Augury Medical GmbH ("Augury Medical", "we", "us") operates Navicor, a clinical decision support web application available at [Navicor app URL] (the "Service"). This policy explains what personal data we collect when you use Navicor, why we collect it, and your rights regarding that data.
We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and the privacy laws of the US states where our users are located. Where the EU General Data Protection Regulation (GDPR) applies, for example if you use Navicor as part of a clinical study in Europe, we also process your data in accordance with the GDPR.
This policy covers the Navicor application only. Our website, augurymedical.com, is covered by our website Privacy Policy. Your use of Navicor is also governed by the Navicor Terms of Service. If you use Navicor as part of a clinical study under a separate agreement with us, you will receive additional privacy information for that study, which applies alongside this policy.
1. Data controller
The data controller for personal data processed through Navicor is:
Augury Medical GmbHQuellgasse 21
2502 Biel/Bienne
Switzerland
2. Data we collect
Account information
When you create an account, we collect your email address and a password. Your password is handled only by our login provider and is never visible to us. During onboarding, we ask for your first and last name, your professional role, and how you heard about Navicor. We also record when you accepted the Terms of Service and this Privacy Policy, and whether your account is active.
Billing information
Payments are handled by Stripe. When you subscribe, Stripe collects your name, email address, billing address and payment details. Your full card number stays with Stripe and never reaches us. We receive and keep only what we need to manage your subscription: its status, plan, billing dates, Stripe reference numbers and, if a payment is disputed, the fact and status of the dispute.
Usage and settings
We save your display settings so they stay the same across devices, and we record roughly when you last used Navicor. Our login provider keeps a history of logins to your account, including the time, IP address and browser used.
Security and technical data
To protect the Service and to make it available only in the United States, we briefly process your IP address to check your country and to limit excessive requests. We do not store your IP address in our systems. Our hosting provider records standard request data, including IP addresses, as part of operating its network. Our application logs contain only internal reference numbers and technical information. They do not contain your name, email address, IP address or any clinical findings you enter.
Support requests
When you contact us, for example at support@augurymedical.com, we process your name, email address and the content of your message to respond to you.
Categories and sources
In the terms used by US state privacy laws, we collect the following categories of personal information:
- —Identifiers: your name, email address, IP address and account reference numbers.
- —Professional information: your professional role.
- —Commercial information: your subscription, payment and billing records.
- —Internet or network activity: your login history, last activity time and display settings.
- —Sensitive personal information: limited to your account login credentials, which we use only to provide and secure the Service.
We collect this information directly from you, from our login and payment providers, and automatically when you use the Service.
3. Clinical findings you enter
Navicor is designed to work with clinical findings, not patient identities. It asks only for clinical values, such as a patient's age, blood pressure or diagnoses, and never for a patient's name, date of birth, medical record number or other identifier. As set out in our Terms of Service, you must not enter any information that directly identifies a patient.
The clinical findings you enter are sent to our servers only to generate your results. They are processed in memory for that single request, are not stored and not logged, and are not linked to your account or to any patient's identity. While you are using Navicor, they are held in your browser's memory and are cleared when you close the tab.
Navicor is not designed to receive protected health information (PHI), and we do not enter into HIPAA business associate agreements for this version of the Service.
4. Purposes and legal basis
We process personal data to create and secure your account, to provide the Service, to manage your subscription and payments, to respond to support and data requests, to keep the Service secure and available only in the United States, and to understand, in aggregate, how users find Navicor and which professional groups use it.
We rely on the following legal grounds (with the corresponding GDPR provision, where the GDPR applies):
- —Performance of our contract with you (Art. 6(1)(b) GDPR): creating and managing your account, providing the Service, keeping your settings, and managing your subscription and payments.
- —Legitimate interests (Art. 6(1)(f) GDPR): keeping the Service and your account secure, preventing abuse, restricting access to the United States, handling payment disputes, responding to support requests, and producing aggregated statistics on how users find Navicor.
- —Legal obligation (Art. 6(1)(c) GDPR): keeping accounting and tax records, and responding to requests to exercise your data protection rights.
We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects for you.
5. Service providers
We use the following service providers, who process personal data on our behalf under data processing agreements:
Okta, Inc. (Auth0) (USA)
Login and account security. Stores your email address, your password in protected (hashed) form, and your login history.
Stripe Payments Europe, Limited (Ireland)
Subscription payments and invoicing. For payment processing and fraud prevention, Stripe also acts as an independent controller under its own privacy policy.
Render Services, Inc. (USA)
Hosting of the Navicor application and database, including its network provider. Our database is hosted in Render's US region.
Hostpoint AG (Switzerland)
Email. Sends the verification codes used when you sign up and hosts our support mailbox.
We do not sell your personal data, share it for cross-context behavioral advertising, or use it for targeted advertising. Our service providers may use your data only to provide their services to us.
6. International transfers
Augury Medical is based in Switzerland. Our login and hosting providers are based in the United States, and our payment provider, Stripe, also processes personal data there. For these transfers, we rely on the providers' certification under the Swiss–US and EU–US Data Privacy Frameworks or, where that is not available, on standard contractual clauses recognized by the Swiss Federal Data Protection and Information Commissioner (FDPIC) and approved by the European Commission.
7. Retention
We keep your account information while you use Navicor. We delete it after 2 years without a login or an active subscription. If you close your account or ask us to delete your data, we delete it within 30 days. In each case, we keep information longer only where the law requires it.
We keep billing records, including records of any payment disputes, for as long as accounting and tax law requires, which in Switzerland is generally 10 years.
We keep support emails for 2 years after our last contact with you.
Login history and server logs are kept by our providers for a limited period for security purposes and are then deleted automatically. Database backups are kept for up to 1 year and are then deleted automatically. Data we have deleted may remain in these backups until they expire.
Clinical findings you enter are not stored (see Section 3).
8. Your rights
Depending on where you live, you may have the right to:
- —Access the personal data we hold about you
- —Have inaccurate data corrected
- —Have your data deleted
- —Object to or restrict processing of your data
- —Receive your data in a portable format
- —Opt out of the sale or sharing of your personal data, targeted advertising and profiling (we do not do any of these)
To exercise any of these rights, email us at support@augurymedical.com or write to us at the address in Section 1. You may also use an authorized agent to make a request on your behalf. We may need to verify your identity, or the agent's authority, before acting on a request. We will respond within 30 days. Where the law allows us more time, we may extend this period and will tell you why.
If we decline your request, you may appeal by replying to our decision. We will respond to your appeal within 45 days. If we deny your appeal, you may contact your state attorney general.
We will not discriminate against you for exercising any of these rights.
You also have the right to lodge a complaint with a data protection authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC). Where the GDPR applies, you may also complain to the supervisory authority in your country of residence.
10. Security
We protect your data with appropriate technical and organizational measures. All connections are encrypted, your password and payment details are handled only by our specialized providers, access to our database is restricted, our backups are encrypted, and our logs are kept free of names, email addresses, IP addresses and clinical findings.
11. Children
Navicor is intended only for healthcare professionals, and for students and trainees in these professions, who are at least 18 years old. It is not directed at children, and we do not knowingly collect personal data from anyone under 18.
12. Changes to this policy
We review this policy at least once a year and may update it from time to time. We will update the "Last updated" date at the top of this page, and we will notify you of material changes by email or in the Service before they take effect.
13. Contact
Questions about this policy or how we handle your data can be sent to support@augurymedical.com, or in writing to the postal address in Section 1.