MEDUMIXBack to Registration

Privacy Policy

Last updated: April 2026

1. Data Controller and Data Protection Officer

The data controller is MEDUMIX S.R.L., a Romanian limited liability company registered at the Oficiul Registrului Comerțului de pe lângă Tribunalul Hunedoara under J2021001300205, CUI 44820533. Contact: privacy@medumix.de. Full company details in the Impressum or Informații legale.

Data Protection Officer (DPO). We have appointed a Data Protection Officer pursuant to GDPR Art. 37(1)(c), given large-scale processing of special-category health data (Art. 9). You may contact the DPO at dpo@medumix.de for any request concerning your rights or our processing activities. Response time is 30 days, extendable by up to 2 months for complex requests (Art. 12(3) GDPR).

2. Data We Collect

Account data: Name, email, phone number, password (hashed).

Health data: Allergies, medical history, consultation notes, prescriptions, diagnoses, uploaded medical documents. This constitutes special category data under GDPR Art. 9.

Usage data: Login timestamps, IP addresses (for audit and security), pages visited.

Payment data: Processed by Stripe. We do not store credit card numbers.

3. Legal Basis for Processing

Health data (GDPR Art. 9). The primary legal basis for processing data concerning your health is Art. 9(2)(h) — processing necessary for the provision of health care by a healthcare professional subject to the obligation of professional secrecy under Art. 9(3). The professional-secrecy obligation applies per jurisdiction: art. 383 Legea 95/2006 for doctors practicing in Romania, §203 StGB for Germany, and §54 Ärztegesetz for Austria.

Your explicit consent under Art. 9(2)(a) + Art. 6(1)(a), provided at registration, serves as a secondary and independent legal basis for onboarding, storing your medical history before the first consultation, and enabling the patient-driven features of the platform (document sharing, messaging).

Contract (Art. 6(1)(b)): Processing necessary to perform the consultation contract you booked and to maintain your account.

Legal obligation (Art. 6(1)(c)): Medical-record retention (see §7 for the per-jurisdiction duration) and accounting retention under Legea nr. 82/1991.

4. Data Storage and Security

All data is stored on EU servers (Hetzner, Frankfurt, Germany). Sensitive fields (CNP) are encrypted with AES-256-GCM. Database connections use TLS encryption. Access is role-based — doctors can only see data from their own patients.

5. Data Sharing (Processors)

Your data is shared only with the following processors under a GDPR Art. 28 data-processing agreement:

  • Your doctors (independent controllers) — only doctors you book with or explicitly share documents with can access your health data.
  • Stripe Payments Europe, Ltd. — Ireland (EU) — payment processing only (PCI-DSS). No access to health data.
  • Sendinblue SAS (Brevo) — France (EU) — transactional emails (appointment confirmations, reminders).
  • LiveKit — self-hosted on Hetzner Online GmbH, Nuremberg, Germany (EU) — real-time video/audio transport. No media is recorded or persisted.
  • Hetzner Online GmbH — Nuremberg, Germany (EU) — hosting infrastructure, database, object storage.

All processors are located within the EU / EEA. We do not transfer personal data to third countries. We do not sell your data. We do not share data with advertisers.

6. Your Rights (GDPR)

You have the right to:

  • Access: Export all your data in JSON format from your profile.
  • Rectification: Update your profile information at any time.
  • Erasure: Delete your account. Personal data is anonymized; medical records are retained for legal compliance.
  • Data portability: Download your data in a structured, machine-readable format.
  • Withdraw consent: You may withdraw your data processing consent at any time by deleting your account.
  • Lodge a complaint: With the lead supervisory authority under GDPR one-stop-shop — Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), https://www.dataprotection.ro, B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336 București. Residents in Germany may additionally file a complaint with their local Landesbeauftragten für den Datenschutz; residents in Austria with the Datenschutzbehörde.

7. Data Retention

Account data: Retained while your account is active. Deleted / anonymized upon account deletion, except as required by §7 retention rules below.

Medical records are retained by the treating doctor as an independent controller, for the period required by the doctor's home jurisdiction. MEDUMIX, acting as processor for the doctor under GDPR Art. 28, preserves the records for the same period:

  • Doctors practicing in Romania: 30 years — Legea nr. 95/2006 art. 383 and OMS nr. 1410/2016.
  • Doctors practicing in Germany: 10 years — §630f Abs. 3 BGB.
  • Doctors practicing in Austria: 10 years — §51 Ärztegesetz.

Account and billing history: 5 years after account closure — Legea contabilității nr. 82/1991 and general limitation period.

Audit logs: 5 years, for security and compliance purposes.

8. Cookies

We use essential cookies only (session management, authentication). We do not use tracking or advertising cookies.

9. Contact

Data Protection Officer (DPO): dpo@medumix.de

General privacy queries: privacy@medumix.de

MEDUMIX S.R.L.
Sat Totia, Comuna Băcia, Nr. 64
337045 Băcia, jud. Hunedoara
România