Privacy Policy
Last updated: February 2026
Your privacy is important to us. This Privacy Policy explains how DR RAZVAN VASILAS LTD collects, uses, and protects your personal information when you use the TR Passport mobile application.
1. Who We Are
TR Passport is operated by DR RAZVAN VASILAS LTD (Company Number: 13319935), a company registered in England and Wales.
For data protection purposes, we are the "data controller" of your personal information.
Contact: privacy@tr-passport.com
2. Information We Collect
We collect the following categories of personal information:
2.1 Account Information
- Full name
- Email address
- Phone number
- Date of birth
- Gender
- Country of residence
- Profile photo
2.2 Health Information
- Aesthetic treatment history (e.g., Botox, fillers, skin treatments)
- Allergies and medical conditions
- Current medications
- Lab results and medical documents you upload
- Prior treatment records
2.3 Emergency Contact Information
- Name and phone number of your designated emergency contact
3. How We Use Your Information
We use your personal information for the following purposes:
- App Functionality: To provide and maintain the TR Passport service
- Authentication: To verify your identity and secure your account
- Treatment Records: To store and display your aesthetic treatment history
- QR Code Sharing: To enable you to share your medical passport with healthcare providers
- Customer Support: To respond to your enquiries and provide assistance
We do NOT use your data for: Advertising, marketing, analytics profiling, or selling to third parties.
4. Legal Basis for Processing (UK GDPR)
We process your personal information based on:
- Contract: Processing necessary to provide the TR Passport service you requested
- Consent: Your explicit consent for processing health data (which you can withdraw at any time)
- Legitimate Interests: For security, fraud prevention, and service improvement
5. Data Storage and Security
Your data is stored securely using Supabase, with servers located in Germany (EU).
We implement appropriate technical and organisational measures to protect your data, including:
- Encryption in transit (TLS/SSL) and at rest
- Secure authentication mechanisms
- Regular security assessments
- Access controls and audit logging
6. Data Sharing
We do NOT sell, rent, or trade your personal information.
Your data may only be shared:
- With your consent: When you choose to share your medical passport via QR code with healthcare providers
- Service Providers: With Supabase for secure data storage (acting as our data processor)
- Legal Requirements: If required by law, court order, or governmental authority
7. Your Rights
Under UK GDPR, you have the following rights:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your data ("right to be forgotten")
- Portability: Receive your data in a portable format
- Restriction: Limit how we process your data
- Objection: Object to certain types of processing
- Withdraw Consent: Withdraw consent at any time for health data processing
To exercise these rights, contact us at privacy@tr-passport.com
8. Data Retention
We retain your personal data for as long as you maintain an active account.
Upon account deletion:
- Your data will be permanently deleted within 30 days
- Backups containing your data will be purged within 90 days
9. Children's Privacy
TR Passport is intended for users aged 18 years and older. We do not knowingly collect information from anyone under 18. If we become aware that we have collected data from someone under 18, we will delete it promptly.
10. International Transfers
Your data is stored in Germany (EU), which is covered by the UK adequacy decision for data transfers. We do not transfer your data outside the UK/EU.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes via the App or email. Continued use of the App after changes constitutes acceptance of the updated policy.
12. Contact Us
For any questions or concerns about this Privacy Policy or our data practices:
DR RAZVAN VASILAS LTD
Company Number: 13319935
Email: privacy@tr-passport.com
13. Supervisory Authority
You have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data protection rights have been violated:
Information Commissioner's Office
Website: ico.org.uk
Phone: 0303 123 1113