Legal

Privacy policy

Effective date: May 9, 2026.

ELITE Specialist Clinic (“Elite”) protects the privacy of its patients and website visitors in accordance with the Personal Data Protection Act of the Republic of Serbia (Off. Gazette RS, no. 87/2018) and the general principles of the EU General Data Protection Regulation (GDPR).

This privacy policy explains who collects your data, what data we collect, why and how, with whom we share it, how long we retain it, and what rights you have regarding your data.

1. Who is the data controller

The controller of your personal data is:

ELITE Specialist Clinic
Address: Jalijska Prva 73, 22000 Sremska Mitrovica, Serbia
Phone: +381 22 641 300
Email: sm.elite@yahoo.com

For any question concerning the processing of your data and the exercise of your statutory rights, you may contact us in writing at the address or email above.

2. What data we collect

Depending on your interaction with us, we collect different categories of data:

Identification and contact data

  • First and last name
  • Date of birth
  • Residential address
  • Phone number, email address, occupation

Health data (special category of data)

  • Medical history
  • Examination findings (audiograms, endoscopy recordings, photo and video documentation)
  • Diagnoses and treatment recommendations
  • Data on surgical procedures and anesthesia
  • Information on the medications you take and your allergies

Technical data from the website

  • IP address, device and browser type
  • Date and time of visit, pages viewed
  • Cookie data (see Cookie Policy)

3. Why we collect your data

We process your data solely for the following purposes:

  • Provision of health care — consultation, diagnostics, treatment, surgical procedures, follow-up
  • Maintaining medical records in line with statutory obligations
  • Communication with you — scheduling appointments, reminders, sharing reports
  • Billing services and issuing receipts
  • Legal and regulatory obligations (tax, statistical, health inspection)
  • Site security and abuse prevention

4. Legal basis for processing

We process your data on one or more of the following legal bases:

  • Consent you have given us for specific processing (e.g., sending informational messages by email)
  • Performance of a contract for the provision of health services to you
  • Legal obligation of the controller (Health Care Act, Health Records Act, tax laws)
  • Protection of vital interests of the patient — particularly in emergencies
  • Legitimate interest of the controller for site security and service improvement

5. With whom we may share your data

We do not sell or transfer your data to third parties for marketing purposes. We may share it only with:

  • Healthcare professionals involved in your care — anesthesiologist, nurses, external consultants
  • Other healthcare institutions to which we refer you for further diagnostics or treatment, with your consent
  • Laboratories and radiology facilities performing additional tests at our request
  • Accounting and legal advisors to the extent necessary for their services to us
  • Government bodies when required by law (tax authority, health inspection, courts)
  • IT service providers (hosting, email, scheduling systems) that act on our instructions and with whom we have signed processing agreements

Everyone with access to your data is bound by an obligation of medical and business confidentiality.

6. How long we keep your data

  • Medical records — in accordance with the Health Records Act, at least 10 years from the last examination (certain record types longer)
  • Accounting records — at least 10 years in accordance with tax laws
  • Marketing contact data — until consent is withdrawn
  • Technical data from the site — at most 12 months, unless a specific cookie is set to a shorter period

7. Your rights regarding your data

Under the Personal Data Protection Act, you have the following rights:

  • Right of access — to know what data of yours is being processed
  • Right to rectification of inaccurate or incomplete data
  • Right to erasure (“right to be forgotten”) — subject to legal limitations (medical records)
  • Right to restriction of processing in certain circumstances
  • Right to data portability in a commonly used structured format
  • Right to object to processing based on legitimate interest
  • Right to withdraw consent at any time, without consequences for processing performed before withdrawal
  • Right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection

You may submit requests in writing to the controller’s address or by email at sm.elite@yahoo.com. We aim to respond within the statutory 30-day deadline.

8. How we protect your data

We apply organizational and technical safeguards appropriate to the processing risk:

  • Access to medical records is limited to staff bound by medical confidentiality
  • Physical records kept in locked cabinets on clinic premises
  • Electronic records protected by password and role-based access
  • Site protected by SSL certificate (HTTPS)
  • Regular data backups

9. Cookies and site technical data

Our site uses cookies for proper functioning and to improve the user experience. For details on the cookies used, see our Cookie Policy.

10. Changes to the Privacy Policy

We may update this Privacy Policy from time to time. The most recent version is always available on this page, with the effective date noted. We will notify you of significant changes directly (by email or a site notice) before they take effect.

Contact for privacy questions

ELITE Specialist Clinic
Jalijska Prva 73, 22000 Sremska Mitrovica, Serbia
Email: sm.elite@yahoo.com
Phone: +381 22 641 300

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