Privacy Policy

01Who is responsible

For your account data (as our customer), the controller is CodeSoft Lab LLC.

For patient and caregiver data entered by a practice, the controller is the practice; CodeSoft Lab LLC acts as processor. Patients who wish to exercise their rights should first contact their practice.

02Data we process

Depending on use:

• Account details: name, email, phone, role, practice
• Patient data entered by the practice: contact details, history, diagnoses, exams, treatments, appointments, documents
• Inpatient caregiver data: name, relationship, contact details
• Usage data: sign-ins, actions in the app (activity history)
• Technical data: IP address, browser, device
• Payment details: processed directly by the payment provider — we do not store card numbers

03Why we use it

We use data to:

• provide, secure and improve the service
• manage your account and subscription
• send notifications, reminders and portal links on behalf of the practice
• provide technical support
• comply with legal obligations

04Legal basis

Processing is based on our contract with you, our legal obligations, our legitimate interests (e.g. service security) and, where required, consent. For health data, the legal basis is determined by the practice as controller.

05Partners & sub-processors

We do not sell or share data for commercial purposes. We only use the necessary providers, bound by confidentiality and security obligations:

• hosting and database
• email and SMS delivery
• subscription payments
• telehealth video
• AI provider — only if the practice enables AI features with its own key
• Google Calendar — only if the practice connects its account

06Transfers outside the EEA

If a provider processes data outside the European Economic Area, the transfer takes place with the appropriate safeguards required by the GDPR.

07Security

We apply technical and organisational measures, including:

• encryption in transit (TLS) and at rest
• per-practice data isolation at database level (row-level security)
• roles and permissions per member (RBAC)
• portals with personal, time-limited links
• an activity history for every record
• regular backups

08Retention

Account data is kept while the subscription is active and for a reasonable period afterwards for legal and accounting purposes. Patient data is kept according to the practice's instructions and medical record-keeping obligations; after the relationship ends, the practice can request its export and deletion.

09BrainRM patient account

For the optional BrainRM patient account, the controller of the account's own data is CodeSoft Lab LLC; for the record held at each practice, the practice remains the controller. We process:

• email, the date it was verified, language and the version of the terms you accepted
• a password only as an irreversible hash (scrypt), if you choose to set one
• passkeys (Face ID, fingerprint etc.): only the public key, its identifier and the device name — biometric data never leaves your device
• one-time email codes, stored only as a hash and deleted after 7 days
• sessions and the account's security history (sign-ins, changes, links to practices), with device type and a hashed IP address
• the links between the account and your records at practices

10Record sharing between practices

Sharing is decided by the patient: they choose the source practices, the categories of items and the duration, and explicitly approve every request. Before approval, the requesting practice only sees the name, date of birth, source practices and categories. Mental health, sexual health, HIV and genetics are shared only if explicitly chosen; private psychotherapy notes and the doctor's free-text notes are never shared.

On approval, the receiving practice gets a copy of the selected items (and the patient's national ID number to match the record) and becomes the controller of that copy. Revoking stops future updates but does not delete what has already been copied; for rectification or erasure the patient contacts the practice that received it, subject to the legal exceptions for medical records.

CodeSoft Lab LLC performs the transfer as processor on behalf of the practices, on the patient's instruction. We log who requested, approved or revoked and when, and how many items per category were transferred — not their content. Source practices see in their activity history that a share was made on the patient's instruction.

11Links for doctors without BrainRM

A patient can give a doctor who does not use BrainRM a read-only link or QR code (International Patient Summary / SMART Health Links standards). The content is built at the moment of creation and stored encrypted with a key that exists only inside the link — we do not store it and cannot read it.

The link expires in 24 hours, in 7 days or after one view, can be protected with a PIN (locked after 5 wrong attempts) and can be revoked by the patient at any time. On expiry, revocation or lock the encrypted content is deleted.

So that the patient can see when the link was opened, we log every opening, wrong PIN and revocation, with time, device type, a hashed IP address and the name the reader entered. These entries are deleted after 180 days. The viewing page uses no analytics and no cookies. If the doctor prints or downloads the summary, that copy is then their responsibility.

12Support requests

When you send a support request from inside the app, we process the subject, category, description and your attachments, your name, email and practice, as well as technical details attached automatically:

• the app page and its title
• the browser and operating system (user agent) and its language
• screen and window size and time zone
• the app's interface style and color theme

13Your rights

Under the GDPR you have the right to:

• access your data
• rectify inaccurate data
• erasure
• restrict processing
• data portability in a readable format
• object
• withdraw consent at any time
• lodge a complaint with the competent supervisory authority

14Cookies

We use the necessary cookies and browser local storage to run the app: sign-in, security and preferences such as language and appearance. These do not require consent.

Only if you accept it in the cookie notice, we measure traffic anonymously and in aggregate (Vercel Web Analytics) to improve our pages. We do not use advertising cookies or third-party tracking cookies.

You can change your choice at any time from the "Cookie settings" link at the bottom of every page.

15Contact

For questions about data protection or to exercise your rights, write to us at info@codesoftlab.com.