Who we are

Our website address is: https://www.doctormedlink.com

Introduction

E-lite Mode M.M. Ltd (“E-lite”, “DoctorMedLink”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, disclose and otherwise process personal data when you visit, access or use the DoctorMedLink website and platform (the “Platform”), whether you simply browse the Platform, search for doctors or healthcare services, create an account, use the services available through the Platform, register as a doctor or specialist, or otherwise interact with DoctorMedLink.

For the purposes of Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”) and applicable Cyprus data protection legislation, E-lite Mode M.M. Ltd is the data controller in respect of the personal data described in this Privacy Policy, except where otherwise stated.

The Platform is intended for different categories of individuals. These include visitors who access or browse DoctorMedLink without registering (“Visitors”); individuals who use DoctorMedLink to search for and interact with doctors, specialists and healthcare services (“Service Users”); and doctors, specialists and other healthcare professionals who register to create and manage professional listings and make their services available through the Platform (“Healthcare Professionals”).

References to “you” or “your” in this Privacy Policy apply to any individual whose personal data is processed through the Platform, as applicable.

Who We Are and How to Contact Us

E-lite Mode M.M. Ltd operates the DoctorMedLink Platform and is responsible for the processing of personal data described in this Privacy Policy.

Our contact details are:

Company: E-lite Mode M.M. Ltd
Platform: DoctorMedLink
Registered Address: Agias Sophias, 65, 3065, Limassol, Cyprus
General Contact Email: info@doctormedlink.com
Telephone: +357 96384096
Data Protection Officer: Ismini Dritsa
DPO / Data Protection Contact: +357 22 260032

If you have any questions about this Privacy Policy, the way in which we process your personal data or wish to exercise any of your data protection rights, you may contact us or our Data Protection Officer using the details above.

Definitions

For the purposes of this Privacy Policy:

“Personal Data” means any information relating to an identified or identifiable natural person.

“Processing” means any operation or set of operations performed on Personal Data, whether or not by automated means, including its collection, recording, organisation, storage, use, disclosure, alteration, retrieval or deletion.

“Visitor” means an individual who accesses or browses DoctorMedLink without necessarily registering for an account.

“Service User” means an individual who uses DoctorMedLink to search for and interact with doctors, specialists and healthcare services.

“Healthcare Professional” means a doctor, specialist or other healthcare professional who registers with DoctorMedLink to create and manage a professional listing and make their services available through the Platform.

“Special Categories of Personal Data” means categories of Personal Data afforded additional protection under Article 9 GDPR, including data concerning health.

Personal Data We Collect

The personal data we collect depends on how you interact with DoctorMedLink and which Platform functionality you choose to use.

Visitors and Platform Usage

When you access or browse DoctorMedLink, we may process technical and usage information generated through your interaction with the Platform. This may include your IP address, browser type and version, device information, operating system, session information, cookie identifiers and preferences, security information and information about how you access and use the Platform.

Where you choose to enable location functionality, location information may also be processed to provide geographically relevant search results.

Service Users

Where you register as a Service User, we may process the following Personal Data, depending on the information you provide and the functionality you use:

• • first name and last name; 

• • username and display name; 

• • email address and account credentials; 

• • telephone number; 

• • profile photograph; 

• • address, city, postal code, state and country; 

• • information provided within your “About” section; 

• • social media profile links, where voluntarily provided; 

• • booking information; 

• • saved Healthcare Professional profiles; and 

• • communications exchanged through the Platform. 

Certain information is optional and is only processed where you choose to provide it.

Healthcare Professionals

Where you register as a Healthcare Professional and create a professional listing, we may process:

• • name and account information; 

• • specialty and professional category; 

• • professional biography and description; 

• • qualifications and professional certification documentation; 

• • practice, clinic or hospital affiliation; 

• • practice address and location; 

• • telephone and other professional contact information; 

• • website information; 

• • working hours and availability; 

• • languages spoken; 

• • GESY-related information, where applicable; 

• • services offered; 

• • photographs and profile images; 

• • social media links; 

• • FAQs and keywords; and 

• • other information voluntarily submitted as part of the professional listing. 

Information provided for inclusion in a Healthcare Professional’s listing may be made publicly available through DoctorMedLink so that Visitors and Service Users can identify and contact the Healthcare Professional. Professional certification documentation submitted for verification purposes is not intended to be publicly displayed.

Third-Party Sign-In

DoctorMedLink allows users to create an account or sign in using supported third-party authentication services.

Where you choose to register or sign in using Google, DoctorMedLink may receive your first name, last name, email address and profile picture from your Google account.

Use of third-party authentication is voluntary where an alternative registration method is available.

Location Information

DoctorMedLink provides location-based search functionality to assist Visitors and Service Users in identifying Healthcare Professionals and healthcare services based on geographical location.

Where you choose to allow access to your location through your browser or device, location information may be processed through mapping functionality to provide geographically relevant search results.

Location access is subject to your browser or device permissions. You may refuse or withdraw location access through your browser or device settings. Where available, you may instead manually select or enter a preferred location.

DoctorMedLink does not intend to retain your device location as part of your user profile.

Bookings

Where a Service User makes or manages a booking through DoctorMedLink, we process information necessary to provide the relevant functionality, including the date of the booking and the Healthcare Professional with whom the booking has been made.

Saved Healthcare Professionals

Where a Service User chooses to save a Healthcare Professional, DoctorMedLink retains the relevant Healthcare Professional profile reference so that it can subsequently be accessed through the “Saved” section of the Service User’s account.

Communications

Where Service Users and Healthcare Professionals communicate using the Platform’s Inbox or other communication functionality, the messages exchanged are processed and stored within DoctorMedLink in order to provide the communication functionality.

The content of communications is determined by the individuals using the Platform and may, depending on the information communicated, include personal data concerning health or other sensitive information.

Payments and Sponsored Listings

Healthcare Professionals may purchase sponsored or promoted listing services through DoctorMedLink.

Where a paid service is purchased, payment processing is facilitated through external payment service providers. DoctorMedLink may receive and retain transaction information necessary to confirm and administer the relevant purchase and comply with applicable accounting or legal requirements.

Payment information processed directly by an external payment service provider is subject to the relevant provider’s privacy practices.

How We Collect Personal Data

We collect personal data directly from you when you register for an account, complete or update your profile, create or manage a Healthcare Professional listing, make or manage a booking, save a Healthcare Professional, communicate through the Platform, purchase a service, contact us or otherwise provide information to DoctorMedLink.

We also collect certain information automatically when you access and use the Platform through cookies, server logs, session technologies, security tools and similar technologies.

Where you choose to use third-party authentication or integrated third-party functionality, we may receive information from the relevant provider in accordance with your interaction with that service and the permissions associated with it.

How and Why We Use Your Personal Data

We only process Personal Data where we have a lawful basis for doing so. The lawful basis applicable to the processing depends on the purpose for which the Personal Data is processed and the circumstances of the relevant processing activity.

We may process your Personal Data for the following purposes and on the following lawful bases:

Where we rely on our legitimate interests, we consider whether those interests are proportionate and whether your interests, fundamental rights or freedoms require the protection of your Personal Data to take precedence.

Where processing is necessary for the performance of a contract, failure to provide Personal Data that is necessary for the relevant service may mean that we are unable to provide the requested account, booking, listing or other Platform functionality.

Where we are required to process Personal Data to comply with a legal obligation, we will process the Personal Data to the extent necessary to meet the applicable legal or regulatory requirement.

Where processing is based on your consent, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before your consent was withdrawn.

Health and Other Special Categories of Personal Data

DoctorMedLink does not currently operate as an electronic medical record system and does not maintain patient medical records as part of the Platform’s current functionality.

However, certain interactions with DoctorMedLink may reveal or involve information concerning health. For example, searching for or booking a particular type of Healthcare Professional, or information voluntarily communicated between a Service User and Healthcare Professional through the Platform, may reveal information concerning the Service User’s health.

Where DoctorMedLink processes data concerning health or another special category of personal data, such processing will only take place where permitted under the GDPR and where an appropriate condition under Article 9 GDPR applies.

Service Users are encouraged not to include health information or other sensitive personal data within general profile fields or other areas of the Platform that are not intended for such information.

Public Healthcare Professional Profiles

The purpose of a Healthcare Professional listing is to make relevant professional information available to individuals searching for healthcare services through DoctorMedLink.

Accordingly, information submitted for inclusion in a Healthcare Professional’s public listing may be accessible to Visitors and Service Users. This may include the Healthcare Professional’s name, photograph, specialty, professional biography, practice or hospital affiliation, practice location, professional contact information, working hours, availability, languages spoken, services, website and social media information.

Information collected solely for verification or administrative purposes, including professional certification documentation, is not intended to be publicly displayed.

Healthcare Professionals should ensure that information they submit for publication is accurate and does not unnecessarily include personal data relating to other individuals.

Sharing of Personal Data

We do not sell your personal data.

We may disclose or make personal data available where necessary to operate DoctorMedLink and provide the requested functionality. Depending on the circumstances, recipients may include Healthcare Professionals with whom Service Users choose to interact; hosting and infrastructure providers; authentication providers; mapping and location service providers; payment service providers; security and anti-bot providers; IT and technical support providers; website and Platform service providers; and analytics, advertising or cookie-related providers where applicable.

We may also disclose personal data to our professional advisers and to regulatory, supervisory, judicial, law enforcement or other competent public authorities where disclosure is required or permitted by law.

Where a service provider processes personal data on our behalf, we take appropriate measures to ensure that the processing is subject to appropriate contractual, confidentiality and data protection requirements.

Certain external providers may process personal data as independent data controllers for their own purposes. Their processing is subject to their respective privacy information and applicable legal obligations.

International Transfers

The DoctorMedLink website/application and associated data are currently hosted in Germany, within the European Economic Area (“EEA”).

However, some third-party service providers used in connection with DoctorMedLink may process or access personal data from locations outside the EEA.

Where personal data is transferred outside the EEA, we will ensure that the transfer is made in accordance with the requirements of Chapter V GDPR. Depending on the circumstances, this may include transferring personal data to a country recognised by the European Commission as providing an adequate level of protection or implementing appropriate safeguards such as the European Commission’s Standard Contractual Clauses and supplementary measures where required.

You may contact us or our Data Protection Officer for further information concerning the safeguards applicable to international transfers of your personal data.

Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including for the purposes of satisfying applicable legal, regulatory, tax, accounting and reporting requirements and, where appropriate, for the establishment, exercise or defence of legal claims.

The applicable retention period depends on the nature of the personal data, the purpose for which it is processed and applicable legal and operational requirements.

Account information will generally be retained while the relevant account remains active or for as long as necessary to provide the requested services.

Where a registered user requests or exercises available account deletion functionality, Personal Data associated with the account will be deleted from the active Platform environment, subject to any information that the Company is required or permitted to retain. Copies contained within hosting backups may remain for up to 30 days following deletion before being removed through the applicable backup cycle.

Specific information may be retained for a longer period where retention is required by applicable law or necessary for the establishment, exercise or defence of legal claims.

Cookies and Similar Technologies

DoctorMedLink uses cookies and similar technologies to operate the Platform, maintain user sessions, remember preferences, provide embedded or third-party functionality and, where applicable, support analytics, advertising and similar functionality.

Some cookies and technologies are necessary for the operation and security of DoctorMedLink, while others are used only where permitted under applicable law and, where required, after obtaining your consent.

When accessing DoctorMedLink, you may be provided with a cookie preference mechanism through which you can manage your applicable cookie choices.

Further information concerning the cookies and similar technologies used by DoctorMedLink, including their providers, purposes and duration, is available through our Cookie Policy and cookie preference tool.

Security of Personal Data

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Access to personal data is limited to persons who require access for legitimate business or operational purposes and is subject to appropriate confidentiality and security requirements.

Although we take appropriate measures to protect personal data, no electronic transmission or storage system can be guaranteed to be completely secure. Registered users are responsible for maintaining the confidentiality of their account credentials and should notify DoctorMedLink if they believe their account has been accessed or used without authorisation.

Your Data Protection Rights

Subject to the conditions and limitations provided under applicable data protection legislation, you may have the following rights in relation to your Personal Data:

• • Right of access – to request confirmation as to whether we process your Personal Data and obtain access to the Personal Data we hold about you. 

• • Right to rectification – to request correction of inaccurate Personal Data or completion of incomplete Personal Data. 

• • Right to erasure – to request deletion of your Personal Data in certain circumstances. 

• • Right to restriction of processing – to request that we restrict the processing of your Personal Data in certain circumstances. 

• • Right to object – to object to the processing of your Personal Data where the processing is based on our legitimate interests or those of a third party. 

• • Right to data portability – where the applicable conditions are met, to receive Personal Data you have provided to us in a structured, commonly used and machine-readable format and to request that it be transmitted to another controller. 

• • Right to withdraw consent – where processing is based on your consent, to withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn. 

• • Rights relating to automated decision-making – where applicable, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. 

• • Right to lodge a complaint – to lodge a complaint with the competent supervisory authority if you consider that the processing of your Personal Data infringes applicable data protection legislation. 

To exercise any of the above rights, or if you have questions concerning the processing of your Personal Data, please contact our Data Protection Officer using the contact details provided in this Privacy Policy.

We may request information reasonably necessary to verify your identity before responding to your request.

Please note that these rights are not absolute and may be subject to conditions, limitations and exemptions under applicable data protection legislation. 

Complaints

If you have concerns about how we process your personal data, we encourage you to contact us or our Data Protection Officer so that we can review and address your concerns.

You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus if you consider that the processing of your personal data infringes applicable data protection legislation. The Commissioner’s published complaint procedure confirms that data subjects may complain regarding alleged GDPR infringements and may first contact the controller or its DPO regarding their concerns. 

The competent supervisory authority in Cyprus is:

Office of the Commissioner for Personal Data Protection
Office address: Iasonos 1, 1082 Nicosia, Cyprus
Postal address: P.O. Box 23378, 1682 Nicosia, Cyprus
Telephone: +357 22818456
Email: commissioner@dataprotection.gov.cy

Third-Party Websites and Services

DoctorMedLink may contain links to websites, professional pages, social media profiles and services operated by third parties.

Where you follow an external link or use a third-party service, the relevant third party may collect and process personal data independently and in accordance with its own privacy practices. DoctorMedLink does not control and is not responsible for the privacy practices of independent third-party websites or services.

We encourage you to review the privacy information of the relevant third party before providing personal data through an external website or service.

Children

Future Platform Functionality

DoctorMedLink may introduce additional functionality as the Platform develops, including remote or video consultations and online prescription-related functionality.

These functionalities are not currently operational and are therefore not described in this Privacy Policy as current processing activities.

Before introducing functionality that materially changes the nature, purposes or categories of personal data processed through DoctorMedLink, we will assess the applicable data protection requirements and, where necessary, update this Privacy Policy and implement appropriate data protection measures.

Company Structure and Responsibilities

There are currently four people involved in the DoctorMedLink project: two based in Cyprus and two based abroad.

The individuals involved in the technical development do not require access to the personal data stored on the platform as part of their normal work. Their access should be limited to the technical development, maintenance and implementation of new features where required.

There are currently no separate internal departments. Responsibilities are shared depending on the area of work.

External Support

The Company works with external service providers for certain operational activities, including marketing and accounting.

An external marketing company is also expected to start working on the DoctorMedLink project from next Monday, initially focusing on preparing and publishing marketing materials and photographs.

Platform Launch and Future Development

The initial version of DoctorMedLink will focus primarily on allowing users to search for and view Healthcare Professional profiles and relevant information about doctors and healthcare professionals.

Additional functionalities will be introduced gradually after launch. These may include video consultations and other features that will be determined as the platform develops and based on the operational requirements of DoctorMedLink.

The final list of future functionalities has not yet been determined.

Access by Developers

Developers and technical partners should not have general access to the personal data stored on the DoctorMedLink platform.

Where access is technically required for development, troubleshooting or implementation of a specific feature, such access should be limited to what is necessary for the relevant technical task.

Minors

We would like DoctorMedLink to be accessible to individuals under the age of 18, as a minor may need to search for a healthcare professional and potentially contact a healthcare professional through the platform.

We would therefore like the GDPR documentation and the platform’s processes to take into account the use of DoctorMedLink by minors and advise us on any additional measures, notices, age-related requirements, parental/guardian requirements or other safeguards that should be implemented to allow this functionality while maintaining GDPR compliance.

Automatic Translation

DoctorMedLink is intended to provide automatic translation of Healthcare Professional information.

Where a doctor or healthcare professional does not provide a Greek version of their profile/information, the platform may automatically translate the available information into Greek so that it can be displayed to users.

The exact technical translation provider/service will be confirmed separately.

Marketing

The Company already has an external marketing company that will begin working on DoctorMedLink from next Monday. The initial work will include preparing and publishing photographs and other marketing content.

The specific marketing tools, analytics services and advertising platforms will be confirmed separately once the relevant setup has been finalized.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to DoctorMedLink, our processing activities, applicable legal requirements or other operational developments.

Where appropriate, we will take reasonable steps to bring material changes to your attention.

The most current version of this Privacy Policy will be made available through DoctorMedLink, and the “Last Updated” date at the beginning of the Policy will indicate when it was most recently revised.