Unomed® privacy policy

1. Controller

Unomed AG
Tramstrasse 9
8050 Zurich
Email: info@unomed.ch

This privacy policy applies to the use of our website, web app and mobile app (“services”). It sets out which personal data we collect, how we process it and which rights you have.

2. Scope

This policy applies to:

• visitors to our website
• users of the Unomed web app and mobile app, including medical professionals, organisation administrators, patients, legal entities and other contacted persons.

3. Definitions

Personal data: any information relating to an identified or identifiable person.

Special categories of personal data: health data and other particularly sensitive data within the meaning of the Swiss FADP (DSG) and the GDPR.

Processing: any operation involving personal data, such as collection, storage, use or erasure.

4. Collection of access data and log files

When you call up our website, technical information is collected automatically, including:

• IP address
• browser type and version
• operating system
• referrer URL
• date and time of access

This data is processed to ensure technical operation, for IT security and to optimise our offering. It is not evaluated on a personal basis.

5. Cookies and similar technologies

We use cookies and similar technologies in order to:

• ensure the technical operation of the website
• store settings (e.g. language, login status)
• enable certain functions
• analyse use of the website (e.g. Google Analytics, Matomo)

Non-essential cookies (statistics, marketing) are only set after your express consent, which you can give through our cookie banner. Essential cookies include the security and performance cookies of our CDN/WAF (e.g. cf_clearance, _cfuvid). These are required to operate and protect the website and are set without consent.

Note: you can withdraw or adjust your consent at any time through the “Cookie settings” link on our website.

6. Embedded content and third-party services

Our website may embed third-party content or functions (e.g. maps, fonts). These are only loaded if you have consented beforehand. When such content is retrieved, technical information (including your IP address) may be transmitted to the respective provider.

7. Data collection and processing

7.1 Types of data processed

• contact data (name, email address, telephone number)
• user account data (login, verification status, date of birth, GLN and ZSR number where available, professional title, language skills, nationality, gender, place of work)
• communication content (text, files, images, audio; end-to-end encrypted, except for technical metadata)
• chat metadata (e.g. sender, recipient, timestamp)
• uploaded files (e.g. PDFs, DICOM images)
• health and patient data (only where provided by the user)
• audio and voice recordings (only during transcription; not stored after the session ends)
• log data (IP address, technical logs)
• push notification tokens
• camera and storage access (when the corresponding functions are used)
• no collection of location data (despite the permission declared in iOS; not used in the code)

7.2 Sources of the data

• direct entry by users
• invitation by other users
• transmission by third parties (e.g. in the course of patient communication)

When invitation links are shared through third-party platforms (e.g. email, messenger), the privacy terms of the respective provider apply; Unomed keeps invitations data-minimal (no health content).

8. Purposes of processing

We process data exclusively for:

• secure medical communication and collaboration
• patient communication without the need for an app or an account (e.g. via an email or SMS link)
• obtaining and managing second opinions (including patient upload via web link or upload form)
• documentation and speech-to-text transcription (without storing the audio content; no use for model training or improvement)
• providing a medical directory (for verified members only)
• storing medical files (including DICOM) in secure cloud storage
• sending notifications (push, email, SMS)
• verifying user identities (including liveness check)
• operation, maintenance and security of the services

9. Processing on behalf of healthcare providers

If you use our services in the course of treatment by a physician or another medical professional, we process your data exclusively on behalf of that healthcare provider, as their auxiliary person within the meaning of Art. 321 of the Swiss Criminal Code and Art. 9 FADP (DSG). Under data protection law the medical professional remains the controller and is responsible for the lawfulness of the processing and for obtaining the necessary consent from patients.

Retention obligations and erasure periods are set by the medical professional or organisation; Unomed processes the data exclusively on their instructions in accordance with the contractual arrangements (data processing agreement).

10. Legal bases

• Art. 31 para. 2 lit. a FADP (DSG) / Art. 6 para. 1 lit. b GDPR: performance of a contract
• Art. 31 para. 2 lit. b FADP (DSG) / Art. 6 para. 1 lit. c GDPR: compliance with legal obligations
• Art. 31 para. 1 FADP (DSG) / Art. 6 para. 1 lit. f GDPR: safeguarding legitimate interests
• Art. 6 FADP (DSG) / Art. 6 para. 1 lit. a GDPR: consent
• Art. 9 para. 2 lit. h GDPR: processing of special categories (health data) for healthcare purposes

11. Storage and erasure

• Data is stored only for as long as it is required for the respective purpose.
• Where Unomed processes health and patient data on behalf of a medical professional or organisation, that professional or organisation determines the retention period and erasure as the controller under data protection law.
• Statutory archiving and retention obligations (frequently 10 to 30 years, depending on the applicable law and the healthcare provider) lie with the customer or healthcare provider; Unomed assumes no obligation to archive long term unless expressly agreed in writing.

12. Disclosure of data

Personal data is only disclosed:

• to processors (e.g. hosting, storage, delivery services, AI processing)
• on the basis of legal obligations
• where we are the controller ourselves, with the express consent of the data subject

Where we act on behalf of a medical professional, their statutory authority or the consent they have obtained for involving auxiliary persons applies.

We use only carefully selected service providers who are contractually bound to confidentiality and secure data processing in accordance with the FADP (DSG) and the GDPR.

A current list of all processors can be requested from us at any time.

13. Processors (overview by function)

• hosting & database operation (server location Switzerland)
• cloud storage for files and DICOM (server location Switzerland)
• identity and liveness check (processing in the EU (Ireland), storage in Switzerland)
• speech recognition (processing in the EU (Denmark), no storage, no model training)
• LLM-supported processing (server location Switzerland, locally operated model, no model training)
• email delivery (server location Switzerland)
• SMS delivery (server location Switzerland)

14. Security

• end-to-end encryption for chats and AI processing
• encryption in transit and at rest for all stored data
• access restrictions based on roles and verification
• no disclosure or sale of data to third parties for marketing purposes

15. Mobile-app-specific information

• permissions: microphone (transcription), camera (file and image upload), storage access
• no active location tracking
• push notifications via Firebase Cloud Messaging (messaging token only, no analytics or crashlytics)
• no analytics or tracking services in the app; only technical error messages at API and network level

16. Rights of data subjects

You have the right to:

• information
• rectification
• erasure
• restriction of processing
• data portability
• withdrawal of consent given
• lodge a complaint with the supervisory authority

17. Changes to this privacy policy

We reserve the right to amend this privacy policy at any time. The version in force at any given time is available in our services.

18. Contact

Data protection officer:
Clemens Bürli, Unomed AG
Email: support@unomed.ch