DATA PROTECTION DECLARATION OF THE COMPANY

« DOCADOM SA »

1. General information

DOCADOM SA, a company with its registered office at Avenue Béthusy 29, 1004 Lausanne, Canton of Vaud, Switzerland (hereinafter referred to as the “Company”) is the owner of the “DOCADOM” application (also available on the website www.docadom.ch) (hereinafter referred to as the “Application”) and provider of the services offered by this application and provider of the services offered by this Application. The User is any person who accesses the DOCADOM application (hereinafter referred to as the “User”). These data protection declarations apply to both the DOCADOM application and the www.docadom.ch website.

DOCADOM SA is therefore responsible for the collection, processing and use of your data and ensures that its actions comply with Swiss law.

The protection of your personal data is of utmost importance to our Company.

We hereby inform you of the data that will be collected on our Application and how it will be used. You will also learn how to ensure that this information is correct and how to request the deletion of your data.

By using our Application, you expressly acknowledge that we may process your Personal Data in accordance with this Privacy Policy.

Please note that this Data Protection Statement may be subject to periodic changes. We therefore recommend that you read this Data Protection Statement regularly to ensure that you are always aware of the most recent version.

2. Collection, Use and Processing of Personal, Medical and Computer Data

2.1 Personal and medical data

“Personal data” means any information relating to an identified or identifiable physical person as defined by Swiss data protection legislation.

“Sensitive data” particularly refers to any information concerning a natural person’s health data or genetic data.

“Data Processor”: the person who determines the purposes and means of processing personal data.

“Sub-processor”: the person who carries out data processing in accordance with instructions defining the essential parameters for data protection. They act under the authority of and on the instructions of the Data Processor.

The Company acts as a Processor of Personal Data collected in the course of usage of the Application. The Application will collect personal and sensitive data about you – in particular in the context of making an appointment, in order to be able to inform the Doctor, who will go to the place of appointment, about the case to be treated.

This may include:

– Your last name, first name, home address, e-mail address, telephone number, gender;

Your insurance number;
Your pathologies and symptoms (sensitive data);
Any sensitive data you may share.

Access to the Application may not be possible if you do not wish to provide the requested information

2. The Company acts as a Sub-processor to the Doctors (who then act as Data Processors) with regard to Personal Data collected in the course of any consultation or follow-up with the Patient.

The Doctors will collect your personal and sensitive data – in particular in the context of booking an appointment and during the consultation – in order to be able to perform their services diligently as any competent professional in this field. You will be informed by the Data Responsible Physician about the data that is collected. You will be able to obtain information from the Data Responsible Physician at any time.

This may include:

Your last name, first name, home address, e-mail address, telephone number, gender;
Your insurance number;
Your medical and family history;
Your pathologies;
Your social environment and lifestyle;
Any data or information necessary for the anamnesis in order to establish a diagnosis;
Your therapy plan and management;
Your medical record.

3. Whether the Company acts as a Data Processor or Sub-processor, it takes the necessary measures to ensure the protection and confidentiality of the Personal and Sensitive Data that are held or processed, in compliance with the applicable legal regulations.

The Company may collect data and information and store it either in paper format or in electronic or computerized format, including on its Application.

This data and information will never (except in the case mentioned in the paragraph below) be transmitted to third parties not working in the medical field, except in the case of express agreement of its patients.

This data and information may only be transmitted to third parties outside the medical service for computer storage purposes (servers, computer companies etc.). These non-medical third parties will have to guarantee by separate agreement that this data will not be transmitted to third parties or stored outside Switzerland. In addition, such third parties shall undertake by separate agreement to take security measures to ensure optimal security and confidentiality of its data and information. The Company shall not be liable for any failure of its third parties. Any claims must be made directly against them, to the exclusion of any claims against the Company.

The following articles and provisions (from section 2.2 onwards) apply exclusively to electronic and navigation data, excluding Sensitive and Personal Data

2.2 Computer and navigation data

When the User visits the Application, certain information and navigation data are automatically recorded for system administration, statistical and security purposes.

This includes:

The name of the User’s Internet service provider;
The User’s IP address;
The version of the User’s browser software;
The operating system of the computer with which the User accessed the Website;
The date;
The time of day;
The website from which the User accessed the Website;
The search terms that the User used to find the Website.
The type of mobile phone and/or operating system.

By logging in or registering as a User and entering your data on the Website, you agree that your data may be used in connection with the services offered.

2.3 Doctors’ Data:

The Company collects information such as first name, last name, telephone number, from the Doctors. This also allows to inform the Patient of the information about the Doctor who will perform the medical visit.

3. Use and reason for collecting personal data

The User’s data is collected and used so that the Company can provide the service as described in the Terms and Conditions. The Patient must be able to identify himself/herself and explain his/her symptoms on the Application, so that a Doctor can carry out a medical visit. The Doctor’s data is collected and processed by DOCADOM so that the Patient can find out which Doctor will visit him/her.

As a responsible organization that respects your privacy, DOCADOM does not process User data in order to draw up a profile of the User via a profiling process. The Company does not make decisions with legal effects on Users based exclusively on automated processing (automated individual decision).

The Company may combine the User’s personal data with other information (aggregate it) or delete any identifying information (anonymize it), so that it is no longer considered Personal Data, in which case this Privacy Policy will no longer apply to such data and The Company may use it for purposes not provided for in this Policy (e.g., to perform anonymous statistics on the use of the Company’s Services).

Beyond the processing necessary to provide medical services, the Company may use certain Patient data, after irreversible anonymization, for scientific research, statistical analyses, or service improvement purposes.

Such anonymized data does not allow Patients to be identified and is therefore no longer considered personal data under the applicable legislation.

General consent for this use is obtained upon registration with the Application or the telephone service. Patients may withdraw this consent at any time, without affecting their access to medical services.

4. Transmission of personal data:

Your personal data may be transferred to our partners (third parties) if this is necessary for the provision of the services offered by the Company or for other legitimate reasons. If we transfer your data to external providers, technical and organizational measures will be taken to ensure that such transmissions comply with the legal provisions on data protection. If you provide us with your personal data, we undertake not to use, process or transmit it beyond what is permitted by law or by your consent. For this reason, we only pass on your data to external suppliers if this is necessary for the processing of appointments or for storage purposes and if this meets the strict requirements of confidentiality and diligence. Beyond this, we will only transfer your data to third parties if we are legally obliged to do so or if we are ordered to do so by the authorities or the authorities’ courts. You can inquire at any time about which partners your data is shared with.

The data may be passed on to the doctor who will visit you, in order to follow up on the appointment made on the Application. The Doctor obtains all the information relating to your situation, in order to be able to proceed with the medical consultation. The Doctor is solely responsible for processing your Personal Data in the context of a treatment or consultation, in accordance with the Data Protection Act. For more information on how the Doctor processes your Personal Data, please contact the Doctor directly.

In case of legal necessity, your data may be disclosed by the Company.

5. Transfer of data

Users’ personal data is stored in Switzerland.

User data is not made available to other countries, except under certain circumstances. Users’ Personal Data may be made available to recipients located abroad. Personal Data is only transferred abroad if the applicable legal requirements are met. Service providers abroad are obliged to observe data privacy to the same extent as the Company.

If you transmit data to us, you are considered to consent to such data transfers. You can request further information by sending us an e-mail: info@docadom.ch.

We only transfer your personal data, including medical information, to external third parties if the law permits, requires it, or if you have given your consent during your treatment.

Your data is transmitted to your health insurance, accident insurance, or disability insurance for the settlement of the services provided, in accordance with legal provisions.
Cantonal and national authorities, such as the cantonal medical service or health departments, receive your data in compliance with legal reporting obligations.
Optional: If necessary, required patient and billing information is transmitted to the debt collection agency for payment of debts.

Depending on your medical treatment and your consent, data may occasionally be transmitted to other authorized parties, such as laboratories or other doctors.

Services related to the application:

Usage Analysis

We collect information about your activity on our services and how you use them (e.g., the date and time of your connection, the functions you used, the clicks, and the pages presented to you) and how you interact with other users, via Segment. Segment is a data aggregation tool that captures data on how users interact with the product.

Usage data and other types of data indicated in the service’s privacy policy are processed. The place of processing is located in the United States. By continuing to navigate our Application, you declare your acceptance of this data transfer.

Application Monitoring

These types of services allow this Application to monitor the use and behavior of its components so its performance, operation, maintenance, and troubleshooting can be improved. What Personal Data will be processed depends on the characteristics and implementation of these services, whose function is to filter the activities of this Application. DOCADOM uses Sentry for this purpose. Sentry is an error and crash monitoring service that helps to discover, sort, and prioritize errors in real time. Sentry processes different types of Data indicated in the service’s privacy policy. Data is processed in the United States.

Push Notifications

This Application may send push notifications to the User for the purposes presented in this privacy policy. In most cases, it is possible to opt-out of receiving push notifications by checking the device’s settings, such as mobile phone notification settings, and then changing these settings for this Application, for some, or for all apps on that particular device. Users should be aware that disabling push notifications may negatively affect the use of this Application, especially when a medical consultation is requested.

The Application uses Wonderpush. Wonderpush is a service designed to send push notifications to mobile apps and websites. Different types of Data indicated in the service’s privacy policy are processed.

The place of processing the data is in France.

By continuing to navigate our Application, you declare your acceptance of this data transfer.

Platform and Hosting Services

These services serve to host and run key components of this Application, thereby enabling the provision of this Application from a unified platform. This type of platform provides DOCADOM with a wide range of tools, such as: analytics, user registration, commenting, database management, e-commerce, payment processing – which involves the collection and handling of Personal Data.

Some of these services operate through geographically dispersed servers, making it difficult to determine the actual location where personal data is stored.

DOCADOM makes its application available on the Apple App Store (Apple Inc.), a platform for the distribution of mobile applications provided by Apple Inc. Because of its distribution through this app store, Apple collects basic analytics and provides reporting features that allow DOCADOM to view usage analytics and measure the performance of this Application. Much of this information is processed on an opt-in basis. Users can block this analysis feature directly through their device settings. More information on how to manage analytics settings can be found on this page. Usage data is processed. The place of processing is the United States. Data protection declaration: https://www.apple.com/legal/privacy/

DOCADOM is distributed on the Google Play Store (Google Ireland Limited), a platform for the distribution of mobile applications provided by Google Ireland Limited. Because of its distribution through this app store, Google collects usage and diagnostic data and shares aggregated information with DOCADOM. Much of this information is processed on an opt-in basis. Users can block this analysis feature directly through their device settings. Personal data processed: Usage data. Place of processing: Ireland. Privacy policy. By continuing to navigate our Application, you declare your acceptance of this data transfer.

The website www.docadom.ch may contain interactive buttons called “social media plugins” that allow establishing a connection with the servers of social networks such as Facebook, Twitter, Instagram, etc. When you click on one of these buttons, you agree that certain necessary data, such as your IP address and your browsing activities on the website, are transmitted to the operator of the concerned social network. This data transfer is carried out in accordance with the privacy policy of each social network, allowing the social network to personalize your experience, present you with targeted ads, and improve their services in general.

The main purpose of social media buttons is to facilitate the sharing of content between the website and social media platforms. By integrating these buttons, the site allows users to share articles, images, videos, and other interesting content with their friends and followers on social media with a single click.

It is essential to consider this information before interacting with social media plugins. If you have concerns about the collection or use of your data by these social networks, we encourage you to consult their privacy policies to learn more about how your data is processed. Your continued use of this website is considered acceptance of these terms of use for social media plugins. By continuing to navigate our website, you declare your acceptance of this data transfer.

6. Data retention:

The User’s data shall be deleted as soon as it is no longer required for the performance of the service offered by DOCADOM. The duration may vary depending on the type of data concerned and the applicable legal requirements.

Generally, your personal data is retained for a duration of [x weeks/months]. If we collect your IP address, it is only saved for the duration of your use of the website and is then immediately deleted or made anonymous by truncation.

Personal data are collected as part of the contractual relationship between DOCAOM and the User. This data is kept for the duration of the contractual relationship, as long as a User’s account is active, and is then archived for the legal retention period.

Data collected on the basis of User consent is retained until the User revokes consent.

Personal data collected for the Company’s legitimate interests (market research, legal purposes or to improve services,) is retained for as long as necessary to achieve those purposes.

Data used for research or statistical analysis purposes is stored exclusively in an anonymized form, which does not allow the identification of Patients.

The Company may also need to keep the User’s personal data for a longer period of time, if this is necessary to comply with a legal obligation (e.g. accounting rules or tax law), by order of an authority or in the context of a legal proceeding. Certain information relating in particular to the contractual relationship must be kept for at least 10 years and certain data relating to care services for at least 20 years.

The retention periods for personal data are determined solely by the Company in its capacity as Data Processor. In the case of processing carried out as a Sub-processor, the Company acts only on the instructions of the Processors and does not determine the retention period itself. If you have any questions about the duration of the storage of personal data for which DOCADOM acts as a Processor, you are advised to contact your Doctor, the Data Processor, directly. In view of the legal filing obligations for Healthcare Professionals, they may store Users’ Personal Data on their own tools for longer periods than those indicated above in order to ensure that Patients receive optimum medical follow-up and care.

7. Right of access, deletion and rectification

You can request information about the data we collect about you at any time (right of access). To do so, you need to send us a request for information together with a document confirming your identity by e-mail to the address given below.

You also have the right to request the deletion or correction of your data at any time. Of course, you also have the right to revoke your consent to the future use or processing of your personal data at any time. For these matters, please write to us by e-mail to the following address info@docadom.ch

Stored data that are no longer necessary to achieve the stated purpose will be deleted.

With regard to the deletion of data, it should be noted that we are subject to legal provisions that require certain data to be retained and are therefore obliged to comply with them. If you wish to delete data subject to this retention obligation, we will lock this data in our system and use it only in connection with the legal retention obligations. This data will be deleted after the end of the retention period in accordance with your request.

8. Data Security

We – or our third-party IT service providers – will keep your data secure and will therefore take all necessary measures to protect it from loss, unauthorized access, misuse or otherwise. Our employees and contractual partners who have access to your data are subject to a contractual obligation of confidentiality and must comply with the legal provisions on data protection. In some cases, it will be necessary for us to transmit your inquiries to our affiliated companies. In these cases, too, your data will be treated as strictly confidential. The Company cannot be held responsible for any breaches of duty by third-party service providers. Any claims must be made directly against them, to the exclusion of any claims against the Company.

9. Cookies

We use cookies to facilitate the use of our Website.

Cookies are small files which, on DOCADOM, only contain information relating to your browsing preferences and in no case sensitive information.

These cookies are necessary for the proper functioning of our website. The information contained in the cookies is used to improve your browsing experience on our website and to ensure optimum user comfort.

Cookies are automatically accepted by most navigators. You can prevent this by changing the settings. You can also delete all Cookies stored on your web navigator by deleting the temporary files.

By disabling cookies, you may not be able to take advantage of all the features available on our website.

Cookies for tracking and audience measurement on the website:

Cookies for analysis and audience measurement cookies are used on our website (www.docadom.ch), to improve our services and to guarantee you a pleasant experience.

The purpose of these cookies is to allow monitoring and analysis of the content available on our website and the ergonomics of the site.

These cookies are in no way intended to identify the people who visit the website and do not have this function. The sole purpose of these cookies is to generate traffic statistics. Thus, the cookies are not linked to the user’s account and the data collected is not cross-referenced with other personal data processing.

It is possible to deactivate these cookies at any time by going to the cookie management page.

10. Changes

Any changes to this data protection declaration will be published on this application. This way, you can inform yourself about the stored data and how we collect and use them at any time. You can save or print the data protection statement here: https://www.admin.ch/opc/fr/classified-compilation/19920153/index.html.

11. Acceptance of Data Processing

By ticking “validate,” I confirm that I consent to the processing of my personal and sensitive data, to their access by DOCADOM SA and by the Doctor, as well as to their transmission to third parties in accordance with this Privacy Policy.

I also consent to certain of my data being used in a strictly anonymized form for statistical analyses, scientific research, or service improvement purposes. Under no circumstances will personally identifiable data allowing my direct identification be used for these purposes without my prior written consent. I may withdraw this consent at any time by contacting info@docadom.ch, without this affecting my access to medical services.

I further consent to mutual communication between DOCADOM, the Doctors, and myself as a patient via the Application. DOCADOM transmits patient information exclusively through secure communication channels. I accept that communication may take place via the DOCADOM Application and/or, when necessary, by unencrypted e-mail or SMS, being informed of the risks associated with these means of communication.

Finally, I acknowledge that the Federal Health Insurance Act (LAMal) requires patients to receive a copy of DOCADOM’s invoice.

12. Contact

If you have any questions or comments, you can contact us at any time by e-mail at the following address : info@docadom.ch

Our team will be pleased to answer you!

Status as of September 9, 2025

Data protection