Medioguide Privacy Policy

1. Who we are and scope of this Privacy Policy

Medioguide International Kft. (“Medioguide”, “we”, “us” or “our”) provides non-clinical patient guidance and administrative patient journey coordination services for individuals who are exploring medical or dental treatment options with selected partner clinics in Europe.

This Privacy Policy explains how we collect, use, share, store and protect personal data when you visit our website, contact us, submit an enquiry, upload case materials, communicate with us, or use our patient guidance and coordination services. It is intended for individuals in the United Kingdom and the European Economic Area who use our website or contact us in relation to our services.

Medioguide is not a clinic or healthcare provider. We do not provide medical treatment, diagnosis, clinical opinions, treatment plans or medical advice. Clinical assessment, treatment planning, medical advice, treatment, pricing, informed consent and clinical follow-up are the responsibility of the relevant partner clinic or healthcare professional.

Data controller

For the personal data described in this Privacy Policy, the data controller is:

We process personal data in accordance with applicable data protection laws, including the UK GDPR, the Data Protection Act 2018, the EU GDPR and applicable Hungarian data protection laws.

2. What data we collect

In the course of operating our website and providing our services, we may collect and process the following categories of personal data:

Identity and contact information

Name, email address, phone number, country of residence and preferred contact method.

Information you provide during enquiries

Information submitted through website forms, email, phone calls, video calls, WhatsApp or other messaging tools, including treatment interests, preferences, questions and administrative needs.

Health-related information

Where relevant to your enquiry and where you provide it, or where you explicitly consent to us processing or sharing it where required, we may collect health-related information such as dental photographs, X-rays, CBCT scans, symptoms, treatment needs, previous treatment history, medication or allergy information, and other diagnostic or case materials that you choose to share.

Health-related information is special category data. We use it only for limited purposes connected with facilitating case assessment by selected partner clinics and coordinating the administrative aspects of your patient journey. Medioguide does not use it to make clinical decisions.

Communication data

Records of communications between you and Medioguide, including emails, call notes, messages, consultation notes, and records of your preferences, instructions or consent choices.

Technical and usage data

IP address, browser type, device information, website interactions and cookie or analytics data, where applicable. Non-essential analytics or marketing cookies are used only with consent through our cookie banner or cookie settings.

Marketing preferences

Your preferences regarding marketing communications, including whether you have opted in or unsubscribed.

Providing certain data may be necessary for us to respond to your enquiry or coordinate your requested services. If you do not provide the necessary data or do not give explicit consent for health-related data where required, we may not be able to assist you or share your case with partner clinics.

3. How we collect your data

We may collect personal data directly from you when you:

• submit an enquiry through our website;
• contact us by email, phone, video call, WhatsApp or other messaging channels;
• send us health-related documents, images, scans or other case materials;
• speak with our team during patient guidance or coordination calls;
• use our website, cookies or similar technologies;
• give consent or communication preferences through an online form, checkbox, email, call or another recorded method.

We may also receive information from partner clinics or service providers where this is necessary for your patient journey and consistent with applicable law.

4. Purposes and legal bases for processing

We process personal data only where we have a lawful basis to do so. For health-related information, we also identify a separate condition for processing special category data.

In summary, our main processing purposes and legal bases are:

• Responding to enquiries and providing administrative and informational guidance — identity, contact, enquiry and communication data — pre-contractual steps or contract performance; legitimate interests in responding to enquiries and operating our business.
• Coordinating introductions to partner clinics and supporting the administrative aspects of the patient journey — identity, contact, enquiry, communication and, where relevant, health-related data — pre-contractual steps or contract performance; for health-related data, explicit consent where required.
• Sharing health-related information with selected partner clinics for case assessment and treatment planning by those clinics — health-related information and relevant identity/contact information — explicit consent for health-related data; contract/pre-contractual steps where necessary to provide the requested coordination service.
• Communicating with you during the process — contact and communication data — contract performance; legitimate interests in maintaining communication and service quality.
• Operating, securing and improving our website and services — technical, usage and communication data — legitimate interests; consent where required for non-essential cookies or analytics.
• Marketing communications — identity, contact and marketing preference data — consent where required; legitimate interests where legally permitted and appropriate.
• Compliance, accounting, legal claims and regulatory obligations — relevant identity, contact, communication, contractual and case records — legal obligations; legitimate interests in establishing, exercising or defending legal claims; where special category data is necessary for legal claims, the relevant legal claims condition.

5. Health-related information and explicit consent

Because health-related information is sensitive, we will ask for your explicit consent before we share it with selected partner clinics and, where required, before we process it for patient journey coordination purposes.

This consent may be requested through a clearly worded, unticked checkbox, an electronic form, an email confirmation, a recorded oral statement, or another clear affirmative action that specifically refers to processing and sharing your health-related information. The consent may be collected in the same online or electronic flow as acceptance of our Terms and Conditions, but it should be distinguishable from general acceptance of the Terms.

Your consent may cover the partner clinic or partner clinics discussed with you orally, in writing or electronically. We do not need to request a new separate consent before every individual document transfer, provided the purpose, recipient or category of recipients is known to you in advance or is reasonably identifiable from our discussion, and we keep an appropriate record of the consent.

You may withdraw your consent at any time by contacting us. Withdrawal of consent does not affect processing already carried out before the withdrawal. If you withdraw consent or do not provide consent where it is required, we may not be able to continue coordinating your case or share your information with partner clinics.

6. What we use your personal data for

We use your personal data to:

• respond to your enquiries and provide administrative and informational guidance;
• understand what type of clinic, treatment route or administrative support you are looking for;
• connect you with appropriate partner clinics within our network;
• facilitate communication with partner clinics so that those clinics can carry out clinical assessment, consultation and treatment planning;
• coordinate administrative aspects of your patient journey, such as communication, scheduling and document transfer;
• communicate with you throughout the process;
• record consent, instructions and patient journey milestones for evidence and service quality;
• improve our website, systems and services;
• send marketing communications where you have opted in or where otherwise legally permitted;
• comply with legal obligations and protect our legal rights.

Medioguide does not provide medical treatment and does not make clinical decisions.

7. Data sharing

We may share your personal data with the following categories of recipients where necessary and lawful:

Partner clinics

We may share relevant personal data, including health-related information where you have given explicit consent, with selected partner clinics so that they can assess your case, communicate with you, provide consultation, prepare treatment plans or offer treatment. Partner clinics act as independent data controllers for the personal data they receive and process for their own clinical and administrative purposes. Their own privacy notices and clinical documentation will apply to their processing.

Service providers

We may use trusted service providers that support our operations, including providers of website hosting, email, cloud storage, CRM or case management systems, analytics, IT security, telephony, video calls, messaging or WhatsApp-related services, and other business tools. These providers may process personal data only as necessary to provide their services to us and subject to appropriate contractual and security safeguards.

Professional advisers and authorities

We may share personal data with legal, tax, accounting, compliance or professional advisers, insurers, courts, regulators or public authorities where required by law or necessary to protect our rights.

We do not sell your personal data.

8. International data transfers

Medioguide is established in Hungary, which is a member state of the European Economic Area. If you are located in the United Kingdom, your personal data may be transferred to and processed in Hungary and elsewhere in the EEA in connection with our services.

Some of our service providers may process personal data outside the United Kingdom and/or the EEA, for example where cloud, email, analytics, communications or IT infrastructure providers use international systems or sub-processors.

Where an international transfer requires safeguards, we will use appropriate legally recognised transfer mechanisms, such as adequacy regulations or adequacy decisions, the UK International Data Transfer Agreement or UK Addendum, EU Standard Contractual Clauses, or other lawful transfer mechanisms as applicable.

9. Data retention

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy and in accordance with applicable legal, accounting and regulatory requirements. We do not keep health-related information longer than necessary for patient journey coordination, unless a longer period is required for legal, regulatory or claims-related reasons.

When data is no longer needed, we will delete, anonymise or securely archive it as appropriate.

10. Cookies and similar technologies

Our website may use cookies and similar technologies. Strictly necessary cookies may be used to operate the website and provide essential functionality. Non-essential cookies, including analytics or marketing cookies, will be used only where you have given consent through our cookie banner or cookie settings.

More detailed information about the cookies we use, their purposes, retention periods and how you can change your preferences should be provided in our Cookie Policy.

11. Data security

We implement appropriate technical and organisational measures to protect personal data, including sensitive health-related information. These measures may include:

• role-based access controls and restricted access to personal data;
• multi-factor authentication for key systems where available;
• encryption or secure transfer methods where appropriate;
• access logging or audit trails where supported by our systems;
• secure cloud and IT service providers;
• internal policies and instructions for handling health-related information;
• limiting access to health-related data to people who need it for the relevant case.

We take particular care when handling health-related information and aim to avoid sending sensitive information through unsecured channels where a more secure alternative is available. No system can be guaranteed to be completely secure, but we take reasonable steps to protect personal data against unauthorised access, loss, misuse or disclosure.

12. Your rights

Subject to applicable conditions and limitations, you have the right to:

• access your personal data;
• request correction of inaccurate or incomplete data;
• request deletion of your data;
• restrict or object to processing;
• request data portability;
• withdraw consent at any time, where processing is based on consent;
• object to direct marketing at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. We will usually respond to rights requests within one month, unless the request is complex or we are legally entitled to extend the response period.

You also have the right to lodge a complaint with a supervisory authority. If you are in the United Kingdom, you may contact the Information Commissioner’s Office (ICO): https://ico.org.uk. As Medioguide is established in Hungary, you may also contact the Hungarian National Authority for Data Protection and Freedom of Information (NAIH): https://www.naih.hu.

13. Marketing communications

Operational communications about your enquiry, document transfer, appointment coordination, Partner Clinic communication, complaint forwarding or aftercare coordination are part of the patient journey coordination service and are not treated as standalone marketing communications.

We will send marketing communications only where we have an appropriate legal basis, such as your consent where required. You can unsubscribe or withdraw your consent at any time by using the unsubscribe link in our messages or by contacting us at info@medioguide.com.

We will use your name, image, testimonial, review, before-and-after material, case story or other identifiable marketing material only where there is an appropriate legal basis and, where required, your separate consent.

14. Automated decision-making

We do not use your personal data to make decisions based solely on automated processing that produce legal or similarly significant effects on you. We do not use health-related information for automated diagnosis, automated treatment planning or automated clinical triage.

15. Contact

If you have any questions about this Privacy Policy or how we process personal data, please contact us at:

16. Updates to this Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website. Where changes are significant or materially affect your rights, we may notify you by email or through a prominent notice on our website.