DrAtlas

DrAtlas Privacy Policy

Version 28.09.2026 — revizia 2 · In force from 28.09.2026

This is Part V of the unified DrAtlas document. It explains what data we process, why, on what basis, with whom we share it, how long we keep it and what rights you have, under Regulation (EU) 2016/679 ("GDPR") and Romanian law. The rest of the document is in the Terms of Use, and the agreement with doctors in the Data Processing Agreement (DPA). This is a translation; the Romanian version prevails.

37. Controller and contact

ALTANET S.R.L., tax ID 15748710, J2003001373160, registered office Str. Amilcar Sandulescu 11 Bl. A32 Sc. 1 Ap. 13 Cod 200689 is the controller for managing accounts, running and securing the Platform, doctors' subscriptions, reviews and its own obligations.

Data contact: hello@medi-max.ro
The data protection officer (DPO) is being appointed; until then, data requests go to the address above.
A data protection impact assessment (DPIA) has been carried out for the processing of health data.

For medical records and patient care, the doctor/practice is the controller. ALTANET acts as a processor for hosting and running the tools used by the doctor, under Annex 1.

38. Data we process

Depending on the account and features, we process:

We do not receive or store the full card number or the CVC.

You can search for doctors and view their profiles without an account. In that case we create no profile: we only process what is needed to show you the results (your IP address, your search criteria and, if you allow it, your approximate location) and do not store them.

39. Sources of data

Data comes from the user, the representative, the doctor/practice, the device, the chosen sign-in provider (Google or Apple), Stripe for payment status and communications providers for delivery. Professional data may be checked in registers or with competent bodies.

40. Purposes and legal bases

PurposeMain legal basis
Account, sign-in and supportPerformance of the contract
Search and appointmentsPerformance of the contract
Sending messages/documentsPerformance of the contract; for medical content the relevant condition in Art. 9 GDPR also applies
Medical records and careSet by the doctor; usually Art. 9(2)(h) GDPR; ALTANET processes under instructions and Annex 1
Health data processed by ALTANET in the app (appointments, own documents, family members)Explicit consent — Art. 6(1)(a) and Art. 9(2)(a)
Verifying doctorsLegitimate interest and applicable obligations
Subscription, payments and invoicingContract and legal obligation
Security, fraud prevention and logsLegitimate interest and legal obligations
Reviews and moderationProviding the feature and legitimate interest; reviews must not include clinical details, and the name appears only as first name and initial
Account/appointment notificationsContract and legitimate interest, by type
MarketingWe do not currently send any; if we do, based on consent
Authorities and disputesLegal obligation and defence of rights

Consent can be withdrawn without affecting earlier processing. Withdrawing it may stop the feature that needs that data.

41. Recipients and providers

Data is shared only as far as needed with:

Current technical providers:

ProviderRoleDataWhere
ALTANET (own infrastructure)Hosting of servers, database, files, e-mailAll Platform dataRomania
Twilio Inc.Processor — SMS (codes, confirmations, reminders)Phone number, SMS textUSA
Expo (650 Industries, Inc.)Processor — push notification deliveryPush token, notification textUSA
Apple Inc. (APNs) / Google LLC (FCM)Push notification delivery on iOS / AndroidPush token, notification textUSA
Google LLC / Apple Inc.Sign-in, only if you choose itE-mail, name, identifierUSA
StripeDoctors' subscription payments (independent controller for payment data)Doctor's billing and payment dataEU (Ireland), with access from the USA
OpenStreetMap FoundationMaps and address searchIP address, search text (not account data)United Kingdom

The list is updated before a new provider is added; doctors are notified at least 30 days in advance (Annex 1, A6).

We do not sell data, use behavioural advertising, or third-party analytics or crash reporting, and we do not use medical content to train AI models.

42. Transfers outside the EEA

Platform data is stored in Romania. It leaves the European Economic Area only through the providers above that operate outside it:

Only the data strictly needed for the feature leaves through these providers (for example a phone number and the text of an SMS); medical records, documents and messages stay in Romania.

43. Cookies and similar technologies

DrAtlas does not use analytics, advertising or profiling cookies and does not use third-party crash reporting. We use only strictly necessary elements, which do not require consent:

ElementWherePurposeDuration
Session cookie (dratlas-session)Website and web panelKeeping the session and sign-inUntil sign-out or after 120 minutes of inactivity
XSRF-TOKENWebsite and web panelProtection against forged requestsAs long as the session
remember_web_*Web panel"Remember me", only if you tick itUntil sign-out
Secure storage on the phone (Keychain / Keystore)Mobile appSession, chosen language, events added to the calendarUntil sign-out or uninstall

If non-essential technologies are introduced, we will ask for the corresponding choice before activating them.

44. Notifications and confidentiality

E-mail, SMS and push carry only the minimum information needed. Medical content is accessed after signing in to the Platform and is not included by default in lock-screen notifications: by default, push notifications only say "You have a new notification", and details can be turned on in the profile.

Users can configure the available channels. Mandatory security or contractual messages may be sent regardless of preferences.

45. Retention periods

DataPeriod
Account and profileLife of the account; then deletion or anonymisation from active systems (section 52)
Unused accountsAfter 3 years without any sign-in you receive a warning e-mail; if you do not sign in within 30 days, the account is deleted
Future appointmentsUntil they take place or are cancelled; on account closure they are cancelled and participants informed
Appointment history in the PlatformAs long as the account exists; on deletion it is anonymised, separately from the records the doctor keeps by law
Administrative messagesAs long as the account and conversation exist; deleted when the account is deleted
Clinical messages/medical recordsPeriod set by the doctor and the law; ALTANET only under Annex 1. After a doctor's account closes: 90 days for handover, then deletion
Personal documentsUntil you delete them or the account is deleted; the doctor's copy is separate
Professional verification documentsFor the life of the doctor account; deleted when it closes
Anti-abuse identifier derived from the phone3 years from the use of the free trial, to prevent its repeated use; then deleted automatically
Invoices/supporting documentsUsually 5 years, calculated under accounting law, with applicable exceptions
Security logs12 months (see below)
Reports/challengesWhile being resolved and at most 12 months afterwards, if necessary
Verification codesExpire after 15 minutes; deleted when used, when a new code is issued or after expiry
E-mail/SMS delivery records12 months; also deleted when the account is deleted
Push tokenUntil revoked, sign-out or account deletion
BackupsAt most 30 days from deletion in the active system (daily backup, overwritten after 30 days)
Proof of acceptance and paymentsLife of the contract and the period needed to defend legal rights/obligations

Backups are isolated copies used to restore the service after an incident. Data deleted from the active system may remain temporarily in a backup until it is overwritten, without being used; if a backup is restored, deletions made in the meantime are re-applied before the service goes back online.

Security logs record admin panel sign-ins (successful and failed, with IP and browser), temporary lockouts after wrong passwords, administrative actions and e-mail/SMS delivery. Only DrAtlas administrators can see them, and they are extracted only to investigate incidents or at the lawful request of an authority. They are kept for 12 months.

46. Security

We apply measures appropriate to the risk, including encryption in transit (HTTPS), private storage of documents reachable through temporary links, role-based access, hashed passwords, temporary account lockout after wrong passwords, two-factor authentication for the admin panel, logging of administrative access, checking the type and size of uploaded files, backups and an incident procedure.

Messages are intended only for the participants, but we do not describe the service as end-to-end encrypted without a technical audit (Terms, section 32).

47. Automated decisions

We do not make automated diagnoses, recommendations or medical decisions. There are no automated medical questionnaires.

The system may detect failed payments, spam, security risks or repeated cancellations. A limit on bookings after repeated cancellations or no-shows is applied only after human review; any significant limitation can be challenged.

48. Your rights

Under the GDPR you have the right to information, access, rectification, erasure, restriction, objection, portability, withdrawal of consent and protection against certain automated decisions.

You can correct most data directly in the app and download a copy of your data in Profile → Download my data. Other requests go to hello@medi-max.ro. We may verify identity proportionately. We usually reply within one month.

For records controlled by the doctor, the request is addressed to the doctor/practice. If we receive it, we forward it securely and assist under Annex 1.

You can complain to ANSPDCP, dataprotection.ro, and go to court.

49. Minors

The account is intended for persons aged at least 18. A parent/representative may manage a minor's appointment and must provide only the data needed. The doctor sets the conditions for consent to the medical act.

50. Impact assessment and data protection officer

Given the nature, scale and systematic character of processing health data, messages and documents, ALTANET assessed the need for a data protection impact assessment and carried it out before launch. The data protection officer is being appointed; their contact details will be published here.