This notice describes how we handle the data given through this website, by phone or by message. The clinic’s own privacy notice for its treatment activity governs the health documentation connected to a treatment; this document does not replace it.
The controller
Controller: RR Aesthetics Kft. Registered seat: 1134 Budapest, Kassák Lajos utca 58-60., staircase B, ground floor 3. Company registration number: 01-09-409484. Tax number: 32156320-2-41. Represented by Ráti Renáta, managing director.
Email address for data protection matters: [email protected]
Within the monthly website care arrangement, and for as long as it runs, Kindl Dávid, sole trader (registration number: 62358013), takes part in operating the website as a processor. His role and obligations are set out in a data processing agreement that takes effect together with the monthly care arrangement.
The legal background of the processing is the General Data Protection Regulation (GDPR) and Act CXII of 2011 on informational self-determination and freedom of information. The supervisory authority is the Hungarian National Authority for Data Protection and Freedom of Information.
Booking
Online booking is currently not available on this website. You can ask for an appointment by phone, on Messenger or on Instagram; messages are covered under “Messages on Messenger and Instagram”.
Purpose: arranging the appointment.
Legal basis: processing necessary for the performance of a contract (Article 6(1)(b) GDPR). The appointment request itself is the expression of an intention to enter into a contract.
Data processed: name, phone number or Messenger or Instagram username, the service asked for and the agreed appointment time.
Processor: Salonic International Zrt. (the provider of the clinic’s appointment system). Retention period: [TO BE CONFIRMED]
If the appointment request leads to a treatment, the data connected to that treatment is transferred into the clinic’s own treatment documentation, and from then on the retention period for health documentation applies to it.
Forms
There is currently neither a contact form nor a consultation request form on this website. You can reach the clinic by phone, on Messenger or on Instagram.
Messages on Messenger and Instagram
If you write to the clinic on Messenger or Instagram, the message is carried and stored by the service of Meta Platforms Ireland Limited, under Meta’s own terms of use and privacy policy. The clinic replies from the same Messenger or Instagram account that the website’s buttons point to.
Newsletter
The newsletter is switched off: the signup box does not appear on the website, so the newsletter provider receives no data. Once it is switched on, the following applies.
Purpose: sending the newsletter and information to the subscriber.
Legal basis: consent (Article 6(1)(a) GDPR).
Data processed: email address, the time of the subscription and the time of the confirmation. We authenticate the subscription with a confirmation email: the address is added to the list only if the subscriber clicks the link in the confirmation email, so the consent remains demonstrable afterwards.
Processor: Sendinblue SAS (Brevo, France). The provider’s data processing agreement is part of its terms of use.
Retention period: until the consent is withdrawn or the subscription is cancelled.
The automated assistant
The automated assistant is switched off: it does not appear on the website, and no data reaches a language model through it. Once it is switched on, the following applies.
Purpose: automated information, based on the website’s own published content.
Legal basis: explicit consent (Article 9(2)(a) GDPR), alongside consent under Article 6(1)(a) GDPR, because the text you write may relate to health.
Data processed: the message you write, the last messages of the conversation (at most six), the chosen language and the turn count. The system forwards the message and the last messages of the conversation (at most six) to the language model provider to write the answer, and it forwards the message and the last messages (at most four) to detect urgent situations. The conversation history is kept only in your browser’s memory while the page is open; the browser sends it with every message, but the website does not store it.
We do not store the text of the conversation. A salted, shortened checksum is made from the IP address in order to filter abuse, and it deletes itself at the end of the time window being watched. Apart from this, we record only anonymous counts by month, for example how many questions arrived; none of them can be linked to any visitor.
You can write a message only after accepting the consent statement. The fact that you accepted stays in your browser’s session storage until the browser tab is closed; the system places no cookie. Because we do not store the text of the conversation, withdrawing your consent here means, in practice, ending the conversation.
If the assistant finds no answer, it offers to forward your question. You then give the question, your name and a way to contact you, and you consent to the processing with a separate checkbox. Your browser sends the forwarded question over an encrypted connection to the website, which delivers it in a single email to the clinic’s mailbox and does not store its content. The clinic’s staff do not see the conversation, only what you forward this way.
Processors: Scaleway SAS (France; the language model provider) and Cloudflare, Inc. (serving the website).
Retention period: the website does not store the text sent to the language model. According to the provider’s own information, by default it does not keep the content of requests and answers. The exception is requests that disrupt the operation of the service or suggest abuse: the provider may store their content temporarily, and, for requests that cause an error, for up to two weeks. According to the provider, the data is located in Paris.
Abuse filtering
Purpose: filtering out automated abuse and unsolicited submissions at the newsletter sign-up and in the automated assistant, when these are switched on.
Legal basis: legitimate interest (Article 6(1)(f) GDPR). It is in the interest of both the clinic and the visitors that the submission channels keep working.
Data processed: technical signals about the browser and the request, and a single-use code that proves the result of the check. The check is carried out by the Cloudflare Turnstile service. The service is set up not to place on the website a cookie that exempts the visitor from further checks. The website removes the check code before forwarding.
Processor: Cloudflare, Inc.
Cookies, browser storage and traffic measurement
In your browser’s own storage the website places only the signals it needs to work, for example whether you have closed the funding information block and, when the assistant is switched on, the fact of your consent until the browser tab is closed. None of these go to a third party. The map in the footer is an image drawn into the website that makes no outside request; route planning opens in Google Maps only if you click it.
The website does not run any traffic measurement program in your browser. We use no marketing cookies on the website.
Before-and-after photographs and case studies
We publish a photograph or a case study only with the documented consent of the person concerned.
Two independent consents are needed for this. One is the explicit consent under Article 9(2)(a) GDPR, because a photograph taken before and after a treatment is data relating to health. The other is the consent relating to a person’s likeness under Section 2:48(1) of the Hungarian Civil Code. The two have to be given together; one does not replace the other.
The consent can be withdrawn at any time, without giving a reason.
Retention period
Section 30 of Act XLVII of 1997 on the processing and protection of health and related personal data governs health documentation: the documentation has to be kept for at least thirty years from the recording of the data, and the discharge summary for at least fifty years.
This long retention period applies to the treatment documentation only; it does not apply to an enquiry that arrives through the website and does not lead to a treatment. If the enquiry leads to a treatment, the data goes into the treatment documentation.
The only copy of a submission from the website is the email that arrives in the clinic’s mailbox. That email is both the content of the enquiry and the proof of consent, because it contains the identifier of the accepted consent text and the time of the submission.
The clinic decides how long submissions are kept, and until it decides, every email is kept. Retention period of the emails that prove consent: [TO BE CONFIRMED]. Deletion period of the other submissions that do not lead to a treatment: [TO BE CONFIRMED]. Once the decision is made, we will publish the retention periods on this page.
Processors
- Cloudflare, Inc.: serving the website, abuse filtering, and forwarding the emails sent to the clinic’s email addresses.
- Google Ireland Limited: the provider of the clinic’s mailbox.
- GitHub, Inc.: storing and editing the content of the website. The repository holds no visitor’s personal data.
- Salonic International Zrt.: the provider of the clinic’s appointment system.
- Kindl Dávid, sole trader: operating the website within the monthly care arrangement, for as long as it runs.
The two providers of the switched-off functions receive no data from the website until those functions are switched on:
- Scaleway SAS (France): the language model of the automated assistant and of the AI summary of consultation requests.
- Sendinblue SAS (Brevo, France): sending the newsletter and confirming subscriptions.
Transfers of data outside the European Union
Cloudflare, Inc., which serves the website, and GitHub, Inc., which stores its content, are companies registered in the United States and operate on worldwide networks. The clinic’s Cloudflare subscription does not include the additional service that would restrict processing to the territory of the European Union, so at this layer we cannot promise that the data is processed only within the European Union. For Cloudflare, the transfer rests on the safeguards set out in the provider’s data processing addendum: for transfers to the United States, on the EU-US Data Privacy Framework, and otherwise on the standard contractual clauses adopted by the European Commission. The GitHub repository holds no visitor’s personal data.
In the European Economic Area, the provider of the clinic’s mailbox is Google Ireland Limited. According to Google’s privacy policy, the provider operates data centres around the world, so at this layer, too, we cannot promise that the data is processed only within the European Union.
Salonic International Zrt.’s privacy notice does not name the location of its servers; as hosting providers it lists Rackforest Zrt. and Websupport Magyarország, both in Budapest, and DigitalOcean, LLC in New York.
For the automated assistant and the AI summary of consultation requests, the language model is run by a European Union provider, Scaleway SAS, in Paris. The text reaches it through the Cloudflare network, and the limitation above applies to that layer. While the two functions are switched off, neither sends data to a language model.
With the newsletter switched on, the newsletter provider’s data processing agreement applies: under it, hosting is in France and Belgium, but some parts of the service may require processing outside the European Economic Area, and for these the provider undertakes an adequate level of protection.
Your rights
You may ask for information about which of your data we handle, and you may ask for inaccurate data to be corrected, for your data to be erased and for the processing to be restricted. The right to erasure is limited where the data has meanwhile become part of the treatment documentation, because in that case the law prescribes the retention.
You may object to processing based on a legitimate interest, and you may ask for the data you have given to be released in a machine-readable form.
You may withdraw your consent at any time, without giving a reason. The withdrawal does not affect the lawfulness of the earlier processing.
We fulfil requests within one month at the latest. You may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information, or before a court.
Information about the AI functions
Article 50 of the European Union’s regulation on artificial intelligence requires that you be told when you are interacting with an AI system. This is how we meet that duty on the website.
The automated assistant is switched off. When it is switched on, a sentence visible at the top of the assistant’s window for the whole of the conversation and the first message of the conversation tell you that you are talking to an AI system, and this disclosure also accompanies every answer of the assistant.
When switched on, the assistant writes its answers itself, only from the website’s published content, and next to an answer that states facts it marks which page it relied on. To a medical, suitability or urgent question it does not answer with text written by the model; instead it directs you to the clinic with a fixed text.
The price estimator works to fixed rules, and it gives no diagnosis, no opinion on suitability and no score. While using it, you do not interact with an AI system.
The English and Russian pages were produced with AI translation.
Data breach
In the event of a data breach we meet the notification and information duties prescribed by law.
Updating this notice
This notice was written for the launch of the website. We will fill in the items marked [TO BE CONFIRMED] once they are final, and we will note the change on this page.
If the clinic switches online booking, the forms, the automated assistant, the AI summary or the newsletter on or off, this notice is updated at the same time.