1. Data Controller Information
IDT Dental Clinic
Mosaic of Tirana, Rruga Sandër Prosi
Tiranë 1057, Albania
Email: info@idt.al
Phone: []
Data Protection Officer: [Armand Toci]
2. Data We Collect
Personal Data:
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Name, surname, date of birth
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Contact information (email, phone, address)
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Passport/ID details for medical records
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Payment information
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Emergency contact details
Special Category Data (Health Data):
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Medical and dental history
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X-rays, scans, and dental photographs
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Treatment plans and records
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Health insurance information
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Medication and allergy information
Technical Data:
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IP address, browser type, device information
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Website usage data via cookies
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Communication preferences
3. Legal Basis for Processing
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Contractual Necessity: To provide dental treatment services
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Explicit Consent: For health data processing (Article 9 GDPR)
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Legal Obligation: Maintaining medical records as required by Albanian law
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Legitimate Interests: Improving services, marketing (with opt-out option)
4. Purposes of Processing
Primary Purposes:
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Providing dental treatment and aftercare
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Managing appointments and communications
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Processing payments and insurance claims
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Maintaining medical records as required by law
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Coordinating travel and accommodation
Secondary Purposes (with consent):
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Sending educational materials and oral health tips
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Requesting feedback and reviews
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Marketing communications about services and offers
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Clinical research and outcome studies (anonymized)
5. Data Sharing and Transfers
We Share Data With:
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Medical Professionals: Our dental team and specialists involved in your care
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Service Providers: Hotel partners, transfer services (only necessary information)
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Payment Processors: Banks and payment gateways
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Legal Authorities: When required by Albanian or European law
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Your Local Dentist: With your consent, for follow-up care coordination
International Transfers:
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Data is primarily processed in Albania
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When transferring to EU countries, we ensure GDPR-compliant safeguards
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We use Standard Contractual Clauses for non-EEA transfers
6. Data Retention Periods
Medical Records: 30 years from last treatment (Albanian medical law requirement)
Financial Records: 10 years for accounting purposes
Marketing Data: Until consent withdrawal or 3 years of inactivity
Website Analytics: 26 months maximum
7. Your Rights Under GDPR
You have the right to:
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Access: Receive a copy of your personal data
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Rectification: Correct inaccurate or incomplete data
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Erasure: Request deletion of your data (“right to be forgotten”)
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Restriction: Limit processing of your data
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Portability: Receive your data in a structured, machine-readable format
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Object: Object to processing based on legitimate interests
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Withdraw Consent: Withdraw consent at any time
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Lodge Complaint: Complain to the Albanian Information and Data Protection Commissioner
8. Data Security Measures
Technical Measures:
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SSL/TLS encryption for data transmission
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Encrypted storage of sensitive health data
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Regular security updates and patches
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Secure backup systems
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Two-factor authentication for staff access
Organizational Measures:
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Staff training on data protection
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Confidentiality agreements with all employees
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Access controls and audit logs
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Data protection impact assessments
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Incident response plan
9. Cookie Policy
Essential Cookies:
Required for website functionality (always active)
Analytical Cookies:
Google Analytics (anonymized data, opt-out available)
Marketing Cookies:
Used for remarketing (active only with consent)
Cookie Consent: We use a cookie banner that requires explicit consent for non-essential cookies.
10. Children’s Privacy
We do not knowingly collect data from children under 16 without parental consent. Parents/guardians must consent to treatment and data processing for minors.
11. Automated Decision Making
We do not use fully automated decision-making processes. All treatment decisions involve human professional judgment.
12. Contact and Complaints
Data Protection Officer:
[To be appointed – contact details will be added]
Supervisory Authority:
Information and Data Protection Commissioner (Albania)
Rruga “Abdi Toptani”, Nr. 5, Tirana
Email: info@idp.al
13. Policy Updates
We will notify users of significant changes via email or website notice. Continued use constitutes acceptance of updated policy.
