Privacy Policy

1. General Provisions
This Privacy Policy describes how personal data is collected, used, stored, protected, and disclosed when you visit the website https://ru.refresh-dubai.com/ (the “Website”) and when you use the services of Refresh Clinic (the “Clinic”, “we”, “our”, or “us”). This Policy is developed in accordance with the applicable laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), and other relevant regulations.

2. Data Subjects
This Privacy Policy applies to all Website visitors and Clinic patients who provide their personal data when submitting inquiries, booking appointments, receiving consultations, diagnostics, or medical services.

3. Personal Data We Collect
We may collect the following categories of personal data:
a) Identification data
First name, last name, phone number, email address.
b) Medical data
Medical history, examination results, diagnoses, treatment plans, and other health-related information provided by you in the course of receiving medical services.
c) Technical data
IP address, browser type, cookies, and other technical information collected automatically when you use the Website.
4. Purposes of Data Processing
Personal data is processed for the following purposes:
• Appointment booking and communication with patients
• Provision and administration of medical services
• Improvement of service quality and patient experience
• Compliance with legal and regulatory obligations
• Website administration and analytics

5. Legal Grounds for Processing
Personal data is processed on the basis of:
• Your explicit consent
• Performance of contractual obligations related to medical services
• Compliance with UAE legal requirements
• Other lawful grounds provided under applicable legislation

6. Data Storage and Retention
Personal data is stored in a secure manner and protected by appropriate technical and organizational measures. Data is retained only for as long as necessary to fulfill the purposes described in this Policy or as required by applicable law.

7. Disclosure to Third Parties
Personal data may be disclosed only to: • Authorized medical and administrative personnel of the Clinic • UAE governmental or regulatory authorities, where required by law • Service providers acting on behalf of the Clinic under confidentiality obligations Personal data is not transferred to third parties for other purposes without your explicit consent, except as required by law.

8. Rights of the Data Subject
You have the right to: • Request confirmation of whether your personal data is being processed • Obtain access to your personal data • Request correction of inaccurate or incomplete data • Withdraw your consent to data processing at any time • Request deletion of your personal data, where legally permissible

9. Cookies and Similar Technologies
The Website uses cookies and similar technologies to ensure proper operation, analyze traffic, and improve user experience. You may disable cookies through your browser settings; however, this may affect certain Website functionalities.

10. Data Security
The Clinic implements appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction.

11. Changes to This Privacy Policy
The Clinic reserves the right to amend this Privacy Policy at any time. Updates will be published on the Website with the effective date indicated.

12. Contact Information
If you have any questions regarding this Privacy Policy or the processing of your personal data, you may contact the Clinic using the contact details provided on the Website.