1. General Provisions
This Privacy Policy (hereinafter — the Policy) defines the procedure for processing and protecting the personal data of users of the Boya Hospital website (hereinafter — the Operator), located at No. 346, South Jiefang Road, Yanhu District, Yuncheng, Shanxi Province, China.
The Policy has been developed in accordance with the Personal Information Protection Law of the People's Republic of China (PIPL), Federal Law of the Russian Federation No. 152-FZ 'On Personal Data', and generally accepted international data protection standards, including Regulation (EU) 2016/679 (GDPR).
The Policy applies to all personal data that the Operator may receive from website users. Use of the website constitutes the user's agreement with this Policy.
2. Data We Collect
The Operator collects the following categories of personal data:
Data provided by the user:
- Full name
- Contact phone number
- Email address
- The child's selected diagnosis (when submitting a request)
Medical data (special category):
- Information about the child's diagnosis provided when booking a consultation
Technical data:
- IP address, browser type and version, referral source
- Cookies and similar technologies
Analytics data:
- Data collected by the Google Analytics (GA4) and Yandex.Metrica services
3. Processing Purposes
The collected personal data is processed for the following purposes:
- Booking consultations and appointments with the clinic's specialists
- Contacting the user to provide information about services
- Providing medical rehabilitation services
- Analytics and improvement of the website
- Fulfilling the Operator's legal obligations
4. Legal Basis for Processing
Personal data is processed on the following grounds: consent of the data subject, performance of a service agreement, and the legitimate interests of the Operator (analytics, security).
People's Republic of China: processing is carried out in accordance with the legislation of the PRC on personal information protection — on the basis of the informed consent of the data subject.
Russian Federation: processing is carried out in accordance with Articles 6 and 10 of Federal Law No. 152-FZ — consent of the data subject, including consent to the processing of special categories of data.
Other jurisdictions and international norms: for users from European Union countries, processing is carried out on the basis of Art. 6(1)(a) GDPR — consent, Art. 6(1)(b) — performance of a contract, and Art. 9(2)(a) — explicit consent to the processing of health data.
5. Data Storage and Protection
The Operator takes the necessary organizational and technical measures to protect personal data against unlawful access, destruction, modification, blocking, copying, and distribution.
Personal data is stored on secure servers and is processed only by authorized employees bound by confidentiality obligations.
The retention period for personal data is 3 years from the last interaction with the user or until consent is withdrawn.
6. Data Subject Rights
The user has the right to:
- Obtain information about their personal data processed by the Operator
- Request the clarification, blocking, or destruction of personal data
- Withdraw consent to the processing of personal data
- Appeal against the Operator's actions to the authority responsible for the protection of data subjects' rights
People's Republic of China: data subject rights are exercised in accordance with the legislation of the PRC on personal information protection, including the right of access to, rectification, and erasure of data.
Russian Federation: data subject rights are governed by Chapter 3 of Federal Law No. 152-FZ.
Other jurisdictions and international norms: users from European Union countries additionally have the right to data portability (Art. 20 GDPR), restriction of processing (Art. 18), objection (Art. 21), and the right to lodge a complaint with a supervisory authority.
To exercise these rights, the user may send a request by email or in writing to the clinic's address.
7. Cookies and Analytics
The website uses the following types of cookies:
- Essential — ensure the operation of the website (session, language preferences)
- Analytical — Google Analytics (GA4) and Yandex.Metrica for traffic analysis
- Functional — saving the language selection and settings
The user may disable cookies in the browser settings; however, this may affect the functionality of the website.
8. Data Sharing with Third Parties
The Operator does not sell or share personal data for third-party marketing. Data may be shared with:
- Request processing services (n8n, Telegram bot) — for prompt communication with the user
- Analytics services (Google Analytics, Yandex.Metrica) — for traffic analysis
- Partners providing technical support for the website — subject to compliance with confidentiality requirements
9. Cross-Border Data Transfer
Personal data may be processed outside the People's Republic of China in connection with the use of cloud services and analytics tools, as well as in order to serve Russian-speaking patients from CIS countries.
The Operator ensures an adequate level of data protection during cross-border transfer in accordance with standard contractual clauses.
10. Medical Data and Medical Confidentiality
Information about a child's diagnosis constitutes a special category of personal data (health data).
Medical data is processed only with the explicit consent of the data subject and exclusively for the purpose of providing medical rehabilitation care.
The Operator ensures compliance with medical confidentiality and the privacy of medical information in accordance with the legislation of the People's Republic of China.
11. Changes to the Policy
The Operator reserves the right to amend this Policy. The current version is always available on this page. The date of the last update is indicated at the beginning of the document.
12. Contact Information
For any questions related to the processing of personal data, you may contact us:
- Email: info@dcp-china.ru
- +86 136 8088 0512
- No. 346, South Jiefang Road, Yanhu District, Yuncheng City, Shanxi Province, China