English Čeština Deutsch

Privacy Policy

Effective Date: December 1, 2024
Last Updated: December 1, 2024

1. Introduction

At Mediqom (“we”, “us”, or “our”), we are committed to protecting your privacy and securing your personal health information. This Privacy Policy explains how we collect, use, process, and protect your information when you use our medical record management platform.

1.1 Our Commitment

  • Zero-Knowledge Architecture: We cannot access your encrypted medical data
  • Data Minimization: We collect only what’s necessary for our services
  • Transparency: Clear information about all data practices
  • User Control: You decide how your data is used and shared

1.2 Scope

This Privacy Policy applies to:

  • The Mediqom platform and mobile applications
  • Our website and marketing materials
  • Customer support and communication
  • All services provided through our platform

2. Information We Collect

2.1 Account Information

When you create an account, we collect:

  • Name and contact information
  • Email address for account management
  • Professional credentials (for healthcare providers)
  • Payment information (processed by third parties)
  • Account preferences and settings

2.2 Health Information

Medical data you upload or create:

  • Medical records and documents
  • Health measurements and vital signs
  • Medication lists and allergies
  • Doctor visit notes and summaries
  • Family health history
  • Voice recordings (if using voice analysis features)

2.3 Usage Information

Technical data about platform use:

  • Login times and session duration
  • Feature usage patterns
  • Error logs and system diagnostics
  • Device information (browser, OS, IP address)
  • Performance metrics for service improvement

2.4 Communication Data

When you contact us:

  • Support tickets and correspondence
  • Feedback and survey responses
  • Chat logs with customer service
  • Meeting notes from consultations

3. How We Use Your Information

3.1 Service Provision

We use your information to:

  • Provide medical record management services
  • Process AI analysis of your health data
  • Enable secure sharing with healthcare providers
  • Facilitate AppConnect marketplace transactions
  • Support account management and billing

3.2 Platform Improvement

Usage data helps us:

  • Improve AI accuracy and performance
  • Develop new features based on user needs
  • Fix bugs and technical issues
  • Optimize platform performance
  • Enhance security measures

3.3 Communication

We may contact you for:

  • Service updates and notifications
  • Security alerts and important notices
  • Customer support responses
  • Marketing communications (with consent)
  • Legal compliance requirements

3.4 Legal Requirements

We may process data to:

  • Comply with regulations (HIPAA, GDPR, etc.)
  • Respond to legal requests from authorities
  • Protect our rights and defend legal claims
  • Prevent fraud and abuse
  • Ensure platform security

4. Zero-Knowledge Encryption

4.1 How It Works

Our zero-knowledge architecture ensures:

  • Local key generation: Encryption keys created on your device
  • Client-side encryption: Data encrypted before upload
  • Server-side storage: Only encrypted data stored on our servers
  • No access capability: We cannot decrypt your medical data
  • User-controlled sharing: You control all data access

4.2 What This Means

  • Complete privacy: Your medical data is private even from us
  • No data mining: We cannot analyze your personal health information
  • Secure sharing: Only you can grant access to specific data
  • Lost passphrase: We cannot recover forgotten encryption keys
  • Ultimate control: You own and control all your data

4.3 Technical Implementation

  • AES-256 encryption for data at rest
  • RSA-4096 encryption for key exchange
  • TLS 1.3 for data in transit
  • Perfect forward secrecy for all communications
  • Regular security audits by third parties

5. Data Sharing and Disclosure

5.1 Healthcare Providers

We share data with healthcare providers only when:

  • You explicitly authorize the sharing
  • Time-limited access is granted by you
  • Specific data sets are selected by you
  • Audit trails record all access
  • Access can be revoked at any time

5.2 Service Providers

We work with trusted third parties for:

  • Cloud infrastructure (AWS, with encryption)
  • Payment processing (Stripe, for billing)
  • Email services (for account communications)
  • Analytics (anonymized usage data only)
  • Customer support tools

All service providers:

  • Sign data processing agreements
  • Cannot access encrypted medical data
  • Follow strict security requirements
  • Are regularly audited
  • Provide liability coverage

5.3 Legal Disclosures

We may disclose information when:

  • Required by law or court order
  • Protecting user safety in emergency situations
  • Preventing fraud or illegal activity
  • Defending legal rights in litigation
  • Complying with regulations (with minimal disclosure)

5.4 Business Transfers

In case of merger or acquisition:

  • Users will be notified 30 days in advance
  • Same privacy protections will apply
  • Opt-out options will be provided
  • Data deletion available upon request
  • Regulatory approval required for transfers

6. International Data Transfers

6.1 Cross-Border Processing

Your data may be processed in:

  • European Union (primary data centers)
  • United States (backup and processing)
  • Other regions (with adequate protection)

6.2 Safeguards

We ensure protection through:

  • Adequacy decisions by relevant authorities
  • Standard contractual clauses with processors
  • Binding corporate rules within our organization
  • Certification schemes (Privacy Shield successors)
  • Additional security measures for sensitive data

6.3 Your Rights

Regardless of processing location:

  • Same privacy rights apply globally
  • Local law compliance in your jurisdiction
  • Data subject rights fully honored
  • Local support available in your language
  • Regulatory oversight by appropriate authorities

7. Data Retention

7.1 Retention Periods

Data Type Retention Period Purpose
Active health records Until account deletion Service provision
Inactive records 7 years after last access Legal compliance
Account information 30 days after deletion Account recovery
Usage logs 2 years Security and improvement
Support communications 3 years Service quality

7.2 Deletion Process

When you delete data:

  • Immediate removal from active systems
  • Backup deletion within 30 days
  • Secure erasure using industry standards
  • Verification of complete removal
  • Certificate of deletion available upon request

7.3 Legal Holds

In rare cases, we may retain data longer:

  • Ongoing legal proceedings
  • Regulatory investigations
  • Law enforcement requests
  • Fraud prevention
  • User notification when holds are placed

8. Security Measures

8.1 Technical Safeguards

  • End-to-end encryption for all medical data
  • Multi-factor authentication for account access
  • Regular security audits by external firms
  • Penetration testing quarterly
  • Vulnerability scanning continuous

8.2 Administrative Controls

  • Access controls with least privilege principle
  • Employee background checks and training
  • Incident response procedures
  • Business continuity planning
  • Vendor management programs

8.3 Physical Security

  • Certified data centers (SOC 2, ISO 27001)
  • 24/7 monitoring and surveillance
  • Biometric access controls
  • Environmental protections
  • Redundant systems for availability

8.4 Monitoring and Response

  • Real-time threat detection
  • Automated incident response
  • Security team on-call 24/7
  • User notification of security issues
  • Continuous improvement of security posture

9. Your Rights and Choices

9.1 Access Rights

You can:

  • View all personal data we hold about you
  • Download data in machine-readable formats
  • Request data portability to other services
  • Audit access logs to see who accessed your data
  • Receive copies of data processing agreements

9.2 Correction and Updates

You have the right to:

  • Correct inaccurate personal information
  • Update outdated health records
  • Complete incomplete data sets
  • Challenge automated decision-making
  • Request human review of AI analyses

9.3 Deletion Rights

You can request deletion of:

  • Specific health records or data sets
  • Entire account and all associated data
  • Historical versions of updated records
  • Backup copies within our retention period
  • Third-party shared data where possible

9.4 Consent Management

Control your consent for:

  • Marketing communications
  • Data sharing with partners
  • Research participation (anonymized data)
  • Feature analytics and improvement
  • Cookie and tracking preferences

9.5 Data Processing Objections

You can object to:

  • Automated decision-making
  • Profiling for marketing purposes
  • Data processing based on legitimate interests
  • Cross-border transfers in some cases
  • Third-party integrations

10. Cookies and Tracking

10.1 Types of Cookies

We use cookies for:

  • Essential functions (login, security)
  • Performance monitoring (page load times)
  • User preferences (language, settings)
  • Analytics (anonymized usage patterns)
  • Marketing (with consent only)

10.2 Cookie Management

You can:

  • Disable cookies in browser settings
  • Choose cookie types through our preference center
  • Delete existing cookies at any time
  • Opt out of tracking through industry tools
  • Use privacy browsers that block tracking

10.3 Third-Party Tools

We use:

  • Google Analytics (anonymized, with opt-out)
  • Stripe (for payment processing)
  • Intercom (for customer support)
  • Sentry (for error tracking)
  • All with privacy-preserving configurations

11. Children’s Privacy

11.1 Age Requirements

  • 18 years minimum for independent accounts
  • Parental consent required for minors
  • Family accounts allow supervised access
  • Educational use permitted with school consent
  • Healthcare provider accounts for pediatric records

11.2 Parental Controls

Parents can:

  • Create family accounts for children
  • Control data sharing permissions
  • Monitor account activity
  • Request data deletion for their children
  • Transfer accounts when children reach majority

11.3 Special Protections

For minors, we provide:

  • Enhanced privacy protections
  • Limited data collection
  • No marketing communications
  • Restricted third-party sharing
  • Regular consent renewal requirements

12. Regional Privacy Laws

12.1 European Union (GDPR)

EU residents have additional rights:

  • Data Protection Officer contact available
  • Supervisory authority complaints
  • Right to portability in structured formats
  • Breach notification within 72 hours
  • Privacy by design implementation

12.2 United States (HIPAA)

For US healthcare data:

  • Business Associate Agreement with providers
  • Minimum necessary principle application
  • Patient access rights under HIPAA
  • Breach notification requirements
  • Accounting of disclosures

12.3 Czech Republic

Local compliance includes:

  • Data Protection Authority oversight
  • Czech language support
  • Local data residency options
  • Healthcare law compliance
  • Consumer protection rights

12.4 Other Jurisdictions

We comply with applicable laws in:

  • Canada (PIPEDA)
  • Australia (Privacy Act)
  • California (CCPA/CPRA)
  • Brazil (LGPD)
  • Other jurisdictions as required

13. Changes to This Privacy Policy

13.1 Notification Process

We will notify you of changes through:

  • Email notification to registered users
  • Platform notifications when you log in
  • Website banners for 30 days
  • Version history available on request
  • Summary of changes provided

13.2 Types of Changes

  • Minor updates (clarifications, contact info)
  • Material changes (new uses of data)
  • Legal updates (regulatory requirements)
  • Feature additions (new privacy implications)
  • Policy restructuring (better organization)

13.3 Your Options

When we make material changes:

  • 30-day notice period before implementation
  • Opt-out options for new uses of data
  • Account deletion if you disagree
  • Grandfathering of existing consent where possible
  • Individual consultation for significant concerns

14. Data Processing Legal Basis

14.1 Lawful Basis (GDPR)

We process data based on:

  • Consent: For marketing and optional features
  • Contract: To provide our services
  • Legal obligation: For regulatory compliance
  • Vital interests: For emergency medical situations
  • Legitimate interests: For platform security and improvement

14.2 Special Category Data

Health data processing relies on:

  • Explicit consent for most processing
  • Healthcare purposes where permitted by law
  • Public health interests in some cases
  • Research purposes (anonymized only)
  • Legal claims defense when necessary

14.3 Automated Decision-Making

Our AI systems:

  • Provide suggestions only, not final decisions
  • Include human oversight requirements
  • Allow opt-out from automated processing
  • Provide explanations of AI reasoning
  • Enable appeals of automated decisions

15. Contact Information

15.1 Privacy Officer

Email: privacy@mediqom.com
Phone: +420 XXX XXX XXX
Address: [Privacy Department Address]
Response Time: 30 days maximum (usually within 5 business days)

15.2 Data Protection Officer (EU)

Email: dpo@mediqom.com
Address: [EU Representative Address]
Languages: English, Czech, German
Availability: Monday-Friday, 9:00-17:00 CET

15.3 Regional Contacts

15.4 Supervisory Authorities

You can also contact:

  • EU: Your local Data Protection Authority
  • Czech Republic: Office for Personal Data Protection
  • US: Department of Health and Human Services
  • Other regions: Local privacy regulators

By using Mediqom, you acknowledge that you have read, understood, and agree to this Privacy Policy.

This Privacy Policy was last updated on December 1, 2024. Previous versions are available upon request.