Omedso Hub×

Omedso Hub

Privacy policy

Version 3.3 · Effective November 4, 2026

The Spanish version is the official legal text. Translations are provided for convenience.

01

Controller, scope and privacy contact

OMEDSO S.A.S., tax ID 1391936412001, based in Portoviejo, Manabí, Ecuador, is the controller of the processing carried out by Omedso AI, Omedso Pro, Consulta Médica Ecuador, Omedso Hub and Omedso ID under Ecuador’s Organic Law on Personal Data Protection (LOPDP) and its General Regulations (Reglamento General). This policy is version 3.3, effective from November 4, 2026, and is common to all products; sections marked with the name of a product apply only to that product. Omedso ID keeps the common identity, the consents recorded in it and the record of the account deletions that each product reports to it when it carries them out; Omedso ID does not receive or handle rights requests, which are submitted and handled through the privacy contact, as explained in “Data subject rights”. Each product keeps its own sessions, profiles, permissions and database, and none reads the database of another. A professional, clinic or company may be an independent controller for the information it processes for its own purposes. The privacy contact is support@omedso.com with the subject “Privacy”.

02

Data we process in Omedso Hub

Omedso Hub receives from Omedso ID the identifier needed to link your account and keeps your public name, username, bio, avatar, chosen interests, social connections, communities and community administration permissions, posts, articles, comments, supports, private saves, notifications, friend requests, participation and progress in challenges, blocked accounts, reports and technical security metadata. It does not request clinical records, diagnoses, prescriptions, appointments or medical documents. The medical tourism request is described in its own section. Omedso Hub does not offer direct messages between members, so it does not process private conversations. Appeals against moderation decisions and community complaints are sent by email to support@omedso.com; Omedso processes your email address, the link to the content and your reasons only to resolve them and keeps them with the record of the decision.

03

Identity verification in Omedso ID

Omedso ID is the common identity of the Omedso products and keeps your name, email, sign-in provider, the result of the identity and credential verification, the recorded consents and the record of account closures and deletions. When a product requires you to verify your identity, as Omedso Pro does for professionals, Omedso ID first shows you the biometric processing notice, records the accepted version and the time, and redirects you to Didit. Didit acts as data processor on behalf of Omedso, under contract: in its hosted identity verification service it reads your document, runs the liveness check and compares the facial biometrics of the document photo with your selfie. Biometric data are sensitive data; they are processed only with your explicit consent and only to verify your identity. Omedso ID does not perform OCR or facial comparison, does not capture, receive or store images of the document or selfies, and does not use other providers for that verification; it keeps the result and the document data needed to evidence it for the periods set out in “Retention and deletion”. Didit keeps the verification data in accordance with the instructions and periods set in its contract with Omedso and may operate outside Ecuador, with the international transfer safeguards described in this policy. Regarding these data you may request access, rectification, erasure, objection, suspension of processing or portability, and withdraw your biometric consent at any time, by writing to the privacy contact under the procedure in “Data subject rights”; Omedso handles the request and forwards it to Didit where applicable. Withdrawal does not affect a verification already completed, but a product that requires a verified identity may not enable the functions that depend on it. You may also lodge a complaint with the Superintendencia de Protección de Datos Personales.

04

Purposes and legal bases

We use data to create and protect accounts and sessions, provide the requested function in each product, manage plans, payments, quotas and orders, send authorised notices, prevent fraud and abuse, handle rights requests and comply with legal and health obligations. Each processing operation is linked to a specific purpose. Depending on the case, the legal basis is the performance of the service or of pre-contractual measures, explicit and revocable consent for sensitive data and optional functions, healthcare for the health data a professional processes in the clinical record, a legal obligation or a previously assessed legitimate security interest. Health data are sensitive data: they are processed to the minimum necessary, encrypted at rest when identifiable and with access logging. We do not bundle into a single acceptance consents that must be independent; the professional or institution obtains the clinical consents that fall to them.

05

Artificial intelligence and automated decisions

Omedso products use Anthropic Claude to process text, images and documents when you request an AI function, only to generate the requested response; Omedso ID also uses it to read the professional degree document you upload when validating your credentials. No product sends audio to an AI provider or uses Google AI models. AI output is identified as such and requires human review before it produces a clinical or legal effect: a professional reviews, corrects and accepts each clinical draft before signing it, and the author of an article reviews and approves the generated informational content. No decision with significant effects for you is made solely by automated means; you can request information, an explanation and human review, and object where applicable. We do not use identifiable content to train general or clinical models without specific, separate and revocable consent, and the AI provider’s commercial terms, which incorporate its data processing agreement, prohibit it from training its models on the content we send it.

Search in official sources. In the “General” conversation of Omedso AI and in the “General” and “Scientific” modes of the Omedso Pro assistant, the assistant may search the internet, at most three times per response, a closed list of official health sites and medical literature, such as the World Health Organization, the Pan American Health Organization, Ecuador’s Ministerio de Salud Pública (Ministry of Public Health), the United States National Institutes of Health (including PubMed), MedlinePlus, the CDC, the FDA, the NHS, NICE, ECDC, EMA and Cochrane, and shows the pages cited at the end of the response. Omedso configures the assistant to formulate those searches only with general medical terms and never with your name, age, identification, contact details, dates or other data of yours or of a patient; even so, the general topic of the question reaches the search service used by the AI provider. Search is not used in the “Legal” mode of Omedso Pro or when you attach a file. The cited sources are third-party sources, Omedso does not control their content and they do not replace professional judgement.

Authorisation. By creating the account you authorise the content you send to the product’s AI functions to be processed with this provider for that purpose. On iPhone, Omedso AI and Omedso Pro also ask you, before the first use of an AI function, for explicit permission to send that content to Anthropic. You can withdraw it at any time from Account, in Omedso Pro, or from Preferences › “AI privacy”, in Omedso AI. If you choose “Not now” or withdraw it, nothing is sent from iPhone to the AI provider and in Omedso AI the automatic AI tasks for your account are skipped. On the web and on Android the authorisation given when creating the account applies. A provider failure generates an internal alert without personal data.

06

AI in Omedso Hub

Omedso Hub does not use clinical data to rank the feed and does not make automated clinical decisions. Moderation may use technical signals to prioritise reviews, but a significant restriction keeps a reason, the possibility of an explanation and a second human review, which you can request by writing to support@omedso.com. An article’s “Learn more” block is generated once with Anthropic Claude from the text of the article, never from readers’ data, and is published only when its author approves it. Translation of posts uses a non-generative translation service operated by Omedso.

07

Recipients and international transfers

Processors and providers. The following may be involved, each for its own task, under contract and as data processors on Omedso’s behalf unless otherwise indicated: Anthropic (United States) for the requested AI functions, for the daily advice in Omedso AI, which includes the watch’s sleep hours when you link a health device, for the Omedso AI assistant with the history and closed consultations of a linked Omedso Pro record, when you authorise it, for reading the professional degree in Omedso ID and for the search in official sources; Didit for identity verification with facial biometrics; Lemon Squeezy (United States), as merchant of record and payment processor for subscriptions, which receives payment and billing data and also processes them as a controller for its own obligations; PayPhone (Ecuador) for payments for consultations and physical products, and the logistics operator that delivers an order; Meta Platforms (WhatsApp Business Platform) when a professional connects their number, to send notices and transmit the patient service Chat messages; the Servicio de Rentas Internas (SRI) for the receipt and authorisation of electronic invoices; Apple and Google for sign-in with their accounts, notifications, app stores, Apple Health and Health Connect, and the device’s speech recognition; if Omedso enables a third-party wearable connector, the processor announced in this policy; and the providers of cloud infrastructure, databases, file storage, antivirus scanning, transactional email, queues and notifications (Vercel, MongoDB Atlas, Neon, Upstash and Google Cloud). Each provider receives only the data needed for its task.

International transfers. Several of these providers operate outside Ecuador, mainly in the United States, a country that the Ecuadorian authority has not declared to have an adequate level of protection. Each international transfer is covered by a contract with appropriate safeguards that obliges the provider to meet a standard of protection equal to or higher than that of the LOPDP: with Anthropic, the standard contractual clauses included in its data processing agreement, which forms part of its commercial terms; with the other providers, the data processing agreement that forms part of their terms of service, and, for the health data that the AI provider receives for the advice using the watch’s sleep hours and for the assistant with the history of a linked record, also on your explicit consent. Omedso registers these transfers with the authority when the regulations require it, and you can request information about the safeguards applied through the privacy contact. A valid legal requirement may oblige us to disclose data to an authority.

Between Omedso products. Consulta Médica receives from Omedso Pro only the public directory profile and availability; Omedso AI receives from Omedso Pro the plans that the professional assigns to you and, when you link your record, the clinical records, certificates, prescriptions and tests that the professional shares and, only with your separate consent, the history and closed consultations of that record for the assistant, as explained in “Linking your Omedso Pro record to Omedso AI”; Omedso Pro receives from Omedso AI the health summary that the patient authorises; Omedso ID records identity, consents, referrals and points from Omedso Pro and Omedso AI, settlements, refunds and account deletions; Omedso Hub receives from Omedso Pro the verified professional badge, from Consulta Médica whether the profile is published and from Omedso AI whether you have an Omedso AI account and whether you linked a phone or a watch, without measurements.

What we do not do. Omedso does not sell personal data or hand it over to advertisers, data brokers, insurers or employers.

08

Medical tourism

If you send an “I’m interested” request from an article, Omedso Hub processes, with your explicit consent, your contact details, country, age, relevant medical history, allergies, medication, tobacco use, tentative dates, budget and the answers specific to the procedure, together with the article reference. These are self-reported health data used to coordinate an assessment; they are not a clinical record. They are encrypted at rest, never appear in technical logs or analytics and are seen only by the Omedso team that coordinates the request, which logs every access. Omedso shares them with the treating professional only for the assessment and only with your consent; the author of the article does not receive them. The form you complete is saved in your Hub account so that you are not asked for it again; each request is kept for a maximum of 24 months from its last status change. You can withdraw consent, request deletion of the form and the requests, restrict processing or download your data from Settings › Privacy; when your Hub account is deleted, at the end of the 90-day closure period, they are deleted as well. The “Learn more” block is generated from the article and does not use readers’ data.

09

What may be public in the Hub

Your username, display name, bio, avatar, current badge and the content, articles or comments you publish with a public audience can be seen without signing in. Saves are private. If you take part in challenges, your display name, avatar and position may appear in the ranking for other members. Your global identity, email, private interests, internal roles, blocks, the identity of whoever reports and your medical tourism requests are not published.

10

Retention and deletion

We keep each piece of data only as long as necessary for the purpose for which we process it and, when that ends, we delete it, anonymise it or, where the law requires us to keep it, block it so that it is used only for that obligation. Temporary operational sessions expire; the profile and necessary records are kept while the account or the purpose is active. A closed account is kept blocked and unused during the 90 days in which you can reactivate it, unless you choose its immediate deletion; when that period ends, the deletion described in “Account closure and data deletion” and what follows applies.

Omedso ID. The common identity is kept while you have at least one product account. When the last one is deleted, Omedso ID anonymises the common identity and keeps separately, encrypted, the data of the verified identity (name, document and verification result) for five years, to prevent impersonation and fraud and to evidence the verifications carried out; they are then deleted. The record of consents and of account deletions is kept for five years from the last recorded action, as evidence of compliance. The points ledger of the referral program is not modified or erased, because it is the proof of each movement, and it is kept linked to the anonymised identity, without contact details.

Omedso Pro. Signed clinical records and documents are kept in accordance with the obligations of the professional or institution and for the period required by Ecuadorian health regulations for clinical records; cancelling a subscription or closing an account does not authorise their destruction. Electronic invoices and their supporting documents are kept for the period required by Ecuadorian tax regulations for electronic receipts. The audio of a consultation is not kept. Patient service Chat conversations are deleted 90 days after their last message. When a professional’s account is deleted, their account and contact data are anonymised and their directory profile is withdrawn; their bank account for settlements is deleted, unless there is a balance payable, which is kept until it is paid.

Omedso AI. When the account is deleted, on day 90 or immediately, the readings from health devices and the advice written with them, the daily check-ins, the daily record, the conversations with the assistant, the food and exercise logs, the summaries, the notifications, the plans, the medical history you recorded, the alerts, the past appointments saved in Omedso AI, the delivery addresses, the notification devices and preferences, the usage quotas and the challenge points are deleted; identification and contact data are anonymised and authorisations to clinics are revoked. Readings from a health device are kept for at most 730 days from their start, as explained in “Health devices”. Records of consultation payments and purchases are kept blocked for the tax and accounting periods.

Consulta Médica. Appointments and reviews are kept while the account exists. When the account is deleted, the patient’s appointments, reviews, notifications and references are deleted, except appointments with a pending or disputed refund, which are kept until resolved; audit logs are kept without identifying the person. Records of consultation payments and refunds are kept in Omedso AI and in Omedso ID for the tax and accounting periods. The data of the bank account used for a refund are blocked after the transfer and kept only as evidence of that refund, for those same periods.

Omedso Hub. When the account is deleted, your posts, comments and medical tourism requests are deleted, and your profile is anonymised (“Deleted member”). Audit records of the acceptance of the legal documents are kept for 365 days and audit records of conversations, for 180 days. Moderation cases and actions are kept while the account exists, without a fixed period, and those relating to your account are deleted when it is deleted. Medical tourism requests are deleted at most 24 months after their last status change. The record of your privacy actions in the Hub is kept for six years as evidence of compliance.

Technical data. AI usage logs are kept for 180 days and do not contain the text of your messages or data that identify you. To prevent a late sync from recreating health device readings after an account is deleted, Omedso AI keeps a technical marker with the account’s internal identifier, the reason and the date, without health or contact data.

Exceptions. What we must keep because of a legal obligation, to establish, exercise or defend claims, or for security and fraud prevention is kept blocked, only for that purpose and only for as long as it is justified.

The full schedule by category, product and role is available through the privacy contact.

11

Account closure and data deletion

Closing your account. You can close your account from each product’s settings. When you close it, the account becomes inactive immediately: all your sessions are closed and the product can no longer be used, and for 90 days your data are kept blocked, unused, so that you can change your mind. We send you an email with a single-use “Reactivate my account” link and the deadline; signing in to that product before that date also reactivates the account and leaves it as it was. By closing the account you accept that 90-day period before final deletion; if you do not want it, you can choose immediate deletion, as explained below. Some accounts cannot be closed from settings while a link exists: those of professionals, reception or audit users of a clinic, which the clinic administers, and those of Omedso AI linked to a company or with data shared with a clinic. In those cases you can request closure or deletion through the privacy contact. In Omedso Hub, while its settings are not available, closure and deletion are also requested through the privacy contact.

Deletion on day 90. If you do not reactivate the account, when the 90 days are up the product carries out the final deletion: it irreversibly deletes or anonymises your profile, your tracking and the content of that product, except for what the law requires or allows to be kept and which is detailed in “Retention and deletion”, and reports it to Omedso ID, which records the deletion with its date. When the deletion is completed, we send you an email confirming it.

Immediate deletion. If you do not want to wait for the 90 days, when closing your account from the settings of Omedso AI, Omedso Pro or Consulta Médica you can choose “Delete now” and confirm it by typing the word shown by Omedso AI or Omedso Pro or, in Consulta Médica, by typing your email address and turning on “Delete now”. The deletion is carried out at that moment, with the same scope and the same exceptions as the one on day 90: there is no 90-day period, the account cannot be reactivated and we send you an email when it is completed. In Consulta Médica, if you have an open or disputed refund, the deletion is completed when that refund is resolved. If you have a subscription with active renewal, you must first cancel its renewal; if you have future paid appointments in Consulta Médica, they are cancelled and their refund is generated.

Deletion on request. If you cannot delete your account from settings, because it is linked to a clinic or a company, because you do not have access to it or because it is Omedso Hub while its settings are not available, request deletion expressly through the privacy contact, stating the product or “all of Omedso”. That request is a deletion request under article 15 of the LOPDP: we log it, we handle it within the time limits in “Data subject rights”, it does not allow later reactivation and we confirm by email when it is completed.

One product or all of Omedso. Closing or deleting the account of one product does not close or delete the others: the common identity in Omedso ID and the data of other products are managed separately. If you request deletion of all of Omedso, we carry it out in each product in which you have an account and, when the last one is deleted, Omedso ID anonymises the common identity, with the exceptions in “Retention and deletion”.

Clinical records. Signed clinical records and documents in Omedso Pro are not deleted when the professional’s or the patient’s account is closed, or when a subscription is cancelled: the professional or institution that created them must keep them for the periods set by health regulations, they are corrected only through addenda, and Omedso holds them in custody on behalf of that professional or institution. If you ask Omedso to delete or rectify data in your clinical record, we will inform you that the decision rests with the responsible professional or institution and we will forward your request to them.

Suspension. The Omedso team does not delete accounts on its own initiative: it can only suspend them for the reasons set out in these documents, and a suspension does not delete data.

12

Data subject rights

Your rights. You may request information about the processing of your data, access, rectification and updating, deletion, objection, portability and suspension of processing; withdraw a consent at any time; and not be subject to a decision based solely on automated assessments that produces legal effects on you or affects your rights, for which you may request an explanation, submit comments and challenge the decision before a person. Exercising these rights is free of charge and you do not need to justify your request.

How to submit a request. Write to support@omedso.com with the subject “Privacy”, preferably from your account email, or deliver it in writing at Omedso’s address in Portoviejo. State your name, the product or products it concerns, the right you want to exercise and what you are asking for and, if you can, the data or the part of the product concerned. If you act on behalf of another person, attach the document proving your representation. The privacy email is the official channel for all rights requests and is handled directly by Omedso; the products and Omedso ID do not have their own form for them. Some actions you can also take yourself, without waiting for a reply: close your account or delete it immediately from the settings of Omedso AI, Omedso Pro and Consulta Médica, as explained in “Account closure and data deletion”, withdraw from Preferences in Omedso AI the consents for AI indicated there, unlink a health device in Omedso AI, stop receiving optional communications and, while the Omedso Hub community is enabled, download your data or restrict processing from Settings › Privacy.

Identity verification. Before delivering, changing or deleting data we check that the request comes from the data subject or their representative, asking only for what is necessary: normally it is enough for you to write from the email registered in your account; if that is not possible, we will ask you to confirm details already on record in it and, only if needed, your national ID number (cédula) to check it against your identity verified in Omedso ID. We will never ask you by email for passwords, access codes or photographs of your document or your face.

Time limits. We confirm by email that we received the request and the date of receipt. If information is missing, we will ask you for it once, within the following five business days, and you will have ten business days to complete it; if you do not, we will archive the request and tell you, and you may submit a new one. We respond and, where appropriate, carry out what was requested within ten business days of receiving the complete request and, in any case, within the fifteen days that the LOPDP sets for access, rectification and updating, deletion and objection, counted from when we receive it. We do not extend these time limits.

Response. We reply in writing, with reasons, to the email you wrote from: what we did, in which products, what data we keep and why. If we deny the request in whole or in part, we tell you the legal ground and your right to complain. Access is delivered in a readable format and portability, where applicable, in a structured, commonly used format, such as JSON or CSV. If we must keep part of the data because of a legal obligation, for example a signed clinical record or an invoice, we tell you and delete, anonymise or block the rest within the same time limit. When we rectify or delete data that we had disclosed to a processor or a third party, we inform them so that they do the same.

Request log. Omedso logs every rights request it receives, with its date of receipt, the product, the right exercised, the time limit, the response, the date of response and what was carried out, and keeps that log and the correspondence for five years from when the request is closed to demonstrate compliance to you and to the authority. That log is kept manually by Omedso’s privacy team, which also records in it the deletion requests received through the privacy contact; Omedso ID only records the account deletions that each product reports to it.

Complaints. If you do not receive a response within the time limit or you disagree with it, you may file a complaint with the Superintendencia de Protección de Datos Personales (Superintendency of Personal Data Protection), without prejudice to the other actions the law grants you.

13

Withdrawal of consent

An optional consent may be withdrawn at any time without affecting prior lawful processing. Withdrawal disables only the function or communication that depends on that consent, but does not by itself delete the common identity or clinical information that must be kept due to health obligations, defence of claims or security. You may also object to processing based on legitimate interest so that we assess your situation.

14

Security

We apply role-based access controls validated on the server, encryption in transit (TLS) and encryption at rest (AES-256) of clinical text, messages, signature certificates, medical tourism requests and secrets, secrets management, usage limits, a log of every access, edit and signature, revocable sessions, antivirus scanning of files, and technical logs that avoid including credentials, identification or sensitive content. The bank account details you provide for a refund are also encrypted at rest, shown masked to the team that pays the refund, and every full disclosure is logged with its reason. No system guarantees zero risk. In an incident we will apply containment, assessment and notification as required by law.

15

Device, communications and analytics

The apps and the web may request the camera or photo library for documents and images (Omedso AI and Omedso Pro), the microphone for live transcription of the consultation with the browser or system recogniser (Omedso Pro), local or push notifications for reminders and notices, and read-only access to Apple Health or Health Connect when you choose to connect them (Omedso AI). Authorisation is explicit, granular and revocable from the device. No product reads your contacts or uses precise location. Operational communications are kept separate from optional marketing, which you can withdraw without losing the service. Our own analytics are enabled only according to your consent and must not receive conversations, clinical records, transcriptions, files, identification, post bodies or credentials.

16

Cookies and storage in Omedso Hub

Omedso Hub uses only necessary cookies: __Host-hub_session keeps you signed in (HTTP only) and __Host-hub_csrf protects your actions against forged requests; they last at most one hour and are deleted when you log out. Omedso Hub does not use optional analytics, advertising cookies or session recording. In your browser we store the chosen language (localStorage) and, while the tab is open, the page you return to after signing in (sessionStorage).

If you choose to sign in with an external provider such as Google or Facebook, that provider loads its own script and may use its cookies under its policy.

17

Minors

Omedso products are not directed to people under 18, including Omedso Hub. Data of a minor or represented person must be processed only within a specific flow, with the involvement of the representative and the required authorisations; the medical tourism request does not accept minors. If we detect an unauthorised registration, we may block it and process its deletion.

18

Effective date and changes to this policy

The version and effective date appear at the beginning and are the same across all products. Material changes will be published and notified before taking effect when they modify purposes, recipients or rights, and when you enter the product we will ask you to accept the new version. Previous versions are kept for traceability and can be requested from the privacy contact.

Questions, rights and complaints

Write to support@omedso.com. For privacy and rights over your data, use the subject “Privacy”.

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