الخصوصية ومعالجة البيانات

Last updated: 19 September 2026.

This notice explains, in line with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and the equivalent UK GDPR, Swiss FADP and UAE PDPL obligations referenced in our compliance plan, what personal data GINKGO collects through myginkgo.eu, why, on what legal basis, and what rights you have over it. GINKGO acts as a private advisor and does not itself provide medical treatment; clinical care remains with the doctors and partner clinics you are referred to.

Who is responsible for your data

The data controller for myginkgo.eu is [legal entity name, registration number and registered address to be inserted once the operating company is registered]. Until then, all privacy questions and requests can be sent to care@myginkgo.eu.

What we collect

Account data: your email address and a securely hashed password — we never store your password in plain text. Consultation data: the direction you are enquiring about, your name, phone number and the notes you enter when arranging a consultation, together with the confirmed date, time and Google Meet link once a consultation is booked. Technical and security data: the IP address recorded when you give consent or log in, and a minimal audit log of account events (registration, verification, login) kept to protect your account and meet accountability obligations under Article 5(2) GDPR. Cookies are described in our separate Cookie notice.

Health-related information

Notes you choose to share when arranging a consultation may reveal information about your health, which GDPR treats as a special category of data (Article 9). We only process this information with your explicit consent, given when you tick the consent box before registering, and only to pass your enquiry to the relevant doctor or partner clinic. We do not use it for any other purpose, and we do not sell or share it for marketing.

Why we process your data

To create and secure your account and verify your email address; to arrange, confirm, remind you of and follow up on consultations; to keep the minimal records needed to demonstrate that you gave consent and when; and to meet legal and security obligations, including responding to lawful requests from supervisory authorities.

Legal basis

We rely on your consent (Article 6(1)(a), and Article 9(2)(a) for anything you share about your health) for account registration and for processing health-related notes; on performance of a contract (Article 6(1)(b)) to arrange and manage a consultation you request; and on our legitimate interest (Article 6(1)(f)) to keep the security and audit logs that protect your account. You can withdraw consent at any time by writing to care@myginkgo.eu, without affecting the lawfulness of processing carried out before withdrawal.

Who sees your data

The doctor or partner clinic you are matched with, so your consultation can take place. Service providers acting on our instructions as data processors: Google (Google Calendar and Google Meet, to schedule and host your consultation) and Resend (email delivery service, to send account and booking emails from support@myginkgo.eu) and our hosting provider, which stores the application and database. We do not sell your personal data, and we do not share it with advertisers.

International transfers

Google provides its services under the EU Standard Contractual Clauses and its own data-processing terms, which apply if your data is processed outside the European Economic Area. If you are referred to a partner clinic outside the EEA, UK, Switzerland or United Arab Emirates, we will tell you before your data is shared and rely on an appropriate safeguard, such as Standard Contractual Clauses.

How long we keep it

Account data is kept for as long as your account is active. If you never verify your email, unverified sign-up data is deleted automatically. Consultation notes and booking records are kept for as long as needed to provide the service and meet our accountability obligations, after which they are deleted or anonymised. Consent and audit-log records are kept for [retention period to be confirmed with counsel] to demonstrate compliance. You can ask us to delete your account and data at any time, subject to the exceptions described under Your rights.

Your rights

Under Articles 15 to 22 GDPR you have the right to access the personal data we hold about you, to have inaccurate data corrected, to ask us to erase it, to restrict or object to certain processing, to receive your data in a portable format, and not to be subject to decisions based solely on automated processing — we do not use automated decision-making or profiling. To exercise any of these rights, write to care@myginkgo.eu; we will respond within one month, as required by Article 12(3) GDPR.

Complaints

If you believe your data has not been handled correctly, you can contact us first at care@myginkgo.eu, or lodge a complaint directly with your local data protection supervisory authority — for example the Slovak Office for Personal Data Protection (Úrad na ochranu osobných údajov SR, dataprotection.gov.sk) if you are in Slovakia, or the supervisory authority of your own country.

Cookies

We use only the essential session cookie needed to keep you signed in. See our separate Cookie notice for details.

This notice describes our data practices in good faith and in line with GDPR requirements. Final wording is pending review and sign-off by qualified legal counsel before GINKGO's public launch, together with the equivalent UK GDPR, Swiss FADP and UAE PDPL notices referenced in our compliance plan (see tz-myginkgo-v1.md, раздел 8).