Privacy policy

This privacy policy explains how VIP Cure Trip processes personal data, in particular health data, when you use our website or request a free consultation. It applies under the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR). Last updated: [待确认]

1. Controller

[待确认：company name, address] Privacy contact: {{EMAIL}} EU representative under Art. 27 GDPR: [待确认：required?]

2. Data we process

Contact data:

name, email, phone/WhatsApp, country

Health data:

diagnosis, reports, imaging, doctors' letters and your questions – sensitive data (FADP Art. 5(c); GDPR Art. 9)

Organisational data:

travel dates, passport details for appointment booking, companions

Technical data:

IP address, browser, access time (see Cookie policy)

3. Purposes and legal bases

Purpose	Legal basis
Answering your enquiry	Pre-contractual steps (GDPR Art. 6(1)(b))
Processing health data to organise, translate and forward your records	Explicit consent (FADP Art. 6(7); GDPR Art. 9(2)(a))
Transfer to a hospital in China	Separate explicit consent (see section 4)
Running and securing the website	Legitimate interest (GDPR Art. 6(1)(f))
Statutory retention	Legal obligation

4. Transfer to China

China is not recognised under Swiss or EU law as providing an adequate level of data protection. We therefore send your records to a hospital in China only with your separate, explicit consent (FADP Art. 17(1)(a); GDPR Art. 49(1)(a)), and only to the hospital you choose.

Before you consent, we explain the risks: authorities in China may in some circumstances access data, and your rights may be harder to enforce there. In China, the hospital is subject to China's Personal Information Protection Law (PIPL). [待确认：lawyer to review consent wording and PIPL duties]

You can withdraw consent at any time with effect for the future. We cannot retrieve data already sent, but we will ask the hospital to delete it where legally possible.

5. Recipients and processors

The hospital you choose (only with consent)
Medical translators [待确认：confidentiality agreement]
Hosting: [待确认：provider, Swiss/EU location]
Encrypted file upload: [待确认：provider]
Email and messaging: [待确认：provider]; WhatsApp only at your request and not for medical records [待确认]
Analytics: [待确认：privacy-friendly tool, e.g. cookieless]

6. Retention

Enquiries without engagement: deleted after [待确认：12 months]
Case files after engagement: deleted [待确认：24 months] after completion, unless the law requires otherwise
Accounting records: 10 years (statutory), without health data

7. Security

TLS in transit, encrypted storage, access limited to responsible staff, logging. [待确认：technical details]

8. Your rights

You have the right to access, rectification, erasure, restriction, data portability, objection and withdrawal of consent. Contact: {{EMAIL}}.

You may complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC) or to the supervisory authority in your EU country of residence.

Language of the first page

When you open the site at the bare domain, we may send you to a language version. We look first at a language cookie you set yourself, then at your browser’s Accept-Language header, then at the country named by the hosting network. That country code is used only to choose the response. It is not stored and it is not written to a log. The basis we rely on is our legitimate interest in showing a page you can read. This paragraph is a draft for legal review.

9. Changes

We update this policy when our processing or the law changes. The published version applies.

Medical disclaimer: VIP Cure Trip is not a medical provider and does not diagnose or treat. The content on this page is general information and does not replace advice from a qualified physician. All medical decisions are made by the treating doctors. In an emergency, call 144 (Switzerland) or 112 (EU). Full medical disclaimer