1. Scope
This addendum applies to clinics operating in Pakistan that use Enamela, in addition to the Terms of Service, Privacy Policy, and Data Processing Agreement. Where this addendum conflicts with those documents on a matter specific to Pakistan, this addendum controls for that matter.
2. Prevention of Electronic Crimes Act (PECA), 2016
The Prevention of Electronic Crimes Act (PECA), 2016 is Pakistan's principal law governing cybercrime, unauthorized access to data, and electronic communications, including messaging. Clinics using Enamela's messaging features (for example WhatsApp appointment messages) to communicate with patients remain responsible for using those features lawfully and in a manner consistent with PECA and its rules on unsolicited or harmful electronic communications.
Enamela's own security measures (encryption, role-based access, audit logging, consent-based support access) are described in the Data Processing Agreement and the Security page. This addendum does not represent that these measures have been assessed against PECA by a Pakistani regulator or court.
3. Personal Data Protection Bill
Pakistan's Personal Data Protection Bill has not yet been enacted into law as of the date of this addendum; it remains a bill before Parliament, and its final text, scope, and effective date are not yet settled. Enamela is monitoring the Bill's progress and will update this addendum and its data-handling practices as needed once it is enacted.
In the meantime, Enamela handles clinic and patient data from Pakistan under the general commitments in the Privacy Policy and the Data Processing Agreement (purpose limitation, security measures, and processing only on the clinic's instructions for patient data).
4. PMDC record-keeping expectations
The Pakistan Medical and Dental Council (PMDC) sets expectations for how registered dental practitioners keep patient and treatment records. Enamela's patient records, treatment notes, and odontogram/treatment charting features are designed to support a clinic's own record-keeping, but the clinic (and its registered dental practitioners) remains responsible for meeting PMDC record-keeping and retention requirements that apply to their practice.
Clinics should confirm with their own professional obligations, and with counsel where needed, how long specific record types must be retained under PMDC and other applicable Pakistani rules, and configure their use of Enamela accordingly.
5. Data hosting location
Clinic and patient data is currently hosted in the ap-southeast-1 (Singapore) region with our database provider, as described in the Subprocessors page and the Data Processing Agreement. Enamela does not currently host Pakistan clinic data in-country. Whether in-country or regional hosting is required or advisable for particular clinics is a question we are reviewing with counsel, and this addendum will be updated if hosting arrangements change.
6. No compliance claim
This addendum is a general description of relevant Pakistani laws and regulatory bodies for context. It is not legal advice, and it is not a representation or certification that Enamela or a clinic's use of Enamela complies with PECA, the Personal Data Protection Bill (once enacted), PMDC requirements, or any other Pakistani law. Clinics should seek their own legal advice on compliance.
7. Contact
Questions about this addendum can be sent to legal@enamela.app [confirm address]. [Company legal name]; [registered address].