Privacy Notice

1. About our EU service and UK testing

ChatDoc is a medical service live and based in the EU and is not an emergency service. In the UK, it is a test service, not currently offering doctor consultations or medical advice while we await CQC regulation. The testing disclosures below apply to UK testing, not live EU care. Independent Cyprus medical services are provided personally by Dr Thanos Emmanuel, Cyprus Medical Register Number 8922, at Omirou 7, Aglangia, Nicosia 2121, Cyprus.

• Personal data collected: we collect the details you give when you register — name, email address, date of birth, phone number, postal address and photo ID — so we can verify who you are and set up your account
• Medical information collected during UK testing: we collect the health information you submit — symptom descriptions, questionnaire answers, uploaded photographs, AI assessment results and any messages — so we can test and develop the UK service
• Health information is confidential special-category data. Access is limited to personnel authorised by the responsible controller for the relevant purpose. Technical or testing access is not clinical review; UK testing submissions are not sent for medical consultation.
• Information submitted during UK testing is used to test the service, check safety and quality, and prepare for UK launch. Information submitted for live EU care is used to provide your consultation and treatment as described below. Your health data is never used for advertising and is never sold
• UK testing submissions do not receive clinical review and are not requests for medical care. No diagnosis, treatment or prescription is provided. Do not rely on AI output or await a doctor response. In an emergency call 999 (UK) or 112 (EU); in the UK contact NHS 111 for urgent non-emergency advice.
• You can ask us to delete your test data at any time by emailing doctor@chatdochealth.com

Before the service becomes live in the UK, we will tell UK test users about any change to how their data is used and ask them to agree again before a live consultation takes place. This does not affect the existing live EU service.

1a. Platform testing, service improvement and research

ChatDoc may process personal information and health data for the purposes described below, subject to applicable data protection law and the lawful basis identified for each activity.

• Platform testing and development: where you explicitly consent to participate in testing, we may use the information you provide, including symptom descriptions, questionnaire responses, medical photographs and relevant technical information, to evaluate the functionality, reliability, accessibility and safety of our digital healthcare platform. Testing participation does not constitute a medical consultation. No diagnosis, treatment or prescription is provided through the UK testing service
• Explicit consent for UK testing: a separate, unticked health-data consent box is required, independent of accepting our Terms and Privacy Notice. Signed-in participants’ consent is recorded with date, time and notice version before UK testing submissions. UK guests must create an account and consent before submitting health information for testing.
• Service improvement and quality assurance: we may analyse service performance, technical errors and user feedback to improve the platform. Wherever reasonably possible, we use anonymous or aggregated information. Where identifiable or pseudonymised health information is necessary, we will identify and document an appropriate lawful basis and Article 9 condition before processing
• Artificial intelligence: AI is used to prepare general health information from the symptoms, answers and photographs you submit. This information is sent to our AI service provider through the Lovable AI Gateway under contractual safeguards. Identifiable patient information will not be used to train third-party AI models unless an appropriate lawful basis, required transparency measures and contractual safeguards have been established
• Your choices: withdraw consent for testing or research by emailing doctor@chatdochealth.com or using the privacy request form in your account. Consent-based processing must stop following withdrawal; the UK testing retention limit is 90 days from submission, not 90 days from withdrawal. Withdrawal does not affect prior lawful processing. Any legal reason for retaining limited records, including consent evidence, will be explained.

2. The data we collect

Depending on how you use ChatDoc, the responsible controller identified above collects the following data. Medic World Ltd processes Cyprus consultation information on behalf of Dr Emmanuel, except for its own separately identified purposes:

• Identity and contact data: name, email address, date of birth, gender, postal address, phone number
• Health data (special category): your health questionnaire answers, symptoms, medical history, medications, allergies, GP details, photographs of the affected area, clinician assessments, diagnoses, prescriptions and reports
• Consultation communications: messages between you and your clinician, with access restricted by role.
• Identity documents: the photo ID you upload for our mandatory identity verification, completed before any consultation
• Payment data: handled by Stripe. We receive confirmation of payment only and never see or store your card details
• Technical data: IP address, device and browser information, security and audit logs

3. Why we use your data and our lawful bases

Each controller is responsible for the lawful basis and, where health data is involved, the Article 9 condition for its own activities. Medic World Ltd does not rely on an independent clinical-care basis when acting only as Dr Emmanuel’s processor.

• Medic World Ltd — registration, account administration and platform services: Article 6(1)(b), performance of the separate platform contract.
• Medic World Ltd — UK testing health information and photographs: Article 6(1)(a) and Article 9(2)(a), separate explicit consent. Testing provides no clinical review, diagnosis, treatment or prescription.
• Dr Thanos Emmanuel — independent Cyprus consultation, assessment, report and prescription: Article 6(1)(b), clinical contract, and Article 9(2)(h), healthcare under a professional duty of confidentiality.
• Dr Thanos Emmanuel — necessary clinical records and professional obligations: Article 6(1)(c) where an applicable legal obligation requires processing, with Article 9(2)(h); Article 9(2)(i) applies only to applicable public-health obligations with the required legal safeguards.
• Optional consent-based activities — Medic World Ltd for marketing and non-essential analytics (Article 6(1)(a)); Dr Emmanuel for optional clinical-report sharing (Article 6(1)(a) and Article 9(2)(a)). Health data is not used for marketing.
• Claims and complaints — the controller responsible for the platform or clinical matter: Article 6(1)(f) and, where necessary for health data in legal claims, Article 9(2)(f).
• Medic World Ltd — platform security and fraud prevention: Article 6(1)(f). For identifiable or pseudonymised health data used in improvement or research, the responsible controller must document a specific Article 6 basis and Article 9 condition before processing; pseudonymisation does not make data anonymous.
• Dr Thanos Emmanuel — exceptionally, vital interests: Article 6(1)(d) and Article 9(2)(c) only where their conditions are met, including inability to consent. This does not make ChatDoc an emergency service.

Where we rely on consent you can withdraw it at any time; this does not affect processing carried out before withdrawal, and we may still need to keep your medical record to meet legal obligations.

4. Automated processing and AI support

AI prepares general information for platform testing or supports a live EU consultation, depending on your residence:

• The AI produces general health information — a summary of what you told us, conditions commonly linked to those symptoms and how they are generally managed — and does not diagnose you or select a treatment for you
• For live EU medical consultations, Dr Emmanuel reviews the clinical case and makes clinical decisions, including prescriptions. UK testing submissions do not receive clinical review, diagnosis, treatment or prescriptions.
• No decision producing legal or similarly significant effects is made about you by automated means alone (Article 22 GDPR)
• EU patients may request clinical review without reference to AI output by emailing us. This option is not a clinical service for UK testing participants.

5. Who we share your data with

We share the minimum necessary data with:

• Dr Thanos Emmanuel, independent Cyprus clinical controller, for live clinical care only; UK testing submissions do not enter this clinical-review pathway.
• Medic World Ltd, acting as processor for Cyprus clinical information: technology, secure storage and administrative support on Dr Emmanuel’s documented instructions, subject to a written Article 28 agreement. Its separate platform-controller processing is described above.
• Your GP or another clinician, only where you have given explicit consent or where there is a serious risk to life
• Our processors: cloud hosting and database, email delivery (Resend), payment processing (Stripe), and the Lovable AI Gateway for the AI-supported assessment
• Pharmacies you choose to present your prescription to
• Regulators, courts or authorities where we are legally required to disclose

When Medic World Ltd processes clinical information solely on Dr Emmanuel’s instructions, a written Article 28 GDPR agreement is required between them before that processing. It must cover instructions, confidentiality, security, sub-processors, rights requests, breach assistance, deletion or return and audits. This notice does not confirm that the agreement has been signed. Other processors must have appropriate written terms and safeguards; we do not certify execution of all agreements here. Health data is not sold or used for advertising.

6a. Optional ChatGPT history transfer

If you choose to link ChatGPT to your ChatDoc account, the following applies:

• Linking is opt-in. You confirm it while signed in to ChatDoc and again in the ChatGPT app, and you can unlink at any time from your dashboard
• We only receive a history summary when you ask ChatGPT to send one: your main concern, duration, symptoms, medical history, medications, allergies, the original questions and answers, and an optional AI summary. We never receive or export your full ChatGPT conversation
• A summary you have not approved expires 30 minutes after it arrives, or straight away if you discard it, and is permanently deleted by an automatic clean-up that runs every 5 minutes. Once you approve it, the approved version is kept for up to 24 hours so you can complete your consultation; if it is not attached to a submitted consultation in that time it is deleted the same way
• Nothing is shared with a doctor until you review, correct and approve the exact content and complete a normal consultation. We record your approval with a fingerprint (hash) of the approved content
• Approved information that becomes part of a submitted consultation forms part of your medical record and is kept as described in the retention section
• Your use of ChatGPT itself is governed by OpenAI's own terms and privacy policy

Unlinking stops any further transfers and discards drafts you have not yet approved. It does not delete consultations you have already submitted.

7. International transfers

Core records are hosted in the EEA. The responsible controller must assess international transfers, including overseas remote access by processors, under the EU GDPR and/or UK GDPR as applicable; EEA hosting alone does not establish safeguards for every service provider.

• EU GDPR transfers outside the EEA: an applicable European Commission adequacy decision or appropriate safeguards such as the EU Standard Contractual Clauses, with a transfer impact assessment and supplementary measures where needed.
• UK GDPR restricted transfers: applicable UK adequacy regulations, or the UK International Data Transfer Agreement / UK Addendum to the EU clauses, with a transfer risk assessment and supplementary measures where needed.
• Each controller is accountable for the transfers in its role. Medic World Ltd must follow Dr Emmanuel’s documented instructions for Cyprus clinical data and obtain the required authorisation for sub-processors. Applicable safeguards must be established before transfers occur.

You can request a copy of the safeguards in place by emailing doctor@chatdochealth.com.

8. How long we keep your data

We keep data only as long as necessary:

• UK testing health data, including symptoms, answers, photographs, AI output and testing messages: maximum 90 days from each submission, then deleted or irreversibly anonymised. Keeping your account does not extend this limit. Shorter ChatGPT draft limits still apply.
• Live EU clinical records (case, questionnaire answers, photographs, assessments, reports, prescriptions, consultation messages): 6 years from your last contact with the service
• Consent records and audit logs: 6 years, as evidence of accountability
• Uploaded identity documents: maximum 30 days from upload, then securely deleted; a minimal verification outcome may be retained separately where necessary. Identity images are not retained as clinical photographs.
• Payment and accounting records: 6 years, as required by UK tax law
• Account data where you have had no consultation: deleted 12 months after your last sign-in
• Contact form and support messages: 24 months
• Website analytics data (only with your consent): 14 months

These are the retention limits adopted for identity documents and UK testing data. Any legally necessary exception must be documented and explained; UK testing records are not automatically kept for six years as clinical records.

9. How we protect your data

Our security measures under Article 32 GDPR include:

• Access-controlled messaging
• HTTPS / TLS in transit
• Photographs stored in a private bucket, reachable only through short-lived signed links
• Role-based access control: a clinician can only open the cases assigned to them; administrative access is separate and limited
• Automatic sign-out after 30 minutes of inactivity
• Audit logging of access to medical records and of sensitive operations
• Multi-factor protection of administrative accounts and least-privilege service credentials
• Regular review of access rights, backups and restoration testing

10. Your rights

Under the EU GDPR and, where applicable, UK GDPR and the Data Protection Act 2018, you have the following rights, subject to their legal conditions:

• Access: obtain a copy of your personal data — you can download it instantly from the Privacy and your data page in your account
• Rectification: have inaccurate data corrected
• Erasure: have your data deleted where we no longer have a legal reason to keep it
• Restriction: ask us to pause processing while a concern is investigated
• Portability: receive your data in a structured, machine-readable format
• Object: object to processing based on our legitimate interests
• Withdraw consent: withdraw any consent you have given at any time
• Complain: contact the UK Information Commissioner’s Office (ICO), https://ico.org.uk, or the Cyprus Commissioner for Personal Data Protection, https://www.dataprotection.gov.cy, as applicable. EU residents may also complain to the supervisory authority in their habitual residence, place of work or place of the alleged infringement.

Submit any request from the Privacy and your data page in your account, or email doctor@chatdochealth.com. We respond within one month and will tell you if that period needs to be extended for complex requests. There is no charge for a first request.

11. Children

Registration is available from age 16. Medical care is generally for adults aged 18 and over. Patients aged 16–17 may receive care only for acne, skin infections, eczema, hyperhidrosis, insect bites, dandruff and birth control, subject to clinical suitability and applicable law. Other conditions and treatments remain 18+. UK access is testing only, not medical care.

• We do not accept registrations or health-data submissions from anyone under 16. If such data is identified, we assess and remove it where no lawful retention obligation applies.

12. Cookies

We use a small number of cookies:

• Strictly necessary cookies keep you signed in and protect the service — these do not require consent
• Preference cookies remember your language choice
• Analytics cookies are used only if you accept them in the cookie banner, and you can change your mind at any time

13. Personal data breaches

We maintain a documented breach procedure:

• Any suspected incident must be reported internally immediately and is recorded in our breach register
• We assess the risk to you without undue delay
• The responsible controller notifies the competent supervisory authority — Cyprus Commissioner for Personal Data Protection and/or UK ICO as applicable — without undue delay and, where feasible, within 72 hours of awareness, unless the breach is unlikely to risk individuals’ rights and freedoms.
• Where the risk is high, we notify affected patients directly and explain what to do

14. Data protection impact assessment

A DPIA is required where processing is likely to create a high risk under Article 35 GDPR. We do not currently claim that a DPIA has been completed or that residual risks have been approved.

• The responsible controllers must document the assessment, necessary safeguards and any requirement for supervisory-authority consultation before high-risk processing proceeds.

15. Changes to this notice and earlier versions

Each version of this notice is dated and numbered. We keep archived copies of every previous version together with a record of the version each user agreed to at registration, so we can show what you saw and accepted. You can request an earlier version by emailing doctor@chatdochealth.com.