Privacy policy

1 Who we are

The MedKeep app is operated, and your data processed, by AI World Hub SRL – a company registered in the Republic of Moldova, IDNO 1026023041256, address: MD-2001, Chișinău, 49 Tighina St.. The company decides why and how your data is processed and is responsible for it as the controller.

Moldova is not part of the European Union, so under Article 27 of the GDPR we have appointed a representative in the EU and the UK – the company DataRep.

This policy describes the data processed by the mobile app. The medkeep.ai website has its own policy: it covers the data you leave on the site before registering.

2 What data we collect

We collect only what the app needs to work, and we do not buy data about you from third parties. The data falls into seven groups:

Doctors’ contacts and the emergency contact are other people’s data. By entering them you confirm that you are entitled to share them: that is a condition of the Terms of use.

3 Why and on what basis

Account data and technical data are needed so that you can sign in and the service can run securely.

Health data is a special category of data. We process it only on the basis of your explicit consent, not “legitimate interest” and not “performance of a contract”. The profile, treatment, notes, reminders and contacts are covered by the consent to the processing of health data. Files and the data recognised from them also need the consent to file storage, and sending text and files to the assistant needs the consent to the assistant.

4 Consents and their withdrawal

At registration you see one screen with four lines, none of them ticked in advance:

• the Terms of use and this policy – required;
• the processing of health data – required;
• the storage of medical files – optional; without it uploading files is unavailable;
• the Nomi assistant – optional; without it the chat and document recognition are unavailable.

The consents you did not give at registration will be requested by the app when they are first needed. For every consent we keep the version of the text, the language, the time, the device and the IP address – this confirms that the consent was given.

The consents to files and to the assistant can be withdrawn at any time under “Settings → Privacy and consents”. The required consents cannot be withdrawn separately: you exercise the right to withdraw them by deleting the account.

After the consent to file storage is withdrawn, uploading new files stops at once. Files already uploaded stay available to you for another 30 days – only for viewing, downloading and export: we do not recognise or process them. This period is agreed in advance so that you have time to save the files or change your mind. During it the consent can be restored without losing data, or the files can be deleted at once. After 30 days the files and everything connected to them are deleted for good, while the profile, courses and contacts remain. We will remind you of the deadline by email.

5 The Nomi assistant

Nomi helps fill in the profile, add a course from what you tell it, recognise a document and find data in your test results. For this, your text – and, for recognition, the contents of the file – is sent to an external language model provider. Its name, the country of processing and the retention period for requests are shown on the consent screen before you give it.

We send requests with an instruction not to store them. Nomi does not diagnose and does not interpret results: it only finds and extracts your data, and everything extracted is saved only after your confirmation.

Withdrawing the consent to the assistant stops new requests at once. The data you have already confirmed stays yours, and requests already sent to the provider cannot be recalled.

6 How we store data

Data and files are stored in the Amazon Web Services cloud, in the Frankfurt region, Germany. The files are encrypted, there are no public or permanent links to them, and the file name in storage contains none of your data.

A new file is checked for its type and for malicious content and is unavailable until the check is finished. The preview, the recognised data and the comments are protected in the same way as the file itself. MedKeep staff have no standing access to the contents of files.

A copy of every file is also kept in the app’s protected storage on your phone so that files open without an internet connection. It is not visible to other apps and is erased when you delete the document or the account, free up space or sign out with deletion of data from the device, and also when the period after withdrawal of consent ends.

7 Notifications and emails

Dose reminders arrive as push notifications. By default they show the name of the medicine and the dose – including on a locked screen and on a connected watch. The details can be hidden in the reminder settings. Apart from the text, a notification contains no medical information.

The device time zone is needed so that reminders arrive on time. By email we send only service messages: registration confirmation, password recovery, messages about consents and about account deletion. You can only stop them by deleting the account.

8 Whom we share data with

We do not sell data and do not pass it to advertisers. Part of the work is done by services we entrust it to:

The contents of medical files are received only by AWS storage, where they sit encrypted, and – with your separate consent – by the model provider. Notification and model providers may process data outside the EU, for example in the USA. Such a transfer only takes place on grounds permitted by the GDPR.

9 Retention periods

Consent and security logs outlive the deletion of an account in anonymised form: they confirm that the processing was lawful and protect access.

10 Deleting data and the account

Deletion is real: data is deleted, not hidden. A deleted document becomes unavailable at once, then the file, the preview, the recognised data, the comments, the linked reminder and the copy on the phone are deleted. A course created from the document remains.

The account is deleted in the settings – with a double confirmation and a password. Access closes at once, the account can be restored for 30 days, and after that the data and the files are deleted beyond recovery. In the email about the final deletion you receive a case number: with it you can later request information about the processing of your data.

11 Your rights

• Access and correction – right in the app.
• Deletion – deleting a document or the account in the app.
• Withdrawal of consent – the consents to files and to the assistant in the settings, the rest by deleting the account.
• Portability – export of all data and files as one archive, by a link from the settings.
• Objection and other requests – by writing to the address in the “Contacts” section.

We answer requests about personal data within 30 days, as the GDPR requires. You also have the right to lodge a complaint with a data protection supervisory authority.

12 Security

Files and traffic are encrypted. Every request verifies that the data belongs to you, sessions can be revoked, and the technical logs contain no medical data. Sensitive actions are written to a log and the database is backed up daily.

If an incident affecting your data occurs, we will inform you about it.

13 Age

The app is intended for people aged 18 and over. If we learn that an account belongs to someone younger, the account will be deleted.

MedKeep is not a covered entity under the US HIPAA law. A launch in the USA is not part of the beta.

14 Data from the website

If you signed up for the beta on medkeep.ai and registered in the app with the same email, the sign-up and the survey answers are linked to your account. The consent to beta emails given on the website is not carried over into the app.

15 Changes to the policy

Every version of the policy is kept and available at a permanent address. A new version takes effect on the date of publication.

If the changes are significant, the app will ask you to accept the policy again, and until then access to the app will be limited. We will also write to you by email about what has changed. If the changes are editorial, a notice in the app is enough.

16 Contacts

With questions about data and requests about your rights write to privacy@medkeep.ai. Postal address: AI World Hub SRL, MD-2001, Chișinău, 49 Tighina St., Republic of Moldova.