Privacy Policy

1. Introduction

This policy explains how CluvixHealth collects, uses, and protects personal data, both on the cluvixhealth.com website and within the CluvixHealth clinic management software used by our clinic customers.

CluvixHealth plays two different roles depending on context: it acts as a data controller for information about website visitors and customers who register for the service; and it acts as a data processor for medical record data that a clinic enters into the software. The clinic remains the data controller of its own patients’ data.

2. Data collected on the website

The "Request a consultation" form on the Contact page does not currently send data to CluvixHealth’s servers. When you click submit, your own browser opens your default email application with the content pre-filled, and the email is sent directly from your own mailbox to the CluvixHealth team. We do not store the information you enter into the form in any database until that email is sent.

If the website integrates a server-side form submission or a visitor-analytics tool in the future, this policy will be updated to accurately describe the data collected, its purpose, and the corresponding retention period.

3. Data processed within the CluvixHealth software

When a clinic registers to use CluvixHealth, the system processes the following categories of data, entered by the clinic or its staff:

• Clinic staff account information (full name, email, phone number, role)
• The clinic’s administrative customer information (full name, contact details, appointments)
• Electronic medical record data (diagnoses, orders, prescriptions, lab/imaging results), classified as sensitive personal health data
• Operational data (pharmacy inventory, invoices, reports) not directly tied to a specific individual

Medical record data is owned and controlled by the clinic. CluvixHealth processes this data as instructed by the clinic (as controller) and does not use it for its own purposes beyond operating and improving the service.

4. Purposes and legal basis for processing

• Providing and operating the software under the service contract signed with the clinic
• Responding to consultation or technical-support requests initiated by the customer
• Sending operational notices (maintenance, feature updates, invoices)
• Complying with legal obligations, including requests from competent state authorities

5. Sharing data with third parties

CluvixHealth does not sell personal data. Data is shared only with parties that process it on CluvixHealth’s behalf to operate the service, and only to the extent necessary, for example: cloud server infrastructure, payment gateways, e-invoice providers, and Zalo ZNS/SMS messaging providers when a clinic enables appointment reminders through those channels. These parties are bound by equivalent confidentiality obligations.

6. Data security

• Data encryption and role-based access control within the clinic
• Periodic data backups
• Electronic medical records built in line with Circular 32/2023/TT-BYT issued by the Ministry of Health
• Operating infrastructure hosted on internationally certified cloud platforms

No system is ever completely secure. If we discover an incident affecting personal data, CluvixHealth will notify the affected clinic and, where required by law, the competent authority within the prescribed time limit.

7. Retention period

Data is retained for as long as the service contract remains in effect, plus the minimum retention period required by law for medical records and accounting records. When the contract ends, the clinic may request that its data be exported or deleted in accordance with the service contract.

8. Rights of the data subject

Under Decree 13/2023/NĐ-CP on personal data protection (Vietnam’s Personal Data Protection Decree), you have the right to be informed, to consent, to access, to withdraw consent, to erasure, to restriction of processing, and to object to the processing of your personal data. For medical record data managed by a clinic, please contact that clinic directly. CluvixHealth assists the clinic in fulfilling such requests within the system when instructed to do so.

9. Cookies

See the separate Cookie Policy for details.

10. Changes to this policy

This policy may be updated as the product or legal requirements change. The most recent update date is always shown at the top of the page.

11. Contact

For any questions about this policy, please contact contact@cluvixsolutions.com or hotline 0976 365 284.