Privacy Policy

Privacy Policy regarding the processing and protection of personal data of users of the website https://www.phlebos.com.ua of the medical institution LLC “Phlebology and Aesthetic Medicine Medical Center ‘Phlebos’”

LLC “Phlebology and Aesthetic Medicine Medical Center ‘Phlebos’” (hereinafter referred to as the “Medical Center,” “Company,” “we”) adheres to the principles of legality, fairness, transparency, and security when handling personal data of users of the website https://www.phlebos.com.ua (hereinafter referred to as the “Website”). This Privacy Policy (hereinafter referred to as the “Policy”) explains what personal data we collect, for what purposes, on what legal grounds, and how we process, store, and protect it.

1. Legal grounds for personal data processing

1.1. The processing of personal data is carried out in accordance with the Constitution of Ukraine, the Law of Ukraine “On Personal Data Protection,” the Civil Code of Ukraine, the Law of Ukraine “On Information,” the Law of Ukraine “Fundamentals of Ukrainian Legislation on Healthcare,” and other regulatory acts.

1.2. Providing personal data by the User is voluntary; however, refusal to provide certain data may limit the possibility of using the Website or receiving specific services.

2. Categories of personal data processed

2.1. We may collect the following categories of personal data:

Full name, date of birth;
contact information (phone, email, postal address);
health-related data (previous diagnoses, complaints, medical examinations, prescriptions, etc.);
identification and payment details (when paying online);
technical data: IP address, device type, browser, date and time of access, cookies.

2.2. We do not process special categories of personal data (e.g., racial or ethnic origin, political views, religious beliefs), unless required by law or necessary for the provision of medical services.

3. Purpose of personal data processing

3.1. Users’ personal data is collected for the following purposes:

provision and organization of medical services (including initial consultation, appointment scheduling, diagnostics, treatment);
maintenance of electronic medical records;
communication with the User (including via email, phone, or messengers);
processing online bookings, inquiries, requests, complaints;
ensuring the performance of medical service agreements;
analytics and improvement of Website functionality;
compliance with healthcare, tax, and accounting regulations.

4. Data retention period

4.1. We store personal data no longer than necessary to achieve the purposes of processing or within the period established by law (in particular, medical records must be kept for at least 3 years).

4.2. After the retention period expires, data is deleted or anonymized in accordance with internal policies and legal requirements.

5. User rights

5.1. Every User has the right to:

know the source of collection of their personal data, its location, and purpose of processing;
obtain information about the conditions of access to their data;
request correction, update, or deletion of their data in case of inaccuracy or unlawful processing;
withdraw consent to data processing (considering the consequences for receiving medical services);
contact the Ukrainian Parliament Commissioner for Human Rights or the court to protect their rights.

6. Disclosure of personal data to third parties

6.1. We do not disclose personal data to third parties, except in the following cases:

with the User’s consent;
at the request of public authorities within their competence and in the manner prescribed by law;
when engaging contractors to process data (e.g., cloud storage providers), provided a confidentiality agreement is in place;
as part of fulfilling obligations under an agreement with the Patient.

7. Personal data protection

7.1. We have implemented administrative, technical, and physical security measures, including:

protection of internal systems and databases with passwords, firewalls, antivirus software;
access to data is restricted to authorized personnel only;
monitoring data integrity and proper use.

7.2. We periodically conduct audits of our information security systems.

8. Use of cookies

8.1. Our Website may use cookies to improve user experience, analytics, and advertising.

8.2. The User may at any time restrict or disable the use of cookies through their browser settings.

9. International data transfer

9.1. We do not transfer personal data outside the territory of Ukraine, except in cases expressly provided by law or international agreements of Ukraine.

10. Changes to the Privacy Policy

10.1. We reserve the right to modify or update this Policy at any time. The current version is always available on the Website.

10.2. We recommend checking this Policy periodically for updates.

11. Contact information

LLC “Phlebology and Aesthetic Medicine Medical Center ‘Phlebos’”
Address: 01133, Kyiv, Lesi Ukrainky Boulevard, 7-B
E-mail: info@phlebos.com.ua
Phone: +38 (063) 500 11 55
Website: www.phlebos.com.ua