Pasindora | Clinica Valcea
Pasindora | Clinica Valcea

Privacy Policy

Last updated: 22 September 2026

1. Introduction

The protection of personal data is a fundamental commitment for Pasindora. We process your data in accordance with Regulation (EU) 2016/679 on the protection of personal data (“GDPR”), the applicable Romanian legislation and the obligations specific to the provision of medical services.

This Privacy Policy explains what data we collect, how we use it, the legal bases for processing, who may receive it, how long we retain it and the rights available to you.

This Policy applies to individuals who:

  • visit the pasindora.ro website;

  • contact us by telephone, email, online forms or social media;

  • request an appointment;

  • receive medical services at our clinic;

  • purchase or use a Pasindora subscription;

  • are registered as members of a FAMILY subscription;

  • receive marketing communications from us;

  • interact with Pasindora in any other way.

We may periodically update this Policy to reflect legal, technical or operational changes. The updated version will be published on the website together with the date of the latest revision.

2. Who is the data controller?

The controller of your personal data is:

SC SMILE HOLIDAYS SRL, trading under the commercial name Pasindora

  • Registered office: 31 Aleea Castanilor, Râmnicu Vâlcea, Romania

  • Trade Register number: J2017000621384

  • Unique registration code: 37751554

  • Email: contact@pasindora.ro

  • Telephone: 0775 555 000

  • Website: https://pasindora.ro

For questions or requests regarding the protection of your personal data, you may contact us using the details above.

3. What personal data do we collect?

Depending on how you interact with us, we may collect the following categories of data.

3.1. Identification and contact details

  • first name and surname;

  • date of birth or age, where required;

  • telephone number;

  • email address;

  • postal address;

  • city and county;

  • identification information required for invoicing or compliance with legal obligations.

3.2. Appointment and service information

  • appointment date and time;

  • requested service;

  • selected doctor or specialist;

  • appointment history;

  • confirmations, cancellations and rescheduling information;

  • communications with the clinic’s reception or staff;

  • information required to manage our relationship with the patient.

3.3. Pasindora subscription information

  • the type of subscription purchased;

  • purchase, activation and expiry dates;

  • included and used services;

  • subscription status;

  • payment and order history;

  • cancellation or refund requests;

  • details of members included in a FAMILY subscription;

  • information required to manage and renew the subscription.

3.4. Payment and invoicing information

  • name and billing details;

  • transaction amount and currency;

  • payment method;

  • transaction identifier;

  • payment status;

  • information required to issue tax and accounting documents;

  • information relating to cancellations, refunds and any recurring payments.

Online payments are processed through NETOPIA Payments or other payment providers identified on the payment page.

Pasindora does not store the complete card number, CVV/CVC code or other complete card security information. This information is entered and processed within the secure infrastructure of the payment provider.

3.5. Medical information

As part of the provision of dental services, we may process health-related information, including:

  • medical and dental history;

  • symptoms, conditions and diagnoses;

  • allergies, treatments and medication;

  • treatment plans and recommendations;

  • medical records and clinical observations;

  • X-rays, scans and other investigations;

  • intraoral or extraoral medical photographs;

  • information about procedures performed;

  • medical consent forms;

  • other information required for assessment and treatment.

Health information is a special category of personal data and receives an enhanced level of protection.

Such information is processed only where necessary for assessment, diagnosis, treatment, management of medical services and compliance with the professional and legal obligations of the clinic and its medical staff.

3.6. Technical data and information about website use

When you visit the website, we may collect:

  • IP address;

  • device and browser type;

  • operating system;

  • pages accessed;

  • date and duration of the visit;

  • source through which the website was accessed;

  • interactions with pages and forms;

  • cookie and similar identifiers;

  • technical information required for the security and operation of the website.

Our use of cookies and similar technologies is explained separately in our Cookie Policy.

3.7. Communication information

We may retain messages and information sent through:

  • email;

  • telephone;

  • website forms;

  • WhatsApp or other messaging services used by the clinic;

  • Facebook, Instagram, TikTok or other social media platforms;

  • requests, complaints and enquiries sent to the clinic.

We recommend that you do not send sensitive medical information through public or unsecured communication channels.

4. Where do we obtain the data from?

We generally obtain personal data:

  • directly from you;

  • from a parent, guardian or legal representative;

  • from the person purchasing a FAMILY subscription;

  • from the payment provider in relation to transaction status;

  • from the device and browser used to access the website;

  • from appointment, communication, analytics or advertising platforms, subject to the settings and permissions applied;

  • from medical professionals or healthcare providers where the transfer is lawful and necessary for continuity of care.

A person registering other members under a FAMILY subscription must ensure that they are authorised to provide the relevant information and that any registered adult members have been informed about this processing.

5. Children’s data

Pasindora provides dental services to children and young people. We may therefore process a minor’s data where it is required for appointments, assessment, provision of medical services or inclusion in a FAMILY subscription.

A minor’s information is provided and managed, as applicable, by their parent, guardian or legal representative.

Consent for medical procedures involving a minor is obtained in accordance with the applicable medical legislation, taking into account the patient’s age, capacity to understand and individual circumstances.

We do not use a minor’s image, identity or medical information for marketing purposes without an appropriate legal basis and, where required, the express consent of their legal representative.

6. Purposes and legal bases for processing

6.1. Appointments and provision of medical services

We process data for:

  • registering and managing appointments;

  • medical assessment;

  • establishing a diagnosis;

  • developing and carrying out a treatment plan;

  • monitoring the patient’s progress;

  • communicating with the patient;

  • maintaining medical records;

  • ensuring continuity of care.

The legal bases for processing may include:

  • taking steps requested before entering into a contract;

  • performance of a service contract;

  • compliance with legal obligations;

  • provision of healthcare and management of healthcare services and systems;

  • protection of vital interests in circumstances provided for by law.

Medical information is processed by individuals who are subject to confidentiality and professional secrecy obligations.

6.2. Administration of SINGLE and FAMILY subscriptions

We process data for:

  • registering the order;

  • confirming eligibility;

  • activating the subscription;

  • registering FAMILY members;

  • recording included and used services;

  • managing the validity period;

  • communicating information about the subscription;

  • managing renewal, cancellation and expiry;

  • responding to requests and complaints.

The principal legal basis is the performance of a contract or taking steps requested before entering into a contract.

6.3. Payment processing and invoicing

We process data for:

  • initiating and confirming payments;

  • preventing and investigating fraud;

  • managing transactions;

  • issuing invoices and financial documents;

  • managing refunds;

  • complying with tax and accounting obligations.

The legal bases are the performance of the contract, compliance with legal obligations and, where applicable, our legitimate interest in protecting the business against fraud.

Where recurring payments are available, they will be activated only after the customer has made a clear selection and received the relevant information. Recurring payments may be stopped in accordance with the conditions communicated when they were activated.

6.4. Administrative communications

We may use your contact information to send:

  • appointment confirmations;

  • rescheduling or cancellation notifications;

  • order and payment information;

  • confirmation that a subscription has been activated;

  • notifications regarding available services;

  • subscription expiry reminders;

  • important information concerning the contractual or medical relationship.

These communications do not constitute direct marketing where they are necessary for the performance of the contract or management of the requested services.

6.5. Marketing communications

With your consent, we may send you:

  • newsletters;

  • information about services;

  • offers and campaigns;

  • invitations to events;

  • educational materials;

  • communications tailored to the interests you have expressed.

You may withdraw your consent at any time by using the unsubscribe option or by contacting us at contact@pasindora.ro.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

We do not make the provision of medical services conditional upon acceptance of marketing communications.

6.6. Website improvement and performance measurement

Depending on your cookie preferences, we may use tools such as Google Analytics, Meta Pixel, TikTok Pixel, Microsoft Clarity or similar technologies for:

  • measuring website traffic;

  • understanding how the website is used;

  • identifying technical issues;

  • measuring campaign performance;

  • improving content and user experience;

  • displaying and measuring relevant advertising.

Cookies that are not strictly necessary are used only in accordance with the choices you make through the consent mechanism available on the website.

You may subsequently modify or withdraw your choices through the “Cookie Settings” section.

6.7. Security, fraud prevention and protection of legal rights

We may process data for:

  • protecting the website and our information systems;

  • detecting unauthorised access;

  • preventing fraud;

  • creating backups;

  • investigating incidents;

  • establishing, exercising or defending legal claims;

  • managing complaints and disputes.

These activities are based on our legal obligations and our legitimate interest in protecting patients, staff, systems and the clinic’s operations.

7. Mandatory and optional information

Certain information is required for:

  • making an appointment;

  • assessing and providing medical services;

  • purchasing and administering a subscription;

  • processing payment;

  • issuing an invoice;

  • complying with legal obligations.

If you do not provide the required information, we may be unable to register the appointment, process the order, activate the subscription or provide the requested service.

Information used exclusively for marketing or optional cookies is not mandatory.

8. Who may receive your data?

Where necessary, we may disclose data or provide access to the following categories of recipients:

  • authorised doctors, medical staff and administrative personnel;

  • healthcare providers and dental laboratories;

  • the NETOPIA Payments payment provider;

  • banks and financial institutions;

  • web hosting, server, IT maintenance and security providers;

  • providers of the subscription management platform;

  • email, SMS and notification service providers;

  • appointment and patient relationship management providers;

  • accounting, invoicing and archiving service providers;

  • legal and tax advisers and auditors;

  • analytics and advertising providers, where you have accepted the relevant cookies;

  • public authorities, courts, professional bodies or other institutions where disclosure is required or permitted by law;

  • insurance companies or other recipients at the patient’s request and with their authorisation or on another valid legal basis.

Providers processing data on our behalf receive only the information required to provide their services and must comply with contractual confidentiality, security and data protection obligations.

We do not sell your personal data.

9. International data transfers

Some technology, analytics, advertising or communication providers may process information outside Romania or the European Economic Area.

Where such a transfer takes place, we seek to use an appropriate legal mechanism, such as:

  • an adequacy decision adopted by the European Commission;

  • Standard Contractual Clauses;

  • additional protection measures;

  • another transfer mechanism permitted under the GDPR.

Additional information about transfers carried out through cookies and similar technologies is provided in the Cookie Policy and the consent management mechanism.

10. How long do we retain your data?

We retain personal data only for as long as necessary for the purposes for which it was collected and to comply with our legal obligations.

The specific period depends on the nature of the information and the purpose of processing:

  • medical information is retained in accordance with healthcare legislation, professional obligations and the rules applicable to medical records;

  • order, payment and invoice information is retained in accordance with tax and accounting obligations;

  • subscription information is retained for the duration of the contract and afterwards for as long as necessary to comply with legal obligations, manage complaints or protect legal rights;

  • appointment and communication information is retained for as long as necessary to manage the relationship with the patient;

  • marketing information is processed until consent is withdrawn or until the information is no longer required;

  • consent preferences may be retained to demonstrate compliance with the choices expressed;

  • technical data and security logs are retained for periods proportionate to security and incident-prevention purposes;

  • information required for a dispute may be retained until the proceedings have ended and the applicable legal limitation periods have expired.

At the end of the applicable retention period, the information is deleted, anonymised or archived as required by law.

11. How do we protect your data?

We implement appropriate technical and organisational measures to protect personal data against:

  • unauthorised access;

  • loss;

  • destruction;

  • alteration;

  • disclosure;

  • improper use.

These measures may include:

  • secure HTTPS connections;

  • role-based access controls;

  • passwords and authentication mechanisms;

  • backups;

  • IT security measures and updates;

  • limiting access to authorised staff;

  • confidentiality obligations;

  • procedures for managing security incidents.

No method of electronic transmission or storage can guarantee absolute security. However, we implement measures that are reasonable and proportionate to the nature of the information being processed.

12. Your rights

Subject to the conditions established by the GDPR, you have the following rights.

Right of access

You may request confirmation as to whether we process your data and obtain relevant information and a copy of the personal data concerning you.

Right to rectification

You may request the correction or completion of inaccurate or incomplete information.

Right to erasure

You may request the deletion of your data in the circumstances provided for by law.

This right is not absolute. We may retain certain information where processing is necessary for:

  • compliance with a legal obligation;

  • provision and documentation of medical services;

  • reasons of public interest in the area of public health;

  • establishing, exercising or defending legal claims.

Right to restriction of processing

You may request a temporary restriction on the use of your data in the circumstances provided for by the GDPR.

Right to data portability

Where applicable, you may request to receive the data you provided in a structured, commonly used and machine-readable format or request its transfer to another controller.

Right to object

You may object to processing based on our legitimate interests for reasons relating to your particular situation.

You may object to direct marketing at any time without having to provide a reason.

Right to withdraw consent

Where processing is based on consent, you may withdraw that consent at any time.

Right not to be subject to a solely automated decision

You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or similarly significantly affects you.

Pasindora does not ordinarily make medical or contractual decisions that produce such effects exclusively through automated means.

Right to lodge a complaint

You have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing if you believe your personal data has been processed unlawfully.

13. How to exercise your rights

To exercise your rights, you may contact us:

  • by email: contact@pasindora.ro;

  • by telephone: +40 743 410 314;

  • by post: SC SMILE HOLIDAYS SRL, 31 Aleea Castanilor, Râmnicu Vâlcea, Romania.

Please clearly describe your request and the right you wish to exercise.

To protect your information, we may request additional details to verify your identity. We will not request more information than is necessary for this verification.

We will respond within the period provided for by the GDPR. For complex or numerous requests, this period may be extended, in which case the person making the request will be informed in advance.

Exercising your rights is generally free of charge. In the case of manifestly unfounded or excessive requests, we may charge a reasonable fee or refuse the request, subject to the conditions established by law.

14. Complaints to the supervisory authority

The competent authority in Romania is:

National Supervisory Authority for Personal Data Processing – ANSPDCP

Without affecting your right to contact the authority directly, we encourage you to contact us first so that we can attempt to resolve your concern.

15. Links to other websites

The website may contain links to services or websites operated by third parties.

Pasindora does not control and is not responsible for the privacy practices of these third parties. We recommend reviewing the privacy policy of each service you access.

16. Changes to this Privacy Policy

We may amend this Policy where there are changes to:

  • the way we process data;

  • the services we provide;

  • the providers we use;

  • website technologies;

  • legal requirements or guidance issued by competent authorities.

The updated version will be published on the website. Where the changes are significant, we may display an additional notice or contact you using the available contact details where required.

17. Contact

For questions about this Policy or how Pasindora processes personal data, you may contact:

SC SMILE HOLIDAYS SRL – Pasindora

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