Almost.MD

notice-v2

Privacy notice: almost.md and the Almost.MD waitlist

Version 2,

This notice explains what happens to your data when you visit almost.md and when you join the Almost.MD waitlist there.

Who we are

The controller of your data is Meducase sp. z o.o., ul. Karpacka 18A, 54-617 Wrocław, Poland, entered in the National Court Register (KRS) under number 0000581184, NIP 8943067789, REGON 362777567. Almost.MD is a Meducase product.

Write to privacy@mdcse.com about anything in this notice. We have not appointed a data protection officer. For other questions, write to hello@almost.md.

You must be 16 or older

The waitlist is for people aged 16 or over. By ticking the box you confirm you are at least 16. If you are younger, please don't sign up. If we learn that a sign-up belongs to someone under 16, we delete it.

What we collect

When you visit almost.md, our server reads only what each page request carries anyway, and nothing else from your browser:

  • the kind of page you open and, on a Cohort link, its Medical school, but never the page's address or anything from a private link;
  • the language of the page;
  • the day of your visit;
  • whether the request comes from a bot, judged by its User-Agent or by the lack of one. We count a bot's view apart, with no country, city or Entry source, and the counts keep nothing of the User-Agent;
  • whether your browser is only loading the page ahead of time (a prefetch), which we don't count;
  • your IP address, shortened to its network (the first three of the four numbers of an IPv4 address, or the first 48 bits of an IPv6 address). Our server uses it only to look up your country and city in a database on our own server, and drops it in the same request;
  • how you reached almost.md (the Entry source): the campaign tags of the link you followed (utm_source, utm_medium, utm_campaign), or else the website you came from, or else that you came directly.

From these we keep only daily counts: views per page and language, with bots counted apart; views per country and city; entries per entry page, language and Entry source; sign-ups, confirmations and unsubscribes per Medical school, language and Entry source, where all school names typed in by hand count together, never under the name typed; and full Cohorts per Medical school. The counts hold no IP address and no identifier, and we keep a city together with nothing but its country and the day. A count of a few views or sign-ups can still point to you, together with what your sign-up keeps, such as its day, Medical school and Entry source, so we treat the counts of pages, entries and waitlist steps as your personal data. We write the counts of cities only once a day is over, all of that day's cities together, so that they point to nobody.

When you join the waitlist, we also collect:

  • your email address;
  • the language of the page you signed up on;
  • your Medical school as you picked it from our list, or the name you typed if your school isn't listed, or that you're not in medical school yet (Pre-Med);
  • your consent: that you ticked the box, when, and the version of its wording (this includes your statement that you are 16 or older);
  • your answer, Yes or No, to our question about emails on Meducase products: when you gave it, the version of the question's wording and of this notice, when you last extended a Yes, and, if you withdraw a Yes, when you did;
  • the Entry source of your sign-up: its source, medium and campaign, but never your city;
  • the Sign-up number and Cohort you get when you confirm your email, and the status of your sign-up (unconfirmed, confirmed, invited, voided);
  • a record of each email we send you: its type, when we sent it, and the delivery id from our email provider (Resend);
  • which of the daily counts your sign-up and your confirmation went into, so that we can take them out if you ask us to delete your data or object to the counts, and whether you objected;
  • private links in our emails: to confirm your address, to unsubscribe, to stop emails about Meducase products if you said Yes to them, to extend that Yes, to your Player card, and, if we can't find the school you typed, to pick it from our list;
  • a one-way hash of your IP address, to stop abuse.

We set no cookies on almost.md, run no analytics in your browser and do not fingerprint your device. Our server counts visits as described above. We do not track whether you open our emails or click their links.

Why we use it, and on what legal basis

  1. To send you emails about the launch, on your consent (GDPR art. 6(1)(a)). They are:

    • the email asking you to confirm your address;
    • the "You're #N" email with your Sign-up number and Player card;
    • "You're already on the list", with your Player card link, if you sign up again with an address that is already confirmed;
    • if you typed your school's name: an email when we add it, or when we can't find it;
    • "Your Cohort is full", once;
    • your invite to the closed beta;
    • the public launch;
    • between these, at most one email a month with news about the launch.
  2. To place you in a Cohort and give you a Sign-up number and Player card, on the same consent. Full Cohorts get invited first. On almost.md we show how many people from each Medical school have signed up, as counts only, never names or email addresses. Your Player card is visible only to people you share its link with.
  3. To send you emails about Meducase products, if you said Yes to them, on your consent (GDPR art. 6(1)(a)) and, because they come by email, your prior consent under art. 398 of the Electronic Communications Law (Prawo komunikacji elektronicznej). They are emails from Meducase, the company behind Almost.MD and TheCall, about its products for future and current medical students and health professionals: new tools and early access for students and, after the public launch, Almost.MD. The launch emails in point 1, the news about the launch among them, are not emails about Meducase products: your consent to the waitlist covers them. One of the emails about Meducase products is the reminder that we send you before your Yes ends (see below).
  4. To prevent abuse (bulk and fake sign-ups, rate limits), and to show that we had your consent, also after we delete your sign-up, on our legitimate interest (art. 6(1)(f)) in keeping the waitlist fair, meeting our duty to prove consent (art. 7(1)) and defending legal claims. This includes a Yes to emails about Meducase products after you withdraw it or after it ends. We keep this proof even if you ask us to delete your data (art. 17(3)(e)).
  5. To count visits to almost.md and where they come from, on our legitimate interest (art. 6(1)(f)) in knowing which pages, places and channels bring visitors and sign-ups, so that we can plan where to reach out to Medical schools and cities before the closed beta. This covers reading each page request as described above, the daily counts, the Entry source of your sign-up and which counts your sign-up went into.

Giving us your data is voluntary, but without your email address and the ticked box we can't put you on the waitlist. Consent to emails about Meducase products is up to you: when you confirm your address, we ask you to answer Yes or No, and either answer confirms your sign-up the same way. We make no decisions about you based solely on automated processing that have legal or similarly significant effects.

Who else processes your data

We use these service providers, who process data only on our instructions under data processing agreements:

Provider What it does Where the data are Transfer outside the EEA
Northflank Ltd (UK) hosts almost.md and its database until we move to Hetzner EU data centre in Frankfurt to the UK, on the European Commission's adequacy decision for the UK
Hetzner Online GmbH (Germany) hosts almost.md and its database after the move, planned before the closed beta Germany none
Plus Five Five, Inc. (Resend), USA sends our emails emails are sent from the EU; account data and sending logs are stored in the USA to the USA, on the EU-US Data Privacy Framework (art. 45 GDPR), with the Commission's standard contractual clauses as a fallback (art. 46(2)(c))
Cloudflare, Inc., USA runs our domain's DNS and forwards mail sent to hello@almost.md global network to the USA, on the EU-US Data Privacy Framework, with standard contractual clauses as a fallback
Functional Software, Inc. (Sentry), USA records technical errors; we keep personal data out of error reports EU data region possible to the USA through its subprocessors, on the EU-US Data Privacy Framework, with standard contractual clauses as a fallback

You can ask us for a copy of the safeguards for any transfer at privacy@mdcse.com. We look up countries and cities in a copy of DB-IP's database on our own server, so nothing about your visit reaches DB-IP. We do not sell your data or share it with anyone else, unless the law requires us to.

How long we keep it

Your sign-up We keep it until
Not confirmed 14 days after you signed up
You unsubscribe We delete it at once, and keep only the proof of your consent (below).
Confirmed, and you don't create an account 6 months after the public launch of Almost.MD. Then we keep only the proof of your consent (below) and, if your Yes to emails about Meducase products still stands, what we need to go on sending them (below).
You create an Almost.MD account We remove it from the waitlist; your Sign-up number and Medical school move to your profile, which the app's privacy notice covers.
We void it for abuse, such as a fake or bulk sign-up 30 days after we void it, or when you unsubscribe, if that is sooner. While we keep it, the same address can't sign up again. If you had confirmed your address before, we then keep only the proof of your consent (below).
Proof of your consent We keep it for 5 years after we delete your sign-up, when we delete it because you unsubscribe or ask us to delete your data, or because its time is up after you confirmed your address. It holds only: a hash of your email address made with a secret key, from which no one can read the address; the language of your sign-up; the date of your consent and its wording version; the date you confirmed your address, if you did; if you said Yes to emails about Meducase products, the date of that Yes, the versions of the question's wording and of this notice, the date you last extended it and the date you withdrew it, if you did; and the date of the deletion, and whether you had withdrawn a consent or the time was up. We keep it only to show that we had your consent, and it doesn't stop you from signing up again. A sign-up you never confirmed leaves no proof when its time is up. When we delete what we keep to send you emails about Meducase products, we keep a proof of your Yes to them in the same way, for the same 5 years.
Your Yes to emails about Meducase products It stands until you withdraw it, or until 3 years after you said Yes or last extended it. 30 days before the end, we send you one reminder with a link to extend it: press the button on the page that the link opens, and your Yes stands for 3 years from then. When we delete your confirmed sign-up 6 months after the public launch, a Yes that stands outlives it: we keep only your email address, the language of your sign-up, your Yes with its dates and versions, the link in our emails that stops them, and a record of each email we send you, so that we can go on sending them. When your Yes ends, or you withdraw it or ask us to delete your data, we delete these too and keep only the proof of your consent.
IP address hash 30 days
Our emails to you Our email provider, Resend, keeps each email, with your address, for 30 days after we send it, and its backups keep it 7 days more. If you ask us to delete your data within that time, we ask Resend to delete them.

Your answer about emails on Meducase products stays with your sign-up and goes when it goes, except a Yes that outlives it (above). The Entry source of your sign-up and which daily counts it went into stay with your sign-up and go when it goes. If you withdraw a Yes, or it ends, we keep the Yes with your sign-up, with the date you withdrew it, to show that the emails before were sent with your consent.

We keep the daily counts for 25 months, so that we can compare a month with the same month a year before. Your visits count with nothing that tells them apart from other people's. While your sign-up exists, we can find two things in the counts: your waitlist steps, and the visit on which you signed up, if you came to that page from outside almost.md and no other count of that day holds the same Entry source in your language. If you ask us to delete your data, or object to the counts, we take your sign-up, your confirmation and that visit out of them. We cannot find your other visits (GDPR art. 11(2)). Once your sign-up is gone, we can still find two of your steps: your unsubscribe, if no one else unsubscribed, asked us to delete their data, or stopped emails about Meducase products after their sign-up was gone, on that day; and the confirmation of your address, if no one else confirmed their address in your language on that day. We take them out if you ask. Your other steps and your visits we can no longer tell apart from other people's.

What we delete stays in the backups of our database until they expire, at most 30 days later. We use the backups only to restore the database after a failure.

Your rights

  • Withdraw your consent to the launch emails at any time, and leave the waitlist: use the unsubscribe link at the bottom of any launch email, or your mail app's Unsubscribe button on one, or write to us. We delete your sign-up, and emails about Meducase products stop with it.
  • Withdraw your consent to emails about Meducase products at any time, and keep your place on the list: use the "Stop emails about Meducase products" link at the bottom of our emails, or your mail app's Unsubscribe button on an email about Meducase products, or write to hello@almost.md. If your Yes outlives your sign-up, the link keeps working. Neither withdrawal affects the lawfulness of what we did before it.
  • Object to direct marketing at any time (GDPR art. 21(2) and (3)): emails about Meducase products are direct marketing, and once you object, we stop sending them to you. You can object in the same ways as you withdraw your consent to them.
  • Access your data and get a copy, correct it (to change your Medical school, write to hello@almost.md), delete it, restrict its use, and receive it in a machine-readable format to pass to someone else. A copy shows which daily counts hold your waitlist steps and the visit on which you signed up, as far as we can find them, but not how many other people they count.
  • Object to our use of your data based on legitimate interest. Your browser can object for you to the lookup of your country and city and to the Entry source: if it sends Global Privacy Control or Do Not Track, we skip both: we count your views and your sign-up without them, and your sign-up stores no Entry source. To object to the Entry source that your sign-up already stores, write to privacy@mdcse.com. To object to the counts of your waitlist steps and keep your place on the list, write to privacy@mdcse.com: we take your sign-up, your confirmation and the visit on which you signed up out of the counts, as far as we can find them, and count none of this sign-up's later steps.
  • Complain to a supervisory authority. In Poland that is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl). You can also complain in the EU country where you live or work.

Write to privacy@mdcse.com to use any of these rights. We answer within one month.

Changes

If we change this notice, we publish the new version here with its date. If a change affects what you consented to, we ask again.