Controller
The controller of personal data is:
MEDIJENNA OÜ Registry code: 17267664 General and data protection contact: info@medijenna.ee Telephone: +372 5699 6938 Website: https://medijenna.ee/
MEDIJENNA has not appointed a formal data protection officer. Please send data protection questions to the email address above.
Scope
This notice explains how MEDIJENNA processes personal data when a person uses the website, sends an enquiry, books an appointment, prepares for or receives healthcare, makes a payment, or submits feedback, a complaint or a compensation claim.
Health data are special-category personal data. MEDIJENNA processes them only where there is a legal basis, only to the extent necessary, and subject to healthcare confidentiality. Processing health data for healthcare is generally not based on a general data-protection consent. It is based on the Estonian Health Services Organisation Act, the healthcare contract, statutory duties and Article 9(2)(h) GDPR. The patient's informed consent to the healthcare service itself is a separate requirement.
Data processed
Depending on the relationship and service, MEDIJENNA may process:
- identity and contact data: name, telephone, email, communication language and, where necessary, national identification code or date of birth;
- booking data: service, date, time, practitioner, status, changes, cancellation, lateness and non-attendance;
- health and care data: health status, concerns, history, assessments, test results, care or action plan, service provided, instructions and other data required for proper documentation;
- payment and accounting data: invoice details, payer, method, amount, debt and transaction data;
- communications: enquiries, emails, feedback, complaints, replies and timestamps;
- consent and evidence data: applicable terms version, time of confirmation, and consent or withdrawal where consent is relevant;
- website technical data: IP address, request time, URL, general browser and device data, security and error logs, and strictly necessary cookies or storage;
- incident and dispute data: description, evidence, demands, responses, insurance information and procedural data.
MEDIJENNA does not intentionally collect diagnoses, national identification codes, discharge summaries, test results, images or other health data through the public contact form. Do not send such information by ordinary email or a public form. Use the secure eKliinik channel approved by MEDIJENNA.
Purposes and legal bases
| Purpose | Data | Legal basis |
|---|---|---|
| Website operation, security, error detection and prevention of misuse | technical logs and strictly necessary storage | Article 6(1)(f) GDPR: MEDIJENNA's legitimate interest in security and reliability |
| Replying to a general enquiry and preparing a service | contact data and correspondence | Article 6(1)(b): pre-contractual steps; where needed, Article 6(1)(f): evidencing communications and defending claims |
| Booking, changing or cancelling an appointment | identity, contact and booking data; the service category may itself reveal health information | Articles 6(1)(b), (c); for health data, Article 9(2)(h) and § 4¹ TTKS |
| Providing and documenting healthcare | identity, health and care data | Articles 6(1)(b), (c), 9(2)(h); TTKS, the healthcare provisions of VÕS and applicable record rules |
| Billing, payments and accounting | identity, invoice and payment data | Articles 6(1)(b), (c); accounting and tax duties |
| Debt recovery and protection of legal rights | contract, communications, payment data and evidence | Article 6(1)(f); for special-category data, Article 9(2)(f) |
| Feedback, complaints, patient safety and quality | contact, communication, health and incident data | Articles 6(1)(c), (f); Article 9(2)(f) or (h), as applicable |
| Healthcare provider liability insurance incident and compensation claim | identity, health, service, damage and evidence data | Articles 6(1)(c), (f), 9(2)(f), (h); Estonian Patient Insurance Act |
| Voluntary information or marketing, if introduced | contact and consent record | Article 6(1)(a) and electronic marketing rules; consent can be withdrawn |
| Non-essential analytics or marketing cookies, if introduced | online identifiers and usage data | Article 6(1)(a); the tool is not loaded before valid consent |
MEDIJENNA does not use health data for targeted advertising, create advertising profiles of patients, or make solely automated decisions that produce legal or similarly significant effects.
Sources
Data primarily come from the patient or their legal representative, the eKliinik booking environment, the course of healthcare, lawful access to the Estonian health information system or another healthcare provider, and payment or communication partners. A person submitting another person's data must have authority to do so and should inform that person where possible.
Recipients and service providers
MEDIJENNA discloses data only where necessary and where there is a legal basis. Recipients or processors may include:
- Connected OÜ (registry code 11356823), providing the eKliinik booking and client management service, under the contract and the actual allocation of roles;
- Zone Media OÜ (registry code 10577829), providing web hosting and related technical services;
- the Health and Welfare Information Systems Centre (TEHIK) and the Estonian health information system where transmission or access is required by law or permitted for healthcare;
- banks and payment service providers;
- AS Merit Tarkvara (registry code 10254977), whose Merit Aktiva environment is used to manage accounting and process accounting records;
- the healthcare provider liability insurer once cover is effective;
- IT, cybersecurity, communications and archiving providers bound by confidentiality and data protection duties;
- Terviseamet, the Data Protection Inspectorate, Tervisekassa, a court, law-enforcement or another competent authority where disclosure is legally required or needed to protect rights.
A processor may use a subprocessor only in accordance with applicable data-protection requirements and its contract with MEDIJENNA. MEDIJENNA does not sell patient data.
Retention
Data are retained for as long as needed for the purpose, a statutory duty or a legal claim.
| Data | General retention criterion |
|---|---|
| Web-server security and error logs | generally up to 90 days; for an incident or claim, until final resolution and expiry of the claim |
| General enquiries that do not create a care relationship | generally up to 3 years after the last substantive communication |
| Booking, cancellation and non-attendance evidence | generally up to 3 years; longer if part of a health record or dispute |
| Healthcare records | under TTKS and the applicable documentation and retention rules; the erasure right does not require premature deletion of a mandatory record |
| Accounting source documents and invoices | generally 7 years after the end of the statutory accounting period |
| Complaints, damage and insurance incidents | until final resolution and then until the applicable claim expires; depending on the incident, up to 10 years may be necessary |
| Evidence of consent | while consent is valid and generally up to 3 years after withdrawal or the end of the activity where evidence remains necessary |
| Cookie preference | under the actual technical configuration and cookie table, no longer than necessary |
If the actual system differs from the general period, the system or notice must be corrected before publication. Data are not retained merely for an undefined possible future use.
Confidentiality and security
MEDIJENNA uses technical and organisational measures appropriate to risk and sensitivity, including role-based access, confidentiality obligations, secure connections, updates, backups and incident procedures. Only persons who need health data for their duties or under law receive access.
Ordinary email is not suitable for health data or medical documents. If a patient voluntarily emails sensitive information, MEDIJENNA may require the conversation to continue through a secure channel and restrict further use of the email.
Data subject rights
Subject to legal conditions, a patient has the right to:
- information and access;
- a first copy, generally free of charge;
- correction of inaccurate data;
- restriction of processing;
- erasure where no continuing legal basis exists; this is not absolute for healthcare records, accounts or legal claims;
- receive data they provided in machine-readable format and transmit them to another provider where portability applies;
- object to processing based on legitimate interests;
- withdraw consent at any time without affecting earlier lawful processing;
- not be subject to a solely automated decision unless law permits otherwise.
Send requests to info@medijenna.ee. MEDIJENNA may ask for proportionate information to verify identity. A response is generally provided within one month. For a complex request or a large number of requests, the period may be extended by up to two months, with notice during the first month.
If a patient believes processing is unlawful, they are encouraged to contact MEDIJENNA first. A complaint may also be filed with the Estonian Data Protection Inspectorate: https://www.aki.ee.
Minors and representatives
Where care is provided to a minor or a person with limited legal capacity, patient and representative data are processed to the extent permitted by law. The practitioner assesses the patient's ability to weigh the advantages and disadvantages of care and involves the legal representative as required, while respecting the patient's wishes and confidentiality where possible.
Changes
MEDIJENNA updates this notice when laws, services or technology change. The current version and date are published online. Material changes are communicated appropriately where necessary.