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.
4. Legal Basis for Processing
We process personal data under the following bases (as applicable):
Contractual Necessity
Article 6(1)(b) GDPR / UK GDPR for delivering the services you request.
Legal Obligation
Article 6(1)(c) for compliance with healthcare, pharmacy, tax, and consumer laws.
Legitimate Interests
Article 6(1)(f) for fraud prevention, platform security, service improvement, and dispute handling, balanced against your rights.
Consent
Article 6(1)(a) for non-essential cookies, marketing emails, and advertising/retargeting activities.
For special category data (such as medical information) and biometric data used for identity verification, we rely on the relevant Article 9(2) GDPR / UK GDPR conditions in combination with Article 6(1), including healthcare provision and safety, compliance with legal obligations, and fraud prevention.
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.
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.
