Privacy Policy

This app is intended for clinicians and is not for use by consumers.

Version 1.0. Effective 8 October 2026.

1. Who we are

1.1 The Ozana AI Interpreter app (the "App") is provided by Doctoria Ltd (company no. 13487661, ICO registration ZB282500), The Innovation Pop Up, Gilbert Scott Building (Level A), Leeds General Infirmary, Great George Street, Leeds, LS1 3EX, United Kingdom. Our subsidiary Ozana Labs Inc, 10300 Eaton Place, Suite 440, Fairfax, VA 22030, USA, supports users in the United States.

1.2 Our role.

Data	Our role
Consultation content: what is said during a consultation, its translation and summary, and any patient details entered for the session	Processor under UK and EU GDPR, and business associate under HIPAA, acting on the instructions of the clinician's organisation
Data about App users: account, sign-in, billing and support	Controller

Patients should send requests about a consultation to the organisation that treated them. We will help that organisation respond.

1.3 Data Protection Officer. privacy@doctoria.co.uk, or by post to the address above, marked "Data Protection Officer".

2. Data we process

Data	Purpose	Lawful basis	Retention
Consultation content	Real-time interpretation and the session summary	Processed on the organisation's instructions. Its basis is UK GDPR Art. 6(1)(e) or (f) and Art. 9(2)(h)	Deleted when the session ends
Patient consent record: time, consent text version, answer, language pair	Evidence that the patient agreed	As above	Made available to the organisation, then deleted within 30 days
Account data: name, work email, profession, professional registration number, organisation, region	Providing your account	Contract, Art. 6(1)(b)	Life of the account plus 30 days
Acceptance records: which versions of our Terms, Privacy Policy and Cookies Policy you accepted, and when	Evidence of acceptance	Legal obligation and legitimate interests, Art. 6(1)(c) and (f)	6 years after the account is closed
Security logs: sign-in events, IP address, device type, app version	Protecting the App and investigating incidents	Legitimate interests, Art. 6(1)(f)	12 months
Service metrics: session length, language pair, error codes, with no consultation content	Running and improving the App	Legitimate interests, Art. 6(1)(f)	13 months, then anonymised
Billing data	Payment and tax records	Contract and legal obligation, Art. 6(1)(b) and (c)	6 years
Support messages	Answering your queries	Contract, Art. 6(1)(b)	24 months

2.1 We do not make automated decisions about patients or users that have legal or similarly significant effects.

2.2 We do not sell personal data or use it for advertising. Our Cookies Policy explains what the App stores on your device.

3. AI, storage and sharing

3.1 No AI training. We do not use consultation content to train or improve AI models. Our AI provider is contractually prohibited from doing so.

3.2 No storage after the session. Consultation content is held in encrypted memory only while the session is active. It is not saved to our databases, backups or logs, and it is deleted when the session ends. We cannot retrieve a past consultation. Clinicians must copy anything they need into their own clinical record before ending the session.

3.3 Where data is stored. Data for UK and all non-US accounts is processed and stored in the United Kingdom. Data for US accounts is processed and stored in the United States. Consultation content is not transferred between these regions. If our staff need to access account or support data from another country, we protect the transfer with the safeguards the law requires, such as the UK International Data Transfer Agreement.

3.4 Sub-processors.

Sub-processor	Service	Location
Google Cloud	Hosting and AI services	UK for UK accounts, US for US accounts
Microsoft 365	Email and support	UK and EU
HubSpot	Customer relationship management, business contact details only	EU and US

Apple and Google process purchase data as independent controllers when you buy through their app stores. We tell customers before adding a sub-processor that handles consultation content.

3.5 Other disclosures. We share personal data with others only where the law requires it, or with a buyer of our business under equivalent protections.

4. Security

4.1 We protect personal data with technical and organisational measures suitable for health data, including encryption in transit and at rest, multi-factor authentication, role-based access and staff training. Our information security management system is aligned with ISO/IEC 27001:2022, and we hold Cyber Essentials certification.

4.2 If a personal data breach affects an organisation's data, we notify that organisation without undue delay so it can meet its own legal obligations.

5. Your rights

5.1 Under UK and EU data protection law you can ask to access, correct or delete your personal data, restrict or object to its use, or receive it in a portable format.

5.2 In the United States, patients exercise their HIPAA rights through the organisation that treated them. App users in states with privacy laws can ask to access, correct or delete their account data, and can appeal our decision by emailing privacy@doctoria.co.uk.

5.3 To make a request, email privacy@doctoria.co.uk or go to Account > Privacy & Legal in the App. We reply within one month, or within 45 days for US state law requests. We may need to confirm your identity. Because we do not keep consultation content, we cannot answer requests about a past consultation.

5.4 Patients under 18 may take part in a consultation with a parent, guardian or clinician acting for them. The same deletion rules apply.

5.5 We will tell you in the App before we make material changes to this policy.

5.6 If you have a concern, please contact our DPO first. You can also complain to the Information Commissioner's Office (ico.org.uk), your local EU data protection authority, or, in the US, the HHS Office for Civil Rights or your state Attorney General.