controller). Business address: 35 Myasnikova Street, Premises 4, Minsk, Republic of Belarus. Registered address: 35 Myasnikova Street, Premises 4, Minsk, Republic of Belarus.
1.2.1. The Clinic provides medical services under license No. 02040/3536 issued by the Ministry of Health of the Republic of Belarus.
1.3. Data Controller's contact information: phone +375 (29) 335-35-00, email book_visit@perfectsmile.by. Questions regarding personal data processing may be directed to the specified email address. Requests for which legislation requires a specific form or identification of the applicant must be submitted in accordance with Section 9.
1.4. The Data Controller complies with the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On Personal Data Protection" and other applicable regulatory legal acts.
1.5. The Website is intended for adults. The Clinic does not provide separate appointment booking services for minors through the Website. If the Clinic identifies personal data relating to a minor that has been submitted without the required legal basis, such data will be handled in accordance with applicable legislation and either deleted or processed on another applicable legal basis.
1.6. This Policy applies to data processing through the Website. Medical records that may subsequently be created by the Clinic during the provision of medical care are maintained and retained in accordance with separate healthcare legislation requirements and are not automatically subject to the deletion rules applicable to website requests.
2. Basic Principles of Processing
2.1. The Data Controller processes personal data for specific lawful purposes, does not knowingly collect excessive data, and grants access only to individuals who require it to perform their duties.
2.2. Personal data is not used for medical profiling, the sale of databases, or advertising communications without an appropriate independent legal basis. Disclosure to third parties is permitted only where a legal basis exists and only to the extent necessary.
2.3. Visitors are advised not to include diagnoses, examination results, images of medical documents, medical record numbers, or health-related information that is unnecessary for initial communication in Website forms or the AI Chat.
3. Categories of Personal Data, Purposes, and Legal Bases for Processing
3.1. Appointment Requests, Callback Requests, and General Inquiries
Data subjects: Visitors submitting requests.
Data processed: Name, selected contact method (phone, email, or messaging application), type of inquiry, and, where provided, selected doctor, service, free-text comments, technical timestamps, and consent records. Contact information may include multiple communication channels if voluntarily provided by the visitor.
Purpose: To receive and process an inquiry, contact the visitor, and coordinate the next steps, including a possible appointment with a doctor.
Legal basis: Consent of the personal data subject to the processing of personal data in accordance with Articles 5 and 7 of the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On Personal Data Protection".
Retention period: After a request has been processed, an employee manually deletes the record. The Clinic monitors remaining records older than 30 calendar days from the date of receipt.
Recipients: Authorized users of the Website's administrative panel and the infrastructure provider within the scope of its responsibilities.
3.2. Health Information Included in Request Comments
If a visitor voluntarily provides symptoms, treatment information, or other health-related data, such information will be received and stored together with the request in a restricted-access system. Such information may constitute special categories of personal data.
Purpose: To understand the content of the inquiry and arrange communication with the Clinic; not to create a medical record or establish a diagnosis based on the form.
Legal basis: Consent of the personal data subject to the processing of special personal data concerning health status in accordance with Article 8(1) of the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On Personal Data Protection".
Access and retention: Access is limited to authorized personnel within the scope of the request. Retention and deletion are governed by Section 3.1, except where data must be retained under mandatory legal requirements.
3.3. Comments, Complaints, and Visitor Messages
Data processed: Name, contact details, and message content, including information about services provided and possible health-related information.
Purpose: To contact the visitor, clarify the circumstances, review comments or complaints, and take appropriate measures to resolve the situation.
Legal basis: Consent of the personal data subject in accordance with Articles 5 and 7 of the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On Personal Data Protection". Where a message contains special categories of personal data, including health information, the additional requirements of Article 8 of the Law apply.
Access and retention: Messages are stored until their processing is completed and are deleted by a Clinic employee no later than 30 calendar days after receipt, unless legislation provides another legal basis or mandatory retention period.
Messages submitted through the Website's contact form are intended for prompt communication with the Clinic and resolution of relevant issues. The form is not a designated channel for submitting electronic appeals under the legislation of the Republic of Belarus governing appeals from citizens and legal entities.
3.4. Reviews Submitted Directly Through the Website
Data processed: The author's name or pseudonym, review text, rating, possible association with a doctor or service, submission date, moderation records, and consent records. Review content may include health-related information.
Purpose 1 — Receipt and moderation: To review the content, verify its authenticity to the extent reasonably possible, and ensure compliance with publication rules.
Legal basis: Consent of the personal data subject in accordance with Article 5 of the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On Personal Data Protection".
The processing of special categories of personal data, including health information voluntarily provided by a visitor in a review, is carried out on the basis of the visitor's consent in compliance with Article 8(1) of the Law.
Public publication of a review, including the author's name or pseudonym, rating, review text, and, where applicable, information about the doctor or service provided, is based on the visitor's separate consent to publication.
Visitors have the right to withdraw their consent in accordance with the legislation of the Republic of Belarus. Upon withdrawal of consent, the Clinic ceases the relevant processing and removes the review from public display unless another lawful basis exists for continued processing.
Purpose 2 — Public publication: To display an approved review to other visitors. Publication occurs only after moderation and upon obtaining separate, appropriate authorization from the author.
Retention period: Automatic deletion of published and unpublished reviews is not implemented. Deletion or removal from publication is performed manually.
3.5. Use of the AI Assistant
Data processed: Messages submitted by visitors to the AI Assistant, the context of up to six most recent messages in the conversation, and technical data required for request rate limiting. Messages may contain personal data, including health-related information.
Purpose: To provide general reference information about the Clinic, its services, specialists, and appointment booking procedures. The AI Assistant does not provide medical care, establish diagnoses, or prescribe treatment.
Legal basis: Voluntary, informed consent of the personal data subject in accordance with Article 5 of the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On Personal Data Protection". Where special categories of personal data, including health information, are processed, the additional requirements of Article 8 of the Law apply.
Before submitting their first message, visitors are informed about the purposes of processing, categories of data transferred, external recipients, and potential cross-border transfers. Use of the AI Assistant is permitted only after obtaining the visitor's separate consent.
Recipients: Messages are transmitted from the Website's server through OpenRouter to the OpenAI provider for processing by the GPT-4o mini model. The current technical configuration provides for a single provider, prevents automatic switching to alternative providers (fallback), and requires Zero Data Retention (ZDR).
Cross-border transfers: Messages may be processed by external providers outside the Republic of Belarus. Such transfers are permitted subject to compliance with Article 9 of Law No. 99-Z, including applicable conditions and necessary personal data protection safeguards.
Retention: The Clinic does not store conversation history in its persistent PostgreSQL database. Messages are processed to generate responses, while technical rate-limiting data is temporarily stored in the server's memory. The procedures and retention periods for information processed by external providers are governed by their applicable terms of service.
Visitors are advised not to include diagnoses, examination results, medical documents, or other confidential health-related information in their messages.
3.6. Analytics
Yandex Metrica. The Clinic uses the Yandex Metrica web analytics service to analyze Website traffic, evaluate Website performance, identify technical issues, and improve usability.
When this service is used, the following information may be processed: IP addresses, browser identifiers and cookies, device and browser information, visited pages, referral sources, and visitor interactions with the Website.
Yandex Metrica is activated only after the visitor consents to the use of optional analytics technologies. Webvisor, click map, and link tracking features are disabled.
Legal basis: Consent of the personal data subject in accordance with Article 5 of the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On Personal Data Protection".
Retention period: Data is processed and stored by Yandex in accordance with the service's terms and the applicable retention periods for the relevant categories of information.
Google Analytics. The Clinic uses Google Analytics to analyze Website traffic, collect statistics on visitor interactions with Website pages, and improve Website performance and quality.
When Google Analytics is used, the following information may be processed: device and browser characteristics, cookie identifiers, visited pages, referral sources, interaction events, and other technical data necessary to generate analytics statistics.
Google Analytics is activated only after the visitor consents to the use of optional analytics technologies.
Legal basis: Consent of the personal data subject in accordance with Article 5 of the Law of the Republic of Belarus No. 99-Z "On Personal Data Protection".
Retention period: The retention period for user-level and event-level data in Google Analytics is configured by the Clinic in the service settings and is 14 months. This period does not automatically apply to all categories of aggregated statistics and technical data processed by Google.
Processing restrictions: The Clinic does not intend to transmit visitors' names, phone numbers, email addresses, request content, AI Assistant messages, diagnoses, or other health-related information to analytics services.
Consent management: Visitors may accept, reject, or modify their consent to optional analytics through the Website's cookie settings. Refusing analytics does not prevent the use of the Website's essential functions.
When consent is withdrawn, the Clinic stops subsequent transfers of analytics data to the extent permitted by the Website's technical capabilities. Processing of information previously transferred to external providers is governed by applicable legislation and the relevant providers' terms of service.
Detailed information about the cookies and similar technologies used, their purposes, and how to manage them is provided in the Cookie and Similar Technologies Policy.
3.7. Exercising Personal Data Subjects' Rights
Data processed: Information necessary to identify the applicant and provide a response, the content of the request, and the time and outcome of its consideration.
Purpose and legal basis: Compliance with the Data Controller's legal obligations.
Retention period for applications and documents: In accordance with applicable recordkeeping legislation. For applications submitted by personal data subjects, the standard retention period established by the applicable records retention schedule is one year, unless another mandatory period applies to a particular document.
4. Data Storage Location and Recipients
4.1. The main database containing requests, reviews, and administrative data is hosted in PostgreSQL, while content files are stored in S3-compatible MinIO/SILO storage. VPS hosting is provided by cloudvps.by, with servers located in the Republic of Belarus.
5. Retention Periods and Backups
5.1. Each processing activity is subject to its own purpose and retention period as specified in Section 3. There is no general rule stating that all data is retained for 30 days.
5.2. Standard requests are manually deleted by employees after processing. Records remaining in the system for more than 30 calendar days are subject to monitoring. Retention periods for formal claims and complaints may differ.
5.3. Backups of the PostgreSQL database and file storage are created daily on the same VPS and, at the Clinic's discretion, retained for up to 30 days. After this period, backup archives must be deleted. When restoring backups, measures must be taken to prevent previously deleted data from reappearing.
5.4. Evidence of consent is subject to a separate mandatory retention period of one year after the expiration of the relevant consent, unless legislation establishes another period for a specific type of document. This requirement does not justify retaining the entire text of a request or review together with the minimum consent record.
5.5. Retention periods for data processed by external services are determined by their terms and available settings. The Data Controller monitors the relevant arrangements and does not guarantee immediate deletion of data already transferred to third-party providers without confirmation that such deletion is technically supported.
6. Security Measures
6.1. The Clinic implements authentication for administrative access, separation of public and restricted data through routing and server-side checks, secure connections, user access controls, and backups. Technical security measures are reviewed during Website deployment and modifications.
6.2. Administrators are prohibited from sharing passwords or archives with third parties, using real patient data for testing, publishing screenshots of submitted inquiries, or storing medical information in operational logs.
6.3. The Data Controller does not guarantee absolute security of the Internet but is required to implement security measures prescribed by applicable legislation.
7. Visitors' Rights
7.1. Within the limits established by legislation, personal data subjects have the right to obtain information about the processing of their personal data, request corrections, receive legally required information about disclosures to third parties, withdraw previously given consent, request the termination of processing and/or deletion of data where legally justified, and challenge the Data Controller's actions.
7.2. Withdrawal of consent does not always result in the termination of processing if another lawful basis exists for retaining certain information, such as a legal obligation to preserve a particular document. The Data Controller communicates its decision in accordance with the established procedure.
7.3. Exercising these rights is not conditional on purchasing services. The Data Controller does not charge fees except where expressly permitted by law.
8. Consent Modification and Analytics Settings
8.1. Consent to personal data processing, review publication, and AI Assistant use constitutes separate actions for their respective purposes. Refusal to consent to optional analytics does not prevent access to the Website's main information.
8.2. Visitors can modify their analytics preferences using the "Cookie Settings" link on the Website. Upon withdrawal of consent, the subsequent loading of optional analytics is stopped within the capabilities of the implemented mechanism. Processing of previously transmitted data is governed by the capabilities of the respective services and applicable legislation.
9. How to Contact the Data Controller
9.1. The primary contact for personal data inquiries is book_visit@perfectsmile.by. The responsible person is Elena Dmitrievna Kassikhina, and the designated substitute is Alexander Vladimirovich Kassikhin. These contact details do not exclude other legally established channels for submitting requests.
9.2. Applicants should indicate which right they wish to exercise and provide a means of contact. For requests subject to statutory requirements regarding identification details, signatures, or written or electronic form, applicants will receive instructions on proper submission. Passport scans or medical documents should not be sent by ordinary email unless specifically necessary and a secure communication channel is available.
9.3. The Data Controller may request the minimum information necessary to verify an applicant's identity and prevent disclosure of personal data to third parties. Requests are reviewed within the time limits established by legislation. Clarifications and any reasoned refusals are communicated to applicants in accordance with the prescribed procedure.
10. Changes to This Policy
10.1. The Data Controller may amend this Policy in response to changes in processing activities, service providers, legislation, or Website functionality. Updated versions are published together with their effective dates.
10.2. If a change requires new consent, the Data Controller obtains it before carrying out the relevant processing activity. Previously obtained consent does not automatically extend to new, independent purposes.