1. Who We Are

Company Name: Transtoyou eHealth OÜ

Registered in: Estonia

Company Number: 17350744

Email: info@transtoyou.com

Transtoyou is a digital intermediary platform that connects users with independent, licensed physicians and registered pharmacies. Transtoyou is not a healthcare provider, pharmacy, or prescriber.

2. What Data We Collect

We collect and process the following personal data:

Identity Information

Name, date of birth, gender (if relevant to treatment), nationality, and account identifiers.

Contact Information

Email address, telephone number, delivery address, and billing address.

Medical Information

Health conditions, symptoms, medical history, medication use, allergies, intake answers, consultation summaries, and prescription decisions.

Order and Payment Information

Order history, invoices, payment status, transaction references, and fraud-screening signals.

Technical and Usage Data

IP address, device type, browser information, log files, session data, and platform usage behavior.

Communication Data

Messages and emails with customer support, physicians, or pharmacies.

Verification and Security Data

ID verification status and metadata, biometric facial match data where required for identity checks, and 2FA session logs.

Consultation Recordings

Where recording is necessary for patient safety, quality assurance, training related to safety, or dispute handling, video and/or chat consultations may be recorded and stored temporarily (see Section 7).

Social Login Data

If used: basic profile data provided by the social login provider (such as name, email, and a unique account ID).

We only collect data necessary to deliver our services and store it securely.

3. How We Use Your Data

Your data is used to:

  • Provide healthcare services, consultations, and prescriptions
  • Process payments and deliver orders
  • Send reminders for consultations, health checks, and orders
  • Manage subscriptions, returns, and customer service
  • Improve our services and platform functionality
  • Run A/B tests and experiments to enhance user experience
  • Personalize communication and product recommendations
  • Use analytics and browsing behavior to build lookalike and custom audiences, support advertising campaigns, and optimize retargeting via third-party platforms (e.g., Meta, TikTok, Google), only with your explicit consent
  • Comply with legal and regulatory obligations
  • Prevent fraud and ensure cybersecurity
  • Enforce Two-Factor Authentication (2FA) for secure access

Marketing emails are only sent with your explicit consent and always include an opt-out option.

5. AI Use for Translations

Transtoyou uses AI-enabled tools solely to support translations of informational, medical, and legal content on the platform.

AI-assisted translations that relate to medical intakes, prescription pathways, product safety information, or legally binding documents are always subject to mandatory human review, including back-translation checks, to ensure accuracy, clarity for lay users, and compliance with medical and consumer safety duties.

6. Automated Communication and Analytics

We may send automated emails and notifications that are necessary to provide and secure our services, including messages about:

  • Incomplete orders or unpaid subscriptions
  • Consultation or health-check reminders where medically or operationally required
  • Product availability or delivery updates
  • Feedback and review requests
  • Account security alerts and identity verification steps

Some service emails may include tracking pixels or monitored links to measure engagement (such as open and click rates) and to improve our communications. We also run A/B tests using pseudonymised or aggregated data to optimize platform and communication performance.

Behavioral segmentation and scoring are only used with your consent and do not produce legal or significant effects (Art. 22 GDPR).

7. Data Retention

Medical Data

Up to 20 years where required by applicable medical record retention laws, or shorter where no such obligation applies.

Consultation Recordings

Retained securely for 90 days and then automatically deleted unless a longer retention is required due to an open complaint, legal obligation, or ongoing investigation.

Transaction Data

7 years (tax compliance).

Account Data

Deleted after 4 years of inactivity unless required by law.

Support and Communication Data

Kept as long as needed to handle your request, disputes, or legal obligations.

8. Sharing Your Data

We share personal data only where necessary for service delivery and compliance. This may include:

  • Independent physicians who conduct consultations and make clinical decisions
  • Registered partner pharmacies that dispense medicines and fulfil orders
  • Payment providers and fraud-prevention tools
  • Hosting, IT, and security service providers
  • Logistics partners and carriers
  • Marketing and analytics providers only where you have provided explicit consent
  • Public authorities where required by law
  • Social login providers (e.g., Google or Meta) when you choose to use social login
  • Identity verification providers for one-time ID checks; Transtoyou receives only the verification outcome and necessary metadata

All third parties operate under binding Data Processing Agreements (DPAs).

We never sell your data.

9. Marketing and Remarketing

With your explicit consent, we may use your activity data to:

  • Personalize offers and content
  • Serve targeted ads via third-party platforms
  • Create anonymized audiences
  • Run retargeting campaigns

You can withdraw your consent at any time via email or the unsubscribe link.

10. International Transfers

When transferring data outside the EU/EEA or UK:

  • We apply Standard Contractual Clauses (SCCs)
  • We conduct Transfer Impact Assessments (TIAs)
  • Additional safeguards are implemented where required

11. Your Rights

You have the right to:

  • Access your data
  • Correct inaccurate data
  • Request deletion where legally possible
  • Restrict processing in certain cases
  • Object to processing, including direct marketing
  • Receive your data in a portable format and request transfer where applicable
  • Withdraw consent where processing is based on consent
  • Not be subject to solely automated decisions with legal or similarly significant effects, where this right applies
  • Lodge a complaint with your local authority

Supervisory Authorities

EU users: Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)

UK users: Information Commissioner's Office (ICO)

12. Data Access via Your Account (EU Data Act)

You can access, download, and export your account and service-generated data directly through your Transtoyou dashboard.

Where technically feasible, you may also request that Transtoyou transmits this data to a third party designated by you, in line with applicable EU data access and portability rules, including the EU Data Act where relevant.

13. Cookies and Tracking Technologies

We use cookies and similar tools to ensure platform functionality, measure usage, run experiments and heatmaps, and personalize content and ads.

Non-essential cookies (including analytics, profiling, and advertising cookies such as Google Analytics, Meta Pixel, and TikTok Pixel) are used only after you provide explicit consent via our Cookie Settings banner.

You can change or withdraw your consent at any time through Cookie Settings in the website footer.

14. Children's Privacy

Our platform is not intended for users under 18. We do not knowingly collect data from minors. If discovered, such data will be deleted immediately.

15. UK Representative (UK GDPR)

Because Transtoyou is established in the EEA and offers services to users in the United Kingdom without a UK establishment, Transtoyou appoints a UK representative where required under the UK GDPR.

Details are available upon request via privacy@transtoyou.com.

16. Data Breaches

In the event of a data breach:

  • We notify authorities within 72 hours
  • Affected users will be informed where there is risk
  • Remedial actions are taken without delay

17. Language Disclaimer

This privacy policy is available in multiple languages. In case of discrepancies, the English version prevails.

18. Informational Content Disclaimer

Content shared on our platform, website, or emails is for general information only and does not constitute medical advice. Always consult a licensed medical professional for personal health concerns.

19. Internal Privacy Officer

Transtoyou is not legally required to appoint a Data Protection Officer (DPO) under Article 37 GDPR, as our activities are carried out under the supervision of licensed medical professionals.

However, we have appointed an internal privacy officer who:

  • Monitors compliance with our privacy practices
  • Maintains the processing register
  • Performs Data Protection Impact Assessments (DPIAs)
  • Reviews processor agreements

This officer serves as the point of contact for data protection matters within the organization.

20. Contact Us

For any questions, requests, or concerns:

Email: privacy@transtoyou.com

By using our services, you acknowledge that you have been informed about this Privacy Policy.