Effective Date: November 2026 | Policy Version: v1.0

1. Who We Are (Data Controller)

Anima Clinic (“we,” “our,” or “us”) operates the website https://ivfanima.com/ and provides IVF, fertility, and reproductive healthcare services in Tbilisi, Georgia. For the purposes of the EU General Data Protection Regulation (GDPR) and applicable data protection laws, Anima Clinic is the Data Controller responsible for your personal data.

2. Personal Data We Collect

  • Contact & Inquiry Data: Full name, email address, phone number, and message details submitted via our Contact Us form, WhatsApp/Chaty widget, or email.
  • Health & Medical Information (Special Category Data): Any fertility, medical history, or diagnostic information you voluntarily share when requesting a consultation.
  • Technical & Lead Source Data: IP address, browser/device information, pages visited, and referral/UTM parameters (utm_source, utm_medium, utm_campaign).
  • Consent Records: Timestamp, policy version (v1.0), and selection status for inquiry processing and optional marketing communications.

3. How and Why We Use Your Data (Legal Bases)

  • Responding to Inquiries (GDPR Art. 6(1)(b) & Art. 6(1)(a)): To answer your questions, schedule consultations, and provide requested information about our fertility programs.
  • Processing Health-Related Inquiries (GDPR Art. 9(2)(a) & Art. 9(2)(h)): Where you voluntarily include medical details in an inquiry, we process this data solely based on your explicit consent to evaluate and provide healthcare services.
  • Marketing Communications (GDPR Art. 6(1)(a)): Only if you explicitly tick the optional marketing consent box, we may send you clinic news and educational fertility updates. You may withdraw consent at any time.
  • Website Security & Analytics (GDPR Art. 6(1)(f) & Art. 6(1)(a)): To maintain site security and analyze website traffic (only where you have consented to analytics cookies).

4. Data Sharing & International Transfers

We do not sell, rent, or trade your personal data. Data is shared only with essential service providers (secure hosting, email delivery, WhatsApp Business tools, and analytics platforms) under strict confidentiality and data processing agreements, with appropriate safeguards (such as Standard Contractual Clauses) where applicable.

5. Data Retention

  • General Inquiries: Retained only as long as necessary to handle your request and follow-up communications (typically up to 12–24 months unless you become a patient).
  • Patient Medical Records: Retained in accordance with mandatory Georgian healthcare regulations.
  • Marketing Data: Retained until you unsubscribe or withdraw consent.

6. Your Rights Under GDPR

You have the right to access, rectify, or erase your personal data, restrict or object to processing, request data portability, and withdraw consent at any time without affecting prior lawful processing. To exercise these rights, contact us at info@animaclinic.ge.

7. Security Measures

We implement SSL/TLS encryption, strict access controls, and secure storage to protect your personal and medical data against unauthorized access or disclosure.