What is MediXSpace?

Safe digital space for all cancer patients

Only 30% of cancer patients actively seek a second opinion before making crucial treatment decisions. Out of this number, 88% of patients end up with their diagnosis clarified or changed completely.

The second opinion in oncology can save lives, but getting it can be troublesome, especially if there is a shortage of medical specialists available locally. That’s why we have come up with a solution to make cancer care expertise accessible to all patients across borders.

A cloud-based platform for cancer patients seeking a second opinion or looking to get their treatment plan reviewed by a tumour board.

A marketplace for medical providers that offers a smart matching service for finding the right doctor or a clinic, all based on the patient`s case, request and location.

A toolkit for providers that allows applying for tumour boards and hosting them online, as well as engaging external clinical experts in the process of decision-making.

Copyright Medixspace 2023

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MEDIXSPACE PRIVACY POLICY

1. What this Policy covers

This Policy explains what information we, Medixspace B.V., process to provide our products and services and services of our partnering organizations.

This Policy covers the following of our products:

Name of the product
Description of the product
Medixspace™ Platform
A safe space for cancer patients from all over the world where they can interact with each other, easily share information about their condition and find resources best matching their individual needs. It connects patients with the best oncologists, provides access to 2nd opinion and further treatment, and delivers trusted educational content and information about relevant services offered by our partners. It offers tools for medical providers to review patient cases, host virtual consultations and multidisciplinary Tumor Board conferences, and helps stay in touch with their patients no matter where they live and what languages they speak. Medical services are provided by carefully selected medical organizations renowned for their excellence in cancer care. We also partner with providers of other related services to empower and engage patients and make their journey easier.
Medixscan™ app
A mobile application for capturing and digitizing medical documents, maintaining a library of medical documents for the entire family, and sharing these documents with other individuals and medical services providers. Medixscan also delivers useful medical content related to these documents. This content may include educational materials, news, and relevant information about diagnostics, treatment and other information from our partners.

In this Policy, we also let you know your rights, so that you know how to control your privacy.

Medixspace B.V. is a 'controller' of your personal data. Personal data is any information we have that can identify you, such as your name, medical history, or credit card details. Being a 'controller' of personal data means that we're responsible for how personal data that we have access to is handled and what it's used for through this company. If you wish to exercise any of your rights, you should reach this company directly.

Below is the more detailed description of the information we process, by each of our product, and in general:

2. What data we hold, how we get it, and what we use it for

Below we describe what type of personal data we collect through our different products, when we collect it, and why we collect it, including the legal basis for processing. Where the legal basis for processing is indicated as “consent”, it means that we receive your explicit consent before collecting this information from you. You can withdraw the given consent at any time – refer to Section 7 “Your Rights” for details. In some processing cases we rely on our legitimate interests or the legitimate interests of a third-party, such as our users, where they are not outweighed by your interests or fundamental rights and freedoms. You have the right to object to, and seek restriction of, the processing based on legitimate interest – refer to Section 7 for more information.

Medixspace™ Platform
Category of information
What information we collect
When we collect it
Purpose of collection and what we use your data for
Legal basis for processing
Personal details: patients
  • Name
  • Date of birth
  • Email address or phone number
When you register as a patient with the medical provider through our platform
We need this information to enter a contract with you and deliver services. We are contracting with you by means of а public offering, to which you agree by accepting our Terms and Conditions {insert a link}. We also will be using this information to exercise your rights as a data subject – for example the right to delete your data (Refer to Section 7). Therefore, the information you give us must be accurate. If you give us information about yourself or another person, you're confirming that you're authorized to do so.
Provision of services
Personal details: medical professionals
  • Name
  • Photograph
  • Medical specialization
  • Description of qualifications (i.e., education, professional degrees).
Medical professionals
Making possible for a medical organization to provide medical advice services for our users. We use personal data of medical professionals who participate in the tumor board from the side of the medical services provider. We share this information with patients for the purpose of informing them about tumor board participants and their qualifications. We also share this information during the tumor board (if the patient is present) and while sharing with the patient your report with recommendations upon completing the tumor board.
Provision of services/ Legitimate interest
Details of users’ conversations with us: patients and medical providers
  • Records of your consultations and your conversations with us: emails, calls or live chat conversations
During your communications with our support team
To improve our services. This is so we have an easy way to access your consultations to monitor the quality of our service and healthcare.
Our legitimate interests and those of our users
Health and medical data: patients
  • General health history
  • Your diagnoses/conditions
  • Symptoms, treatments, allergies, and medications
  • Consultations, such as notes and recordings
  • Procedures, such as surgery
  • Results of medical tests (including genetic tests), investigations, and medical images
  • Molecular profile
  • Treatment outcomes
When you start using our services as a patient, including built-in features such as text recognition.
This information we get from your directly during the preparation of your case for the tumor board or via our medical providers – during your interaction with their specialists. We keep your medical data secure by applying technical and organizational measures to protect it. For example, we de-identify your medical data and store them separately from your personal data – refer to Section 4 for details.
Consent
Making the use of our portal comfortable for you. By using text recognition feature we make it possible for you to treat scanned images as text – i.e., to perform full-text search and copy-paste functions. We further use natural language processing algorithms to automatically extract key information such as: date of document creation, title, type of a document, personal data, medical terms. We use this information to automatically create a document summary, categorize documents, and mask your personal data, thereby making it easier for you to manage your documents’ library.
Consent
Offering you additional services and information. We will use your medical data and contacts to recommend you targeted educational and marketing content and services of our partners. This may include invitation to take part in clinical trials. We use automated algorithms to match such content to your profile. We only use anonymized data for this matching and never share these data with third parties unless you use features of our applications allowing to share your information with other individuals or providers of services. If you do not provide consent, we will still post generic educational and marketing content, but it may not be relevant to your medical profile.
Consent

Helping health research. We use your data for health research. For example, to better understand health behavior, disease risk or health outcomes. We aim to publish our research results in peer-reviewed journals or by working with academics. We may conduct research with partner organizations such as universities or other academic institutions. For this purpose, we may use any medical information contained in your medical documents.

We remove from this information any details that could identify you. This includes your name and contact information. Our research follows the Declaration of Helsinki ethical principles, which were developed by the World Medical Association.

Consent
Medixscan™ App
Category of information
What information we collect
When we collect it
Purpose of collection and what we use your data for
Legal basis
Personal details: app users
  • Name
  • Biological sex
  • Date of birth
  • Email address
  • Mobile phone number
  • Photograph (optional)
When you register as a user in our app

We need your personal information to enter a contract with you and deliver services. We are contracting with you by means of а public offering, to which you agree by accepting our Terms and Conditions {insert a link}.

We also will be using this information to exercise your rights as a data subject – for example the right to delete your data (Refer to Section 7). Therefore, the information you give us must be accurate. If you give us information about yourself or another person, you're confirming that you're authorized to do so.

Provision of services
Details of users’ conversations with us: patients and medical providers
  • Records of your consultations and your conversations with us: emails, calls or live chat conversations.
During your communications with our support team
To improve our services. This is so we have an easy way to access your consultations to monitor the quality of our service and healthcare.
Our legitimate interests and those of our users
Medical documents processed by our OCR services: app users
  • Your personal details (i.e. name, address, date of birth and other non-medical personal information contained in your medical documents)
  • General health history
  • Your diagnoses/conditions
  • Symptoms, treatments, allergies, and medications
  • Consultations, such as notes and recordings
  • Procedures, such as surgery
  • Results of medical tests (including genetic tests), investigations, and medical images
  • Molecular profile
  • Treatment outcomes
After you start using our text recognition services by activating them via explicit action in our app. Important!! Before you start using these services all scanned medical documents are stored on your mobile device or in any third-party cloud-based repositories explicitly chosen by you, and as such, are neither collected, nor in any other way processed by us.
Making the use of our app comfortable for you. By using text recognition feature we make it possible for you to treat scanned images as text – i.e., to perform full-text search and copy-paste functions. We further use natural language processing algorithms to automatically extract key information such as: date of document creation, title, type of a document, personal data, medical terms. We use this information to automatically create a document summary, categorize documents, and mask your personal data, thereby making it easier for you to manage your documents’ library.
Consent
Offering you additional services and information. We will use your medical data and contacts to recommend you targeted educational and marketing content and services of our partners. This may include invitation to take part in clinical trials. We use automated algorithms to match such content to your profile. We only use anonymized data for this matching and never share these data with third parties unless you use features of our applications allowing to share your information with other individuals or providers of services. If you do not provide consent, we will still post generic educational and marketing content, but it may not be relevant to your medical profile.
Consent

Helping health research. We use your data for health research. For example, to better understand health behavior, disease risk or health outcomes. We aim to publish our research results in peer-reviewed journals or by working with academics. We may conduct research with partner organizations such as universities or other academic institutions. For this purpose, we may use any medical information contained in your medical documents.

We remove from this information any details that could identify you. This includes your name and contact information. Our research follows the Declaration of Helsinki ethical principles, which were developed by the World Medical Association.

Consent

3. Other data we collect

Technical information and analytics

When you visit our website or use our app, we may collect the following data, where this is allowed by your device or browser settings:

  • The IP address used to connect your mobile phone or other device to the internet
  • Your browser information, such as Google Chrome or Apple Safari
  • Login and operating system
  • The make and model of your device
  • Resettable device identifiers
  • Time zone, language, and location settings
  • Your mobile network provider and your location (based on your IP address)
  • Information about your visit to our website or use of our app, for example when you first visited the site or how many times you've visited
  • Information about the products or services you viewed or used
  • App response times and updates
  • Information about your interactions, like what notifications you opened
  • Any phone number used to call our customer service number.

We work with other companies that provide us with analytics and advertising services. This is to:

  • Help us understand how people interact with our services
  • Provide the adverts for our services on the internet
  • Measure the performance of our services and our adverts.

We will never share neither your personal data, nor your health information with these third parties.

Credit and debit card information

If you make a payment on the app or site, your credit and debit card details are processed by a third-party payment provider. We don't store any of your credit or debit card information and we only keep details of the transactions on our secure servers.

Cookies

We also use 'cookies'. Cookies are files saved on your phone, tablet, or computer when you visit a website. They collect information about how you use the website and the pages you visit. We do not use cookies on your medical or health information. You can find out more about how we use cookies in our cookie policy {insert a link}.

Information from third-party services

You may connect your social media accounts, or your wearable device (like a smartwatch) with our services. If you choose to do this, we'll receive the following information about you from the third party:

  • Name
  • Email address
  • Username or ID
  • Health and lifestyle habits and information

If you use login details from third parties, they will also process your login data, and they are solely responsible for handling this.

Improving Medixspace’s functionality and usability

We use your health and medical information to improve our services, including our artificial intelligence algorithms. This helps us deliver better services to you and other Medixspace users.

We remove details that could identify you from this information, such as your name, address and contact details. These are called 'personal identifiers'.

If you have questions about the way your data has been handled, please contact [email protected].

4. How we store your data

Personal health and medical information

Your personal health and medical information are stored on secure servers.

If you've chosen a password or authentication method to access your user profile, you're responsible for keeping this password and/or authentication method confidential. Please don't share it with anyone.

We encrypt data transmitted to and from the website. Once we have your information, we use strict procedures and security features to prevent unauthorized access. We will take all precautions to make sure that your data is treated securely.

As mentioned before, we de-identify your medical data and store them separately from your personal data – to minimize the risks of exposure to personal health data theft. If you share with us digital copies of your medical documents, these documents may contain your personal information. We offer masking and other de-identification functionalities for processing your scanned documents. However, de-identification of such documents may not be possible if you choose to use another scanning apps which do not offer such feature. Also, medical providers may require that your medical documents are identifiable. To minimize the risks of personal data leakage we will always use encryption while transferring medical documents over Internet.

Credit and debit card information

We don't store any of your credit or debit card information. Payments are processed through a third-party payment provider that follows strict industry data security standards. These are known as Level 1 Payment Card Industry (PCI) data security standards.

Any payments you make are encrypted using SSL technology (which converts the information into code to stop fraud).

Where we store and process your data

Your data will be processed and stored inside the country or a region (i.e., European Union) where you are located. We enter into the contracts with our storage space providers, such as Amazon Web Services, in each country where we attract the clients and where we enter in the contract agreement with the clinics. These companies can only use your data based on our instructions and they cannot use the data for their own purposes. This storage will always be in line with applicable data protection lawful mechanisms (such as appropriate contractual terms) and subject to local privacy laws.

5. How and why we share your data

To be able to deliver our services to you as a patient we share your personal data with different organizations, i.e., medical providers, that you have chosen for your patient case review.

Medical services providers

Medical services providers that you have chosen for reviewing your case have access to your medical information via our platform during tumor board conferences.

These providers may be located in the countries different from the country where you are located, and in this case sharing your data with them falls under cross-border data transfer definition. This sharing will always be in line with applicable data protection lawful mechanisms (such as appropriate contractual terms) and subject to strict safeguards.

Patients

Personal data of medical professionals participating on behalf of medical providers in tumor board conferences are shared with the patients as described in Section 2.

Third-party services providers

If a third-party software is used for performing our services (for example, external data storage services or teleconferencing), the provider of that service may request some of your personal data, for example email address. We will pass this information to such provider. If you or medical provider wish the virtual tumor board conference to be recorded, the provider of the videoconferencing service will store this recording according to the Terms and Conditions of that provider’s services.

For further information on how we protect your data if we perform cross-country transfers, contact us by email at: [email protected].

Aggregated data

We may show on our website or share with our commercial partners data that do not personally identify you, but which show general trends. These are 'aggregated' data and not personal data. Such data might include, for example, the number of users of our service or trends in a particular location.

6. How long we keep your data

Your information
How long we keep it (its 'retention period')
Your login credentials
One year after last activity.
Identifiable medical data and medical documents
For the period of time required by applicable regulations of the country of the medical services provider or one year since patient’s last activity – whatever period is longer.
De-identified medical data and medical documents
Indefinitely
Video conference services provided by third parties
According to the Terms and Conditions of the provider
Video conference services provided by us
One month from the date of the conference
Communications with our support team, including phone calls, emails and live chats - patients
One year after your last activity.
Communications with our support team – medical services providers
30 days after termination of a contract.
Communications between medical providers and patients
30 days after the termination of a contract with a provider.

We will delete your personal data as per your request within 30 days after receiving such a request, provided that we are not legally obliged to keep it longer for various legal purposes. Refer to Section 7 to understand your rights regarding control over your personal information.

The deletion logs should be kept for a certain period of time because deletions may have to be proven in some cases. These could include, for example, data subjects or supervisory authorities requesting proof of the deletion of the relevant data. This period of time depends on the privacy laws of the country where our users reside.

If you want to see any of this information while we have it (in its 'retention period'), you can ask for it by emailing us at: [email protected].

7. Your rights

You're in control of your personal information. Under data protection law, you have the right to:

  • Remove or change your consent at any time, if we are using your data in a certain way based on it. You can do this by going to your account, selecting 'Your account' and then 'Privacy Preferences'.
  • Ask for a copy of the personal data we hold about you. Your data is stored in line with our legal obligations. Refer to Section 6 above to see on how long we keep your data.
  • Ask us to correct information that's wrong, delete it, or ask that we only use it for certain purposes.
  • Ask us to restrict any automated (computer-made) decisions made with your data.
  • Ask for your data to be provided in a portable format that allows you to move, copy or transfer it. Or ask us to send it in this format to someone else.

To do any of these things, please complete our online webform.

Alternatively, please contact us at: [email protected] or:

Data Protection Officer

Medixspace B.V.

Maria Dermoutlaan, 5

Amstelveen

1187 VL The Netherlands

We'll ask you for a proof of identity. Data protection laws give us one month to get back to you.

8. National Regulator

We're regulated by the Dutch Data Protection Authority: Autoriteit Persoonsgegevens (AP). If you're not happy with any aspect of our data handling, you can complain to the ICO directly. You can contact them at:

Autoriteit Persoonsgegevens

Bezuidenhoutseweg 30

PO Box 93374

2509 AJ DEN HAAG

Telephone number: (+31) - (0)70 - 888 85 00

Fax: (+31) - (0)70 - 888 85 01

9. Changes to this policy

We might update this policy from time to time. If we make any important changes, we'll let you know, and give you the chance to review them.

If you agree to the changes, you don't need to do anything. Just keep using our services with the updated policy and we'll assume you are happy with the way we use your data.

If you don't agree to the changes, then you can stop using our services at any time.