Your privacy is part of the care we provide.
At Primea Polyclinic, we care not only about your health, but also about the trust you place in us. That is why we handle your personal data with particular care, respecting your privacy at every step. This Privacy Policy explains what information we collect when you visit our website, contact us or book an appointment, how we use it, and the measures we take to protect it. We want you to feel confident that, in every interaction with us, your personal data is handled responsibly, transparently and with respect.
This Privacy Policy explains how Primea Polyclinic collects and uses your personal data when you use our website and electronic services (such as the contact form and appointment booking form). Protecting our patients' privacy is our priority. All data is processed in accordance with the Personal Data Protection Act ("Official Gazette of RS", no. 87/2018) and relevant data protection regulations.
You can learn more about the use of cookies on the website in the separate Cookie Policy.
The data controller is:
BILJANA ALEKSIĆ-PAVLOVIĆ, ENTERPRENEUR POLYCLINIC IN THE FIELD OF PEDIATRICS, GYNECOLOGY AND OBSTETRICS, AND INTERNAL MEDICINE PRIMEA BELGRADE (ZVEZDARA), with registered seat in Belgrade, Bulevar Kralja Aleksandra 142, 2nd floor, section C, block 10, company ID 68411742.
The table below shows:
| Purpose | Legal basis | Type of data |
|---|---|---|
| Recruitment process | Contract conclusion with the related person | Name and surname, contact information, details from the biography and motivational letter |
| Contacting candidates who were not initially hired to apply for newly opened positions | Consent | Name, contact information, details from the resume and motivation letter |
| Booking an appointment (via web form, phone, in person, through insurance companies, or through partners with whom the controller collaborates) | Conclusion of a contract with the data subject | Identification (first name, last name, gender) and contact details (email and/or phone number), date of birth, service being booked |
| Creating an account on the website within our clinical software for booking appointments | Conclusion of a contract with the data subject | Identification (first name, last name, gender) and contact details (email and phone number), date of birth, service being booked, SMS verification code |
| Opening a medical record in our clinical software and providing healthcare services | Legal obligation of the controller Performance of a contract with the data subject | Identification and contact details, mandatory medical documentation in accordance with regulations governing healthcare documentation and records |
| Opening an electronic health record on the patient portal My e-record | Consent | Identification (first name, last name, gender) and contact details (email and phone number), date of birth, identification number, mandatory medical documentation in accordance with regulations governing healthcare documentation and records |
| Uploading documentation onto the patient portal My e-record | Consent | Medical and other documentation that patients upload to the portal themselves, for the content and accuracy of which they are solely responsible |
| Access to the electronic health record by authorised persons granted unrestricted access rights by the patient | Consent | Identification (first name, last name, gender) and contact details (email and phone number), date of birth, identification number, mandatory medical documentation in accordance with regulations governing healthcare documentation and records; medical and other documentation uploaded to the portal by patients themselves |
| Email communication during the contract duration | Execution of a contract with the data subject | Email address, content of email messages |
| Billing for services through insurance | Legal obligation of the controller Performance of a contract with the data subject | Referral, medical report, data required for payment |
| Payment of fees to partners who facilitated the booking appointments | Legitimate interest | First and last name, type of service |
| Communication via web form inquiries | Legitimate interest | First and last name, email address, phone number (optional), content of communication |
| Giveaway prize delivery (Instagram / Facebook) | Conclusion and performance of a contract with the data subject | First and last name, email address, phone number |
| Newsletter | Consent | |
| Filling out questionnaires published on our website and/or social media | Consent | First and last name, email address, date of birth, questionnaire responses including health data |
| Sending specialized publications and other promotional materials | Consent | First and last name, email address |
| Video surveillance | Legitimate interest | Video recording |
We retain the personal data of job applicants who have consented to being contacted about suitable future vacancies for 12 months from the date of their initial application. We retain the same data retention period for prospective clients who have booked an appointment that did not take place.
Medical, financial, and insurance documentation is retained for the periods prescribed by applicable laws.
We retain the personal data of job applicants who have consented to being contacted about suitable future vacancies for 12 months from the date of their initial application. We retain the same data retention period for prospective clients who have booked an appointment that did not take place.
Medical, financial, and insurance-related documentation is retained for the periods prescribed by applicable laws.
If individuals who have created an account on the Patient Portal (electronic record) withdraw their consent and request the deletion of their account, the data controller is still required to retain certain documentation that was available through the portal within its clinical software, in accordance with applicable laws. When an account on the Patient Portal is deleted, the following data are permanently deleted: the account itself, associated notifications, delivery records, push notification subscriptions, and documents uploaded to the account by the individual.
We retain the personal data of job applicants who have consented to being contacted about suitable future vacancies for 12 months from the date of their initial application. We retain the same data retention period for prospective clients who have booked an appointment that did not take place.
Medical, financial, and insurance-related documentation is retained for the periods prescribed by applicable laws.
If individuals who have created an account on the Patient Portal (electronic medical record) withdraw their consent and request the deletion of their account, the data controller is still required to retain certain documentation that was available through the portal within its clinical software, in accordance with applicable laws. When an account on the Patient Portal is deleted, the following data are permanently deleted: the account itself, associated notifications, delivery records, push notification subscriptions, and documents uploaded to the account by the individual.
Communications submitted through the website's contact form are deleted once the enquiry has been answered and the purpose of the communication has been fully fulfilled. Personal data collected on the basis of consent are retained until that consent is withdrawn.
Video surveillance recordings are generally retained for 30 days. They may be retained for longer where incidents have been recorded that require the initiation of relevant proceedings.
Your personal data may be shared with third parties in the following cases:
In the case of individuals who have created an account in the patient portal (electronic record) and granted access to specific authorised persons, those authorised persons have unrestricted access to the account, without the ability to hide individual examinations or appointments. Authorised persons have the same rights to manage the account as the account holder, including uploading and downloading documents through the portal. Access rights may be revoked either by the person who granted them, by withdrawing their consent, or by the authorised person themselves. Once access rights are revoked, the authorised person loses all access to the account. However, this does not affect any rights the authorised person exercised while access was granted.
Parents of children under the age of 15 have the right to create a patient portal account for their child. After the child turns 15, the child has the right to create an account independently and to restrict parental access to their portal, in accordance with personal data protection and patient rights regulations.
We process personal data in Serbia or in countries that provide an adequate level of data protection, except where we use Meta social media platforms for giveaway campaigns, which may process data in third countries in accordance with the transfer mechanisms and rules available on Meta’s website.
In accordance with the conditions regulated by the Law, you have the following rights:
You can submit a request to exercise any of these rights via email at: privatnost@primea.rs.
If you believe that your rights have been violated, you have the right to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia.
The Controller applies appropriate technical, organisational and personnel measures to protect your personal as effectively as possible against loss, misuse, or unauthorised disclosure. All collected data is securely stored on protected servers that meet high security standards. Access to this information is strictly controlled and allowed only to authorised personnel who need the data to perform their tasks.
All changes to this Privacy Policy will be published on this page with an updated effective date.
Primea Polyclinic does not carry-out automated decision-making or profiling based on personal data.
For any questions, comments, or requests regarding the processing of personal data, you can contact us via:
Address: Bulevar Kralja Aleksandra 142, Landmark Residence, 2nd floor
Email: privatnost@primea.rs
Valid from 15th October 2026
