Patient Information Text

CALLENDOC DATA PROTECTION POLICY - PATIENT VERSION

Last Updated: November 2025

CALLENDOC is committed to protecting your personal and health data in compliance with UK data protection law. This policy explains what personal data we collect, how we use it, who we share it with, and your rights.

1. DATA CONTROLLER INFORMATION

1.1 WHO WE ARE

Data Controller:
Callendoc Ltd.
London, United Kingdom

Callendoc Ltd. is the data controller responsible for determining how and why your personal data is processed.

Data Protection Officer (DPO): [email protected]

1.2 CONTACT INFORMATION

For data protection queries:

• Email: [email protected]
• Privacy: [email protected]
• General: [email protected]
• Mailing Address: Callendoc Ltd., Data Protection Officer, London, United Kingdom
• Response Commitment: Within 30 calendar days

2. PERSONAL DATA CATEGORIES WE COLLECT

2.1 IDENTITY DATA

• Full name
• Date of birth
• Gender
• Nationality (if provided)
• National identification number (if required)

Purpose: Account creation, identity verification, service delivery
Legal Basis: Contract, Legal obligation

2.2 CONTACT INFORMATION

• Email address
• Phone number
• Postal address
• Emergency contact information
• Preferred contact method

Purpose: Service communication, appointment notifications, support
Legal Basis: Contract, Legitimate interests

2.3 HEALTH & MEDICAL INFORMATION (SPECIAL CATEGORY)

• Current medical conditions
• Medical history
• Current medications
• Allergies
• Vaccination records
• Consultation notes and records
• Test results and diagnoses
• Prescriptions and treatment plans
• Mental health information (if disclosed)

Purpose: Service delivery, healthcare provision, medical records
Legal Basis: Explicit consent, Legal obligation (healthcare regulations)
Special Protection: Health information processed with your explicit consent and enhanced safeguards

2.4 FINANCIAL & PAYMENT DATA

• Billing address
• Payment method details (minimal - see below)
• Transaction history
• Invoice information
• Refund records
• Payment status

Important Note: We do not collect or store full credit card numbers. Payment processing handled by PCI DSS-compliant third-party providers (Stripe, PayPal).
Purpose: Payment processing, billing, financial records, fraud prevention
Legal Basis: Contract, Legal obligation (accounting/tax)

2.5 CONSULTATION & APPOINTMENT DATA

• Consultation dates and times
• Healthcare Professional details you consult with
• Consultation duration
• Consultation type (video/voice/text)
• Appointment status
• Cancellation/rescheduling information
• Pre-consultation questionnaires
• Consultation recordings (where applicable)

Purpose: Service delivery, record-keeping, quality assurance
Legal Basis: Contract, Legitimate interests

2.6 COMMUNICATION DATA

• Messages to Healthcare Professionals
• Support requests and responses
• Complaint records
• Feedback and reviews
• Email correspondence
• Appointment reminders and communications

Purpose: Service delivery, customer support, service improvement
Legal Basis: Contract, Legitimate interests

2.7 TECHNICAL & USAGE DATA

• IP address
• Device information (type, model, OS)
• Browser information
• Cookie identifiers
• Login dates and times
• Features used and pages visited
• Time spent on pages
• Error reports

Purpose: Service improvement, security, fraud prevention, analytics
Legal Basis: Legitimate interests, Consent (analytics)

3. LAWFUL BASES FOR PROCESSING

3.1 UK GDPR LAWFUL BASES

(A) CONTRACT

We process data because:

• Necessary to perform our agreement with you
• Needed to provide telemedicine services
• Required for appointment booking
• Necessary for billing and payment

(B) LEGAL OBLIGATION

We process data because:

• Healthcare laws require medical records retention
• Tax laws require financial records
• Anti-money laundering regulations
• Professional regulation compliance
• Court orders or legal requests

(C) LEGITIMATE INTERESTS

We process data because:

• Service improvement and analytics
• Fraud prevention and security
• Marketing and communications
• Customer support
• Business continuity
• Legal claims defense

(D) EXPLICIT CONSENT

We process data because you have given clear permission for:

• Health information processing (special category)
• Marketing communications (optional)
• Analytics cookies (optional)
• Biometric data (if applicable, optional)

Withdrawing Consent: You may withdraw consent anytime at [email protected] with no penalty.

4. PURPOSES & USE OF YOUR DATA

4.1 DIRECT SERVICE DELIVERY

• Create and manage your patient account
• Provide healthcare consultations
• Process appointment bookings
• Send appointment reminders and confirmations
• Process payments and billing
• Issue invoices and receipts
• Provide customer support
• Maintain health records
• Manage prescription referrals

4.2 SERVICE IMPROVEMENT

• Analyze Platform usage
• Improve features and functionality
• Personalize your experience
• Develop new services
• Troubleshoot technical issues
• Monitor service quality
• Gather user feedback

4.3 SECURITY & FRAUD PREVENTION

• Detect unauthorized access
• Prevent fraud and misuse
• Protect against cyberattacks
• Monitor suspicious activity
• Comply with security standards
• Investigate incidents
• Enforce terms of service

4.4 LEGAL & REGULATORY COMPLIANCE

• Comply with healthcare laws
• Comply with tax obligations
• Respond to legal requests
• Maintain required records
• Meet regulatory requirements
• Defend against legal claims

4.5 MARKETING & COMMUNICATIONS (WITH CONSENT)

• Send service updates and news
• Offer new services (with consent)
• Send health tips and newsletters (with consent)
• Conduct surveys
• Request feedback

Important: We only send marketing communications with your explicit consent. You may unsubscribe anytime.

5. WHO WE SHARE YOUR DATA WITH

5.1 HEALTHCARE PROFESSIONALS

• Healthcare Professionals you consult with
• Only with your explicit consent for each consultation
• Information limited to relevant medical details
• Healthcare Professionals are data processors bound by confidentiality

5.2 SERVICE PROVIDERS & PROCESSORS

Cloud Infrastructure: AWS - Cloud hosting (EU/UK regions)
Payment Processors: Stripe, PayPal
Communications: SendGrid (email), Twilio (SMS)
Analytics: Google Analytics (anonymized data)
Customer Support: Zendesk

All processors have Data Processing Agreements ensuring GDPR compliance.

5.3 AUTHORIZED THIRD PARTIES

• Accountants and auditors (financial data only)
• Lawyers (legal advice, disputes)
• Insurance providers (indemnity insurance)
• Regulatory bodies (when legally required)

5.4 LEGAL REQUIREMENTS

We may disclose data when:

• Required by law (court order, subpoena)
• Necessary for public safety
• To prevent crime or fraud
• Required by healthcare regulators

5.5 NO SELLING OR COMMERCIAL USE

Callendoc will NOT:

• Sell your personal data
• Share data for commercial purposes without consent
• Transfer data to data brokers

6. DATA RETENTION PERIODS

Account Data: Retained during account existence, plus 6 years after closure (legal requirement)

Health Records: 10 years minimum (medical standards)

Transaction & Financial Data: 7 years (tax and financial regulations)

Appointment Records: 10 years minimum

Backup Data: 6 months

Analytics Data: 26 months (then anonymized)

You may request deletion subject to legal retention requirements.

7. YOUR DATA RIGHTS AS A PATIENT

7.1 RIGHT TO ACCESS (Subject Access Request)

You have the right to:

• Request a copy of your personal data
• Know what data we hold about you
• Know why we process your data
• Know how long we retain it
• Know who we share it with

How to Request: Email [email protected] with your full name, date of birth, and account details
Response Time: Within 30 calendar days
Cost: Free of charge

7.2 RIGHT TO RECTIFICATION

You have the right to:

• Correct inaccurate health information
• Complete incomplete data
• Update outdated information
• Challenge data accuracy

How to Exercise: Update directly through account settings or email [email protected]

7.3 RIGHT TO ERASURE (Right to Be Forgotten)

You have the right to request deletion when:

• Data no longer necessary for purpose
• You withdraw consent
• You object to processing
• Processing unlawful

Exceptions (Data May Not Be Deleted):

• Legal obligation to retain
• Active healthcare treatment
• Financial or tax records (7 years)
• Legal dispute or claim

7.4 RIGHT TO RESTRICT PROCESSING

You have the right to limit how we use your data, such as:

• Restrict to storage only
• Stop marketing communications
• Preserve data for legal claims

7.5 RIGHT TO DATA PORTABILITY

You have the right to:

• Receive your data in portable format
• Transfer data to another healthcare provider
• Obtain data in machine-readable format (CSV, JSON, XML)

7.6 RIGHT TO OBJECT

You have the right to object to:

• Marketing communications (unsubscribe anytime)
• Processing based on legitimate interests
• Automated decision-making

7.7 RIGHT TO WITHDRAW CONSENT

You may withdraw consent:

• At any time
• Without penalty
• Immediate effect
• For specific processing types

How to Withdraw: Email [email protected]

8. INTERNATIONAL DATA TRANSFERS

8.1 WHERE YOUR DATA IS STORED

Primary Storage:

• United Kingdom data centers
• AWS UK region (primary)
• EU servers (backup)

Healthcare Data Protection:

• Stored in UK/EU only
• Never transferred outside UK/EEA without safeguards
• GDPR-compliant jurisdictions only

8.2 SAFEGUARDS FOR TRANSFERS

If transferred outside UK/EEA (rare):

• Standard Contractual Clauses applied
• Additional protective measures
• Your consent if required
• Prior notification

9. SECURITY MEASURES

Technical Safeguards:

• TLS 1.2+ encryption in transit
• AES-256 encryption at rest
• End-to-end encryption for health data
• Role-based access control
• Multi-factor authentication available
• 24/7 security monitoring

Organizational Safeguards:

• Annual data protection training
• Incident response procedures
• Background checks for staff
• Confidentiality agreements
• Regular access reviews

Physical Security:

• ISO 27001 certified data centers
• 24/7 surveillance and monitoring
• Biometric access controls
• Environmental protections

10. PRIVACY BY DESIGN

We implement privacy-first principles:

• Data minimization - collect only necessary information
• Purpose limitation - use data only for stated purposes
• Storage limitation - retain only as long as needed
• Accuracy - enable you to update your data
• Integrity & Confidentiality - strong encryption and access controls
• Accountability - records of all data processing

11. CONTACT & COMPLAINTS

11.1 DATA PROTECTION CONTACT

For all data protection questions:

Data Protection Officer (DPO): [email protected]
Response Commitment: Within 30 calendar days

11.2 COMPLAINTS PROCEDURE

Step 1: Contact Callendoc

• Email: [email protected]
• Describe concern in detail
• Provide relevant documentation

Step 2: Callendoc Investigation

• Investigation within 20 days
• Written response to complaint
• Remedial action if necessary

Step 3: Regulatory Complaint

If dissatisfied with our response, you may complain to:

Information Commissioner's Office (ICO)
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Phone: 0303 123 1113
Website: www.ico.org.uk
Email: [email protected]

12. CHANGES TO THIS POLICY

We may update this policy to reflect:

• Changes in our data practices
• Regulatory changes
• Technology improvements

Changes will be posted with updated effective date. For material changes, we notify you via email.

ACKNOWLEDGMENT

By using Callendoc services, you:

• Acknowledge reading this Data Protection Policy
• Understand your rights under UK GDPR
• Consent to data processing as described
• Accept the security measures implemented
• Know how to exercise your rights

Questions or concerns? Contact: [email protected]

This Data Protection Policy complies with:

• UK General Data Protection Regulation (GDPR)
• Data Protection Act 2018
• Privacy and Electronic Communications Regulations (PECR) 2003
• Healthcare data regulations
• Professional conduct standards

Last Updated: November 2025
Effective Date: November 2025