Privacy Policy

This Privacy Policy explains how РЕТРОСПЕКТИВА ДОО (trading as Digitermin) collects, uses, stores, transfers, and protects personal data when you use our website, SaaS platform, and related services in the Republic of North Macedonia. We process only what is needed to provide and secure the service.

Controller: РЕТРОСПЕКТИВА ДОО, ЕДБ 4023025514526, ЕМБС 7888376, 8-МИ СЕПТЕМВРИ бр.22, Радовиш, Република Северна Македонија. Email: info@digitermin.com. Phone: 077 893 093.

Processing is governed primarily by the Law on Personal Data Protection of the Republic of North Macedonia (LPDP / ЗЗЛП). We have not appointed a Data Protection Officer; contact info@digitermin.com for privacy requests.

Creating an account or paying an invoice does not by itself mean consent for optional processing. Consent is used only where the law requires it (for example marketing emails or non-essential cookies).

Digitermin is the controller for account, billing, website lead, security, and marketing data we decide how to process.

When a salon, clinic, or other business customer stores client, patient, booking, or clinical data in Digitermin, that business is the controller of that data and Digitermin acts as processor on their instructions. A draft Data Processing Addendum for business customers is available at /dpa.

Data Processing Addendum (DPA) · Terms and Conditions

Business customers must have a lawful basis to enter client/patient data (including health data) and must inform their own clients/patients as required by law.

Depending on how you use Digitermin, we may process:

• Contact and account data: name, email, phone, username, password (hashed), role
• Business data: company name, business type, address, location, public marketplace profile
• Client and booking data entered by your business: client names, phones, notes, appointments, reviews
• Special-category / health-related data when clinic modules are used: date of birth, allergies, medical history, dental odontogram/diagnoses/interventions, optician examinations and prescriptions (entered by the business customer)
• Communications: contact-form messages, support messages, SMS content we send on your behalf, help-chat logs
• Technical and security data: IP address, browser/device info, approximate location, login attempts, push notification tokens
• Usage data: login history, feature use, errors
• Marketing leads: name, email, phone, clinic details, optional marketing consent
• Advertising/analytics identifiers when you accept non-essential cookies (e.g. Google Ads/Analytics, Meta Pixel)

We use personal data to:

• Respond to enquiries and provide support
• Provide the booking platform, CRM, SMS, and related features
• Manage invoices, plan status, trials, freemium limits, renewals, and service notices
• Improve security, reliability, and product quality
• Send optional marketing/educational emails only if you opt in (unsubscribe anytime via the email or by contacting us)
• Comply with legal obligations and protect our rights

We do not sell personal data. Plan billing uses issued invoices in North Macedonia.

We rely on the following bases under the LPDP:

• Contract: to create and run your business account and deliver the SaaS service
• Legal obligation: accounting, tax, and other mandatory records
• Legitimate interests: securing the platform, preventing fraud/abuse, improving reliability (balanced against your rights)
• Consent: optional marketing emails and non-essential cookies/pixels
• Marketing opt-in: when you tick email updates on the contact form, until you withdraw consent or unsubscribe
• Special categories (health): processed only when a business customer uses clinic modules; the business customer must ensure an Art. 13 LPDP exception applies (e.g. explicit consent or healthcare grounds). Digitermin processes that data as processor.

We keep data only as long as needed for the purposes below, then delete it securely from the platform (we do not anonymize as a separate step).

• Active freemium or paid organization data: kept while the account remains active and needed to provide the service
• Terminated / expired organizations (subscriptionType expired): operational workspace data is hard-deleted after 30 days
• After a free trial, eligible salons/clinics move to freemium; their data stays while the freemium account remains active
• Invoices and accounting payment records: retained as required by North Macedonian tax and accounting rules (may outlive a deleted workspace; confirm periods with your accountant)
• Marketing contacts (e.g. Brevo): until you unsubscribe or withdraw consent, or after prolonged inactivity
• Login attempt logs: short TTL (about 24 hours). OTP codes: expire within minutes
• SMS delivery logs with terminal status: typically removed after about 7 days

Disabled accounts that are not marked expired may be retained until reactivated or deleted by Digitermin administration.

We apply technical and organizational measures appropriate to the risk, including:

If a personal data breach is likely to result in a risk to individuals’ rights and freedoms, we will notify the Personal Data Protection Agency (AZLP) without undue delay and, where required, within 72 hours of becoming aware of it. Where the risk is high, we will also inform affected individuals without undue delay.

Under the LPDP, you may have the right to:

To exercise these rights, email info@digitermin.com. We respond within applicable legal timeframes (typically up to 30 days; some requests such as rectification may have shorter statutory deadlines).

Some data is required to enter into or perform the contract (e.g. business contact and account credentials). If you do not provide it, we cannot create or operate the account.

We use service providers to operate Digitermin. They process data under their terms and our instructions. We do not currently have separate signed Data Processing Agreements with every vendor beyond their standard terms; we are working toward written Art. 43 LPDP contracts where required.

• Hostinger: VPS hosting, automated backups, and local MongoDB database storage
• LINK Mobility (Bulgaria): SMS delivery
• Vercel: marketing website / domains
• Anthropic (Claude): optional in-app help chatbot (prompts may include context you send)
• Google: optional staff SSO/OAuth; Google Ads/Analytics when consented; Maps features where used
• Resend: transactional email (OTP, notices)
• Brevo: marketing email only when you opt in
• Formspree: website contact/lead form inbox
• Meta Pixel: advertising measurement when consented
• Firebase / Apple Push (APNs): mobile push notifications where used

Primary application and database data are stored on our Hostinger VPS. Some providers process data in the EU/EEA (e.g. LINK Mobility Bulgaria) or in other countries (e.g. US-based cloud tools such as Google, Meta, Anthropic, Resend, depending on their infrastructure). Where personal data leaves North Macedonia, we rely on appropriate safeguards available under the LPDP (including standard contractual clauses / provider terms where applicable) and AZLP notification or approval procedures as required.

Providers may process data only as needed to perform services for us and must protect confidentiality and security.

We do not use automated decision-making that produces legal or similarly significant effects about you. Tools such as spam/fraud filters or the help chatbot do not replace human decisions about your account. If that changes, we will update this policy and inform you where required.

Digitermin is a B2B service and is not directed at persons under 16. We do not knowingly collect children’s data as end users. Business customers who record minors as patients/clients are responsible for lawful collection (including parental/guardian requirements where applicable).

We may update this Privacy Policy to reflect legal, operational, or product changes. The date above shows the latest version. Where required, we will provide additional notice before material changes take effect.

The Macedonian version of this Privacy Policy is the authentic text for customers in North Macedonia. English and Albanian versions are translations for convenience. If there is a conflict, the Macedonian text prevails.

For privacy questions, requests, or complaints:

РЕТРОСПЕКТИВА ДОО (Digitermin) ЕДБ 4023025514526 · ЕМБС 7888376 8-МИ СЕПТЕМВРИ бр.22, Радовиш, Република Северна Македонија

We respond within applicable legal timeframes, typically within 30 days.