Privacy Policy

The data controller for your personal data is:

We collect the following categories of personal data:

• Account data: your name, email address, and password (stored as a one-way hash). Optionally, a profile picture.
• Health records (special category data): documents you upload: lab results, prescriptions, discharge summaries, and similar medical records relating to care recipients you manage.
• Usage data: IP address, browser/device type, and interactions with the service, collected automatically for security and service improvement.
• Billing data: payment information processed by Stripe on our behalf. We do not store card numbers.
• Communications: any messages you send to us via email.

Health records constitute special category data under Article 9 GDPR. We only process them with your explicit consent, which you provide at registration and may withdraw at any time.

• Providing and improving the CareCircle service
• Enabling you to share health records with circle members you authorise
• Generating AI-assisted interpretations of uploaded documents (optional, per-document, with your consent)
• Sending transactional emails: account verification, invitations, billing receipts, and appointment reminders
• Processing subscription payments
• Detecting and preventing fraud, abuse, and security incidents

We do not sell your personal data. We do not use your health records for advertising or profiling.

When you choose to use the AI interpretation feature, the content of the relevant document is sent to Anthropic PBC (United States) for processing by a large language model. The result is returned to you within the app.

AI interpretations are provided for informational purposes only and do not constitute medical advice. See our Terms of Service for details.

You may use the app without ever triggering AI processing. The feature is opt-in per document.

We share data with the following processors under contractual data protection agreements:

• Anthropic PBC (USA): AI model inference for document interpretation (opted-in documents only). Transfer basis: EU Standard Contractual Clauses pending; interim: your explicit consent (Art. 49(1)(a) GDPR).
• Resend Inc. (USA): transactional email delivery (your email address and name only).
• Stripe Inc. (USA): payment processing (billing data only; Stripe is independently PCI-DSS certified).
• Self-hosted infrastructure (Netherlands): all health records and account data are stored on servers physically located in the Netherlands, owned and operated by CareCircle.

Your account data and health records are stored on servers physically located in the Netherlands, owned and operated by CareCircle.

Certain processors (Anthropic, Resend, Stripe) are US-based. Transfers to these processors are covered by appropriate safeguards: EU Standard Contractual Clauses where available, or, for opted-in AI processing, your explicit consent under Article 49(1)(a) GDPR.

When family members in Nigeria access records you share with them, this constitutes a transfer to a country without an EU adequacy decision. This transfer occurs on the basis of your explicit consent (Art. 49(1)(a)) and is necessary to provide the core functionality of the service.

• Account and health data: retained for as long as your account is active. When you delete your account, all your data (and data belonging to circles you solely own) is permanently deleted within 30 days.
• Billing records: retained for 7 years as required by Dutch tax law.
• Security / access logs: retained for 90 days.

As a data subject under GDPR you have the following rights. To exercise any of them, contact us at [email protected].

• Right of access (Art. 15): request a copy of all personal data we hold about you.
• Right to rectification (Art. 16): correct inaccurate data. Most profile data can be corrected directly in Settings.
• Right to erasure (Art. 17): request deletion of your data. You can also delete your own account directly in Settings → Delete account.
• Right to restriction (Art. 18): ask us to restrict processing while a dispute is resolved.
• Right to data portability (Art. 20): receive your data in a structured, machine-readable format.
• Right to object (Art. 21): object to processing based on legitimate interests.
• Right to withdraw consent: you may withdraw your consent to health data processing at any time. This will not affect the lawfulness of processing before withdrawal, but will mean the service can no longer function as intended.

You also have the right to lodge a complaint with the Dutch Data Protection Authority: Autoriteit Persoonsgegevens at autoriteitpersoonsgegevens.nl

We use the following cookies:

We do not use advertising or cross-site tracking cookies. The analytics cookie (umami.uuid) collects no personally identifiable information; it generates a random identifier used only to distinguish unique page views. All analytics data is stored on our own servers in the Netherlands and is never shared with third parties.

The AI interpretation feature uses automated processing to summarise health documents. This is not a decision that produces legal or similarly significant effects; the output is informational only, and you are always free to disregard it and consult a healthcare professional. No automated decision-making within the meaning of Article 22 GDPR takes place.

We may update this policy. When we make material changes, we will notify you by email or via a banner in the app before the changes take effect. The date at the top of this page always reflects the latest version.

For any privacy-related questions or requests, contact us at [email protected].