IXXO Med App Privacy Policy

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1. Overview & Data Controller Roles

The IXXO Med application (available on iOS and Apple Watch; Android coming soon) is a free mobile application designed for patients to interact directly with their own healthcare provider (“Practice”).

Data Controller: Your specific healthcare practice is the Data Controller responsible for your personal health information.
Data Processor: IXXO Cart Ltd (Registration No. HE 417548, Cyprus) acts as the Data Processor, providing and hosting the IXXO Med software for your practice.

Direct Practice Connection: The app functions only after you connect it to your practice using a QR code or connection link provided by them. All app communication is sent over encrypted HTTPS connections directly to your practice’s designated server. There is no central IXXO server receiving your health data, no central IXXO user account, no advertising, no tracking, no crash reporting, and no third party analytics.

Important Notice: The IXXO Med app is not an emergency service and does not provide medical diagnoses. In case of a medical emergency, please contact 112 or your local emergency services immediately (“Not for emergencies, call 112”).

2. Information Collected & How It Is Used

All collected data is optional and transmission is initiated only when you grant explicit permission or trigger a send action within the app. All data goes directly and exclusively to your healthcare practice:

Data Category	Trigger / Timing	Purpose
Apple Health / Google Health Connect Data (Heart rate, resting heart rate, blood oxygen, blood pressure; on iPhone also irregular rhythm alerts and ECG results, never raw ECG waveforms)	After explicit permission is granted	Allows your treating physician to monitor your vital signs between visits.
Bluetooth Device Readings (Heart rate straps, blood pressure cuffs)	During an active recording session initiated by you	Shares real time physiological metrics with your practice.
Manual Measurements & Symptoms	When typed and sent by you	Shares self reported health readings and notes with your doctor.
Medication Adherence Ticks	When marked as taken	Tracks prescribed medicine adherence for your care team.
Appointment Details	When booking, altering, or canceling visits (including optional reason notes)	Manages your appointments with the practice.
Photos & Notes	When captured/selected and sent (location EXIF metadata and camera details are stripped locally on your device prior to sending)	Shares images of wounds, rashes, documents, or medicine boxes with your practice.
Notification Settings	When notifications are enabled or preferences/quiet hours/time zone are adjusted	Delivers push notifications from your practice.
Technical Identifiers	Sent automatically with every network request	App name, version, device notification token, and IP address logged by the practice server for operational security and service delivery.

Data Exhibited & Cached

To support offline reading, the app displays and stores cached copies of records released by your practice, including appointments, lab results, medical documents, visit summaries, treatment plans, and active prescriptions.

What We NEVER Collect or Transfer

Never Transferred: Your personal offline medicine list, custom reminders, or local app settings.
Never Collected: Precise location data, device contacts, personal calendars, text messages/emails, browsing history, payment/financial details, or advertising identifiers (IDFA/GAID).

3. Store Specific & Health Platform Disclosures

Apple HealthKit Disclosures

Health data obtained via Apple HealthKit is used solely to share health measurements with your designated healthcare provider.
HealthKit data is never used for advertising, marketing, or data mining, never sold to third parties, never stored in iCloud or cloud backups, and the app writes no data back into Apple Health.

Google Health Connect Disclosures & Permissions

Read Permissions & Health Data Types: The app accesses read permissions for Heart Rate, Resting Heart Rate, Blood Oxygen, and Blood Pressure solely after explicit user approval.
Background Access & Historical Data Access:
- Background Access (READ_HEALTH_DATA_IN_BACKGROUND): With your permission, the app reads Health Connect data in the background so that your health metrics can be periodically updated and made available to your practice between active app uses.
- Historical Data Access (READ_HEALTH_DATA_HISTORY): Upon initial connection to your practice, the app may read up to 90 days of prior Health Connect history to establish an initial baseline for your care team.
Limited Use Compliance: The use of information received from Google Health Connect adheres to the Google Health Connect Permissions Policy, including the Limited Use requirements:
- Health Connect data is used strictly to provide and improve healthcare monitoring features shared directly with your practice.
- Health Connect data is never transferred or sold to third parties, advertising platforms, data brokers, or information resellers.
- Health Connect data is never used for serving advertisements or credit assessments.

4. Third Party Services & On Device Processing

Push Notifications: Notifications are routed through Apple Push Notification service (APNs) on iPhone and Google Firebase Cloud Messaging (FCM) on Android. These services receive only a temporary device token and generic non sensitive display text (e.g., “New result from your practice”); medical content is never included. These notification services may process data outside the European Economic Area (EEA).
On Device QR Code Scanning (Android): Android devices utilize Google ML Kit strictly on device to read the practice QR code. Google ML Kit may send basic diagnostics and device information to Google in accordance with platform policies. Health Connect serves as Google’s on device health data store.
iOS Frameworks: The iPhone application relies exclusively on standard Apple system frameworks without embedded third party tracking or advertising SDKs.

5. Storage, Security & Retention

Server Hosting: Your health records reside on your practice’s IXXO Med server instance hosted by IXXO Cart Ltd with Hetzner Online GmbH in Germany (EU), ensuring compliance with EU data protection regulations.
On Device Security: Cached local data is stored within encrypted operating system containers (iOS Keychain & File Protection / Android Keystore). Local app storage is explicitly excluded from standard OS cloud backups (iCloud/Google Drive).
Connection Security: All communication strictly requires encrypted HTTPS; unencrypted plain connections are automatically refused. Your practice retains the authority to revoke app access connections at any time.
Retention: Local data remains on your phone until you disconnect the app or until your practice terminates the connection. Data stored at the practice level forms part of your official medical record and is retained according to statutory medical record retention laws. Notification tokens are deleted when you switch notifications off or disconnect.

6. Disconnection, Data Deletion & Rights

Disconnection & Local Clearing

Navigating to Settings > Disconnect within the app immediately deletes all cached medical records, the connection, and the notification token from the phone (local app display settings remain preserved). It also unregisters push notifications.

Data Deletion & Subject Rights

Under the General Data Protection Regulation (GDPR), you hold the right to access, rectify, request erasure, restrict processing, object to processing, and request data portability regarding your medical records.

Data already transmitted to your practice is managed by the practice as Data Controller. Requests regarding medical records should be directed to your practice or to IXXO at privacy@ixxo.com.

Regulatory Complaints

You have the right to lodge a complaint with the supervisory authority:

Office of the Commissioner for Personal Data Protection (Cyprus)
11 Iasonos Street, 1082 Nicosia, Cyprus
Website: www.dataprotection.gov.cy

7. Age & Minors Policy

The IXXO Med app is intended for individuals aged 16 and older. Minors under the age of 16 may use the app only when connected and managed under the direct supervision of a parent or legal guardian.

8. Contact Information

IXXO Cart Ltd (HE 417548)
90, Arch. Makariou III
7060 Livadia
Larnaca, Cyprus

Email: privacy@ixxo.com

Website: https://ixxomed.com