Privacy Policy
Effective date: October 16, 2026
At a Glance
We do not sell your personal data. We do not use Google Ads or any other advertising cookies on the website. We use analytics cookies only with your consent, which you can refuse or withdraw in the cookie settings at any time.
The two tables below summarise this policy. The detailed sections that follow set out each purpose in full.
What we use your data for and on what legal basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Membership, scheduling, and communication without health information: identification, contact, membership, and billing data | Performance of contract, Article 6(1)(b) |
| Website contact form and callbacks | Steps taken at your request before entering into a contract, Article 6(1)(b) |
| Health-related information you choose to share with us, and the coordination of your requests that uses it, including the history in our CRM | Your consent, Article 6(1)(a), and explicit consent, Article 9(2)(a) |
| Sharing the data needed for a booking with a specific clinic, including health-related information | Your explicit consent to sharing with that clinic, Articles 6(1)(a) and 9(2)(a) |
| Records of consents and of data shared with clinics | Legal obligation to demonstrate consent, Article 6(1)(c), read with Article 7(1) |
| Recording of telephone calls | Legitimate interest, Article 6(1)(f); you can object and ask for a call that is not recorded |
| Billing and accounting | Performance of contract, Article 6(1)(b), and legal obligations under tax and accounting law, Article 6(1)(c) |
| Security, fraud prevention, audit trails, and defence of legal claims | Legitimate interest, Article 6(1)(f); for health-related context also Article 9(2)(f) |
| Marketing emails to existing clients | Legitimate interest, Article 6(1)(f); you can object at any time |
| Marketing emails to everyone else | Consent, Article 6(1)(a), and Section 7 of Act No. 480/2004 Coll. |
| Analytics cookies | Consent given in the cookie banner, Article 6(1)(a) |
Capabilities that are not yet live, such as the client portal and secure messaging, research, and AI-assisted tools, are described in the "Why Do We Process Your Data and What Is the Legal Basis?" section and start only when each goes live.
How long we keep your data
| Data | How long we keep it |
|---|---|
| Contact-form enquiries that do not lead to a client relationship | Up to 12 months from your last interaction with us |
| Client account data, contract, payments, and appointment records (without the reason for the visit) | For the client relationship and 4 years after it ends; individual records up to 10 years where relevant to a specific dispute. Accounting and tax documents are kept for the statutory periods below where those are longer |
| Messages and notes about you in our CRM | For your membership and 30 days after it ends, during which you can download your data |
| Health-related context you shared for navigation | Deleted or anonymised within 30 days after the navigation purpose ends, you withdraw consent, or your account is closed, whichever comes first |
| Telephone call recordings | 30 days from the call date |
| Contact data used for marketing and marketing-consent records | 3 years from your last interaction with our marketing emails, or until you withdraw consent, whichever is sooner |
| Unsubscribe and objection records (a hash of your email address) | For as long as we operate any marketing list |
| Records of consents given and withdrawn, and of data shared with clinics | For the relevant processing, for clients the membership, and at most 3 years after it ends |
| Audit and access logs | 12 months; security-incident and authentication logs up to 24 months |
| Accounting documents and related accounting records | 5 years from the end of the accounting period they relate to, or longer where the Accounting Act requires it |
| Tax documents under the VAT Act | 10 years from the end of the tax period in which the supply took place |
| Medical documentation | Not held by OpenMedical; partner providers keep it for the periods required by Decree No. 98/2012 Coll. |
| Cookies and technical data | As set out in our Cookie Policy. |
Where a dispute, complaint, or legal claim is pending, the health-related context and call recordings it needs are kept until it is finally resolved and for one year thereafter.
Administrator of Personal Data
The Administrator of your personal data is OpenMedical s. r. o., Identification No. 19422784, with its registered office at Prosecká 876/89, Prosek, 190 00 Prague 9, Czech Republic, entered in the Commercial Register administered by the Municipal Court in Prague, Section C, File 386014 (hereinafter referred to as the "Administrator" or "OpenMedical").
OpenMedical (openmedical.cz) is the brand under which the Administrator provides a paid membership and care-navigation service. OpenMedical is not a healthcare provider and does not itself perform medical examinations, diagnoses, treatment, or clinical consultations.
The Administrator is the controller of personal data processed for membership, scheduling, coordination of appointments, communication with partner providers on the client's behalf, payment handling, follow-up reminders, and related administrative support.
This notice describes the maximum scope of processing under the service. At launch, processing is limited to membership administration, scheduling and coordination of in-person appointments at partner providers, communication with the client by phone (including call recording under the conditions described in the "Telephone calls and call recording" subsection below) and e-mail, payment handling, and related administrative tasks. The following capabilities and channels are not yet live and the related processing only begins once each goes live, with this notice updated before it does: the mobile app and client account, the later web client portal, secure in-product messaging and document uploads, accepting medical documents from clients and passing them to partner providers (in this phase we do not accept medical documents through any channel, including e-mail), AI-assisted support tools, telehealth coordination at partner providers, employer-linked and family programmes, clinical studies and research, and WhatsApp and Telegram channels. Where any of those capabilities requires additional consent (in particular for health-related context or telemedicine), that consent will be collected separately at the point of activation.
All medical care is provided by separately licensed partner clinics, hospitals, laboratories, and individual healthcare professionals. Each such partner is an independent controller for the personal data, including health data and medical records, that they create and process when delivering care.
Where, in order to navigate or schedule care appropriately, the client shares health-related information with the Administrator, that information is special-category data under Article 9 GDPR and the Administrator requires the client's explicit consent for it. Processing is limited to what is necessary for the navigation purpose; the detailed legal basis is set out below in the "Why Do We Process Your Data and What Is the Legal Basis?" section.
Introductory Information
This document serves several purposes. You will learn which of your data we process and why, what rights you have in connection with personal data processing, and to whom you can turn with your questions, suggestions, or complaints. We ask that you read the following text carefully. It is divided into sections so that you can easily find the information relevant to you.
If anything is unclear to you regarding the protection of personal data, please do not hesitate to contact us.
For general privacy questions and clarification of this Policy, use the general privacy contact below. To exercise GDPR rights, submit formal requests, complaints, or other data-protection submissions, use the privacy contact point in the following subsection.
- Postal: OpenMedical s. r. o., Prosecká 876/89, Prosek, 190 00 Prague 9, Czech Republic
- By e-mail at: privacy@openmedical.cz
- By telephone at: +420 228 811 976 (9:00-15:00, calls only; no SMS)
Privacy Contact
To exercise GDPR rights, submit formal requests, complaints, or other data-protection submissions, please use the privacy contact point below. We have not formally designated a Data Protection Officer (DPO) under Article 37 GDPR at this time. If the scope of our processing makes the appointment of a DPO mandatory under Article 37(1) GDPR, we will appoint one, notify the Czech Office for Personal Data Protection (ÚOOÚ), and update this Policy accordingly. You can contact us using the following methods.
- Postal: OpenMedical s. r. o., Prosecká 876/89, Prosek, 190 00 Prague 9, Czech Republic
- By e-mail at: privacy@openmedical.cz
- By telephone at: +420 228 811 976 (9:00-15:00, calls only; no SMS)
Supervisory Authority
The supervisory authority for personal data protection in the Czech Republic is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), located at Pplk. Sochora 27, 170 00 Prague 7. Current contact information is available at www.uoou.cz. You have the right to file a complaint with this authority at any time.
Basic Principles of Personal Data Processing
- We process your personal data lawfully, fairly, and in a transparent and comprehensible manner.
- We process your personal data only to the extent necessary and in a manner consistent with the purpose for which it was collected.
- We take care to ensure that the personal data we process is accurate and kept up to date. Inaccurate data is corrected or deleted.
- We process your personal data only for the period strictly necessary. In some cases this period is set by law; in others we define it internally in line with our legitimate interests.
- We secure your personal data against leakage, unauthorised processing, accidental loss, and damage. We apply appropriate technical and organisational measures, including strict access controls, encryption, logging, and physical security.
Legal Framework
The most important legal rules referenced in this policy are listed below. GDPR, Act No. 110/2019 Coll., the Civil Code, and consumer-protection legislation apply to OpenMedical directly. Act No. 372/2011 Coll., Decree No. 98/2012 Coll., and Decree No. 30/2025 Coll. apply to partner healthcare providers and are referenced here for context, because some of your rights (for example access to medical documentation under Section 65 of Act No. 372/2011 Coll.) are exercised at the partner provider that holds those records.
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, "GDPR")
- Act No. 110/2019 Coll., on Personal Data Processing
- Act No. 89/2012 Coll., the Civil Code
- Act No. 372/2011 Coll., on Health Services (applies to partner providers)
- Decree No. 98/2012 Coll., on medical documentation (applies to partner providers)
- Decree No. 30/2025 Coll., governing telemedicine services (applies to partner providers offering telehealth)
- Other regulations in the areas of consumer protection, administration, and accounting
Which of Your Data Do We Process?
Because each client uses our service in their own way, the list below describes the maximum set of data we may process in relation to you. We obtain your personal data directly from you, including context you choose to share with us, and, with your consent, from partner providers as part of scheduling your appointments (for example, a booking confirmation). We do not receive medical documentation from partner providers.
Identification data
Name, surname, date of birth, birth-registration number (rodné číslo), insurance type (including Czech statutory public health insurance: VZP, VoZP, ČPZP, OZP, ZPŠ, ZPMV ČR, or RBP), public health insurance policyholder number, health-insurance provider code, identification document data where required, and your OpenMedical client account identifier.
Insurance information is collected and kept up to date so that we can split clinic services correctly between public-insurance-covered items and self-paid items, tell you which documents to request from the clinic if you choose to claim from your commercial insurer, coordinate care with the right partner providers, and handle billing correctly. OpenMedical does not decide coverage, submit claims, negotiate reimbursement, or act as an insurer, broker, or claims handler. Where you notify us of a change in your insurance during the membership year, we update your record accordingly and reassess clinic-side billing and the documents needed for reimbursement under our Terms of Service.
Contact data
Address of permanent residence, correspondence address, telephone number, e-mail address, data box ID, and preferred language of communication.
Health-related context shared for navigation
Limited health-related context that you choose to share with us so we can navigate care correctly, for example the reason you are seeking care, prior diagnoses you wish to disclose, allergies or medications relevant to scheduling, and, once document upload is launched, copies of medical reports, referrals, lab results, or imaging that you upload to be forwarded to a partner provider. At this stage we do not accept medical documents; you bring your reports to the doctor yourself. We do not create medical documentation, do not record clinical findings, and do not act as the system of record for your medical history; that role belongs to the partner provider that delivers your care.
Data generated through the client portal and digital channels
Appointment records and reminders, once the relevant features are launched also documents you upload to share with partner providers, messages exchanged through secure messaging, audit logs of access to your account and uploaded documents, consent records, and profile settings. OpenMedical does not currently coordinate telehealth consultations at partner providers. If such coordination is launched in the future, those sessions and any recordings will take place on the partner provider’s systems under the partner’s legal basis; OpenMedical does not store telehealth recordings.
Images and documents
Once document upload is launched, photos of documents you upload, for example prior medical reports and referrals, images captured during examinations, and imaging studies. At this stage we do not accept them.
Billing and payment data
Data necessary to bill the membership and coordination service to you directly or to your employer where applicable, including transaction identifiers. We do not store full payment card numbers; these are handled by certified payment providers.
Technical data
IP address, device and browser information, log data, and cookies, collected when you use openmedical.cz or the client portal. Details are provided in our Cookie Policy.
Other personal data
Recordings of telephone calls with our team (both inbound and outbound) captured via the CloudTalk cloud platform, including the call content and metadata (timestamp, duration, telephone numbers, operator identifier). Coordinators write their call notes in our CRM, not in CloudTalk. You are informed of the recording at the start of each call and may request a non-recorded call. Details of the purpose, legal basis, and retention period are set out in the "Telephone calls and call recording" subsection below.
Communications you send us through website chat, WhatsApp, Telegram, or other messaging channels you choose to use.
In What Form Is Your Personal Data Processed?
Personal data we process for the membership and coordination service is held in our secure systems, primarily in electronic form. Access is limited to authorised staff (support, coordinators, administration) based on their role and is logged. Health-related context you share with us for navigation is encrypted in transit and at rest, and access to it is auditable. At this stage we do not accept medical documents.
We do not maintain medical documentation. Medical documentation is created and held by partner healthcare providers who deliver your care, under their own legal duties (in the Czech Republic, in particular Act No. 372/2011 Coll. and Decree No. 98/2012 Coll.).
Production (live) and non-production (testing, development) environments are strictly separated, and real client data is not used in non-production environments.
Why Do We Process Your Data and What Is the Legal Basis?
Delivery of the membership and care-navigation service
This is the primary purpose. For the personal data needed to enter into and perform the membership contract (identification, contact, billing, and membership data, and organisational communication that contains no health information), the legal basis is the performance of our contract with you under Article 6(1)(b) GDPR. Health-related information you choose to share with us, and the coordination of your requests that uses it, including the necessary history in our CRM, are processed on the basis of your consent under Article 6(1)(a) GDPR and your explicit consent to the processing of special-category data under Article 9(2)(a) GDPR. Simply sharing health information, asking us to "book me in", or staying on a call does not by itself amount to that consent. Processing of health-related information is limited to what is necessary for that purpose.
We share the data needed for a booking with a specific clinic (identification and contact details, the requested specialty, and the brief reason you give us for the booking) only with your explicit consent to sharing with that clinic, under Articles 6(1)(a) and 9(2)(a) GDPR. We do not share your communication history or call recordings with clinics.
We keep a record of consents given and withdrawn, and of whom we shared data with and when, so that we can demonstrate consent under Article 7(1) GDPR. The legal basis is compliance with a legal obligation under Article 6(1)(c) GDPR. This record does not hold the full content of your health communications or call recordings.
Website contact and callback handling
When you submit the public contact form, we process the contact-form data needed to respond and arrange follow-up: your name, email address, telephone number if provided, selected programme or specialization, stated intent, privacy acknowledgement, marketing-consent state, locale, and your free-text enquiry message.
The legal basis is taking steps at your request before entering into a contract under Article 6(1)(b) GDPR.
The form is delivered to our operations inbox through our website email infrastructure so coordinators can respond or arrange a callback. This operational handling is independent of marketing consent; MailerLite remains used only for marketing email processing when marketing consent is granted.
Telephone calls and call recording
Telephone communication between you and our team (both inbound and outbound calls) takes place via the CloudTalk cloud platform and is recorded for quality assurance, coordinator training, care coordination, and the defence of legal claims. You are informed of the recording at the start of each call. If you do not wish to be recorded, you may request a non-recorded callback at any time by emailing info@openmedical.cz; we will call you back from a line that is not recorded.
The legal basis has three layers, applied according to the content of the call. For the recording itself, we rely on our legitimate interest under Article 6(1)(f) GDPR (quality assurance, traceability of communication, and defence of legal claims), balanced against your rights and freedoms; you have the right to object under Article 21 GDPR at any time and request a non-recorded call. For the organisational content of the call that contains no health information, with existing clients, we rely on performance of contract under Article 6(1)(b) GDPR. Where you share health-related information during the call (for example the reason you are contacting us, prior diagnoses, or medications), the same legal basis applies as to other health-related information: your consent under Article 6(1)(a) GDPR and your explicit consent under Article 9(2)(a) GDPR, as described in the "Delivery of the membership and care-navigation service" section above.
Recordings are retained for 30 days from the call date and then deleted. Where a dispute, complaint, or legal proceeding is pending in relation to a specific call, the relevant recordings are retained until the matter is finally resolved and for one year thereafter.
Access to recordings is limited to authorised coordinators, support leads, and persons handling a specific complaint or legal claim; access is logged and audited. Details of transfers outside the European Economic Area are described in the "Transfers outside the EEA" section below.
Operation of the client portal, appointments, and secure messaging
Legal basis: performance of contract under Article 6(1)(b) GDPR and our legitimate interest under Article 6(1)(f) GDPR in operating a secure, auditable service. Telehealth coordination through OpenMedical is not currently active; if launched in the future, the telehealth itself will take place on the partner provider’s systems under the partner’s legal basis.
Billing and accounting
Legal basis: performance of contract under Article 6(1)(b) GDPR and compliance with legal obligations under tax and accounting legislation under Article 6(1)(c) GDPR.
Protection of our legitimate interests
This includes security of our systems, fraud prevention, maintaining audit trails, and defence of legal claims. Legal basis: legitimate interests under Article 6(1)(f) GDPR, balanced against your rights and freedoms. Where the establishment, exercise, or defence of legal claims requires us to handle health-related context that you previously shared with us for navigation, Article 9(2)(f) GDPR applies as the additional special-category condition; both layers apply together and only to the extent necessary.
Direct marketing and promotional communications about OpenMedical services
For existing clients, the legal basis is legitimate interests, with the right to object at any time. For non-clients and for marketing by electronic means beyond what is permitted by law, we rely on your consent under Article 6(1)(a) GDPR and Section 7 of Act No. 480/2004 Coll. on certain information society services.
When you tick the marketing checkbox in our contact form, you consent to receive promotional and marketing emails about OpenMedical services. The data we use for this purpose is limited to your name, email address, locale, and the structured form fields you submitted (referral source and selected specialization). The free-text message field is used solely to respond to your enquiry and to coordinate any subsequent care navigation; its content is not transferred to our marketing processor, not used to build or segment marketing audiences, and is not used to infer any special-category data about you. We use the marketing data only to send the communications you have agreed to and to measure their effectiveness.
To send these emails we use MailerLite (UAB MailerLite, Paupio g. 46, 11341 Vilnius, Lithuania) as a processor acting on our behalf under a written data processing agreement. MailerLite hosts subscriber data and email analytics on EU infrastructure. Where MailerLite uses sub-processors located outside the European Economic Area, the transfer takes place under Standard Contractual Clauses approved by the European Commission and supplementary measures. Current details are available in the MailerLite privacy and DPA documentation.
We retain marketing-consent records and contact data used for marketing for three years from your last interaction with our marketing emails or until you withdraw your consent, whichever is sooner. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Every marketing email contains a one-click unsubscribe link. You can also withdraw consent at any time by writing to privacy@openmedical.cz. The active marketing subscriber list and unsubscribe enforcement are operated by MailerLite as our processor under a written data processing agreement; once you unsubscribe, MailerLite stops sending you marketing emails immediately and we remove your contact data from our active marketing list within 30 days. In our own internal records we additionally keep a minimal entry (the sha256 hash of your lower-cased email address together with a timestamp) so we can reliably honour your preference even if our email service provider is later replaced. Without this entry we would not be able to recognise you as a previously-unsubscribed contact.
Clinical studies, research, and statistical purposes
The legal basis has two layers. The standard route is your consent under Article 6(1)(a) GDPR together with, for health data, your explicit consent under Article 9(2)(a) GDPR. Where a specific research project allows it and the law permits, we may also rely on legitimate interests or public interest under Article 6(1)(e) or (f) GDPR combined with the scientific-research condition under Article 9(2)(j) GDPR, always with appropriate safeguards and, wherever possible, pseudonymised or anonymised data.
Use of AI-assisted tools
We are introducing AI-assisted tools gradually. When live, their use will be limited to support functions such as FAQ and support assistance, scheduling and triage support, summarisation of communications, structured extraction from documents you choose to share for navigation, and internal drafting. Each tool will be subject to human oversight. AI is not used to make clinical decisions; clinical decisions are made by clinicians at partner providers.
Before any AI-assisted tool processes information about your health that you have shared with us, we will ask for your separate consent under Article 6(1)(a) GDPR and your explicit consent under Article 9(2)(a) GDPR. For support uses that involve no health information, we rely on performance of contract under Article 6(1)(b) GDPR or our legitimate interests under Article 6(1)(f) GDPR. We will update this notice when each capability goes live.
Your personal data is not used to train third-party AI models. Where AI processing takes place under our supervision, we contractually require that no provider may use your data for training, fine-tuning, or otherwise improving generally available AI models.
Withdrawal of consent and consequences
Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
If you do not give, or you withdraw, your consent to the processing of health-related information, we cannot carry out tasks on your behalf that use that information, in particular booking you with a specific partner provider and coordinating follow-up care. After withdrawal we delete or anonymise that information within 30 days, unless another legal ground requires us to keep what is necessary, for example the defence of a specific legal claim. Your membership contract continues, and organisational and administrative tasks that involve no health information continue. If you withdraw only your consent to sharing data with a specific clinic, we stop sharing data with that clinic; your other consents are not affected. Marketing, research, and other consent-based processing are independent of this and can be refused or withdrawn separately at any time.
Minors
OpenMedical membership is currently offered to natural persons aged 18 and over; we do not establish client accounts for minors at this time. If family or pediatric coordination becomes available, this section will be updated with the applicable guardian, consent and access rules before any minor data is collected.
Access to Records After the Client’s Death
Two separate paths apply when a client dies, because medical documentation and the data we hold for the membership service sit with different controllers.
Medical documentation held by partner providers
Inspection of, and copies from, the deceased client’s medical documentation is governed by Section 33 of Act No. 372/2011 Coll. Close persons (spouse, registered partner, parent, child, sibling, partner, and other persons the client identified as close during their lifetime) have the right to inspect that documentation unless the client expressly prohibited disclosure to specific persons during their lifetime. Because that documentation is held by partner providers, requests for it should be addressed to the partner provider that delivered the care. We will, on request, help identify the relevant partner.
Membership and coordination data we hold
For the data we hold ourselves (the client account, scheduling history, communications with our team, billing records, and any health-related context the client shared with us for navigation), close persons may request access to the extent permitted by law and by any instructions the client left with us during their lifetime. Such requests should be sent by post, in person, or by another secure channel agreed with us. We may require proof of identity and proof of the requester’s relationship to the deceased, for example a birth or marriage certificate, or a sworn declaration where the law allows.
Client’s lifetime instructions
During their lifetime, the client may name persons who are entitled to access data we hold, or, conversely, exclude specific persons. Such instructions are recorded in the client account and applied when handling requests after the client’s death.
Limits on disclosure
Information that the deceased client expressly prohibited from disclosure, and information whose disclosure would breach the legitimate interests of third parties, may be withheld in line with the law. The right of close persons does not extend to data outside the categories named above, except where another statutory basis applies.
To Whom Can We Transfer Your Personal Data?
As a rule, we process your personal data within OpenMedical. In certain cases, however, we may transfer your data to other recipients.
State authorities and public bodies
We may disclose data where we are legally obliged to do so, for example to courts, law enforcement, or other public authorities within the limits of the law.
Partner clinics and specialist providers
OpenMedical coordinates care delivered by a network of partner clinics, hospitals, laboratories, and specialist providers. Where you proceed to receive care from a partner, for example for a consultation, an imaging study, or a laboratory test, we share the data necessary to book your appointment, including any health-related information you have shared with us for that purpose, and only with your explicit consent to sharing with that partner.
Each partner provider is an independent controller for the personal data and medical documentation they create and process when delivering care. Partner providers are bound by their own healthcare confidentiality and data protection obligations under Czech and EU law. In specific pathways where OpenMedical and a partner jointly determine how data is processed, the relationship may be structured as joint controllership under Article 26 GDPR, and you will be informed accordingly.
Some partner clinic premises may operate CCTV for safety and security. In that case the partner clinic is the controller for the camera footage and provides its own information notice and signage at the location.
Insurance and assistance partners
Where you choose a programme that includes a partner-managed insurance or assistance benefit (for example a travel-insurance or worldwide medical-assistance benefit), or ask us to activate such a benefit, we may share the personal data necessary to activate and administer that benefit. This usually includes identification, contact, membership, and eligibility data. The current provider is named in the programme description on our website and may change from time to time.
We share health-related context with an insurance or assistance partner only where it is necessary for the requested benefit or claims handling and only with the applicable legal basis, including explicit consent where required. The insurance or assistance partner acts as an independent controller for its own benefit administration, assistance handling, and claims handling under its own terms and privacy information.
Processors acting on our behalf
This includes providers of IT infrastructure, hosting and protected storage, the client portal and operations platform, secure messaging, document management, identity verification, notifications, audit logging, payment processing, accounting, customer support tools, and website analytics. All processors are bound by written data processing agreements and are selected under strict criteria. OpenMedical does not allow processors to use your data for their own purposes.
For the website, the contact form, email, telephone communication, our CRM, the client app, and accounting we currently rely on the following named sub-processors. If an additional processor is introduced in the future (for example a scheduling tool or analytics platform), this notice will be updated and the new processor will be named here with its country and transfer basis before any related processing begins.
- Hetzner Online GmbH (Germany, EU): hosting of the website and the contact-form backend; servers and databases of our CRM and the client app.
- OVH SAS, OVHcloud (France, EU): file storage in the client app.
- Backblaze, Inc., the B2 Cloud Storage service (data stored in the EU, in the Netherlands; any access from the United States under the EU-US Data Privacy Framework and Standard Contractual Clauses approved by the European Commission): immutable encrypted backup copies.
- Hanko GmbH (Germany, EU): sign-in to the client app.
- 650 Industries, Inc. (Expo), Apple Inc., and Google LLC (United States; Expo and Google under the EU-US Data Privacy Framework, Apple under Standard Contractual Clauses approved by the European Commission): delivery of notifications to the client app. Notifications contain only general text without health information.
- Cloudflare, Inc. (United States, under the EU-US Data Privacy Framework and Standard Contractual Clauses): authoritative DNS, reverse proxy, and DDoS protection for openmedical.cz; all web traffic passes through Cloudflare's edge network, where TLS is terminated, traffic is filtered, and bot protection is applied. On the contact form page, Cloudflare also uses its Turnstile service to check that the form is sent by a person. We also keep encrypted backup copies in the EU in Cloudflare R2.
- Google LLC, Google Workspace (United States, under the EU-US Data Privacy Framework and Standard Contractual Clauses): business email used to receive and reply to your enquiries.
- UAB MailerLite (Lithuania, EU): delivery of subscriber and notification emails.
- FINWAY s. r. o., company ID 22364803, registered office Křesomyslova 248/5, Prague 4 (Czech Republic, EU): bookkeeping and tax administration; processes billing and payment data from accounting documents.
- CloudTalk s. r. o. (Slovak Republic, EU): cloud telephony platform, call recording, operational customer-support, and contact records associated with telephony, including callbacks. For voice routing and recording storage, CloudTalk may rely on sub-processors located outside the EEA (in particular Twilio Inc. and Amazon Web Services, Inc. in the United States) under the EU-US Data Privacy Framework, Standard Contractual Clauses approved by the European Commission, and supplementary measures.
- Google Ireland Limited (Ireland) and Google LLC (United States, under the EU-US Data Privacy Framework, or Standard Contractual Clauses approved by the European Commission should it cease to apply): Google Tag Manager and Google Analytics 4 for website analytics, only if you have given analytics consent via our cookie banner. We do not use Google Ads.
- Functional Software, Inc., the Sentry service (United States; reports are stored in the EU, in Germany; any access from the United States under the EU-US Data Privacy Framework and Standard Contractual Clauses approved by the European Commission): capturing technical errors on the website. We report browser errors only with your analytics consent. We always record server errors, based on our legitimate interest in running the website securely; these reports contain neither your IP address nor cookies.
Google's role for third-party tags and measurement
When Google Tag Manager is loaded after consent and Google tags are used through it (Google Analytics 4), Google also processes a limited set of data on its own infrastructure for its own purposes, in particular network security, fraud prevention, and the development and evaluation of advertising systems. To that extent Google acts as an independent controller under Article 4 GDPR, or as a joint controller under Article 26 GDPR where the purposes are determined jointly with OpenMedical.
For processing carried out solely on OpenMedical's behalf (for example delivery of a specific measurement event that we have configured), Google acts as a processor under Article 28 GDPR. The website analytics layer is limited to allowlisted interaction events and does not send names, e-mail addresses, telephone numbers, free-text enquiry messages, health-related context, or raw submitted form values to Google tags. Pages about individual specialties, clinics, and blog articles are passed on only as a general section of the website, without the page address or title, and the specialty chosen in the contact form is not passed on at all. Automatic collection of user-provided data (e-mail, phone, address) is switched off in our Google Analytics. This subsection does not apply if you have not consented to analytics cookies; in that case no related Google tag-side processing takes place.
You may exercise your GDPR rights in relation to Google's independent or joint controllership directly with Google under its privacy information available at policies.google.com/privacy; for the remainder you contact OpenMedical.
Your employer or corporate client
This applies only where you are enrolled in an employer-linked programme and only to the extent you have agreed to. Employers do not receive your medical data without your explicit consent.
Family members or household members
This applies only where you are enrolled in a family or household account and have explicitly agreed to the applicable access arrangements.
Transfers outside the EEA
We generally do not transfer your medical and client data outside the European Economic Area (EEA). Where any processor is located outside the EEA, or where a sub-processor provides services from outside the EEA, such transfer takes place only under the safeguards required by the GDPR, in particular Standard Contractual Clauses and supplementary measures, and, for health data, only where strictly necessary.
If you consent to analytical cookies on openmedical.cz, Google Tag Manager loads Google Analytics 4. In the EEA it is provided by Google Ireland Limited; certain data associated with those cookies, such as your IP address, cookie identifiers, and allowlisted interaction events, may be transferred to Google LLC in the United States. This transfer relies on the European Commission’s adequacy decision for the EU-US Data Privacy Framework, under which Google LLC is certified; should it cease to apply, Standard Contractual Clauses approved by the European Commission will be used. With the same consent, we report browser errors to the Sentry service of Functional Software, Inc. (United States), which stores them in the EU (Germany). Details are available in our Cookie Policy.
Emails you exchange with our business addresses are processed via Google Workspace, which Google LLC operates from the United States. This transfer takes place under Google’s certification to the EU-US Data Privacy Framework and Standard Contractual Clauses approved by the European Commission.
We keep encrypted backups as two copies in the EU, in Cloudflare R2 and in Backblaze B2. Cloudflare, Inc. and Backblaze, Inc. are based in the United States; any access to these copies from the United States takes place under the EU-US Data Privacy Framework and Standard Contractual Clauses approved by the European Commission.
Notifications to the client app are delivered by 650 Industries, Inc. (Expo), Apple Inc., and Google LLC from the United States. They contain only general text without health information.
Where MailerLite uses sub-processors outside the EEA for delivery of marketing emails, those transfers take place under Standard Contractual Clauses approved by the European Commission.
All communication between your device and openmedical.cz passes through the edge network operated by Cloudflare, Inc., which runs global infrastructure including data centers in the EU and the United States. In doing so, Cloudflare processes your IP address, request headers, and other technical data for TLS termination, attack mitigation, bot detection, and content delivery. The transfer may include processing in the United States under Cloudflare's certification to the EU-US Data Privacy Framework and Standard Contractual Clauses approved by the European Commission.
Telephone calls with our team and the related contact records are processed by CloudTalk s. r. o., headquartered in the Slovak Republic (EU). For voice routing and recording storage, CloudTalk may rely on sub-processors located outside the EEA, in particular Twilio Inc. and Amazon Web Services, Inc. with infrastructure in the United States. Those transfers take place under the EU-US Data Privacy Framework, Standard Contractual Clauses approved by the European Commission, and the supplementary measures described in the CloudTalk data processing agreement.
How Long Do We Retain Your Personal Data?
Your personal data is retained only for the strictly necessary period.
- Contact-form enquiries that do not lead to a client relationship are retained for up to 12 months from your last interaction with us, then deleted.
- Client account data, the contract, payments, and appointment records (without the reason for the visit) are retained for the duration of your client relationship and for 4 years after it ends, so we can defend any legal claims. This reflects the general three-year limitation period under Section 629(1) of Act No. 89/2012 Coll. (the Civil Code) plus a short buffer. Individual records may be retained for up to 10 years where the absolute objective limitation under Section 629(2) is relevant to a specific dispute. Accounting and tax documents that form part of this data, such as invoices and payment records, are kept for the statutory periods set out below where those are longer.
- Messages and notes about you in our CRM, which may contain health information, are retained for your membership and 30 days after it ends. During that time you can download your data; then we delete it.
- Health-related context you shared with us for navigation is deleted or anonymised within 30 days of (a) the navigation purpose ending, (b) withdrawal of your consent under Article 9(2)(a) GDPR, or (c) termination of your account, whichever is sooner. Where a specific legal claim is pending, the records needed for that claim are retained until the claim is finally resolved and for one year thereafter.
- Marketing-consent records and contact data used for marketing are retained for 3 years from your last interaction with our marketing emails, or until you withdraw your consent, whichever is sooner.
- Telephone call recordings are retained for 30 days from the call date and then deleted. Where a dispute, complaint, or legal proceeding is pending in relation to a specific call, the relevant recordings are retained until the matter is finally resolved and for one year thereafter.
- Records of unsubscribes and Article 21 objections are retained on two layers: (a) the active subscriber and unsubscribe record on MailerLite, our email service processor, under its own processor terms; and (b) in our own internal records, a minimal entry consisting of the sha256 hash of the lower-cased email address together with a timestamp, retained for as long as we operate any marketing list. Without this hashed entry we would not be able to reliably honour your preference if we later change email service provider.
- Records of consents given and withdrawn, including the exact wording you agreed to, and records of whom we shared data with and when, are retained for the duration of the relevant processing, for clients the membership, and for at most 3 years after it ends, so we can demonstrate compliance with Article 7(1) GDPR. They do not hold the full content of your health communications or call recordings.
- Audit and access logs are retained for 12 months. Security-incident and authentication logs are retained for up to 24 months, in line with our obligations under Articles 5(2) and 33 to 34 GDPR and applicable Czech cybersecurity legislation.
- Accounting documents and related accounting records are retained for 5 years from the end of the accounting period they relate to, or longer where Section 32 of Act No. 563/1991 Coll., on Accounting, requires it, for example for an unpaid receivable or a document used in proceedings.
- Tax documents under Act No. 235/2004 Coll., on Value Added Tax, are retained for 10 years from the end of the tax period in which the supply took place. Deleting other data after your membership ends does not shorten these statutory periods.
- Medical documentation is held by partner providers, not by OpenMedical, and is retained by them for the periods required by Decree No. 98/2012 Coll. and related legislation (typically 5 to 100 years depending on the type of record, or up to 10 years from the patient’s death).
- Cookies and technical data are retained in accordance with our Cookie Policy.
What happens when your client relationship ends
When you terminate your client relationship with OpenMedical, or we terminate it in line with our Terms of Service, the following applies. From the day your membership ends, we stop booking new appointments, coordinating your requests, and sharing data with clinics. For 30 days after it ends you can request or download your data; we will confirm the exact timing in writing.
After those 30 days we close the account and delete the messages and notes in our CRM and your health-related information, unless keeping them is necessary for a specific legal claim. The contract, payments, appointment records, consent records, and accounting and tax documents are kept separately, only for the periods set out above, and then deleted or anonymised. Copies of medical documentation held by partner providers must be requested directly from those providers under the rules of Section 65 of Act No. 372/2011 Coll.; we will, on request, help you identify the relevant partner.
Your Rights in Relation to Personal Data
As a data subject, you have a range of rights under the GDPR in relation to the data we hold about you for the membership and coordination service. You should provide accurate identification and contact data so we can deliver that service. Where you choose to share health-related context with us for navigation, you may withdraw your consent at any time. Rights you wish to exercise in relation to medical documentation held by a partner provider are exercised at that partner provider, under the rules described elsewhere in this policy.
Right of Access
You have the right to know what data about you we process, for what purpose, for how long, where it was obtained, and to whom it is transferred. Upon request, we will provide a copy of your processed personal data without undue delay. For repeated or excessive requests, we may charge a reasonable fee to cover administrative costs. Access to your medical documentation held by a partner provider is exercised at that partner provider under the rules of Section 65 of Act No. 372/2011 Coll.
Right to Rectification
If you believe any of your personal data is inaccurate or incomplete, you have the right to request correction or completion without undue delay.
Right to Restriction of Processing
You may request restriction of processing in specific cases, for example when you contest the accuracy of your data, when processing is unlawful but you prefer restriction over deletion, when we no longer need the data but you need it for legal claims, or when you have objected to processing and verification is pending.
Right to Object
You may object to processing based on our legitimate interests or carried out in the public interest. If you object, we will only continue processing where we can demonstrate compelling legitimate grounds or where processing is necessary for the establishment, exercise, or defence of legal claims. If you object to direct marketing, we will stop immediately. For processing based on a legal obligation, this right does not apply.
Right to Erasure ("Right to Be Forgotten")
You have the right to have your personal data erased in certain cases, particularly when we no longer need it or when you have withdrawn consent and there is no other legal basis for processing. This right does not apply where processing remains necessary to comply with our legal obligations, for archiving in the public interest, scientific research, or for the establishment, exercise, or defence of legal claims.
Right to Data Portability
Where processing is based on consent or on a contract and is carried out by automated means, you have the right to receive your data in a structured, commonly used, machine-readable format and to transmit it to another controller.
Right to Withdraw Consent
Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Right to Lodge a Complaint
You have the right to lodge a complaint with the Office for Personal Data Protection (www.uoou.cz) at any time if you believe your data is being processed unlawfully.
Automated Decision-Making and AI
OpenMedical does not use automated decision-making producing legal or similarly significant effects on you without human involvement. AI-assisted tools used within OpenMedical are limited to support functions and are subject to human oversight, as described in the section on AI-assisted tools above. Clinical decisions are made by clinicians at partner providers and are not produced by any AI system used by OpenMedical.
Security Measures
- Encryption of sensitive data in transit and at rest
- Strict role-based access control separating clients, support, coordinators, and administrators
- Logging and auditing of access to your account and uploaded documents, including downloads
- Identity verification appropriate to the membership and coordination service
- Separation of production and non-production environments
- Regular staff training and confidentiality obligations
- Vendor due diligence and written data processing agreements
- Incident response and breach notification procedures
How to Exercise Your Rights
For any matter relating to the processing of your personal data, including enquiries, exercise of rights, complaints, or other suggestions, you can contact our privacy contact point.
We will handle your request without undue delay and in any case within one month of receipt. In exceptional cases, particularly due to the complexity or volume of requests, we may extend this period by a further two months. You will be informed of any such extension and the reasons for it.
- Postal: OpenMedical s. r. o., Prosecká 876/89, Prosek, 190 00 Prague 9, Czech Republic
- By e-mail at: privacy@openmedical.cz
- By telephone at: +420 228 811 976 (9:00-15:00, calls only; no SMS)
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