Privacy Policy For Patients

PATIENT PRIVACY POLICY

1. INTRODUCTION & DATA CONTROLLER

At Wupdoc B.V. ("Wupdoc", "We", "Us"), we value your privacy and are committed to protecting the personally identifiable information and special category health data we collect when you use our website at https://www.wupdoc.com and associated mobile/web software applications.

Data Controller:

Wupdoc B.V.

Address: Sloterweg 303 1171 VC Badhoevedorp, Amsterdam, Netherlands

Tax Identification Number: 865127761

Email: support@wupdoc.com
 

By accessing the pages of our website, submitting an Offer Request, or utilizing Wupdoc services, you approve this Patient Privacy Policy ("Policy"). Since the use of services offered on the website is always subject to agreement, you should refrain from using our website if you do not accept this Policy. Wupdoc reserves the right to make changes to this Policy at any time, which become effective on the day of publication.

2. ANONYMITY AND CONTACT PRIVACY GUARANTEE

2.1. Strict Pre-Booking Anonymity: When you create an Offer Request or communicate with Clinics/Providers via Wupdoc In-App Chat, your full name, email address, and phone number are kept strictly hidden and anonymized. Clinics receive only anonymous offer IDs and anonymized treatment details.

2.2. Conditional Release of Contact Details: Your personal contact information (full name, phone number, email address) is released to the selected Clinic ONLY AFTER you successfully complete a Deposit payment on Wupdoc to confirm your appointment.

2.3. In-App Chat Evidence & Safety: Pre-booking communication must occur exclusively inside Wupdoc In-App Chat. Chat transcripts, uploaded medical documents, and messages are processed to ensure platform safety, prevent fraudulent circumvention, and serve as legal evidence in chargeback or service disputes under GDPR Article 9(2)(f).

3. PURPOSES OF DATA PROCESSING

Your personal data and health data are processed under GDPR (EU) 2016/679 and applicable data protection legislation for the following explicit purposes:

1. Service Improvement & Security: Engage in activities to improve our software platform, optimize system performance, and maintain platform security.

2. Account Management: Create, verify, and manage your user profiles, anonymous request IDs, and credentials.

3. Reliable Service Delivery: Provide you with the health tourism intermediation services, offer generation tools, and clinical information you request in the most reliable manner.

4. Fulfillment of Data Submission: Fulfill the specific reasons for which you provided the information to us (e.g., matching your treatment request with relevant clinics).

5. Personalization: Personalize our services, website content, offer display panels, and customer support communications according to your preferences.

6. E-Commerce Protection: Protect you, Clinics, and Wupdoc from fraudulent transactions, unauthorized account access, and crimes processed through electronic commerce.

7. Direct Marketing & Ad Targeting: Display interest-based advertisements, conduct direct marketing via SMS/email (subject to explicit consent), and process hashed/pseudonymized contact data to create custom and lookalike audiences on digital advertising platforms (including Meta and Google Ads).

8. Communication & Support: Respond to correspondence received from you, communicate with you when necessary or requested, and provide updates regarding Wupdoc Services and booking statuses.

9. Informative Updates & Offers: Inform you about Healthcare Providers and Services, send newsletter updates or promotional emails based on your preferences, and facilitate treatment offer comparisons.

10. Legal & Regulatory Compliance: Prevent, detect, and investigate security breaches, fraudulent chargeback claims, and illegal activities; and fulfill our statutory legal obligations under applicable law, court orders, or administrative processes.

11. Rights Protection: Protect your rights, Wupdoc’s intellectual property, financial interests, or third-party safety.

12. Dispute Resolution: Respond to, investigate, and resolve claims or disputes regarding medical bookings, chargeback defenses, or third-party content rights infringements.

4. SPECIAL CATEGORY HEALTH DATA (GDPR ART. 9)

When submitting an Offer Request, you may voluntarily provide special category personal data, including medical photos (e.g., dental, cosmetic, hair transplant photos), treatment preferences, and medical history notes. This data is processed strictly based on your Explicit Consent pursuant to GDPR Article 9(2)(a). Health data is hosted securely on Microsoft Azure cloud infrastructure (located within the EU/EEA or subject to standard contractual clauses) solely for hosting and offer generation purposes.

5. FINANCIAL DATA & PAYMENT PROCESSORS

Reservation Deposit payments made on Wupdoc are processed directly through our PCI-DSS compliant licensed payment gateway partner (Stripe, Inc.). Wupdoc does NOT store full credit/debit card numbers or CVV codes on its servers. Wupdoc retains only transaction reference IDs, deposit amounts, timestamps, and payment verification statuses.

6. YOUR GDPR DATA SUBJECT RIGHTS

Under GDPR and applicable data protection rules, you possess the following rights regarding your personal data:

• Learn whether your personal data is processed,

• Learn the specific purpose of processing,

• Learn about domestic or international data transfers,

• Request correction of inaccurate or incomplete data, its restriction, and notification to third-party recipients,

• Request deletion ("Right to be Forgotten") and notification to third parties when processing grounds no longer exist,

• Request compensation for unlawful damages suffered,

• Object to automated decision-making and profiling that produces adverse legal outcomes.

Contact Channels for Data Rights:

You can convey your request along with identity verification documents through:

• Email to: support@wupdoc.com (with or without electronic signature),

• Physical Mail / Notary to: Wupdoc B.V., Sloterweg 303 1171 VC Badhoevedorp, Amsterdam, Netherlands.

We commit to responding to your request free of charge as soon as possible and within no longer than 30 (thirty) days. You also maintain the right to lodge a complaint with a supervisory data protection authority (e.g., the Dutch Data Protection Authority - Autoriteit Persoonsgegevens).

7. EXPLICIT CONSENT DECLARATION

I ACCEPT AND DECLARE that I give my EXPLICIT CONSENT to Wupdoc B.V. for the processing, secure storage, and conditional transfer to listed Clinics/Providers of my special category personal health data (including medical notes, photos, and treatment preferences) and contact details in accordance with the procedures and principles set forth in this Policy. I acknowledge that my contact information will remain hidden from Clinics until I pay a treatment Deposit. I confirm that I have read and understood this Policy, know my statutory legal rights, and understand that I may revoke my explicit consent at any time by contacting support@wupdoc.com.