Consent to Personal Data Processing

1. About this Consent

This document is the consent of the personal data subject, given to the Operator when a request is submitted through the form on the website. The consent is given freely, by the user’s own will and in the user’s own interest; it is specific, informed, conscious and unambiguous (Article 9(4) of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data").

The consent is deemed given at the moment the request is submitted with the personal data processing consent box ticked. The Operator records the date and time of submission, the IP address and the version of the text under which the box was ticked. The processing procedure is described in detail in the Personal Data Processing Policy.

Operator: Общество с ограниченной ответственностью «Глобал Трафик» (ООО «Глобал Трафик»), TIN 5403091377, KPP 540301001, PSRN 1265400004726. Registered address: 630088, РФ, Новосибирская область, г. Новосибирск, ул. Громова, д. 14, этаж 3, помещение 9. Email of the legal entity: info.globaltraffic@mail.ru.

2. What data is processed

The consent covers the processing of the data the user enters in the request form and provides in further communication with the Operator:

• name (or the preferred form of address);
• contact details: phone number, messenger account, email address — at the user’s choice;
• the selected area of treatment;
• the text of the request — to the extent the user chooses to provide it;
• technical data about the visit: IP address, cookie identifiers, browser and device information, referral source.

Health information

The selected area of treatment and any health information the user chooses to provide belong to a special category of personal data — data concerning health (Article 10 of 152-FZ). The user consents to its processing for the purposes listed below. Medical documents — discharge summaries, scans, test results — are neither requested nor accepted through the website form: they are provided later via a secure channel communicated by the manager and on the basis of a separate consent in written form.

3. Purposes of processing

The data is processed solely in order to:

• contact the user through the channel they specified and clarify the request;
• make a preliminary assessment of the request and select a suitable clinic in China;
• send the request to the selected clinic and obtain its opinion on whether treatment is possible;
• arrange and support the trip: logistics, accommodation, interpreter, communication with the clinic;
• conclude and perform the service agreement;
• inform the user about the progress of the selection and about the Operator’s services;
• comply with the obligations imposed on the Operator by the legislation of the Russian Federation.

4. Operations with the data

The consent covers the following operations, performed both with and without the use of automation tools: collection, recording, systematisation, accumulation, storage, updating (renewal, modification), retrieval, use, transfer (provision, access, cross-border transfer), depersonalisation, blocking, deletion and destruction of personal data.

5. Who the data is shared with

The Operator shares the minimum necessary amount of data with:

• medical institutions of the People’s Republic of China — for consultation, assessment of whether treatment is possible, and its provision;
• travel partners (airlines, hotels, interpreters, transport) — to the extent required for the specific service;
• parties processing data on the Operator’s behalf (hosting, request management systems, telephony and messengers) — subject to confidentiality and the requirements of 152-FZ;
• state authorities — in the cases expressly provided for by the legislation of the Russian Federation.

The Operator does not share personal data with third parties for advertising or marketing purposes.

6. Cross-border transfer of data to China

The user gives separate consent to the cross-border transfer of their personal data, including health information, to the territory of the People’s Republic of China — to the medical institutions engaged for consultation, assessment of whether treatment is possible, and its provision.

The People’s Republic of China is not a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data and is not included in the list of foreign states providing adequate protection of the rights of personal data subjects. Transfer of data to such a state is carried out on the basis of this consent under Article 12(4) of 152-FZ.

The user is informed of the risks of such a transfer: the transferred data is subject to the legislation of the People’s Republic of China, the scope of the data subject’s rights and the way they are protected may differ from those provided for by the legislation of the Russian Federation, and the Operator cannot guarantee that Russian protection standards will be applied to this data.

Data is transferred to a clinic only after the user has agreed with the Operator on a specific clinic or a set of clinics to approach. Until then, personal data is not transferred outside the Russian Federation.

7. Validity and withdrawal of consent

The consent is valid from the moment the request is submitted until the purposes of processing are achieved. For users who have not concluded an agreement, the processing period does not exceed 12 months from the date of the last contact; for clients — the term of the agreement plus 3 years after its termination, unless the legislation provides otherwise.

The consent may be withdrawn at any time by sending a written request to legal@silkwaymed.ru. Upon withdrawal, the Operator stops processing and destroys the data within no more than 30 days, except for data it is required to retain by law. Withdrawing the consent makes further clinic selection and trip support impossible. Data already transferred to a clinic in China is deleted by that clinic in accordance with the legislation applicable to it and the terms of its agreement with the Operator.

8. What the user confirms

By ticking the consent box in the request form, the user confirms that they:

• have read this Consent and the Personal Data Processing Policy;
• provide data that is accurate and relates to them personally; data of third parties (including family members) is provided with their consent;
• understand that the Operator’s services are organisational rather than medical: medical care is provided by the clinic, which also decides on the treatment;
• are informed of the risks of the cross-border transfer of data to the People’s Republic of China and agree to such transfer;
• are of legal age; for a minor, the consent is given by their legal representative.

9. Contacts

Questions about the processing of personal data, withdrawal of consent and requests regarding transferred data — by email to legal@silkwaymed.ru. The response time is no more than 30 days from receipt of the request. The current version of this Consent is published at silkwaymed.ru/consent.