Privacy Policy

In short: DentPark is a dental patient platform that handles health data, so we take extra care with it. This policy explains what personal data we collect about you as a patient, why, who we share it with, how long we keep it, and how to exercise your rights. Your medical and treatment data is processed on the basis of healthcare provision, not consent, and is never sold or used for advertising. If you also see a "GDPR Policy" document on this platform, that is a companion document explaining your rights in more detail and how to exercise them — the two together form the complete information notice required by law.

1. Who We Are

Data controller

The data controller responsible for your personal data on the DentPark platform is DENT PARK EROILOR S.R.L., a Romanian legal entity, with its registered office at Bdul. Eroii Sanitari nr. 25, postal code 050471, Sector 5, Bucharest, Romania, registered with the Trade Registry under no. J2025009875002, fiscal registration number (CUI) 51277198, legally represented by Adrian Croitoru (Administrator). Contact: phone +40 312 296 837, email info@dent-park.ro. Throughout this policy, "we," "us," and "the clinic" refer to this entity.

DENT PARK EROILOR S.R.L. is the data controller both for the data processed through the DentPark platform (this policy) and for the data it holds in its own reception/practice-management system (SPS Stoma), even though that system is operated separately from this platform.

Data Protection Officer (DPO)

We have appointed a Data Protection Officer: DPO Data-Consulting (an external firm), email office@dpo-consultanta.ro, phone +40740.988.880, address: Municipiul București, Sector 2, str. Triteni nr. 3, postal code 023827. You can contact the DPO with any question about how we process your personal data, or to exercise any of the rights described in section 13 below.

Supervisory authority

If you believe our processing of your data breaches applicable data protection law, you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP): B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, Bucharest, Romania; phone +40.318.059.211; email anspdcp@dataprotection.ro; website www.dataprotection.ro. We would appreciate the chance to resolve any concern directly first, but this is never a precondition — you may contact ANSPDCP at any time.

Other parties involved in operating the platform

The DentPark platform is built and maintained for us by SIRONIN DMITRII PERSOANĂ FIZICĂ AUTORIZATĂ (fiscal registration number (CUI) 54506989, Trade Registry no. F2026020454005, Bucharest, Romania), which acts as our data processor under a maintenance and technical support contract that includes a Data Processing Agreement under Article 28 GDPR. It may access personal data only on our documented instructions, and only to the extent strictly necessary to fix technical problems and develop agreed improvements to the platform — see section 9 for details.

2. Scope of This Policy

This policy applies to your use of the DentPark patient web portal, the DentPark mobile app (iOS and Android), and the notifications and communications (push, SMS, email) we send you as part of using either. It does not cover:

• the administrative panel used internally by clinic staff, which is not a patient-facing system;
• SPS Stoma, the clinic's own reception and practice-management software, which the clinic operates and controls directly (see section 9 for how the two systems relate to one another);
• any third-party website or service you may navigate to from a link inside the app or the portal — those are governed by that third party's own privacy notice.

The current version of this policy is always available, free of charge and without needing to log in, from within the app and the web portal.

3. What Personal Data We Collect

We collect the following categories of personal data about you:

Category	What it includes
Identity data	First name, last name, sex, optional nationality, and an optional CNP (Romanian national identification number). The CNP field is never required, is entered voluntarily by you, and is never validated beyond its format. Its only purpose is to identify you with certainty (for example, if another patient has the same name or shares your phone number): clinic staff can see it, and when your account is first linked to your patient file in the clinic's reception system (SPS Stoma), we send it to that system and use it, together with your verified phone number or email address, to find the right file. The CNP alone is never enough to link a file. If a new patient file is created for you, the CNP is recorded in it. The CNP is deleted from this platform when your account is erased; a CNP recorded in your patient file in the reception system is kept there with the rest of that file. Because this field is always optional, we process it on the basis of your consent (see section 6), not any other legal basis.
Contact data	Your email address and phone number, and whether and when each was verified. Used for signing in, delivering one-time login codes, and sending you notifications.
Account and authentication data	The sign-in method you use (email or phone one-time code, or Google), your Google account identifier if you choose to link it, session and device tokens (we record that an authentication event happened, never the underlying codes or tokens themselves), your preferred language, and account activity timestamps.
Health and dental data	See the dedicated section 4 below — this is your most sensitive data category and deserves separate treatment.
Financial data	For reference only, the clinic's own payment and invoice history as it exists in the reception system (SPS Stoma), shown to you but not duplicated into our own records. We do not currently process online payments through the platform; if that changes, we will update this policy, and this section, before it does.
Appointment and scheduling data	Appointment date and time, duration, clinic location and room, the doctor assigned, the specialty or service selected, and whether the appointment was booked by you or created on your behalf by clinic staff.
Files you upload	Any document, image, or imaging study you attach to an appointment. We keep the original file name and any description you add as metadata; the file itself is stored in access-controlled, private storage — never on a public link.
Communication and notification data	A record of the notifications we have sent you (appointment confirmations, reminders, cancellations, and, where you have opted in, marketing messages) and whether each was delivered; and, if you use our mobile app, a push-notification registration tied to that app installation (not a persistent device fingerprint).
Marketing preferences	Your opt-in status for each communication channel (push, SMS, email) and the date and time you gave that preference — kept specifically as proof of your consent, not only as a live setting.
Technical and security data	Your IP address, which we only ever store in an irreversibly hashed form for the purpose of rate-limiting and preventing abuse — never in plain, readable form; basic technical request information used for security and audit logging; and, on mobile, your device platform (iOS or Android), used only to route push notifications correctly.

What we do not collect. For your reassurance: we do not collect GPS or precise-location data, advertising identifiers, biometric authentication data, or your payment card details (we do not process online payments today — see section 3 above), and we do not embed any third-party advertising or analytics tracking software in the platform.

4. Special Category Data — Your Health Information

Because we are a dental clinic, a significant part of what we hold about you is "special category" data under Article 9 of the GDPR — data concerning your health. This includes your appointment and treatment history, treatment plans, radiographs (dental X-rays) and their associated metadata, the doctor and specialty involved in each visit, whether you are a first-time patient, any notes you write when booking an appointment, cancellation reasons, and any files you upload to an appointment (documents, images, DICOM imaging studies, and exported studies).

The legal basis for processing this category of data is Article 9(2)(h) GDPR — provision of healthcare, not your consent. This distinction matters in practice: unlike a marketing preference, this basis cannot be "withdrawn" on request while the clinic still has an ongoing treatment relationship with you or a legal duty to retain the record (see section 13 for what this means for your rights).

Within the clinic, this data can be seen by you, and by clinic staff (operators and administrators) through the administrative panel and directly through SPS Stoma, all of whom are independently bound by professional and medical confidentiality obligations regardless of this platform. Radiographs specifically are served to you only through a private, authenticated connection — never a public link — and every access to them is rate-limited and logged.

5. Where Your Data Comes From

• Directly from you — the information you enter when registering or completing your profile, the appointments you book or cancel, the files you upload, the consent and notification preferences you choose, and any support request you send us.
• From the clinic's reception system (SPS Stoma) — your appointment history, treatments, treatment plans, radiographs, and clinic payment/invoice history, synchronized from the clinic's own practice-management software once you are linked to your clinic patient record.
• From Google, only if you choose to sign in with a Google account — the name and email address Google shares with us as part of that sign-in.
• From clinic staff — appointments or profile details created or edited on your behalf by a receptionist or administrator, for example a phone booking or a walk-in visit later linked to your account.
• Generated automatically by the platform — audit and security log entries, notification delivery records, and session/device metadata.

6. Why We Process Your Data, and Under What Legal Basis

Purpose	Legal basis
Creating and managing your account	Contract (Art. 6(1)(b) GDPR)
Booking, confirming, rescheduling, and cancelling appointments	Contract and provision of healthcare (Art. 6(1)(b) and Art. 9(2)(h) GDPR)
Giving you access to your own treatment history, radiographs, and treatment plans	Provision of healthcare (Art. 9(2)(h) GDPR)
Sending appointment confirmations, reminders, and cancellation notices	Contract and our legitimate interest in delivering the service you asked for (Art. 6(1)(b) and (f) GDPR)
Sending marketing messages	Your consent (Art. 6(1)(a) GDPR) — opt-in, per channel, and revocable at any time
Security, fraud prevention, rate-limiting, and abuse prevention	Our legitimate interest (Art. 6(1)(f) GDPR)
Audit logging of account, security, and medical-record-access actions	Our legitimate interest (Art. 6(1)(f) GDPR), and, for some record types, a legal obligation
Responding to your data-subject-rights requests	Legal obligation (Art. 6(1)(c) GDPR)
Operating and improving the platform (error and incident logging)	Our legitimate interest (Art. 6(1)(f) GDPR)

7. Cookies and Similar Technologies

On the web portal, we currently set only strictly necessary, functional cookies: a session cookie that keeps you signed in (accessible only to our server, not to page scripts), a language-preference cookie remembering whether you use the platform in Romanian or English (kept for one year), and, if you choose "keep me signed in," a signed remember-me cookie (also inaccessible to page scripts, renewed on a rolling 30-day basis). None of these are used for advertising, and none allow us or anyone else to track you across other websites.

We do not currently use any analytics or advertising cookies or trackers. Because only strictly necessary cookies are set, no cookie-consent banner is required under Romanian law (Law no. 506/2004, implementing the ePrivacy Directive). If this ever changes, we will update this section and put a consent banner in place before any non-essential cookie is set.

On the mobile app, there are no cookies as such, but the same idea applies to local device storage: authentication tokens are kept in your device's secure storage (not accessible to other apps), and non-sensitive preferences may be cached locally for a smoother experience.

8. Notifications and Marketing Communications

We distinguish between two kinds of messages:

• Service (transactional) notifications — appointment created, confirmed, cancelled, or reminder messages. These are a necessary part of delivering the service you have requested, are not marketing, and are not subject to a marketing opt-in or opt-out, although you may disable individual delivery channels in your settings as long as at least two channels remain active, so you always have a way to be reached about your appointments.
• Marketing communications — clinic promotions and campaigns. These require your separate, per-channel, opt-in consent, and are off by default. You can change your preference at any time from the app or web settings, and the change takes effect immediately; we keep the date and time of your choice as proof of consent. Every marketing email and SMS also contains an unsubscribe link that withdraws your consent for that channel without needing to sign in.

We may send you notifications by push notification (mobile app only), SMS, and email — see section 9 for which provider delivers each channel. Push notifications never include medical or appointment details in the message text itself; they only carry a neutral prompt (for example, "tap to see details") that opens the app, where the actual information is shown only once you are signed in.

9. Who We Share Your Data With

We share personal data only with the recipients below, and only for the purposes stated. We do not sell your personal data to anyone.

• SPS Stoma — the clinic's own reception and practice-management software, and the clinic's system of record for medical and appointment data. Appointment, treatment, and identity data is synchronized between this platform and SPS Stoma in both directions, as part of delivering your care.
• Brevo (email delivery provider) — processes your email address and the content of the messages we send solely to deliver one-time login codes, appointment notifications, and, where you have opted in, marketing messages by email.
• 4Pay Systems SRL (a Romanian SMS aggregator, sms.4pay.ro) — processes your phone number and the content of the messages we send solely to deliver one-time login codes, appointment notifications, and, where you have opted in, marketing messages by SMS.
• Expo (650 Industries, Inc.), Apple (Apple Push Notification service), and Google (Firebase Cloud Messaging) — deliver push notifications to your device. We share only a device push token and a generic, non-personal notification text with these providers — never your name, appointment details, account credentials, or medical information.
• Google — only if you choose to sign in with a Google account, to authenticate you; in return, we receive your Google account's name, email address, and email-verification status.
• SIRONIN DMITRII P.F.A. (platform developer and maintenance provider, Bucharest, Romania) — acts as our data processor under a maintenance and technical support contract and its Article 28 GDPR Data Processing Agreement. To fix technical problems and develop agreed improvements, it holds secured technical access to the platform's production infrastructure — server, database, stored files, and application logs — and administers the Expo developer account used to send push notifications, which gives it access to device push tokens and push delivery logs. This access can incidentally expose any category of data described in section 3, including health data. It may use this access only on our documented instructions and only to the minimum extent and for the minimum time necessary — never to consult, extract, or use patient data for any other purpose, and never to send you notifications outside agreed maintenance work. It is bound by confidentiality, must notify us of any personal data breach within 48 hours of becoming aware of it, and must delete or return any personal data it holds when the contract ends.
• Our hosting provider — Contabo (contabo.com), based in Germany, within the European Union.
• Our backup storage provider — AlphaVPS (alphavps.com), based in Bulgaria, within the European Union, on infrastructure entirely separate from our primary hosting provider.
• Clinic staff (receptionists, operators, and administrators) — as internal recipients, not external service providers, clinic staff can view and manage appointments, files, and, for administrators, broader account information, strictly as needed to run the clinic and provide your care.
• Legal and regulatory authorities — we disclose personal data to courts, tax authorities, or data protection authorities only where we are legally required to do so.

We never sell your personal data, never share it with advertisers, and never use it for automated profiling that produces legal or similarly significant effects on you (see section 12).

10. International Data Transfers

Our hosting provider (Contabo) is based in Germany, and our backup storage provider (AlphaVPS) is based in Bulgaria — both within the European Union, so no special transfer mechanism is needed for either, even though they are two different EU member states. SPS Stoma is a Romanian company operating a Romanian domain, and we treat it as EU-based on that basis. Our platform maintenance provider (SIRONIN DMITRII P.F.A.) is based in Romania.

Some of our providers are based outside the European Economic Area and therefore transfer data internationally under a recognized safeguard: Google LLC and Expo (650 Industries, Inc.) both self-certify under the EU-U.S. Data Privacy Framework; Apple Inc., for Apple Push Notification service, relies on Standard Contractual Clauses. These are point-in-time facts about our providers' own certifications, which can change independently of us — we review them periodically, including whenever we republish this policy.

11. How Long We Keep Your Data

Data category	Retention period	Reason
Account and profile data	Until you delete your account, or automatically anonymized after 5 years of account inactivity	Data minimization principle
Appointment records	Kept indefinitely, with identifying details removed if your account is erased	Fiscal reconciliation and clinic statistics
Appointment files (documents, images)	Deleted 30 days after you or clinic staff delete them	—
Notification history	Deleted when your account is erased	—
Security and audit logs	60 days	Our legitimate interest in platform security
System error and technical logs	60 days	Operational necessity
Marketing consent records	Kept as proof of your consent until you withdraw it or your account is erased	Our accountability obligation
Backups (all data)	Local copies: the last 3 daily backups. Off-site copies: 30 days. An erased account is excluded from any future restore.	—

12. Automated Decision-Making and Profiling

We do not use your personal data to make any automated decision that produces a legal effect concerning you, or that affects you in a similarly significant way — for example, we never automate treatment or pricing decisions about you. We may use light audience segmentation for marketing purposes (for instance, to identify patients who have been inactive for six or more months, or who have an upcoming appointment) so that any marketing message you receive, if you have opted in, is more relevant to you. This segmentation does not produce any legal or similarly significant effect and is distinct from the profiling this section is about.

13. Your Rights

As a data subject, you have the following rights. The table shows, for each right, exactly how to exercise it on this platform:

Right	How you exercise it
Access	In-app: "Request a copy of my data." We aim to fulfil this within one month.
Rectification	Edit your profile directly for name and contact details; ask clinic staff to correct clinical records held in SPS Stoma.
Erasure ("right to be forgotten")	In-app: "Delete my account" (confirmed by a one-time code). We explain, at that point, exactly what is deleted immediately and what we are legally required to keep — see section 11.
Restriction of processing	Contact us or the DPO directly using the details in section 1.
Data portability	Same data-copy request as the right of access, delivered to you as a structured export.
Objection	For marketing: turn off the relevant channel in your settings. For any other processing based on legitimate interest: contact us directly.
Withdraw consent	For marketing only, from your app or web settings. This does not affect the lawfulness of processing already carried out, and it does not affect the processing of your health data, which is based on provision of healthcare, not consent (see section 4).
Lodge a complaint	With ANSPDCP, the Romanian supervisory authority — contact details in section 1.

We respond to any rights request within one month of receiving it, as required by Article 12 GDPR. In the interest of transparency, we note that some of these requests are currently fulfilled manually, with the involvement of clinic administrative staff, rather than through a fully automated self-service mechanism.

14. Children and Minors

DentPark does not have a parent or child account concept, and none is planned. Booking an appointment through the platform is restricted to adults acting in their own name.

15. Data Security

We protect your personal data through:

• encryption of all data stored on our servers (database, files, and backups) and of every connection to the platform;
• encrypted backups kept with a separate provider in the European Union, with a tested restore procedure;
• private, access-controlled file storage, with no public links to your files;
• sign-in by one-time code or Google, and two-factor sign-in (a one-time code plus a personal PIN) for clinic staff;
• role-based access for clinic staff, so each person sees only what their role requires;
• an audit trail of who accessed what, recorded without your full contact details;
• rate-limiting and abuse protection on sign-in and one-time codes.

Because the platform processes health data, we carried out a Data Protection Impact Assessment (Article 35 GDPR) with the advice of our Data Protection Officer in October 2026, and we review it whenever the platform or its risks change. You can ask our DPO about it using the contact details in section 1.

If something goes wrong despite these measures, see section 16 for what we commit to doing next.

16. Data Breach Notification

If a personal data breach occurs, we will notify the National Supervisory Authority for Personal Data Processing (ANSPDCP) within 72 hours where required (Art. 33 GDPR), and we will notify you directly, without undue delay, where the breach is likely to result in a high risk to your rights and freedoms (Art. 34 GDPR).

17. Changes to This Policy

We may update this policy from time to time. Each version is dated and numbered, and the current version is always available, free of charge, from within the app and the web portal without needing to log in. If we publish a new version, you will be asked to review and accept it the next time you sign in before continuing to use the platform — we never treat continued use after a change as silent acceptance.

18. Contact Us

For any question about this policy or about how we handle your personal data, contact us at phone +40 312 296 837 or email info@dent-park.ro, or contact our DPO, DPO Data-Consulting, at office@dpo-consultanta.ro or +40740.988.880, Municipiul București, Sector 2, str. Triteni nr. 3, postal code 023827. If you prefer, you may also submit a rights request in writing, by post, to either address above, rather than through the app.