Privacy Policy

This policy explains what personal data we collect through this website, why we use it and what rights you have. It follows Albanian Law No. 124/2024 on Personal Data Protection and, for people in the European Union, the General Data Protection Regulation (GDPR).

1. Who is responsible for your data

The data controller is Brunilda Topollaj, operating as Dental Solution Clinic.

• Registered address: Durres, Shijak, SHIJAK, Lagjja Popullore, Rruga sami Frasheri, Objekt me Nr. Pasurie Nr.5/331-ND, Zona Kadastrale 3369
• NUIS/NIPT (tax ID): M01803504A
• Legal form: Person Fizik (sole practitioner)
• Medical director: Dr. Brunilda Topollaj
• Phone: +355 69 840 6639
• Privacy contact: [TODO: privacy email address]
• Representative in the European Union: [TODO: EU representative, if required]

2. What data we collect

Through our forms:

• name, phone number and, if you provide it, email address
• country, taken from your phone number, preferred branch, preferred date, and the service or treatment you are asking about
• the message you write, if you add one
• whether you agreed to receive news and offers
• the campaign tags in the link you arrived from (UTM parameters), if there are any
• the type of request, the page you sent it from and the language of the page

Health questionnaire (optional): quote and consultation forms ask about high blood pressure, heart conditions, diabetes, regular medications, asthma and allergies. This is health data. We receive your answers only if you tick the separate consent box, and you can send your request without answering. You can also choose "none of the above" or "prefer not to answer".

Panoramic X-ray (optional): if you attach one, we receive it as a file. An X-ray is health data, a special category of personal data that receives stronger protection. Please send it only if you want us to assess your case.

Through WhatsApp, Messenger or by phone: the messages and details you choose to share with us.

Technical data: our hosting provider records technical information such as IP address, browser type and time of the request, to deliver the site and keep it secure.

Cookies and similar tools: only as described in our Cookie Policy. Optional tools run only if you accept them.

If you become a patient, your clinical records are kept at the clinic under the rules that apply to healthcare providers.

3. Why we use your data and on what legal basis

• To answer your request, arrange a visit and prepare a quote or treatment plan: your consent, given in the form, and steps taken at your request before a treatment agreement.
• To assess your X-ray and any other health information you send: your explicit consent.
• To use your answers to the optional health questionnaire, so the doctor can assess your case before the visit: your explicit consent, given in the separate box in the form.
• To keep the website working and secure: our legitimate interest in protecting the site and its visitors.
• To meet legal, tax and healthcare record-keeping duties: legal obligation.
• To send you news and offers: your consent, given in a separate optional box. You can withdraw it at any time.
• To measure and show our advertising through Meta Pixel: your consent, given in the cookie banner.

We do not sell your data, and we do not use it for automated decisions that have a legal or similarly significant effect on you.

Giving your name and phone number is needed for us to answer you. Everything marked as optional can be left out.

4. How long we keep your data

• Requests that do not lead to treatment, including any X-ray attached: up to 24 months from our last contact with you, or until you ask us to delete them, unless the law requires us to keep them longer.
• Answers to the health questionnaire: as for the request they belong to, up to 24 months from our last contact with you, or until you withdraw your consent or ask us to delete them. If you become a patient, the doctor may add them to your clinical record.
• Patient records: [TODO: retention period required by Albanian health law]
• Cookie and consent choices: as stated in the Cookie Policy.

5. Who receives your data

Your data is seen only by clinic staff who need it to help you, and by the providers below, who process it for us under our instructions.

• Google (Google Sheets, Google Drive and Apps Script): stores form requests and X-rays in private files.
• Cloudflare: hosts the website and handles technical logs.
• Meta Platforms: Meta Pixel, only after you accept marketing cookies; it receives page views and, when you send a form, only the event name "Lead", without personal data. WhatsApp and Messenger, if you choose to write to us there.
• Google Maps: only if you allow the map to load.
• Resend: staff notification emails about new requests, if this service is enabled.

Your answers to the health questionnaire are stored apart from your contact details, go to Google only as described above, are not included in staff notification emails and are never sent to Meta.

If you ask us to arrange travel or accommodation, we share with those partners only what they need for your booking. We may also disclose data when the law requires it.

6. Transfers outside your country

The clinic is in Albania, which is not a member of the European Union. If you write to us from the EU, your data reaches us in Albania. Our providers may also process data in other countries, including the United States. Where required, we rely on safeguards offered by those providers, such as the European Commission's standard contractual clauses or the EU-US Data Privacy Framework. Ask us for details using the contact above.

7. Your rights

You can ask us at any time to:

• give you access to your data and a copy of it
• correct data that is wrong or incomplete
• delete your data
• restrict how we use it, or object to its use
• transfer the data you gave us to you or to another provider
• withdraw your consent, which does not affect what was done before you withdrew it

You can ask us to delete your answers to the health questionnaire at any time. Your request for a quote or consultation stays valid.

Contact us using the details in section 1. We reply within one month. We may need to confirm your identity first, and some records may have to be kept when the law requires it.

8. Complaints

You can complain to the Commissioner for the Right to Information and Personal Data Protection in Albania (idp.al). If you live in the EU, you can also contact the data protection authority in your country. In Italy this is the Garante per la protezione dei dati personali (garanteprivacy.it).

9. Security

We limit access to authorised staff and keep X-rays in private storage. No online transmission is completely secure, so please do not send more health information than is needed.

10. Minors

If you are under 18, a parent or guardian should contact us on your behalf.

11. Changes to this policy

We may update this policy. The date at the top of the page shows the latest version.