Privacy Policy

1. Who we are

Doctors My Agency ("we", "us", "our") operates the Clinic-OS platform — a Software-as-a-Service (SaaS) product that gives individual doctors and clinics an AI-powered receptionist, appointment booking system, patient CRM, and WhatsApp Business messaging interface.

We are the data controller for platform account data (clinic registration, billing, usage logs). We act as a data processor for patient data that subscribing clinics manage through the platform.

Registered address: doctorsmyagency.com  ·  Contact: support@doctorsmyagency.com

2. What data we collect

2.1 Clinic account data

• Owner name, clinic name, specialty, address, phone number, email
• Account credentials (email + hashed password — we never store plain-text passwords)
• Subscription and billing information (processed by Stripe; we store only plan status and Stripe customer IDs)
• Working hours, treatments offered, AI personality and language settings
• Google Place ID and API key (optional, for review request features)

2.2 Staff data

• Name, email, phone, role (Receptionist / Nurse / Assistant / Manager)
• Login credentials (email + hashed password)

2.3 Patient data (entered by clinics or via inbound messaging)

• Full name, phone number, email address, date of birth, gender
• Medical notes, allergies, blood group (if entered by clinic staff)
• Appointment history, treatment records
• Opt-out / consent status for automated messaging

2.4 Message data

• Inbound and outbound WhatsApp message content (text; media metadata for non-text types)
• AI-generated replies and intent/lead-score classifications
• Message direction, timestamps, read status

2.5 Technical & usage data

• IP addresses, browser type, device type (for security and debugging)
• API request logs and error logs (retained for 30 days)
• Appointment booking analytics and AI performance metrics

3. WhatsApp Business API data

3.1 What we collect via WhatsApp

• Inbound patient messages (text, and metadata for audio/image/document types)
• Patient phone numbers (sender ID from Meta webhook payloads)
• Message IDs assigned by Meta
• WhatsApp Business Account ID (WABA ID) and Phone Number ID for each connected clinic
• OAuth access tokens (encrypted at rest using AES-256-GCM)

3.2 How WhatsApp data is used

• To route messages to the correct clinic's AI receptionist
• To generate and send AI replies on behalf of the clinic
• To create/update patient records and appointment bookings
• To power the clinic's message inbox and analytics dashboard

3.3 Meta's own data use

Messages sent through the WhatsApp Business API are also subject to WhatsApp's Business Policy and Meta's Privacy Policy. Meta processes message metadata in accordance with those policies independently of Doctors My Agency.

3.4 No sale of WhatsApp data

We do not sell, rent, or monetise WhatsApp message content or patient phone numbers collected via WhatsApp. This data is used exclusively to provide the clinic's own receptionist service.

4. How we use data

5. Legal basis for processing (GDPR)

For users in the European Economic Area (EEA) and United Kingdom, we process personal data under the following lawful bases:

• Contract performance — to deliver the SaaS service the clinic has subscribed to
• Legitimate interests — security monitoring, fraud prevention, platform improvement
• Legal obligation — billing records, compliance with applicable laws
• Consent — for optional marketing emails; withdrawable at any time

For patient data, clinics are the data controller and are responsible for ensuring appropriate consent is obtained from patients for AI-assisted communication and messaging.

6. Data sharing & sub-processors

We share data only with trusted sub-processors required to deliver the service. All sub-processors are bound by data processing agreements.

We do not sell personal data to any third party. We do not share data with advertisers.

7. Data shared with Meta

As a Meta Tech Partner and user of the WhatsApp Business API, we transmit certain data to Meta as a technical necessity of the service:

• Message content and phone numbers — transmitted to Meta's Cloud API servers to deliver messages
• Webhook payload data — received from Meta's servers when a patient sends a WhatsApp message to a connected clinic
• OAuth tokens — exchanged with Meta's Graph API during clinic WhatsApp connection (Embedded Signup); stored encrypted, never exposed in transit without TLS
• WABA subscription calls — we call Meta's API to subscribe each clinic's WABA for webhook delivery

We do not pass patient health information (diagnoses, prescriptions, clinical notes) to Meta. Clinics are advised not to request or transmit special-category health data via WhatsApp messages.

Meta's handling of this data is governed by the WhatsApp Business Policy, the Meta Platform Terms, and Meta's Privacy Policy.

8. Retention & deletion

• Active subscriptions — data is retained for the duration of the clinic's subscription.
• After cancellation — clinic and patient data is retained for 90 days, then permanently deleted unless a legal hold applies.
• Billing records — kept for 7 years per accounting/tax obligations.
• API and error logs — automatically purged after 30 days.
• WhatsApp message content — retained for the life of the subscription; exportable on request.

Clinics or patients can request data deletion at any time. See Data Deletion Instructions.

9. Security

• All data in transit is protected by TLS 1.2+ (HTTPS)
• WhatsApp access tokens are encrypted at rest using AES-256-GCM with a clinic-specific encryption key
• Passwords are hashed using bcrypt (never stored in plain text)
• JWT authentication for all API endpoints; tokens expire in 7 days
• Each clinic's data is logically isolated — no cross-clinic data access
• HMAC-SHA256 verification on all inbound Meta webhook payloads
• Rate limiting on all public API endpoints
• Regular dependency audits and security updates

See our full Security Practices page.

10. Your rights

Depending on your location, you may have the following rights regarding your personal data:

• Access — request a copy of your data
• Rectification — correct inaccurate data
• Erasure — request deletion of your data ("right to be forgotten")
• Portability — receive your data in a machine-readable format
• Objection — object to processing based on legitimate interests
• Restriction — request that processing be limited
• Withdraw consent — for any processing based on consent

CCPA (California residents): You have the right to know what personal information is collected, the right to delete, the right to opt out of sale (we do not sell data), and the right to non-discrimination.

To exercise any right, visit our Data Deletion & Rights page or email privacy@doctorsmyagency.com. We respond within 30 days.

11. Cookies

The public website uses minimal cookies:

• Theme preference — localStorage key to remember light/dark mode (not a tracking cookie)
• Session cookie — used only on authenticated dashboard pages (HttpOnly, Secure, SameSite=Lax)
• No third-party advertising cookies

The Meta Facebook SDK (loaded during WhatsApp Embedded Signup) may set Meta session cookies in accordance with Meta's cookie policy. These are only loaded when a clinic clicks Connect WhatsApp — not on general page visits.

12. Children's privacy

Doctors My Agency is a B2B SaaS platform for healthcare professionals. It is not directed at children under 13 (or 16 in the EEA). We do not knowingly collect personal information from children. If a child's information is submitted as part of a patient record, the subscribing clinic is responsible for complying with applicable child privacy laws (e.g. COPPA, GDPR Article 8).

13. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top and notify active clinic subscribers by email if the changes are material. Continued use of the platform after notice constitutes acceptance of the updated policy.

14. Contact & Data Protection Officer