HealthPod Scribe

Legal information

This section covers this page only: the waitlist signup and the emails it leads to. The HealthPod Scribe app has its own legal documents, and they are linked in the footer.

What this covers

Only the waitlist: the email signup on this page and the launch updates it leads to. It does not cover the HealthPod Scribe app. The app has its own privacy policy, terms of service, deletion instructions, imprint and subprocessor list, all reachable from the app's legal documents page linked in the footer, and nothing on this page signs you up to them.

Who we are

The controller for this page is dehaze GmbH, Hans-Sachs-Strasse 1, 82256 Fürstenfeldbruck, Germany. Contact: scribe@dehaze.de.

What this page collects

The signup form takes your email address, and it asks whether you use an iPhone or an Android phone, so that we can open the right beta group for you. Both are required. Recorded alongside them are the language version of this page you signed up on, the time of signup, the consent sentence you ticked in the version shown to you, and the campaign parameters of the link that brought you here, if it carried any. Campaign parameters are words a marketing partner adds to a link before sharing it (utm_source, utm_medium, utm_campaign, utm_content and utm_term); they say which campaign brought you to this page, not who you are, and they are stored with your signup so that we can tell which partner's work led to it. A link from an advertising partner of ours can also carry a campaign identifier, two codes the partner issued, one for that link and one for your click on it; they are recorded with your signup in the same way, and what happens with them, and on what legal basis, is described below, under Marketing partners. When you use the form, a short security check from Cloudflare runs inside it, to make it costly for automated scripts to sign up addresses that are not theirs; what Cloudflare receives for that, and what it stores in your browser, is described below, under Who receives the signups. That is all this page collects: it runs no analytics and loads no tracking script, and the page's own code sets no cookies and writes nothing into your browser's storage. The purpose of the signup and the emails is the one the checkbox names, to tell you about the launch of HealthPod Scribe, and their legal basis is your consent, given with that checkbox (Art. 6(1)(a) GDPR; art. 7º, I, LGPD). You can withdraw it at any time, with the unsubscribe link in any email we send or by writing to scribe@dehaze.de.

Where this page is hosted

The site is served by Google Firebase Hosting, from the content delivery edge nearest the reader, under Google's Firebase data processing and security terms. Hosting produces technical request logs, including IP addresses, needed to deliver and secure the site; the legal basis for those is legitimate interest (Art. 6(1)(f) GDPR; art. 7º, IX, LGPD). For visitors in Brazil, this hosting is an international transfer of personal data under the LGPD. The signup form itself is handled by a small service of ours running on Google Cloud in Brazil (region southamerica-east1), under Google Cloud's data processing addendum; the record it keeps of your signup is described below, under How long we keep your signup. For readers in the European Union this means your signup is processed outside the EU, under the standard contractual clauses in Google Cloud's data processing addendum. The service's logs record the outcome and the time of each request, not your email address. To keep the form from being used to send confirmation emails again and again to people who did not ask for them, the service limits how many signups it accepts from one connection and for one address. For that it keeps a keyed fingerprint of your IP address, not the address itself, and uses it to count; a fingerprint of your email address of the same kind serves the per-address limit. The counter behind each fingerprint is marked as expired one hour after its window closes, 25 hours after it started at the latest, and the database removes expired counters in its own clean-up run; the legal basis is legitimate interest (Art. 6(1)(f) GDPR; art. 7º, IX, LGPD).

Who receives the signups

The form is ours and is served from this website as part of this page. When you send it, your entry goes first to dehaze GmbH: our service in Brazil, described above, writes its own record of the signup and then passes your email address, your phone answer, the page language and the name of this form to our email processor, Mailjet, which stores the signup list on servers in the European Union. The campaign parameters and the campaign identifier stay in our own record and are not passed to Mailjet. Mailjet sends you the confirmation email, and your entry counts once you open the link in it; that confirmation page is theirs. They also send the launch updates, and they tell our service when you unsubscribe, when you mark an email as spam and when an address bounces, so that our record matches theirs. Whether you have confirmed is held on their list, and our service reads that list every fifteen minutes to learn which signups have been confirmed, to mark the ones that were removed there, and to make sure an unsubscribe recorded with us is recorded with them too. They process your data only on our instructions, under a data processing agreement. Mailjet is the same processor that sends sign-in codes for the HealthPod Scribe app, listed in the app's own subprocessor list. Because our record is written before the handover, a signup is not lost when Mailjet cannot be reached: the entry is kept and handed over later, which is why the confirmation email can take longer than usual at times. One more party is involved, and only when you use the form: the security check inside it comes from Cloudflare, a company in the United States, and your browser contacts challenges.cloudflare.com to run it. During the check Cloudflare receives your IP address, characteristics of your browser and its connection (the user agent and the TLS fingerprint), the signals of your interaction with the check, and the address of this site, which it uses to tell a person from a script. Cloudflare states that the check does not read what you type into the form. Cloudflare processes these signals in the United States under its certification to the EU-U.S. Data Privacy Framework and the standard contractual clauses in its data processing addendum; for readers in Brazil this is an international transfer under the LGPD. The check runs in a frame from Cloudflare's own domain, and what Cloudflare stores in your browser for it is governed by Cloudflare's cookie policy, not by this page. A reader who scrolls past the form without using it sends nothing to Cloudflare.

Marketing partners

We work with an advertising partner in Brazil, Infleux (Pubmobile Intermediação de Publicidade e Propaganda Ltda.), whose creators share links to this page. When you arrive through one of those links, it carries a campaign identifier, two codes the partner issued: one for that link and one for your click on it. They say which link was clicked and which click it was, not your name or address. We record them with your signup. While you stay on the page they travel only with the language switch; the links to the legal texts, like the other links to pages of ours, open in a new tab, so that this page keeps them. The page takes them out of the address bar as soon as it opens and writes nothing into your browser's storage. When a signup that carries such an identifier is completed, and again when it is confirmed, our service in Brazil notifies the partner that the referral led to a signup, which is how the creator is paid. That notification carries the two codes the partner issued and an opaque reference of ours, a random code with no relation to your address; it carries no email address and no other personal data about you, and we do not tell the partner who you are. The legal basis for recording the identifier and for the notification is our legitimate interest in paying for the campaign and in checking the partner's invoice against our own record (Art. 6(1)(f) GDPR; art. 7º, IX, LGPD). Once the campaign's billing period is settled and the window for disputing the invoice has closed, our service removes the campaign identifier from your record; the rest of the record stays as described below, under How long we keep your signup. A reader who arrives without such a link, or who arrives through one and does not sign up, sends nothing to the partner.

How long we keep your signup

dehaze GmbH keeps its own record of your signup: your email address, your phone answer, the page language, the time of signup, your consent with the time you gave it and the version of the consent sentence you ticked, the campaign parameters of the link that brought you, the campaign identifier of an advertising partner's link if it carried one and the reference we issue for the partner notification described under Marketing partners, the time and campaign parameters of any later submission of the same address, including attempts the limits refused, and what happened to the entry afterwards (passed to Mailjet, confirmed, unsubscribed, bounced, marked as spam). It lives in a database of ours on Google Cloud in Brazil that is closed to the web and to this page: our service writes and reads it, and our staff read it when they handle a request from you or hand an entry to Mailjet again. The record is filed under a keyed fingerprint of your email address. We keep it until HealthPod Scribe launches in Brazil and for six months after that, because that is how long the list serves the purpose it was collected for; the launch has no date yet, so the end of that period is not known yet either. The campaign identifier has a shorter life than the rest of the record: it is removed once the campaign's billing period is settled and the dispute window has closed, as described under Marketing partners. Unsubscribing stops the emails and clears your email address from our record: what remains is an entry, filed under the fingerprint, that records that the address behind it unsubscribed and is not to be contacted again; it no longer holds the address itself. The same clearing happens when you mark one of our emails as spam and when the retention period ends. Mailjet keeps your entry on its list until you unsubscribe or until we ask Mailjet to remove it on a request from you. To ask for a copy of your data or for its deletion (Art. 15 and 17 GDPR; art. 18 LGPD), write to our data protection contact, named under Data protection contact (Encarregado) on this page; on a deletion request we remove your address, the fingerprint, the campaign parameters and the campaign identifier from the entry, and what remains is a dated entry with the phone answer, the page language, the entry's status and the reference described under Marketing partners.

Your rights

Under the LGPD and the GDPR you can ask for access to your data, its correction, a copy of it, or its deletion, and you can restrict its processing or withdraw your consent. Write to scribe@dehaze.de.

Unsubscribe

With the unsubscribe link at the foot of any email we send, or at any time by email to scribe@dehaze.de.

Complaints

You can complain to the ANPD (Autoridade Nacional de Proteção de Dados) in Brazil, or to the competent German supervisory authority, the Bavarian Data Protection Authority (BayLDA).

Information according to § 5 DDG

dehaze GmbH, Hans-Sachs-Strasse 1, 82256 Fürstenfeldbruck, Germany.

Represented by

The managing director: Marius Klages.

Contact

scribe@dehaze.de

Registry entry

Entry in the commercial register. Register court: Munich. Register number: HRB 288528.

VAT ID

VAT identification number according to § 27 a of the German VAT Act: DE365683923.

Responsible for the content

According to § 18 Abs. 2 MStV: Marius Klages, Hans-Sachs-Strasse 1, 82256 Fürstenfeldbruck, Germany.

Our data protection contact, the Encarregado under the LGPD and the data protection contact in Germany, is Marius Klages. Write to scribe@dehaze.de to exercise any of your rights over your data, or to ask anything about the waitlist privacy policy on this page.