This notice explains how SERGEI FEDOTOV PR Veb portali Novi Sad, the Serbian operator of FHIR Pilot, handles personal data for the website and preflight inquiry process.
1. Who controls the data
SERGEI FEDOTOV PR Veb portali Novi Sad, MB 67268733, PIB 114026461, at Železnička 20, 21000 Novi Sad, Republic of Serbia, acts as controller for website inquiries and first-party product analytics. Contact: support@digitalcognitivesolutions.com.
2. Data we collect
The request form collects work email, company, role, preferred review route, optional non-sensitive context, confirmations and request reference. The site records first-party funnel events such as page view, CTA, pricing or report view, download, form stage and outcome, together with time, page path, basic request metadata and a pseudonymous network hash used for abuse prevention. If you accept optional analytics, Google Analytics also receives page URL and title, referrer and campaign parameters, approximate location derived from the network address, device/browser information and the same non-sensitive funnel event names and parameters. We do not send form contents, email address, company, endpoint details, credentials, FHIR payloads or PHI to analytics.
3. Data you must not provide
Do not submit PHI, patient-identifiable data, production data, endpoint URLs, passwords, API keys, OAuth secrets, tokens or confidential FHIR payloads through the website or ordinary email. The form automatically rejects common URL and secret patterns but that control does not replace your responsibility.
4. Why we use personal data
We use inquiry data to respond, qualify and scope a request; provide and administer an agreed service; prevent misuse; maintain records; and understand whether the product funnel works. The legal bases, as applicable, are steps requested before a contract, performance of a contract, and our legitimate interests in operating, securing and improving a B2B service. Where consent is legally required, we rely on consent.
5. Cookies and analytics choices
First-party server measurement works without analytics cookies and is limited to operational funnel events. Google Analytics is optional and does not load until you select “Accept analytics”. If accepted, Google Analytics may set identifiers such as _ga to distinguish browsers and sessions. The site stores your choice locally so it can be respected on later visits. Advertising storage, Google Signals, ad personalisation and user-ID features are disabled. You may change or withdraw the choice at any time through “Cookie settings” in the footer; withdrawing disables further Google Analytics collection from this browser and removes accessible Google Analytics cookies for this site.
6. Sharing and processors
We do not sell personal data. Hosting infrastructure stores website requests, first-party funnel records and local inquiry records. Google provides optional Analytics and hosted font delivery and receives ordinary technical metadata when those services are used. When you submit the request form, the supplied inquiry fields are also delivered by the server through the Telegram Bot API to our private GPT Work operations group so the team can qualify and respond to the request. Telegram receives those fields and ordinary delivery metadata under its own service terms and privacy practices. Neither Google Analytics nor any advertising platform receives form contents.
7. International transfers
Google, Telegram and hosting providers may process data outside Serbia or your country, including in the United States. Where applicable, the provider’s data-processing terms, recognised transfer mechanism and contractual safeguards apply. Serbia is our operating jurisdiction.
8. Retention
Inquiry and first-party funnel records are automatically pruned from the FHIR Pilot server after 90 days unless a longer period is required for an active engagement, accounting, legal obligations or dispute handling. Google Analytics event-level data is configured for 14 months; aggregated reporting may remain available longer under Google’s service controls. A Telegram copy remains subject to the operations group’s access and deletion controls; operational requests should be removed when no longer needed and ordinarily within the same 90-day period. Customer report and temporary access retention are agreed before paid work.
9. Security
We apply access limitation, data minimisation, input validation, rate limiting and scoped storage appropriate to the service. No internet transmission or storage method is completely secure. See the separate Security & Data Handling page for the current operating boundary.
10. Your rights
Depending on applicable law, you may request access, correction, deletion, restriction, portability or objection, and may withdraw consent without affecting earlier processing. You may also complain to a competent data protection authority. We may need to verify your identity and retain data where law permits or requires.
11. Changes and contact
We will publish material changes with a new effective date. Send privacy requests to support@digitalcognitivesolutions.com. Do not include secrets or patient data.