PRIVACY AND PERSONAL DATA PROTECTION POLICY
1. General Provisions and Data Controller
Within the scope of its activities, KHNAMI processes personal data in accordance with the legislation of the Republic of Armenia.
KHNAMI is responsible for its processing of personal data where it determines the purposes and means of such processing.
These provisions apply to personal data processing carried out by KHNAMI in connection with the Website, Patient personal data, bookings, organization of medical care and services, communications, payments, and related activities.
Contact details:
“KHNAMI” Palliative Care Center LLC
Republic of Armenia, Yerevan, 2 G. Sherami St.
TIN: 00211847
Email: contact@khnami-center.com
Phone: +374(93)57-75-39
Data concerning health condition and medical care may be considered personal data subject to special protection and, at the same time, may constitute medical secrecy in cases provided by the legislation of the Republic of Armenia.
2. Scope of the Provisions
These provisions may apply to:
- persons receiving or applying to receive KHNAMI services,
- legal representatives of the Patient,
- persons authorized by the Patient,
- persons arranging or paying for the Patient’s care,
- registered users of the Website or personal account,
- persons contacting KHNAMI electronically, by telephone, or by another method,
- persons using the Website.
3. What Data We May Process
Depending on the person’s status and the service being received or arranged, KHNAMI may process the following data:
3.1. Identification and Contact Data
- first and last name,
- date of birth,
- sex,
- address,
- telephone number,
- email address,
- necessary information from an identity document,
- information necessary to confirm the identity and authority of a representative or authorized person.
3.2. Health and Medical Data
Depending on the service:
- medical history,
- diagnoses,
- complaints and symptoms,
- information about medications being taken,
- information about allergies,
- examination and laboratory results,
- medical and care records,
- treatment or care plans,
- medical documents provided to KHNAMI,
- other health information necessary for organizing the Patient’s care.
3.3. Photographs
For medical or care purposes, where necessary, photographs required to document the Patient’s health condition, the course of care, or changes in it may be processed.
3.4. Payment and Service Data
- selected services,
- bookings,
- payment status,
- amounts paid,
- invoices and calculations,
- information about refunds.
If card data are entered directly in the fields of a bank or payment service provider, KHNAMI does not store the full card number or CVV code.
3.6. Communication Data
- emails,
- messages,
- inquiries,
- complaints,
- data concerning the organization of visits and consultations,
- records of consents or authorizations given,
- other communications necessary for organizing services or complying with legal requirements.
4. Sources of Data
KHNAMI may receive personal data from:
- the Patient,
- the Patient’s legal representative,
- an authorized person having the relevant authority,
- KHNAMI healthcare professionals and employees during the provision of services,
- other persons lawfully involved in the Patient’s care or treatment,
- payment or technical service providers,
- healthcare or other state bodies of the Republic of Armenia where receipt of the data is permitted or required by law.
A person providing data about another person is responsible for transmitting those data.
5. Purposes of Personal Data Processing
KHNAMI processes personal data for the provision of services and other lawful purposes, including to:
- assess, organize, provide, and document medical care and services,
- plan and provide palliative and other care,
- identify the Patient,
- verify the authority of a representative or authorized person,
- organize visits and consultations,
- maintain medical documents and care-related records,
- operate the Patient’s personal account,
- provide relevant information to the Patient or an authorized person,
- manage payments, invoices, prepayments, and refunds,
- fulfil accounting obligations required by law,
- record or update data required by law in electronic healthcare systems,
- ensure the security of the Website and information systems,
- prevent fraud and unauthorized access,
- respond to inquiries and complaints,
- comply with legal requirements or protect rights,
6. Health Data and Medical Secrecy
The protection of health data is of particular importance to KHNAMI.
Access to the Patient’s medical data is granted only to employees and other persons for whom such access is necessary to perform their professional or work duties or who are entitled to receive such information under the legislation of the Republic of Armenia.
7. Access by Representatives and Relatives
KHNAMI may verify the identity and authority of a person who applies on behalf of the Patient or wishes to receive protected information about the Patient.
Where a valid permission or authorization exists, KHNAMI may determine the scope of access taking into account the authority granted and the nature of the information.
11. Data Recipients and Service Providers
Where necessary and on a lawful basis, data processed by KHNAMI may be made available or transferred to:
- authorized KHNAMI healthcare professionals,
- care specialists,
- relevant administrative employees,
- IT and information security specialists,
- operators of healthcare systems provided by law,
- competent state authorities,
- payment service providers,
- courts, law-enforcement, or regulatory authorities in cases provided by law.
KHNAMI provides data only to the extent necessary for the purpose of the relevant transfer or service.
13. Payment Data
Online payments are processed through banking or payment infrastructure used by KHNAMI.
KHNAMI may retain the transaction amount, payment status, payment date, and other data necessary for accounting or dispute resolution.
15. Photographs
Photographs may be taken or stored where necessary to document medical care, care, or changes in health condition.
Photographs of an identifiable Patient are not published for advertising, public, or marketing purposes without an appropriate separate legal basis and, where necessary, the proper consent of the Patient or the Patient’s authorized representative.
When clinical images are used for professional training, scientific, or presentation purposes, KHNAMI applies the personal data and medical secrecy protection measures required by the legislation of the Republic of Armenia.
The mere fact that a face is not visible is not always sufficient in itself to exclude the possibility of identifying a person.
16. Data Retention Periods
KHNAMI retains personal data only for as long as necessary for the purpose of processing, unless the legislation of the Republic of Armenia establishes a longer mandatory retention period for the relevant type of information.
Medical records are retained for the periods established for the relevant type of document by the healthcare and archival legislation of the Republic of Armenia.
Payment and accounting data are retained for the periods prescribed by the tax, accounting, and other applicable legislation of the Republic of Armenia.
Security, system, and technical records are retained only for as long as necessary for security, prevention of violations, operation of the system, or compliance with legal requirements.
If retention periods change by law, the mandatory requirements in force at the relevant time apply.
17. Complaints and Contact
For questions concerning personal data protection, medical secrecy, or this Policy, you may contact:
“KHNAMI” Palliative Care Center LLC
TIN: 00211847
Republic of Armenia, Yerevan, 2 G. Sherami St.
Email: contact@khnami-center.com
Phone: +374(93)57-75-39
A person may also exercise the right provided by the legislation of the Republic of Armenia to apply to a competent state authority or a court.