Privacy policy and legal notice

This is a translation for information; the Slovenian version is legally binding.

1. General

At www.medicalfabjan.si we value your privacy. The purpose of this privacy policy is to inform clients, prospective clients and visitors of the website www.medicalfabjan.si about the purposes and legal bases for the processing of personal data by the companies Emazing d.o.o. and Medical Fabjan d.o.o. (hereinafter: the provider or the controller of personal data).

Clinic address: Aškerčeva ulica 14, 3000 Celje, Slovenia. Contact for questions about personal data protection: klinika@medicalfabjan.si, phone +386 70 350 330. Company registration number: 3884112000. Tax number: 69025126.

All our activities comply with European legislation (Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data – the General Data Protection Regulation or GDPR) and with the national legislation of the Republic of Slovenia (Personal Data Protection Act – ZVOP-2, Official Gazette of the RS, No. 163/22; Electronic Communications Act – ZEKom-2, Official Gazette of the RS, No. 130/22; Electronic Commerce Market Act – ZEPT).

This privacy policy covers the handling of information the provider obtains from you when you visit the website www.medicalfabjan.si or provide it in another way (during a service at the clinic, by phone or by email).

We may change or supplement this privacy policy at any time. We recommend that you check the current version each time before providing personal data.

2. Which personal data are collected and processed

Through the website we collect and process the personal data of users who subscribe to our newsletter or send an enquiry through a web form or online booking. These personal data include first name and surname, email address and phone number and, when booking, also the location and type of examination.

Special categories of personal data – data concerning health. As a healthcare institution, we also process data that fall within the special categories of personal data under Article 9 of the General Data Protection Regulation (GDPR). These include not only the data in your medical records but also data you already provide to us through the website: the type of procedure or service you are interested in, the content of your message in the contact form, the referral number when booking with a referral, and your consent to view the gallery of treatment results. We process these data on the basis of your explicit consent (Article 9(2)(a) GDPR) or for the provision of health care and the management of health services (Article 9(2)(h) GDPR in conjunction with health legislation). We never use them for advertising and do not pass them on to advertising platforms.

3. Why personal data are collected and processed

a) Booking an examination or treatment. We process first name and surname, email address, phone number, location and type of examination or treatment. Providing these data is voluntary but is a condition for using the service; without them we cannot make the booking. Legal basis: taking steps at your request prior to entering into a contract or performance of a contract (Article 6(1)(b) GDPR); for data concerning health, your explicit consent or the provision of health care (Article 9(2)(a) and (h) GDPR).

b) Answering enquiries. We process first name and surname, email address, phone number, the service you are interested in and the content of your message, so that we can reply and contact you if necessary. Legal basis: taking steps at your request prior to entering into a contract (Article 6(1)(b) GDPR) or our legitimate interest in replying to your message (Article 6(1)(f) GDPR); for data concerning health, your explicit consent (Article 9(2)(a) GDPR).

c) Direct marketing and newsletters. On the basis of your consent, we process first name and surname, email address, town and the type of service received in order to send newsletters, professional articles, information about our offer and special offers, and invitations to events. You may withdraw your consent at any time – by clicking the unsubscribe link included in every marketing email or by writing to klinika@medicalfabjan.si. Withdrawing consent does not affect the provision of health services or the lawfulness of processing before the withdrawal. Legal basis: your consent (Article 6(1)(a) GDPR in conjunction with the Electronic Communications Act – ZEKom-2).

d) Newsletter analytics and segmentation. For emails we send, we track whether the message was opened and which links were clicked, and on this basis we group recipients into segments and send tailored content. The purpose is more relevant information and fewer unnecessary messages. This processing includes profiling, but it has no legal or similarly significant effects on you and does not involve automated decision-making under Article 22 GDPR. Legal basis: your consent (Article 6(1)(a) GDPR); processing ends when you unsubscribe.

e) Compliance with legal obligations. In particular, processing of payment data for tax and accounting obligations, keeping medical records and disclosures required by the competent authorities. Legal basis: compliance with a legal obligation (Article 6(1)(c) GDPR) and, for medical records, also Article 9(2)(h) GDPR.

f) Legitimate interests. Processing for the establishment, exercise or defence of legal claims and for ensuring the security and operation of our systems, where your rights and freedoms do not override these interests. Legal basis: our legitimate interests (Article 6(1)(f) GDPR).

4. To whom we disclose personal data

We may disclose personal data to:

• contract processors that provide services for us – these processors may not use personal data for their own purposes and act solely on our instructions. Currently these are in particular: Webflow (website hosting and delivery and receipt of submitted forms), Google (Google Tag Manager, Google Analytics 4 and Google Fonts), Elfsight (WhatsApp chat widget), our provider of the customer relationship management and email system, the telephony provider, the accounting service and payment service providers;
• providers of marketing services for marketing, market research, statistical analysis and remarketing via Google and Meta (Facebook, Instagram);
• competent authorities, including courts and supervisory authorities, to the extent necessary to comply with legal obligations or to protect rights;
• legal successors in the event of a corporate restructuring, provided that they ensure at least the same level of protection.

Some of these providers are established outside the European Union. In such cases the transfer is based on the standard contractual clauses adopted by the European Commission or on another appropriate safeguard under the GDPR. You may request a copy of these safeguards at klinika@medicalfabjan.si.

5. Your rights

With regard to your personal data, you have the right to:

• access your personal data and obtain a copy;
• rectification of inaccurate data and completion of incomplete data;
• erasure of data where they are no longer needed for the purpose, where you withdraw consent and there is no other legal basis, where you object to the processing and there are no overriding legitimate grounds, or where erasure is required by law;
• restriction of processing;
• object to processing, including processing for direct marketing purposes, which we always uphold;
• portability of the data you have provided to us on the basis of consent or a contract;
• withdraw consent where processing is based on it.

Please send your request to klinika@medicalfabjan.si. So that we can verify that the request really comes from you, it should include your first name and surname and the email address or phone number registered with us. We will reply within one month at the latest.

Medical data and data on clinic visits remain stored in the medical records even after you withdraw consent for marketing, as their retention is required by health legislation. As a patient, in addition to the above rights you also have all the rights under the Patients’ Rights Act (ZPacP).

6. How long we keep data

• data processed on the basis of marketing consent – until consent is withdrawn;
• data on enquiries and bookings – until the purpose is fulfilled and thereafter for as long as necessary for any claims;
• accounting data – for the periods laid down by tax and accounting legislation;
• medical records – for the periods laid down by the Healthcare Databases Act (ZZPPZ).

When these periods expire, we erase the data or irreversibly anonymise them.

7. Social networks and third-party services

The website may use social network plug-ins and features (Facebook, Instagram, YouTube). These features may collect data about your visit and set cookies. If you are logged in to your account with the network provider during your visit, the provider may link the visit to your account. Such processing is governed by the privacy policy of the provider concerned.

8. Children’s privacy

The website is not intended for children under 15, and we do not knowingly collect children’s personal data, except in the course of keeping medical records. If you are a parent or guardian and believe that a child has provided us with their data, please contact us at klinika@medicalfabjan.si.

9. Links to other websites

Our website contains links to external websites whose data protection practices may differ from ours. We are not responsible for the collection and processing of data on those sites; we recommend that you read their privacy policies before providing any data.

10. Cookies

A cookie is a small file that a website stores on your device. We use strictly necessary cookies, which enable the site to work and remember your cookie choice, without consent. We set analytics and marketing cookies and similar technologies only on the basis of your consent, which you give on your first visit through the cookie banner. You can change or withdraw your consent at any time through the same banner, and you can also restrict or disable cookies in your browser settings. If you reject analytics and marketing cookies, the website continues to work, but some features may be limited. Below is an overview of the third-party tools we use on this website.

11. Data security

We have adopted appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure. Only persons who need the data for their work have access to them, and they are bound by confidentiality. Healthcare professionals are in addition bound by professional secrecy.

12. Legal remedies

Please address questions about this privacy policy, our use of cookies or the processing of your personal data to klinika@medicalfabjan.si. We kindly ask you to contact us first with any question or complaint – that way we can resolve it more quickly.

If you believe that your rights have been infringed, you may lodge a complaint with the supervisory authority: Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec), Dunajska cesta 22, 1000 Ljubljana, gp.ip@ip-rs.si.

13. Changes to the privacy policy

We reserve the right to change this privacy policy as necessary and to adapt it to applicable legislation. Any change takes effect when it is published on this page.

14. Legal notice

The content is not medical advice. The content of the website www.medicalfabjan.si is general and informative in nature. It is intended to present the clinic’s services and does not replace a medical examination, diagnosis or advice. A personal consultation with a doctor is always required to assess whether a procedure is suitable and for instructions on treatment.

Treatment results are individual. Descriptions of procedures, recovery and expected results are based on the usual course. The actual result, length of recovery and any complications depend on the individual, so published descriptions, photographs and client statements do not constitute a promise of the same outcome. Before every procedure, the doctor informs you about the risks and possible complications.

Prices and offer. Published prices and services are for information and may change. The binding price is the one confirmed at booking or at the consultation.

Accuracy of content. We strive to keep the published content accurate and up to date, but accept no liability for it. Nor are we liable for any damage arising from the use of or inability to use the website, or from actions based solely on the published content.

Copyright. All content on this website – texts, photographs, graphics, videos and design – is protected by copyright and is the property of Medical Fabjan d.o.o. or its contractual partners. Reproduction, distribution or publication without our prior written consent is not permitted; use for personal, non-commercial purposes is permitted with acknowledgement of the source.

Use of the website. By using the website you agree to this legal notice and the privacy policy. If you do not agree with them, please do not use the site.