Last updated: April 15, 2024
This privacy notice for Doktoro (“Company,” “we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:
- Visit our website at www.doktoro.health, or any website of ours that links to this privacy notice.
- Engage with us in other related ways, including any sales, marketing, or events.
- Use our General Practitioner Registration/Match-making service.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at following e-mail addresses: info@doktoro.health/gdpr@doktoro.health.
Summary of Key Points
This summary provides key points from our privacy notice, but you can find out more details about any of these topics below or by using our table of contents to directly get to the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Doktoro and the Services, the choices you make, and the products and features you use. In principle this is the information that you provide to us when filling out our registration form.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. For our matchmaking service this is candidate registered General Practitioners.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. For instance your data collected via our registration form is end-to-end encrypted, and all data is encrypted at rest when stored on our servers. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Regardless you may review, change, or terminate your account/and collected data at any time, as well as your consent to our data collection.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form (click here), or by contacting us under the following e-mail addresses: info@doktoro.health/gdpr@doktoro.health. We will consider and act upon any request in accordance with applicable data protection laws.
1. What Information do we Collect?
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- phone numbers
- email addresses
- contact or authentication data
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
- health data
- social security numbers or other government identifiers
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Table 1 shows all the personal information that we collect on a consent basis.
| Type of Data | Format | Special Category | Assessed Risk |
| Full Name | Text | No | Low |
| Date of Birth | Date | No | Low |
| Sex | Categorical | No | Low |
| Residency Status (Netherlands) | Binary | No | Low |
| BSN/Social Security Number (Netherlands) | Text/Numerical | No | Medium |
| ID Type | Categorical | No | Low |
| ID Country of Issue | Categorical | No | Low |
| ID Number | Text/Numerical | No | High |
| Mobile Number | Numerical | No | Low |
| Text | No | Low | |
| Address | Text/Numerical | No | Low |
| Health Insurance Information (Which country is your Health Insurance from?) | Categorical | No | Low |
| Health Insurance Information (Does your Health Insurance cover your stay in the Netherlands?) | Binary | No | Low |
| Insurance Policy Number | Text/Numerical | No | Medium |
| Previous General Practitioner | Text | No | Low |
| Pre-Existing Conditions (Asthma, Lung Conditions, Diabetes, Cardio-vascular Disease, Epilepsy, Osteoporosis, High Blood Pressure, Thyroid Disease, Mental Illness) | Categorical | Yes | High |
| Other Medical Conditions | Text | Yes | High |
| Current Specialist Treatment | Binary | Yes | High |
| Specify what Specialist Treatment | Text | Yes | High |
| Prescription Medication | Binary | Yes | High |
| Specify Prescription | Text | Yes | High |
| Allergies | Binary | Yes | High |
| Specify Allergies | Text | Yes | High |
| Smoke | Binary | Yes | Low |
| Specify how often (Smoke) | Categorical | Yes | Low |
| Drink Alcohol | Binary | Yes | Low |
| Specify how often (Alcohol) | Categorical | Yes | Low |
| Take Drugs | Binary | Yes | High |
| Specify type and frequencies of drug usage | Text | Yes | High |
| GP Language Preference | Categorical | No | Low |
| Comments/notes | Text | Yes/No | Medium |
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
As long as the user has an account with us, and once the account has been terminated for a maximum of 36 months (3 years), unless requested by the user otherwise.
2. How do we Process your Information?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. What Legal Bases do we rely on to Process your Information?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. For instance, consent is the basis for which we collect your personal information in our matchmaking form. Click here to learn more.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Analyze how our Services are used so we can improve them to engage and retain users
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers’ privacy practices, you should read their privacy policies and direct any questions you have to them.
4. When and with Whom do we Share your Personal Information?
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work, we only share the minimum of information that is necessary and seek your consent where applicable prior.
The categories of third parties we may share personal information for our matchmaking service are as follows:
- Registered General Practitioners
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
If you want to know with whom exactly, we have shared your personal information with please contact us at gdpr@doktoro.health. You can also find more information in regards to your privacy and data rights (such as the right to limit the use or disclosure of your sensitive personal information to external parties) in section 9 of this Privacy Policy.
5. Do we use Cookies and Other Tracking Technologies?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://doktoro.health/knowledge-base/cookie-policy/.
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.
The legal bases for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of the personal data is not yet contractually required and is also not necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
6. How long do we keep your Information?
In short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than thirty six (36) months past the termination of the user’s account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. How do we keep your Information Safe?
In short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
If a data breach occurs, we will inform you no later than 72 hours after having become aware of it and relevant supervisory authority.
9. What are Your Privacy Rights?
In Short: You may review, change, or terminate your account/and collected data at any time, as well as your consent to our data collection.
We will not discriminate against you if you exercise your privacy rights!
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If you are located in the European Economic Area (EEA) and/or the United Kingdom (UK), you have certain rights under applicable data protection laws most notably the GDPR (GDPR Article 15-22) (Click here for full text). These include the right:
(i) to request access and obtain a copy of your personal information;
(ii) to request rectification or erasure of your data;
(iii) to restrict and/or object the processing of your personal information;
(iv) if applicable, to data portability.
Under these rights falls the Right to be informed – Request to know:
This allows you to request the access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Additionally, you have the right to withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” or use our data subject request form (click here) to make a request.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or use our data subject request form (click here) to make a request.
We will consider and act upon any request in accordance with applicable data protection laws and keep you informed as outlined in Article 12 of the GDPR. Please note that we may need to verify your identify in order to comply with your request. If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://doktoro.health/cookie-policy/.
If you have questions or comments about your privacy rights, you may email us at gdpr@doktoro.health.
10. Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice. Kindly refer to our cookie policy (click here) to learn how to disable any non-essential tracking cookies.
11. Do we make Updates to this Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. How can you contact us about this Notice?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Adam Ragab, by email at a.ragab@doktoro.health.
If you are a resident in the European Economic Area, the “data controller” of your personal information is Doktoro. Doktoro has appointed Nikola Nikolov to be its representative in the EEA. You can contact them directly regarding the processing of your information by Doktoro, by email at n.nikolov@doktoro.health.
If you have any further questions or comments, or want to exercise your data protection rights you may also contact us by email at the following e-mail addresses: info@doktoro.health/gdpr@doktoro.health.