Privacy Policy

This Privacy Policy is issued by Prognia B.V. ("Prognia", "we", "us", or "our"), a private limited company incorporated under the laws of the Netherlands, registered with the Dutch Chamber of Commerce (Kamer van Koophandel) under number [KvK number — to be added], with its registered address at [Registered address — to be added], Amsterdam, the Netherlands.

Prognia B.V. is the data controller for personal data collected through Prognia Hub — the shared network for healthcare students and clinicians described in these Terms — and through your Prognia account generally, which also gives you access to Ward, Suture and Osler (the "Services"). One account and one sign-in works across all of them.

Prognia has not appointed a formal Data Protection Officer. For all privacy-related questions, requests, or concerns, please contact:

We will acknowledge your request within 5 business days and respond in full within 30 days (or within any shorter period required by applicable law).

This Privacy Policy applies to all personal data processed by Prognia in connection with your use of the Services, including when you:

• Create and use a Prognia account — one login that works across Prognia Hub, Ward, Suture and Osler.
• Use Prognia Hub: post to the feed, share photo or video stories, send direct messages or make a voice/video call, join or create a Space (a group), or find colleagues in the member directory.
• Use AI-assisted search across your Prognia account.
• Open Ward, Suture or Osler using your Prognia account. Those apps have their own additional features — study tools, documents, an AI conversation assistant — and where they collect data beyond what's described here, that's disclosed in-app.
• Subscribe to a paid plan for Prognia Hub or any Prognia app.
• Receive push, email, or in-app notifications from us.
• Contact us for support or with enquiries.

This Policy does not apply to third-party websites or services linked to from within the Services. Those are governed by their own privacy policies.

We collect the following categories of personal data, depending on how you use the Services:

3.1 Account and identity data

• Email address.
• Display name.
• Password (stored as a cryptographic hash only — we never store your password in plain text).
• Profile photo, if you add one.

3.2 Profile data

• Country.
• Institution or place of study/work, if you set one.
• Professional role or stage of training (for example: medical student, resident, specialist).
• Study year and specialty or areas of interest, where you provide them during onboarding.
• Any personal study goals you set.

3.3 Content you create

• Posts, comments, and photo or video stories you share on Prognia Hub.
• Direct messages, group messages inside a Space, and voice messages.
• Documents and files you share with others through the Services.
• Spaces (groups) you create or join, and any content posted inside them.
• Voice and video calls you make through the Services (see Section 3.9).

3.4 Coins, levels and streaks

Prognia Hub and the other Prognia apps share one progress system: coins earned for activity such as a daily check-in, the level those coins add up to, and your current streak. This data is shared across your whole Prognia account, not scoped to a single app.

3.5 Usage and diagnostic data — first-party only

We built our own crash, error, and performance reporting instead of using a third-party analytics or crash-reporting SDK. When the app crashes, a screen fails to load, or a request is unusually slow, your device sends a report — the type of failure, an error message and stack trace, app version, device model and OS version, and a timestamp — to our own API, authenticated with your own session. No third-party analytics, advertising, or tracking SDK is built into any Prognia app, and none of this diagnostic data is sent to a third-party analytics company.

We also record ordinary usage data needed to operate the Services: which features you use, session timestamps, and similar activity data.

3.6 Push notification data

• Your device's push token, so we can address a notification to your device through Apple's Push Notification service (APNs).
• Platform (iOS, iPadOS, macOS) and whether the token is a development (sandbox) or production build.
• The notification content itself may include a short preview relevant to the event — for example, who sent a message or which Space it was posted in.

3.7 Subscription and billing data

• Which app and plan (Free, Pro, or Max) you're subscribed to.
• Billing date and subscription history.
• Payment method details: where you subscribe through the Prognia website, these are processed directly by Stripe, Inc.; where you subscribe through Apple's App Store, Apple processes the payment and we receive purchase and entitlement status through RevenueCat. Prognia does not receive or store your full card number, CVV, or Apple ID password.

3.8 Technical and device data

• IP address, used at sign-up to suggest your country and otherwise for security purposes.
• Browser or app version, device type, and operating system.
• Time zone and language settings.
• Session identifiers and authentication tokens.

3.9 Photos, videos, and location data

Photos and videos can carry embedded metadata, including the location where they were taken. When you take a photo or video with the camera inside a Prognia app, we remove that location metadata before the file is stored — it does not reach our servers. If you instead choose a photo or video already saved on your device, it may carry whatever metadata your device's camera originally recorded, including location; we do not read, extract, or use that metadata for any purpose, and it is never attached to your account, your profile, or anything you post.

We do not collect your device's precise GPS location. The only location-related information we hold is the country you tell us (or, where you haven't set one yet, the country your IP address suggests as a default during onboarding), which we use to show you relevant institutions and localised content.

3.10 Calls

Prognia Hub lets you make voice and video calls inside a conversation. Setting up a call involves creating a short-lived, call-scoped access token and routing the audio/video stream through our real-time infrastructure provider, LiveKit (see Section 9). We do not record calls.

3.11 Cookie and tracking data

We use strictly necessary cookies (e.g. session cookies) to keep you signed in and to operate the Services. We do not use analytics, advertising, or tracking cookies, and no third-party analytics or advertising software runs inside the Services. Should we introduce any non-essential cookie or tracking technology in future, we will request your separate consent before it is placed on your device and will update this policy first.

We collect personal data in the following ways:

• Directly from you: when you register for an account, complete your profile, post or message, subscribe to a plan, contact us, or otherwise interact with the Services.
• Automatically: when you use the Services, we automatically collect technical, usage, and first-party diagnostic data as described in Section 3.
• From third parties: we may receive limited data from Stripe or Apple/RevenueCat in connection with payment processing (for example, confirmation of a payment or subscription status), and from Apple's Push Notification service (delivery status of a notification).

For users located in the European Union or European Economic Area, Prognia processes personal data on the following legal bases under the General Data Protection Regulation (GDPR):

Where we rely on legitimate interests, you have the right to object to that processing. See Section 12 for details of your rights. For users outside the EU/EEA, we apply the same processing standards described above, adapted to the requirements of applicable local law.

We use the personal data we collect for the following purposes:

• To create, manage, and secure your account, and to keep you signed in across Prognia Hub, Ward, Suture and Osler.
• To operate Prognia Hub — the feed, stories, direct messages, calls, Spaces, and the member directory.
• To suggest relevant colleagues, institutions, and Spaces based on your profile.
• To power AI-assisted search, and other AI-assisted features, across your Prognia account.
• To award coins, track your level, and maintain your check-in streak.
• To deliver push, email, and in-app notifications you haven't opted out of.
• To process subscription payments and manage your billing relationship via Stripe, Apple, or RevenueCat.
• To act on content and user reports, and to enforce our acceptable-use and zero-tolerance policies (see the Terms of Service).
• To send marketing and promotional communications, where you have opted in. You may withdraw consent at any time by clicking the unsubscribe link in any marketing email or by contacting medical@prognia.nl.
• To detect, investigate, and prevent fraud, abuse, and security incidents, including through first-party crash and error diagnostics.
• To comply with applicable legal obligations, including tax and accounting requirements.
• To respond to your enquiries and support requests.

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are:

When you delete your account from Settings → Delete account, your access is revoked immediately and your data is queued for permanent deletion 30 days later, except where we are required by law to retain part of it for longer (for example, financial transaction records under Dutch tax law). See Section 16 of the Terms of Service for how account deletion works in practice, including on Ward, Suture and Osler.

Prognia does not sell your personal data to third parties, and does not run advertising. We share personal data only with the service providers who help us run the Services, and only under written data processing terms:

8.1 Other people on Prognia Hub

Content you post — your posts, stories, comments, profile, and anything you post inside a Space — is visible to other Prognia Hub members according to that content's audience (for example, a Space's members, or your connections). Direct messages and calls are visible only to their participants.

8.2 Legal and regulatory disclosure

We may disclose your personal data to law enforcement, regulatory authorities, or courts where we are required to do so by applicable law, or where we believe in good faith that disclosure is necessary to: (a) comply with a legal obligation; (b) protect the rights, property, or safety of Prognia, its users, or the public; or (c) detect, prevent, or address fraud, abuse, or security incidents.

8.3 Business transfers

In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of Prognia's assets, your personal data may be transferred to the acquiring entity. We will notify you via email and/or a prominent notice on the platform before your data is transferred and becomes subject to a different privacy policy.

Prognia B.V. is based in the Netherlands. Several of the service providers listed in Section 8 are based in the United States, meaning personal data we share with them is transferred outside the European Economic Area (EEA).

Where we transfer personal data outside the EEA, we ensure an appropriate safeguard is in place in accordance with GDPR Chapter V — in practice, this means Standard Contractual Clauses adopted by the European Commission (Commission Implementing Decision (EU) 2021/914), supplemented where necessary by additional technical and organisational measures, or another lawful transfer mechanism such as an adequacy decision. You may request details of the safeguard applicable to a specific provider by contacting medical@prognia.nl.

We use cookies and similar technologies to operate and improve the Services. Cookies are small text files stored on your device when you visit a website or use an application.

Currently, we use only strictly necessary cookies, required for the Services to function — for example, session cookies to keep you signed in across Prognia Hub, Ward, Suture and Osler. These cookies do not require your consent.

We do not currently place any non-essential cookies, and the Services integrate no third-party analytics, advertising, or tracking software. If that changes, we will request your explicit consent through a cookie consent banner before placing any such cookie on your device, and you will be able to update your preferences at any time.

If you are located in the EU or EEA, you have the following rights in relation to your personal data under the GDPR. You may exercise any of these rights by contacting us at medical@prognia.nl with the subject line "Privacy Request":

11.1 Right of access

You have the right to request a copy of the personal data we hold about you, along with information about how we process it. We will provide this within 30 days of a valid request, free of charge for the first request.

11.2 Right to rectification

You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most of your account and profile information directly in Settings.

11.3 Right to erasure

You can delete your account and its personal data yourself, at any time, from Settings → Delete account. Access is revoked immediately; your data is purged within 30 days, except where we're required by law to retain part of it for longer (for example, financial records). You can also ask us to erase specific personal data outside of a full account deletion by contacting us — for example, a piece of content you can no longer edit, or old diagnostic reports.

11.4 Right to restriction of processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, for example while we investigate a dispute about its accuracy.

11.5 Right to data portability

Where processing is based on your consent or on the performance of a contract, and where processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format (such as JSON or CSV), and to request that we transmit it to another controller where technically feasible.

11.6 Right to object

You have the right to object at any time to processing based on legitimate interests (Article 6(1)(f)). We will cease the relevant processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless the processing is for the establishment, exercise, or defence of legal claims.

You also have the absolute right to object to processing of your personal data for direct marketing purposes. We will stop such processing immediately upon receipt of your objection.

11.7 Rights related to automated decision-making

You have the right not to be subject to a decision based solely on automated processing that produces legal effects or similarly significant effects on you. Prognia does not make any such automated decisions about users. Reports and moderation actions described in the Terms of Service are reviewed by us, not decided by an algorithm.

11.8 Right to withdraw consent

Where processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent for marketing emails, use the unsubscribe link in any email or contact medical@prognia.nl.

If you are a resident of the State of California, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you the following rights in addition to those described elsewhere in this Policy:

12.1 Categories of personal information collected

In the preceding 12 months, Prognia has collected the following categories of personal information as defined by the CCPA:

• Identifiers: name, email address, IP address, account identifiers, device push token.
• Commercial information: subscription records.
• Internet or other electronic network activity: usage data, features accessed, first-party crash and error diagnostics.
• Audio or visual information: voice messages you record and calls you make through the Services (not stored by us beyond the call itself); photos and videos you upload.
• Professional or employment-related information: your professional role or stage of training, if you provide it.
• Inferences drawn from the above: people, institutions, and Spaces we suggest to you based on your profile.

We do not collect Social Security numbers, driver's licence numbers, biometric data, or precise geolocation data.

12.2 Your California rights

• Right to Know: you may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of collection, the business or commercial purpose for collection, and the categories of third parties with whom we share it.
• Right to Delete: you may request deletion of your personal information, subject to certain legal exceptions.
• Right to Correct: you may request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: Prognia does not sell your personal information to third parties for monetary consideration, nor do we share it for cross-context behavioural advertising. You therefore have nothing to opt out of in this respect. If this changes in the future, we will update this Policy and provide an opt-out mechanism.
• Right to Non-Discrimination: we will not discriminate against you for exercising any of your CCPA rights.

12.3 How to submit a California rights request

California residents may submit a rights request by emailing medical@prognia.nl with the subject line "California Privacy Request". We will respond within 45 days of receiving a verifiable consumer request. We may request additional information to verify your identity before processing your request.

You must be at least 16 years old to create a Prognia account or use any Prognia app. If the law of the country you live in sets a higher minimum age for using an online service like ours without parental consent, that higher age applies to you instead. We do not knowingly collect personal data from anyone below the applicable minimum age, and we do not permit registration below it.

If you believe a child below the applicable minimum age has created a Prognia account, please contact us at medical@prognia.nl so we can investigate and, where appropriate, delete the account and associated data.

Prognia implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption of all data in transit using TLS (HTTPS).
• Cryptographic hashing of passwords — passwords are never stored in plain text.
• Row-level database security policies that scope what any given request can read or write to the account making it, rather than relying only on application-level checks.
• Access controls limiting internal access to personal data to authorised personnel only, on a need-to-know basis.
• Regular review of security practices and assessment of risks.

Despite these measures, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of your personal data. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) within 72 hours of becoming aware of the breach, and will notify affected users directly where required by law.

The Services may contain links to third-party websites or resources. This Privacy Policy does not apply to those third-party websites or services. We encourage you to review the privacy policies of any third-party sites you visit. Prognia is not responsible for the privacy practices of third-party operators.

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, the Services we offer, or applicable law. When we make material changes, we will notify you by email to the address registered on your account and/or by posting a prominent notice on the platform, at least 30 days before the changes take effect.

The date at the top of this Policy indicates when it was last updated. We encourage you to review this Policy periodically. Your continued use of the Services after the effective date of a revised Policy constitutes your acceptance of the changes. We maintain a version history of previous Privacy Policies, which is available on request by emailing medical@prognia.nl.

17.1 Contact us first

If you have a concern or complaint about how we handle your personal data, we encourage you to contact us first at medical@prognia.nl with the subject line "Privacy Complaint". We take all complaints seriously and will endeavour to resolve your concern within 30 days.

17.2 Dutch supervisory authority

If you are located in the Netherlands and are not satisfied with our response, you have the right to lodge a complaint with the Dutch Data Protection Authority:

17.3 Other EU supervisory authorities

If you are located in another EU member state, you may also lodge a complaint with the supervisory authority in your country of residence. A list of EU supervisory authorities is available at edpb.europa.eu.