Datenschutzerklärung
Privacy Policy — GDPR (Articles 12-14)
1. Responsible Party (Verantwortlicher)
[Company Name], [Address], [Email], represented by [Name].
Responsible for data protection: [Name / DPO contact].
2. What Data We Collect
- Account data: email address (for login).
- Medical profile: your oncology specialty (LANR), patient volume, treatment experience. This data is encrypted client-side with a key only you hold — we cannot read it.
- Wallet address: your embedded wallet address (for compensation).
- Study matches: which studies you matched and participated in, including zero-knowledge proofs.
- Audit logs: records of data access (retained up to 12 months for security).
3. How We Process Your Data (Art. 13)
- Profile matching: your encrypted answers are matched against study criteria using zero-knowledge proofs. Your plaintext answers never leave your device.
- Study participation: when you participate, a proof is generated and stored (score + fields used — no personal data beyond that).
- Compensation: processed via your wallet address.
4. Legal Basis (Art. 6)
- Consent (Art. 6(1)(a)): you explicitly consent to profile processing, study matching, and compensation.
- Special category data (Art. 9): medical profile data is processed under your explicit consent.
5. Your Rights (Art. 15-22)
- Right of access (Art. 15): download all your data in Settings → "Download my data".
- Right to erasure (Art. 17): delete your account in Settings → "Delete my account". Your proofs will be anonymized.
- Right to withdraw consent (Art. 7(3)): withdraw consent in Settings at any time.
- Right to rectification (Art. 16): correct your data via your profile.
- Right to data portability (Art. 20): export your data in JSON format.
- Right to object (Art. 21): contact us to object to specific processing.
6. International Data Transfers (Art. 44-49)
Your data is processed by:
• Vox Medica servers (hosted on Vercel, EU region).
• Database (Neon, Frankfurt / eu-central-1).
• Privy (authentication provider, US-based) — your email is sent for login verification. Standard Contractual Clauses are in place. TODO: LEGAL REVIEW — confirm SCCs.
7. Data Retention
- Profile + participations: deleted when you delete your account.
- Proofs: anonymized (not deleted) to preserve verifiability for pharma clients.
- Audit logs: retained up to 12 months, then purged.
- Inactive accounts: TODO: LEGAL REVIEW — define inactivity period.
8. Data Security (Art. 32)
Medical profiles are encrypted with AES-256-GCM using keys derived from your wallet (zero-knowledge-to-server architecture). Authentication via Privy JWKS verification. Audit logging on all data access.
9. Contact
For privacy questions or to exercise your rights: [privacy@voxmedica.de]
Supervisory authority: [TODO: insert relevant Landesdatenschutzbehorde]