Privacy Policy

01 Data Controller

Data Controller within the meaning of Art. 4(7) GDPR:

If required by law, MDBase will appoint a Data Protection Officer (DPO). Relevant contact details will be published in this Privacy Policy.

02 Scope of Application

This Privacy Policy applies to:

• Processing of personal data of medical doctors who use the MDBase mobile application ("Users").
• Data collected through the MDBase mobile app and related services available to doctors within the application.
• Recruitment partners, health institutions, and HR consulting agencies interact with MDBase through separate platforms and are subject to separate terms and privacy policies.

03 Categories of Personal Data Collected

3.1 Doctors' Data

• Identification Data: Full name
• Contact Data: Email address, Phone number, Address
• Professional and Recruitment Data: Medical specialty, Education and qualifications, Professional licenses and certificates, CV and work experience, Language skills, Availability and job preferences
• Regulatory and Immigration Data (if provided voluntarily): Work permit or visa status, Recognition of medical diploma (e.g. Approbation status)
• Technical Data: Device type, Log files, App usage data

3.2 Location Data

MDBase may process approximate location data such as Country, Region, and City. Location data may be derived from user-provided information or device settings (where permission is granted). MDBase does not collect precise GPS data or track real-time movements. Users may disable location access at any time through device settings.

3.3 Subscription and Billing Data

Where users subscribe to paid or premium features, MDBase may process limited billing-related information such as subscription status, transaction identifiers, subscription dates, and billing country. MDBase does not collect or store full payment card details. Payments are processed by third-party app store providers (e.g., Apple App Store).

04 Purposes of Processing

• Creating and managing user accounts
• Facilitating recruitment and matching between doctors and recruiters
• Enabling communication between platform users
• Verifying professional qualifications
• Managing subscriptions and contractual relationships
• Providing location-based job opportunities and localized market insights
• Ensuring platform security and fraud prevention
• Improving platform functionality and user experience
• Complying with legal and regulatory obligations

05 Legal Basis for Processing (Art. 6 GDPR)

• Consent (Art. 6(1)(a) GDPR)
• Performance of a contract (Art. 6(1)(b) GDPR)
• Legal obligation (Art. 6(1)(c) GDPR)
• Legitimate interests (Art. 6(1)(f) GDPR)

06 Special Categories of Personal Data (Art. 9 GDPR)

MDBase may process special categories of personal data related to professional qualifications or regulatory requirements. Such data is processed only with the user's explicit consent (Art. 9(2)(a) GDPR) and solely for recruitment and compliance purposes.

07 Data Sharing and Recipients

Personal data may be shared with hospitals, clinics, healthcare institutions, HR consulting and recruitment agencies, IT service providers, and legal or regulatory authorities where required by law. Personal data is never sold and is shared strictly on a need-to-know basis under confidentiality agreements.

08 International Data Transfers

If personal data is transferred outside the EU/EEA, MDBase ensures appropriate safeguards including EU Standard Contractual Clauses (SCCs) and adequacy decisions issued by the European Commission.

09 Data Retention

Personal data is retained for as long as the user account remains active, for up to 6 months after account inactivity, or longer where required by legal or regulatory obligations. Users may request deletion at any time.

10 User Rights

Under the GDPR, users have the right to:

• Access their personal data (Art. 15)
• Rectify inaccurate data (Art. 16)
• Request erasure – "right to be forgotten" (Art. 17)
• Restrict processing (Art. 18)
• Data portability (Art. 20)
• Object to processing (Art. 21)
• Withdraw consent at any time (Art. 7)

Users may lodge a complaint with the Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) in Germany.

11 Data Security

MDBase implements appropriate technical and organizational security measures including encrypted data transmission, restricted access controls, secure hosting infrastructure, and regular security monitoring.

12 Cookies and Tracking Technologies

MDBase may use essential cookies and similar technologies to ensure platform functionality, security, and analytics (where legally permitted). Detailed information is provided in the Cookie Policy, where applicable.

13 Changes to This Privacy Policy

We may update this Privacy Policy to reflect legal or operational changes. Users will be informed of significant changes via the platform.

14 Contact

For privacy-related questions or requests: