Privacy policy

1Data Collected

During the use of the platform, the following information is collected:

• Registration data: name, surname, email, specialty, nationality, license number, and professional association.
• Phone number: only if the user chooses to activate WittyDoctor WhatsApp. It is optional and can be deleted at any time from the profile.
• Payment data: handled directly by Stripe. WittyHelp, S.L. does not store or have access to the user's full card data.
• Invoicing and subscription data (modality, dates, amounts), managed through Stripe.
• The content of the queries submitted to the assistants (prompts) and of the responses generated by the system, including the sources, citations and links displayed, on any of the available channels.
• Conversations held through WittyDoctor WhatsApp.
• Support/notification system communications (messages with Staff, reports, suggestions).
• Record of acceptance of the Terms and the Policy (version accepted, date, time and IP).
• Technical and usage data required for the operation and improvement of the system.

WittyDoctor neither requests nor requires health data or identifiable patient information, and entering such data is expressly prohibited by the Terms and Conditions. However, since queries are written in free text, WittyHelp, S.L. applies automated detection controls and, where appropriate, human review, in order to identify and remove such information. Any identifiable patient data detected is deleted from the content; until removed, it is excluded from any purpose other than providing the service and, in particular, from the production of statistics set out in section 9.

2Purpose of Processing

• To manage access and the user's account on the platform.
• To verify the user's status as a licensed and authorized healthcare professional through official public sources, including free-plan users.
• To manage payments, subscriptions and invoicing (through Stripe).
• To enable and verify access to the WittyDoctor WhatsApp channel.
• To manage system notifications and user support.
• To display advertising directed at healthcare professionals on the free plan, possibly segmented by specialty, country or province (without disclosing identifiable data to third parties).
• To evidence acceptance of the Terms and the Policy for proof purposes.
• To analyze usage data for continuous improvement.
• To produce aggregated and anonymised statistics, analyses and studies on the use of the platform and on the subjects queried, and to commercially exploit them by delivering them to third parties, always on the terms and with the safeguards set out in section 9.
• To comply with applicable legal obligations.

Access upgrades through WittyDoctor Plus codes

For access upgrades (WittyDoctor Plus days) activated through codes, WittyHelp, S.L. may process the necessary information to validate and manage such codes (e.g., code identifier, activation date, validity period, and associated user).

These codes may be acquired by entities in the pharmaceutical or biomedical sector solely to finance the access upgrade to the WittyDoctor Plus modality for professionals who already have a verified account.

WittyHelp, S.L. will not share personal, usage, or identifiable information about beneficiary professionals with such entities, limiting processing to technical management and access verification.

Professional Verification and Fraud Prevention

WittyHelp, S.L. may process the identifying and professional data provided by the user in order to verify their identity and status as a healthcare professional, as well as to prevent misuse or identity impersonation.

This processing is based on the controller's legitimate interest (Art. 6.1.f GDPR) in ensuring system security and authorized use.

3Legal Basis

The processing is based on:

• The user's consent upon registration and, where applicable, upon activating optional features (such as WittyDoctor WhatsApp or commercial communications).
• Performance of the subscription contract and payment management (Art. 6.1.b GDPR).
• The legitimate interest of WittyHelp, S.L. in improving the service, ensuring security, verifying authorized professional access, and funding the free modality through advertising directed at professionals (Art. 6.1.f GDPR).
• The legitimate interest of WittyHelp, S.L. (Art. 6.1.f GDPR) in producing anonymised statistics and analyses and in their commercial exploitation, as a funding route that allows free access to the platform to be maintained. This processing also constitutes further processing for statistical purposes, which Article 5.1(b) GDPR does not consider incompatible with the initial purpose, and is carried out with the safeguards of Article 89(1) GDPR and of section 9 of this Policy. The output delivered to third parties is anonymous and therefore falls outside the scope of the GDPR.
• Compliance with legal obligations, in particular commercial and tax obligations (Art. 6.1.c GDPR).

4Recipients and processors

To provide the service, WittyHelp, S.L. uses providers acting as processors or, where applicable, independent controllers:

• Hosting and infrastructure: Amazon Web Services (AWS), with servers in the EU or under GDPR-compliance guarantees.
• Payments and invoicing: Stripe, which directly handles payment data.
• WhatsApp messaging: Meta Platforms, Inc. (USA), through the official WhatsApp Business API, when the user activates WittyDoctor WhatsApp.
• Language model (AI) providers: technology providers contracted under GDPR-compliant guarantees, with servers in the EU and/or the USA.

The complete and updated list of providers and sub-processors is available upon request at support@wittydoctor.com. No identifiable personal data is disclosed to advertisers or to entities funding codes; they may only receive aggregated and anonymous statistics.

In addition, WittyHelp, S.L. may deliver to third parties —including healthcare data analytics companies and their clients— the analytical products described in section 9. Such products are anonymous: they contain no identifiable personal data and do not allow the information to be attributed to a specific user. This delivery therefore does not constitute a disclosure of personal data.

5Data Retention

As a general rule, data is retained as long as the user maintains an active account. Upon account deletion, the associated information will be erased, including WittyDoctor WhatsApp and support conversations, except for the following:

• Invoicing data: retained for the period legally required by applicable commercial and tax regulations.
• Record of Terms and Policy acceptance: after account deletion, this record is retained in blocked form, solely for the purpose of defending against possible claims (Art. 17.3.e GDPR and Art. 32 LOPDGDD), and is automatically deleted 6 years after account deletion.
• WittyDoctor WhatsApp conversations are also automatically deleted after 36 months of total inactivity, even if the account remains active.
• Protected backups, which are periodically deleted.

6User Rights

The user may, at any time:

• Access, rectify, or delete their data.
• Object to or restrict its processing.
• Request data portability.
• Withdraw consents given (for example, delete their phone number or revoke commercial communications), without affecting the lawfulness of prior processing.
• Object, on grounds relating to their particular situation, to processing based on legitimate interest, including the production of statistics and insights described in section 9 (Art. 21 GDPR). Once the objection is upheld, the content of their queries will no longer be used for that purpose.

The user may access and edit their basic data and delete their account from their profile. For any other request, including the objection provided for in section 9 and obtaining a copy of their data in a portable format, they may contact support@wittydoctor.com, where all requests to exercise rights will be handled.

Objection and erasure operate prospectively. Analytical products already produced and delivered to third parties are anonymous and irreversible: they contain no personal data, it is not technically possible to locate within them the information originating from a specific user and, consequently, they cannot be withdrawn or rectified at an individual's request. For the same reason, such products are unaffected by account deletion.

7Cookies

WittyDoctor uses only technical cookies necessary for the operation of the service: remembering the selected language and keeping the user's session logged in. No analytical, advertising, or third-party tracking cookies are used. As only technical cookies are used, no prior consent is required, without prejudice to this information.

8Advertising on the free plan

The free modality is funded through advertising directed exclusively at healthcare professionals. WittyHelp, S.L. may segment ads based on the user's specialty, country or province, on the basis of its legitimate interest in funding free access. No identifiable personal data is disclosed to advertisers; they may only receive aggregated and anonymous statistics (impressions, clicks). The user may stop viewing advertising by subscribing to a paid modality.

9Anonymised statistics and insights

WittyHelp, S.L. produces, from platform activity, analytical products that may be delivered to third parties in exchange for consideration. This activity is one of the funding routes that allow free access to the platform to be maintained for healthcare professionals.

9.1. Types of analytical product

• Aggregated statistics: volumes, counts and trends regarding the subjects queried (for example, the number of queries about an active substance, a condition or a therapeutic area over a period), broken down by specialty, province and monthly period.
• Anonymised content analysis: queries and responses previously reworded and stripped of any identifying element, together with the specialty, the province, the monthly period and the sources cited by the system, in order to analyse how a subject is represented in the generated responses and which sources are used.

9.2. Safeguards applied

Before any delivery, the following measures are applied cumulatively:

• Original text is never delivered. Only reworded versions of the content are delivered. Texts as originally written do not leave WittyHelp, S.L.'s systems.
• Removal of identifiers. Deterministic automated controls are applied to detect and remove names, exact ages, specific dates, identity documents, medical record numbers, telephone numbers, email addresses, healthcare facilities and localities. Whatever is detected is corrected or excluded from the delivery.
• Generalisation. Ages are expressed in bands; location is limited to province, with no municipality or facility; dates are reduced to month.
• Grouping threshold (k-anonymity). No information is delivered for groups that do not reach a minimum number of distinct professionals, so that no data can be attributed to a specific person.
• Absence of linkage. The rows delivered are not linked to one another nor to a user identifier: two queries from the same professional are delivered as independent records. The files do not allow unique professionals to be counted or individual profiles to be built, either within a delivery or across successive deliveries.
• Singularity control. Content that, by combining low-frequency attributes, could allow the indirect identification of a person is excluded or subjected to prior human review.
• Human review and traceability. Any content flagged by the automated controls requires review and express authorisation by WittyHelp, S.L. personnel. Each delivery is recorded with its date, recipient, criteria applied, number of records and a cryptographic hash of the delivered set.

9.3. Anonymous nature of the output

The analytical products delivered contain no identifiable personal data and do not allow, by means reasonably available to the recipient, the information to be attributed to a specific natural person. Consequently, such products qualify as anonymous data and their processing by the recipient falls outside the scope of the GDPR. WittyHelp, S.L. documents in writing, for each delivery, the identifiability assessment supporting this conclusion.

The process of producing these products does constitute processing of personal data carried out by WittyHelp, S.L., and is performed on the legal basis and with the safeguards set out in this Policy.

9.4. Patient data

Content in which identifiable patient information is detected is excluded from these analytical products and is never delivered to third parties.

9.5. Temporal application

The production of aggregated statistics (section 9.1, first bullet) may also be carried out on activity recorded before this version came into force, as it constitutes further processing for statistical purposes covered by the conditions previously accepted by the user.

Anonymised content analysis (section 9.1, second bullet) applies only to activity recorded from the date on which each user accepts this version. Activity prior to that date will not be used for this purpose.

9.6. Objection

Users may object at any time to the content of their queries being used for the purposes of this section, by writing to support@wittydoctor.com or through the options available in their profile. Objecting does not affect use of the platform or the functionalities available to the user, nor the products already produced, in accordance with section 6.

10Commercial communications

WittyHelp, S.L. will only send commercial or promotional communications (its own or those of third-party partners) if the user has expressly authorized this through a specific option. This authorization is independent of other processing and may be revoked at any time from the user's profile.

11Security Measures

• Encrypted transmission (HTTPS).
• Servers hosted on AWS within the EU or under GDPR guarantees.
• Access protected by login.

12Security Breaches

In the event of a security breach affecting personal data, WittyHelp, S.L. will notify the Spanish Data Protection Agency (AEPD) within a maximum of 72 hours from becoming aware of it, as well as the affected users when there is a high risk to their rights and freedoms, in accordance with Articles 33 and 34 of the GDPR.

13International Transfers

Data is hosted on AWS, with servers located in the EU or under GDPR-compliant guarantees (such as Standard Contractual Clauses). Certain providers (Meta's WhatsApp messaging and language model providers) may process data in the USA; such transfers are covered by the EU Standard Contractual Clauses and/or the EU-US Data Privacy Framework.

14Updates

This policy may be updated and will be notified to the user in case of relevant changes. When changes are substantial, express acceptance of the updated version may be required.

15Complaints

If you believe your rights have not been respected, you may contact the Spanish Data Protection Agency (www.aepd.es).