PRIVACY POLICY

PRIVACY POLICY — CLINICA SANCOS MOBILE APPLICATION

Last updated: 16 July 2026


This Privacy Policy explains how CME SANCOS S.R.L. ("we", "us", "the Clinic") collects, uses, and protects personal data when you use the "Clinica Sancos" mobile application for Android ("the App"). Please read it together with any privacy notice published on our website.


The published version of this policy is available at: https://sancos.md/privacy-policy


1. WHO WE ARE (DATA CONTROLLER)

  CME SANCOS S.R.L.

  Address: Chișinău, bd. Moscova 16, Republic of Moldova

  Phone: (+373) 22 909 909

  Email: info@sancos.md


We are the data controller responsible for your personal data processed through the App.


2. WHAT THE APP IS

The App is a secure client for our online patient/medic cabinet hosted at portal.sancos.md. It displays that portal inside the App so you can sign in and use the same services on your phone. The App itself does not run its own analytics, advertising, or tracking. The personal data you enter or view is processed by the Clinic through the portal, as described below.


3. WHAT DATA WE PROCESS

Depending on how you use the App, we may process:

  - Account and identity data: your login name, name, and the credentials you use to sign in.

  - Contact data: e-mail address and phone number associated with your account.

  - Health data: appointments, schedules, medical documents, results, and other information related to the medical services you receive. This is special-category (sensitive) data and is treated with additional care.

  - Documents and attachments: files or documents that you open, download, or upload through the App.

  - Technical and session data: information required to keep you signed in and to operate the App, including session identifiers, your chosen interface language, device/operating-system information, and the app version.


We do not collect your precise location, and the App does not use the camera or microphone.


4. COOKIES AND LOCAL STORAGE

The App uses the same cookies and local storage that the portal website uses, stored only within the App on your device. These are strictly necessary to:

  - keep you signed in (session);

  - remember your selected language;

  - operate core features of the cabinet.

They are not used for advertising or cross-site tracking.


5. DEVICE PERMISSIONS

The App requests only the permissions it needs to function:

  - Internet / network access: required to connect to portal.sancos.md and load your cabinet.

  - Access to files/photos you choose: when you attach or upload a document, the App accesses only the specific file you select. It does not scan or read your other files or photos.


6. CHAT (THIRD-PARTY SERVICE)

If you use the in-app chat, the conversation is provided through JivoChat, a third-party live-chat service. Messages you send in the chat (and any details you provide there) are processed by JivoChat on our behalf so that our staff can respond to you. Please avoid sending sensitive medical details through the chat unless necessary. JivoChat processes this data under its own privacy terms.


7. HOW AND WHY WE USE YOUR DATA (LEGAL BASES)

We process your data to:

  - provide the medical cabinet services (appointments, documents, results);

  - authenticate you and keep your account secure;

  - communicate with you and respond to your requests, including via chat;

  - maintain, secure, and improve the App and portal;

  - comply with legal and regulatory obligations.


Legal bases include: 

- performance of a contract / provision of the service you request; 

- your consent (where required, in particular for health data and chat); 

compliance with our legal obligations; 

- and our legitimate interests in operating and securing the service. Health data is processed for the purposes of providing healthcare and related administration.


8. SHARING YOUR DATA

We do not sell your personal data. We share it only as necessary with:

  - our IT hosting and infrastructure providers that operate the portal on our behalf;

  - JivoChat, for the in-app chat function (see section 6);

  - Google Play, only for distributing and updating the App (Google may process limited technical data as part of app delivery under its own policies);

  - public authorities or other parties where required by law.


All processors act on our instructions and are bound to protect your data.


9. INTERNATIONAL TRANSFERS

Some of our service providers (for example the chat provider) may process data outside the Republic of Moldova. Where this happens, we take steps to ensure an adequate level of protection consistent with applicable law.


10. DATA RETENTION

We keep your personal data only for as long as necessary to provide the services, to maintain your medical and account records as required by applicable healthcare and record-keeping laws, and to comply with our legal obligations. When data is no longer needed, it is deleted or anonymized.


11. SECURITY

We use appropriate technical and organizational measures to protect your data, including encrypted connections (HTTPS) between the App and our servers, access controls, and short-lived, per-user tokens for accessing documents. No method of transmission or storage is completely secure, but we work to protect your information continuously.


12. YOUR RIGHTS

Under the Law of the Republic of Moldova No. 133/2011 on the Protection of Personal Data and, where applicable, the EU General Data Protection Regulation (GDPR), you have the right to:

  - access the personal data we hold about you;

  - request correction of inaccurate data;

  - request deletion of your data ("right to be forgotten"), subject to legal

    retention requirements;

  - restrict or object to certain processing;

  - withdraw consent at any time, where processing is based on consent;

  - data portability, where applicable;

  - lodge a complaint with the National Center for Personal Data Protection of the Republic of Moldova (or, if you are in the EU, your local supervisory authority).

To exercise any of these rights, contact us at info@sancos.md.


13. CHILDREN

The App is intended for the Clinic's patients and staff and is not directed at children under the age of 16. We do not knowingly collect data from children without the involvement of a parent or legal guardian. If you believe a child has provided us data without proper consent, please contact us and we will address it.


14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The current version is always available at https://sancos.md/privacy-policy, with the "Last updated" date shown above. Material changes will be communicated as appropriate.


15. CONTACT US

For any question or request regarding this Privacy Policy or your personal data:

  CME SANCOS S.R.L.

  Chișinău, bd. Moscova 16, Republic of Moldova

  Phone: (+373) 22 909 909

  Email: info@sancos.md

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