Privacy policy

Document version

Who is responsible for your data

The personal data controller is sole proprietor (FOP) Iryna Vasylenko. She holds an MOH medical practice license and is responsible for how the FAVOR clinic processes data from the site, calls and correspondence.

• — License: Order of the Ministry of Health of Ukraine of 18.09.2020 No. 2126. Details are on the Licenses and documents page.
• — The sole proprietor’s address is in the company details at the bottom of every page of the site.
• — Phone for inquiries: (067) 151-53-03, 24/7.

What data we collect

The site doesn’t ask you to describe a diagnosis and doesn’t require registration. We receive only what you enter in a form yourself or tell us over the phone, plus a few technical details the form can’t work without.

• — The “Request a call back” form: phone number (required) and name (optional).
• — The form on the home page also asks when it’s convenient to talk and what the concern is (alcohol, drugs, gambling, other). The latter is health information, so providing it is optional.
• — Along with the request, the address of the page you sent it from and the time are transmitted automatically.
• — Phone call: the number you call from, and the date and length of the call.
• — Messages on Telegram, Viber or WhatsApp: your number or profile name and what you write. The messenger also processes this data under its own rules.
• — During consultation and treatment: information about your health. It is handled by healthcare workers bound by medical confidentiality.

Technical data and form protection

To keep bots from flooding the clinic with fake requests, the site briefly remembers not the IP address or phone number itself but its hash, an irreversible digital fingerprint.

• — The IP address hash is kept for 15 minutes: up to five requests can be sent from one address during that time.
• — The phone number hash is kept for 10 minutes so that an accidental double click doesn’t create two requests.
• — The hosting server keeps technical visit logs.
• — Cookies and similar technologies are covered in our cookie policy.

Why we use data

Each type of data is needed for a specific action. We don’t use it for any other purpose.

• — To call you back, answer your questions and advise where to start.
• — To arrange a doctor’s visit, an examination, hospitalization or rehabilitation.
• — To provide medical care and keep medical records as required by law.
• — To protect the form from spam and abuse.
• — To assess which pages are useful, only if you have allowed analytics. Analytics is not currently enabled on the site.

On what legal basis

The grounds for processing are set out in Article 11 of the Law of Ukraine “On Personal Data Protection.” Special rules under Article 7 of the same law apply to health information.

• — Your consent, for a request submitted on the site. You tick the box under the form yourself; it is never pre-ticked. The consent text is on the Consent to personal data processing page.
• — Entering into and performing a contract for medical services, when you agree to a consultation or treatment.
• — A legal obligation: medical records and responses to lawful requests from government authorities.
• — The clinic’s legitimate interest: protecting the form from spam.
• — Health information is processed for treatment purposes by healthcare workers bound by medical confidentiality (Article 7 of the law).

Who else sees your data

Your data is seen only by clinic staff who need it to handle your inquiry. We don’t sell data or share it with advertising networks.

• — Email service: a request from the site arrives as an email in the clinic’s mailbox.
• — Binotel telephony: calls to the hotline go through it.
• — The CRM system the clinic uses to track inquiries.
• — Government authorities, only in cases expressly provided for by law.

How long we keep data

Form requests are not stored in the site’s database: the site only forwards the email and keeps nothing. After that, it depends on where the data ends up.

• — IP address and phone hashes: 10–15 minutes, then deleted automatically.
• — Your cookie choice: in your browser until you change it or clear the site data.

Your rights

Article 8 of the Law of Ukraine “On Personal Data Protection” gives you the right to control your data. Here is what that means in practice.

• — To find out what data the clinic holds about you, where it came from, why, and who it was shared with.
• — To get a copy of your data.
• — To correct inaccurate data.
• — To withdraw consent and ask for your data to be deleted if the law doesn’t require it to be kept.
• — To object to processing based on the clinic’s legitimate interest.
• — To file a complaint with the Ukrainian Parliament Commissioner for Human Rights or with a court. The Commissioner’s website: ombudsman.gov.ua.

How to exercise your rights

Call the hotline at (067) 151-53-03 and say it’s a personal data request. To avoid disclosing your data to someone else, we’ll ask you to confirm that the number belongs to you.

We respond within the time limits set by law, no later than 30 calendar days. Usually sooner.

How we protect data

Addiction care is a sensitive subject, so we protect data with extra care.

• — The site works only over an encrypted HTTPS connection.
• — The form accepts requests only from this site, limits how many can be sent and stores nothing in the database.
• — Only the staff who call back and handle inquiries have access to the mailbox and the CRM.
• — The clinic’s healthcare workers keep medical confidentiality.

If a minor is involved

The site is not intended for children. If a minor needs help, their parents or other legal representatives should contact us.

Changes to this policy

When we change the policy, we update the version date at the top of the page. If we add a new service that receives your data, we’ll list it here first.