PRIVACY POLICY  
Last updated: 04.11.2025  
We collect information about you when you provide it to us through our Platform  
DentaxSoft.com / https://dentaxsoft.com/#about/ or when you communicate with us directly, for  
example by contacting our staff or corresponding with us by telephone, email, or otherwise, or  
automatically when you visit our website.  
We may receive special category personal data about your physical or mental health,  
including, but not limited to, genetic or biometric information from application forms, notes and  
reports regarding your health and any treatment or care you have received or may need, notes  
obtained from calls and other communications with us, records of medical services and  
treatment you have received, or when you provide such information to us through our Platform.  
HOW LONG DO WE KEEP YOUR PERSONAL DATA?  
We will retain your personal data only for as long as necessary to fulfill the purpose for which we  
collected it, including for the purpose of complying with any legal or regulatory requirements.  
WHO DO WE SHARE YOUR PERSONAL DATA WITH?  
We may also share your Personal Data with certain trusted third parties in accordance with  
contractual arrangements entered into with them, including:  
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Third parties involved in the provision of services by us to users or subsidiary entities, with  
their prior consent, such as healthcare service providers;  
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Our professional advisers and auditors;  
Suppliers we rely on for certain support services, such as word processing, translation,  
photocopying, and document review; and  
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Our IT service providers.  
Where necessary, or for the reasons set out in this Privacy Policy, Personal Data may also be  
shared with regulators, courts, tribunals, governmental authorities, and law enforcement  
authorities. Although this is unlikely, we may be required to disclose your Personal Data in order  
to comply with legal or regulatory requirements. We will take all reasonable steps to notify you  
before doing so, unless we are legally prohibited from doing so.  
We do not sell, rent, or otherwise make Personal Data available to any third party for commercial  
access.  
HOW DO WE PROTECT YOUR PERSONAL DATA?  
We implement a range of technical and organizational measures to protect your Personal Data  
from unauthorized access, use, disclosure, alteration, or destruction in accordance with  
applicable data protection laws.  
We have appointed a data protection officer, as our core activities require large-scale  
processing of special category data.  
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LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA  
(INCLUDING SPECIAL CATEGORY DATA)  
Under the Law of the Republic of Armenia “On Personal Data Protection” and other applicable  
laws, we must ensure that each use of your Personal Data is justified by lawful grounds. We rely  
on several such grounds.  
In some cases, we process your Personal Data because it is necessary for a contract to which  
you are a party, or to take steps at your request prior to entering into a contract (for example, to  
provide healthcare services). In other situations, we may process your Personal Data where it is  
necessary for our legitimate interests or those of a third party, provided that your interests and  
fundamental rights do not override those interests. Examples of such legitimate interests include  
the administration and management of our services, as well as ensuring network and information  
security.  
We may also process your Personal Data where it is necessary to comply with legal obligations  
(for example, under health and safety legislation or other regulatory requirements).  
In certain circumstances—particularly where we process special category personal data that is  
not covered by the grounds above—we rely on your explicit consent (for example, where we  
need to process certain health data). You have the right to withdraw this consent at any time.  
We may also process special category personal data such as health data, race, religion, or  
genetic/biometric data, which benefit from enhanced protection under data protection laws. In  
addition to relying on one of the lawful bases above, we must have an additional justification to  
process these categories. Processing may be necessary for the provision of healthcare services,  
including preventive or occupational medicine, medical diagnosis, or the administration of  
healthcare systems. It may also be necessary for reasons of substantial public interest, such as  
preventing fraud or protecting someone’s welfare, or for establishing, exercising, or defending  
legal claims. In some cases, it may be required to protect vital interests where an individual is  
physically or legally incapable of giving consent. If none of these justifications apply, we will  
request your explicit consent before processing these special categories of Personal Data.  
HOW DO WE USE YOUR PERSONAL DATA?  
We collect and process your personal data in a number of ways, including through your use of  
our Platform and through the provision of our services.  
We collect, process, store, and use personal data provided to us by our users or subsidiary  
entities, or on their behalf, during and in connection with the services we provide.  
Below we describe how we use your Personal Data and, in each case, the legal basis on which  
we rely. Our legitimate interests are listed where relevant.  
PURPOSE / ACTIVITY — LAWFUL BASIS (INCLUDING LEGITIMATE INTERESTS)  
To register you as potentially interested in the services of healthcare providers listed on our  
website.  
• Necessary for our legitimate interests (to develop our services and grow our business).  
To manage our relationship with you, which will include: (a) informing you about changes to  
our Privacy Policy; (b) inviting you to complete a medical history questionnaire.  
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• (a) Necessary to comply with a legal obligation.  
• (b) Necessary for our legitimate interests (to keep our records up to date and to consider website  
users’, patients’, and healthcare providers’ interest in our services or future services, and ways to  
develop them and grow our business).  
YOUR CONSENT  
To provide you with relevant content and to measure or understand the effectiveness of such  
content.  
• Necessary for our legitimate interests (to study how website users, patients and/or other healthcare  
providers may use our services, to grow our business, and to inform our marketing strategy).  
To help healthcare providers assess your suitability for a procedure or treatment and to  
manage their capacity for relevant/required treatments.  
• Necessary for performance of a contract with you and for our legitimate interests (to provide  
effective healthcare services).  
CHILDREN  
The minimum age to use our Platform is 18. We do not knowingly collect or use personal data of  
persons under 18. If we learn that we have collected personal data from a person under 18, such  
personal data will be deleted as soon as possible. If a child under 18 has provided us with  
personal data, their parent or guardian may contact us.  
COUNTRIES TO WHICH WE TRANSFER YOUR PERSONAL DATA  
To provide our services, DentaxSoft.com and its owner, “Vitarum” LLC, may need to transfer  
your personal data to locations outside the jurisdiction where you provide it or where you view  
the Platform for the purposes specified in this Privacy Policy.  
This may involve transferring your information outside the territory of the Republic of Armenia to  
any country to which you provide your unconditional consent.  
The level of protection in countries outside the Republic of Armenia may be lower than that  
offered in Armenia. In such cases, we will take appropriate measures to ensure your personal  
data remains protected and secure in accordance with applicable data protection laws. We may  
also transfer personal data to countries that have not been assessed as adequate if we use  
appropriate safeguards.  
MAIN SAFEGUARDS USED BY US INCLUDE:  
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Standard contractual clauses approved by the regulator; and  
Additional contractual, organizational, and technical measures (as necessary after a transfer  
risk assessment).  
Transfers within the “Vitarum” LLC group will always be covered by an agreement that  
contractually obliges each company to ensure an adequate and consistent level of protection.  
YOUR RIGHTS REGARDING YOUR PERSONAL DATA  
The Law of the Republic of Armenia “On Personal Data Protection” and other applicable data  
protection laws grant certain rights to data subjects. We want to ensure you are fully aware of all  
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rights provided by data protection laws.  
Under the RA Law “On Personal Data Protection”, each user has the following rights:  
You have the right to request that we correct any information you believe is inaccurate.  
You also have the right to request that we complete information you believe is incomplete.  
You have the right to request that we erase your personal data under certain conditions.  
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You have the right to request that we restrict processing of your personal data under certain  
conditions.  
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You have the right to object to our processing of your personal data under certain conditions.  
You have the right to request that we transfer the data we have collected to another  
organization, or directly to you, under certain conditions.  
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You have the right to request details about the data we hold about you and how we process it.  
You may also have the right (subject to applicable data protection laws) to rectify or erase that  
data, restrict our processing of it, stop unauthorized transfers of your personal data to a third  
party, and in some cases, transfer personal data concerning you to another organization.  
If you object to processing, or if you have given consent for processing and later decide to  
withdraw it, we will respect that choice in accordance with our legal obligations.  
Your objection (or withdrawal of any previously given consent) may mean that we cannot carry  
out actions necessary to achieve the purposes described above, or that you may not be able to  
use services and products we offer. Please note that even if you withdraw your consent, we may  
continue processing your Personal Data to the extent required or otherwise permitted by law, in  
particular in connection with exercising and defending our legal rights or complying with legal and  
regulatory obligations.  
COMPLAINTS  
If you have any concerns about how we use your Personal Data, you can lodge a complaint with  
us using the contact details at the end of this Privacy Policy. Subject to legal and other  
permissible considerations, we will take all reasonable steps to promptly satisfy your request or  
inform you if we need additional information to do so. We may not always be able to fully satisfy  
your request—for example, if it would affect our duty of confidentiality to others, or if we have the  
legal right/obligation to handle the request differently.  
If, after lodging a complaint with us, you remain dissatisfied with how we use your Personal Data,  
you may also submit a complaint to the Office of the Information Commissioner.  
CONTACT US  
We must ensure your Personal Data is accurate and up to date; therefore, please notify us  
immediately of any material changes to the information we hold.  
If you have any questions about the processing of your Personal Data or this Privacy Policy,  
please contact our data protection officer and privacy team at: info@dentaxsoft.com.  
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