Privacy Policy

Personal information health records and identity verification

Last Updated: October 6, 2026

1 Who we are and what this notice covers

Health Online is operated by Healthcare Innovative Solutions B.V., registered in Curaçao under Chamber of Commerce number 163506 (HISBV). Contact us at info@healthonline.app or through healthonline.app about personal-data processing and rights. This notice applies to the app, website, professional and partner accounts, consultations and local-account verification.

HISBV is responsible for its own account, administration, security, billing and eligibility processing. Treating professionals have independent responsibilities for clinical care and recordkeeping. Where HISBV handles records only on a professional’s behalf, it acts in that processing role. Curaçao privacy law applies, and the GDPR applies where its legal conditions are met; a foreign user’s nationality alone does not determine applicability.

2 Information we process

Account and administration information may include name, date of birth, contact details, account credentials, account role, representative authority, professional credentials, partner details and payment references. Health information includes submitted symptoms, history, medication, allergies, consultation communications, clinical notes, diagnoses, prescriptions and uploaded medical documents.

Technical information may include IP address, device and browser information, session and security events, service usage and access records. We record contract acceptances, privacy-notice acknowledgements and separate consents with their versions and timestamps. Payment providers process payment-method information; HISBV does not store full payment-card details.

Local-account verification uses Didit as described below. Its verification data is distinct from the clinical record. We do not intentionally collect more information than necessary for the function being used.

3 Purposes and legal bases

We process information to create and operate accounts, arrange requested services, administer bookings and payments, verify credentials and local-account eligibility, protect the Platform, handle support and complaints, and meet legal obligations. The basis depends on the purpose: performance of a contract or pre-contractual request, legal obligation, proportionate legitimate interests or consent where required.

Health data requires an additional lawful condition under applicable law. Where we rely on explicit consent for Platform health-data processing, it is requested separately through the Patient Consent and Terms of Care process. Professionals may process health data under the applicable healthcare and professional-secrecy conditions. General contract acceptance is not permission for unrelated use of health information.

Where legitimate interests are relied on, we consider necessity and the impact on individuals. Optional marketing, non-essential tracking and any separately required biometric consent are not bundled with consent to medical treatment. We do not sell personal or health data for marketing.

4 Electronic acknowledgement

This notice is the same for each relevant user group and contains no individual name or signature fields. The app records that you received or acknowledged the relevant version; this does not waive privacy rights or itself provide consent for every processing activity. The notice and your applicable consent records remain available through the account or on verified request after closure.

5 Didit and local account eligibility

A local account and access to local prices require successful verification of a valid Curaçao identity card through Didit. The purpose is to verify the document and identity needed for that pricing status. This rule does not impose a separate residence test. A passport alone does not meet this local-account criterion.

Didit processes verification information on behalf of HISBV for this purpose. HISBV remains responsible for deciding why the verification is required and for instructing the service appropriately. Didit’s security measures do not remove HISBV’s own obligations.

HISBV does not store photographs or copies of identity cards or passports in its own systems. Identity-document images and information submitted through the verification flow are processed by Didit. Depending on the checks enabled and explained before verification, the flow may involve a selfie, liveness or facial matching, document data and relevant technical information. If a check processes biometric data requiring separate consent, that consent is requested before the check.

We use the verification result to determine local-account eligibility. Only the minimum result information necessary to administer that status may be retained by HISBV. The verification notice made available before the check identifies the result information received and retained, enabled checks, retention arrangements and relevant provider information. We do not represent that Didit retains no data simply because HISBV keeps no ID image copies.

6 Verification retention and review

Verification inputs held by Didit and eligibility information held by HISBV serve different purposes and are subject to separate retention arrangements. The verification notice specifies the applicable periods or deletion triggers before collection. Document and biometric material must not automatically inherit the medical-record retention period.

Eligibility information is retained only as needed to administer local status, resolve a related dispute or meet a legal duty, with periodic review. Verification images and any biometric templates must be covered by the configured deletion instructions and applicable legal basis. Any separate retention after deletion of a verification session must be disclosed before collection and justified independently.

If you do not complete verification, local prices are not activated. An unsuccessful check is not by itself a finding of fraud. Contact info@healthonline.app to challenge an apparent error, request human review or ask about your data. A pricing verification is not a clinical assessment and does not authorise a medical decision.

7 Who receives information

Treating and appropriately involved professionals receive information needed for authorised care. Authorised HISBV personnel may access limited information for necessary administration, support, security or legal functions; medical access is restricted to a justified purpose.

Service providers support hosting, communications, payments, verification and support under the role and safeguards appropriate to the activity. These include AWS, communications providers such as Twilio where used, Stripe for payment processing and Didit for local-account verification. The designated Netherlands payment entity facilitates payments and receives the information needed for that function, not routine clinical content. Its legal identity is disclosed in payment information.

Current provider information is made available through the Platform. Hotels and employers do not receive individual clinical records through their partnership. Data may be disclosed where law requires it, for lawful claims or in a properly safeguarded business transfer, with notice and rights respected where required.

8 Retention of medical and other records

Medical records are retained for the period required by the law applicable to the treating professional and the care, and longer where lawful and necessary for continuing care or a specific legal reason. The responsible professional and HISBV arrange custody consistently with their respective roles. Ending a paid plan, closing an account or becoming inactive does not automatically end a medical-record duty or trigger deletion.

A request for destruction is assessed separately against the applicable patient right, professional duties and statutory exceptions. During a lawful retention period, restricted archiving may replace ordinary app access. After the purpose and legal retention duties end, records are securely deleted or irreversibly anonymised under the applicable deletion and backup arrangements.

Payment, invoice and accounting information is kept for applicable tax, accounting and claim periods. Account information is kept while needed for the relationship and necessary closure, fraud or dispute handling. Security logs are kept for a proportionate investigation and protection period. Acceptance and consent evidence is kept for the relevant relationship and applicable legal evidence period. Optional marketing information is removed from active campaigns on withdrawal; a minimal suppression record may be retained to honour the choice.

The purpose-specific retention schedule is available through the Platform or on request. Specific periods and backup deletion cycles must reflect the actual services and legal duties. We do not promise immediate deletion from every backup where controlled backup expiry is required; restored data remains subject to outstanding deletion instructions.

9 International processing

Platform administration is based in Curaçao. Providers and payment facilities may process data elsewhere. Didit describes EU processing as its default; the service’s actual region and applicable arrangements must be reflected in the verification and provider information made available to users.

Where the GDPR or another applicable regime restricts an international transfer, we use an appropriate lawful mechanism, such as an applicable adequacy decision or contractual safeguards, together with any required assessment and supplementary protections. Contractual safeguards do not make all transfers automatically lawful. You may request information about the safeguards relevant to your data.

10 Security and incidents

We use safeguards appropriate to the sensitivity and risk of the information, including restricted access, secure transmission, account protection, controlled administration and incident handling. Professionals and service providers must protect data under their applicable obligations. We limit medical access and investigate suspected misuse.

No system can guarantee absolute security. If a breach occurs, the responsible party assesses the risk and makes required regulatory and individual notifications within applicable deadlines. Affected individuals are informed without undue delay where the law requires it; the threshold and timing for individual notice may differ from notice to a regulator. This notice does not waive our security obligations

11 Your rights

Depending on applicable law, you may request access, a copy, correction, restriction, portability or deletion of your information, object to processing based on legitimate interests, withdraw consent, and challenge qualifying automated decisions. Where a record must remain accurate for clinical reasons, a correction or supplementary statement may be recorded without erasing the original clinical history.

Send requests through the app or to info@healthonline.app. We verify identity proportionately and coordinate with the responsible professional or provider where needed. Requests are answered within the applicable statutory period; where the GDPR applies, ordinarily within one month, with any lawful extension explained. Rights may be limited by legal retention, another person’s rights or other applicable exceptions, with reasons supplied where permitted.

You may complain to the competent data-protection authority and seek judicial remedies. Contacting us first is welcome but not a condition for exercising those rights. Mandatory rights are not displaced by Curaçao jurisdiction provisions in another document.

12 Children and representatives

Account registration is intended for adults or persons able to contract under applicable law. Where supported, an authorised adult may arrange care for a minor or represented patient through the appropriate patient profile. We process only the information needed for that arrangement and verify authority as appropriate.

Parental involvement does not remove the patient’s own rights to confidentiality, information or consent where law recognises them. A suspected unauthorised child account is reviewed and access may be restricted; medical records are handled according to lawful retention and safeguarding requirements rather than automatically destroyed.

13 Cookies analytics and communications

Essential technologies support login, security and requested functions. Optional analytics or tracking is subject to the choices and consent required by applicable law. The relevant interface explains the enabled technologies and allows optional consent to be withdrawn. Browser settings may provide additional controls but do not replace any consent we are required to obtain.

Service messages include booking, billing, safety, security and legal notices. Optional marketing can be declined or stopped through the unsubscribe or preference controls. Withdrawing marketing permission does not stop necessary service communications. Health information is not used for targeted advertising under these terms.

14 Changes and continuing access

We notify material changes through the app or registered contact channel before they apply, except where an earlier change is legally necessary. New processing that requires consent will not rely solely on continued use or acknowledgement of this notice.

The current notice, applicable earlier versions and relevant supplementary verification information remain accessible through the account. After closure, request copies at info@healthonline.app. This notice explains practices; it does not create permission to process data contrary to law or to the specific consent given.