DrOnline Privacy Policy

Introduction

Welcome to DrOnline’s privacy policy (the “Policy”).

DrOnline respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you use our website and/or our mobile application (regardless of where you access them from) and tell you about your privacy rights and how the law protects you.

This Policy applies to personal data collected through our website, our mobile application (“App”), and related digital services (together, the “Services”).

1. Important information and who we are

Purpose of this Policy

This Policy aims to give you information on how DrOnline collects and processes your personal data through your use of our website and our App, including any data you may provide through the website and our App when you avail of our services.

Our website and App are not intended for children to use and we do not knowingly collect data relating to children. However, in situations where a child uses our services (for example, during a medical consultation for a minor), any personal data related to that child is provided by their parent or legal guardian. This means that the guardian or parent is the one who supplies the child’s information on their behalf, in accordance with this Policy.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

DrOnline Inc is the controller and responsible for your personal data when you use our website, App, and related platform services for the purposes of providing and operating its technology platform. (collectively referred to as “we”, “us” or “our” in this Policy).

The registered address of Dr Online Inc is 8 The Green STE R, in the City of Dover, County of Kent, Delaware 19901.

We have appointed a Data Protection Officer (“DPO”) and EU Representative who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact either the EU Representative or DPO using the details set out below.

Contact details

If you have any questions about this Policy or our privacy practices, please contact our DPO. For exercising any of your data protection rights or for any queries relating to how your data is processed, please contact the DPO (listed below). Supervisory authorities should contact the EU Representative (see below):

DPO Email address: dpo@dronline.com

DPO Name: Priscila Ganga

EU Representative email address: ireland@dronline.com

EU Representative name: Rúben Silva

You have the right to make a complaint at any time to the Data Protection Commission (“DPC”), the Irish regulator for data protection issues at https://www.dataprotection.ie/. We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

Changes to the Policy and your duty to inform us of changes

We keep our Policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website and App may include links to third-party websites, plug-ins, software development kits (SDKs namely Zoom Meeting SDK), and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, email address, date of birth, phone number or similar identifier.
• Medical Data (Special Category Data) this can include details about your medical history, current health conditions, medications, allergies, and records of consultations, diagnoses, or treatments. Such data is collected, stored, and used to allow doctors to provide healthcare services, and to allow us to manage appointments and comply with applicable medical regulations. We treat this information with the highest confidentiality and in accordance with data protection laws.
• Contact Data includes billing address, email address and telephone number.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, device type, operating system and app version, language settings, browser plug-in types and versions, mobile network information, and other technology on the devices you use to access our website or mobile application. Where you participate in video consultations, audio and video data may be processed in real time to enable communication between you and your healthcare professional.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for or a variety of purposes, including to analyse the use of our websites and services, improve and develop our products and services, monitor service quality and performance, understand patient and user trends, produce internal management reports, measure the effectiveness of marketing activities, support business planning and decision-making, and comply with legal and regulatory reporting requirements. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For

example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Medical and Financial Data when, for example, you:
  
  • Apply for our Services online, such as when you book and pay for an appointment for an online consultation with a doctor.
  • Register for and use our services via the App.
  • Correspond with us by post, phone, email or otherwise.
  • Give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website or App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy at https://dronline.ie/cookie-policy/ for further details. In the App, this data may be collected through SDKs and similar technologies.
  
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • Technical Data from analytics providers and advertising networks.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Video Consultations and Audio/Video Data. Dr.Online provides video consultation functionality to enable communication between patients and independent healthcare professionals.

To facilitate video consultations, Dr.Online uses secure third-party video technology providers, such as Zoom Video Communications, Inc.

During a video consultation, audio, video, and related technical data (such as connection metadata) are processed solely for the purpose of enabling real-time communication between the patient and the healthcare professional.

Dr.Online does not record video consultations. Audio and video data are processed in real time solely to enable communication and are not retained by Dr.Online after the consultation ends.

These video technology providers act as data processors on behalf of Dr.Online and process personal data only in accordance with Dr.Online’s instructions and applicable data protection laws.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where it is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of an individual, medical diagnosis, the provision of healthcare or treatment or the management of health services.
• Where it is necessary for us to comply with a legal obligation to which we are subject.

5. Purposes for Which We Use Your Personal Data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

6. Marketing, Communications Preferences and Notifications

Dr.Online may send communications necessary to provide and operate its platform services, as well as communications relating to user preferences and consent.

These communications may include:

Service and Operational Communications

These are necessary for the provision of platform services and do not require marketing consent. These may include:

• appointment confirmations and reminders
• service updates relating to consultations
• account security notifications
• operational or technical service notifications

These communications may be delivered via:

• email
• mobile application push notifications
• SMS messages (where applicable)

These communications are necessary to facilitate healthcare consultations and ensure proper operation of the platform.

Promotional and Informational Communications

Where you have provided consent, Dr.Online may send promotional or informational communications relating to platform services.

These may include:

• informational emails about platform services
• promotional emails relating to new features or services
• informational push notifications

Promotional communications are sent only where permitted by applicable law or where you have provided consent.

You may withdraw your consent at any time by:

• using the unsubscribe link included in email communications
• adjusting your notification preferences in the mobile application
  
• adjusting your device notification settings

Push Notifications

Push notifications may be used to provide:

• consultation reminders
• service-related notifications
• account or security notifications

Promotional push notifications will only be sent where you have provided consent.

You can manage or disable push notifications at any time through your device or application settings.

No In-App Advertising

Dr.Online does not use in-app advertising or in-app marketing messages from third parties.

Promotional communications are sent only through permitted communication channels and in accordance with applicable data protection laws.

7. Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

8. Disclosures of Your Personal Data

We only disclose personal data where necessary for the purposes described in this Policy and in line with our legal, clinical, and contractual obligations. Disclosures occur under the following categories:

Clinical and Care-Related Disclosures

We may share your personal data, including relevant clinical information, with:

• The doctor conducting your online consultation, to enable safe clinical assessment, treatment, and follow-up.
• Other healthcare professionals involved in your care.

All clinical disclosures are handled under professional duties of confidentiality. Where appropriate, we establish Data Sharing Agreements with clinical partners to ensure that the data remains protected at all times.

Operational and Service-Provider Disclosures

We may share your Personal Data with trusted third-party service providers who perform functions on our behalf. These include, but are not limited to:

• IT and platform providers – Healthie; Siteground; WordPress.com
• Communication systems – Slack; Talkdesk
• Video Consultations – Zoom
• Payments and billing processors – Stripe; Paypal; Klarna; prima.ie

These providers act strictly under our instructions and are not permitted to use your personal data for their own purposes. Each provider is required to implement appropriate technical and organisational measures that meet GDPR standards, formalised in a written contract with Dr.Online.

Legal and Regulatory Disclosures

We may disclose your personal data to competent authorities, regulators, or law-enforcement bodies where required by law or regulation, or where necessary to defend legal claims or comply with statutory obligations.

Corporate Transactions

If we sell, transfer, or merge part of our business or asset, or if we acquire or merge with another entity, personal data may be shared with the new owner or counterparty. Any such recipient will be required to use your personal data only as permitted in this Policy.

9. International Transfers

International Data Transfers

All patient data is stored within the European Union and the United States, using secure hosting environments that operate under strict technical and organisational controls.

When personal data is stored or processed in the United States, we ensure that it is protected with safeguards that provide an equivalent level of protection to that required under the GDPR, including:

• Adequacy mechanisms such as the EU–U.S. Data Privacy Framework or other EU-recognised transfer tools;
• Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring that U.S.-based processors offer protections consistent with EU standards;
• Additional technical and organisational safeguards, including encryption, access controls, continuous monitoring, and data-minimisation practices.

Where data is stored within the EU, it remains fully protected under EU data protection law and is handled exclusively within GDPR-compliant infrastructure.

10. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, including to provide medical services or advice, and to satisfy any legal, regulatory, tax, accounting, or reporting requirements. Personal data may be retained for a longer period if there is a complaint, a reasonable prospect of litigation, or other legal obligations.

In determining the appropriate retention period, we consider the nature, amount, and sensitivity of the data, the potential risks of unauthorized use or disclosure, the purposes for which the data is processed, whether those purposes can be achieved by other means, and applicable legal or regulatory requirements.

Patient-related data will generally be retained for as long as necessary to provide the services or advice for which it was collected and thereafter in accordance with applicable legal, regulatory, and professional obligations.

Unless a longer retention period is required by law or is necessary for the establishment, exercise, or defence of legal claims, medical records will typically be retained as follows:

Adult healthcare records: eight (8) years after the patient’s last treatment or death.

Children’s and young people’s records: until the patient’s 25th birthday, or 26th birthday where the patient was aged 17 at the conclusion of treatment, or eight (8) years after the patient’s death, whichever is later.

Records relating to patients with a mental disorder: twenty (20) years after the last treatment or eight (8) years after the patient’s death, whichever is later.

Records may be retained for longer periods where their contents remain relevant to adult conditions, have genetic implications, or where retention is required to comply with legal, accounting, or regulatory obligations.

Data collected for marketing purposes will be retained only while you have provided your consent.

12. Your Legal Rights

You have the right to:

• Access your data.
• Request correction of inaccuracies.
• Request erasure of data where applicable.
• Object to processing for certain purposes.
• Request restriction of processing.
• Request transfer of your data to another party.

You will not have to pay a fee to exercise your rights unless your request is unfounded or excessive.

13. Updates

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  
• Object to processing of your personal data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.