Legal
Privacy Policy
This Policy explains what personal data CloudClinic collects, why, where it is stored, and what rights you have under Republic Act No. 10173 (Data Privacy Act of 2012).
1.Who We Are
CloudClinic is a clinical documentation and workflow platform for licensed Philippine physicians. CloudClinic is the personal information controller for its own platform, account, security, support, and operational relationship data. For Patient clinical-care data entered or managed by a participating Clinic/Doctor, the Clinic/Doctor is typically the personal information controller for the clinical-care purpose, and CloudClinic processes that clinic-controlled Patient clinical information as a personal information processor under the Clinic DPA. This role wording remains subject to formal legal/privacy review.
Privacy Officer: cloudclinic.ph@gmail.com
2.What Personal Data We Collect
From physicians and clinic staff: full name, email address, password (stored as a one-way hash — we never see the plain text), PRC license number, PTR and S2 numbers where applicable, specialization, credentials, optional profile photo, digital signature image, clinic name and address, and usage data such as login timestamps and actions taken.
From patients (entered by the patient, physician, or authorized clinic staff): name, date of birth, sex, address, contact details, email address, clinical information, intake and consent records, Patient Portal messages, consultation requests, status/payment/document next-action data, and generated documents.
Automatically: session data (login times and IP address, collected by Supabase for security), audit log entries, limited browser/device information for audited or security-relevant actions, and reviewed browser-storage metadata/preferences. Sensitive shared Patient, clinical, KYC, account, workflow, audit, and document truth must not rely on uncontrolled persistent localStorage.
3.Why We Collect It
| Data | Purpose | Legal basis |
|---|---|---|
| Doctor credentials and account data | Account authentication; document signing identity | Performance of contract |
| Patient records and workflow data | Operate clinic workflow, Patient Portal continuity, teleconsult/supporting actions, and clinical documents on behalf of the Doctor/clinic | Legitimate interest (clinical care); consent as applicable |
| Audit logs and document records | Regulatory compliance; dispute resolution; chain of custody | Legal obligation (RA 10173, RA 6675, DOH records requirements) |
| Email delivery data | Deliver documents and minimal transactional Patient Portal notices | Performance of contract and/or legitimate interest in the clinic workflow |
| Session and usage data | Platform security and operation | Legitimate interest |
4.Where Data Is Stored
Supabase (database and authentication): Patient records, documents, audit logs, account data, and workflow data are stored in Supabase on Amazon Web Services (AWS), Mumbai region (ap-south-1), India. Supabase acts as an infrastructure processor/sub-processor under contractual data processing protections. Supabase privacy policy.
Resend (email delivery): Document emails and minimal Patient Portal transactional notices are delivered via Resend. Current portal notices intentionally contain minimum guidance and direct the recipient to sign in to CloudClinic for details; secure message bodies are not included in those notification emails. Resend privacy policy.
Netlify (hosting and scheduled functions): CloudClinic's public frontend and serverless functions are hosted on Netlify. Netlify processes hosting, request, deployment, and function-execution data necessary to operate the public site, Patient Portal notices, and scheduled communication worker.
Browser storage: Supabase/server-controlled storage is authoritative for shared Patient, clinical, account, workflow, audit, and document truth. CloudClinic may use short-lived/session-scoped browser recovery where justified and persistent browser storage only for reviewed non-sensitive metadata/preferences where applicable.
International data transfers: Supabase, Resend, and Netlify may process data outside the Philippines as part of database/authentication/storage, transactional email, hosting, and function execution. CloudClinic relies on the relevant provider contractual protections to ensure appropriate safeguards.
5.How Long We Keep It
| Data type | Retention period |
|---|---|
| Patient medical records and generated clinical documents | CloudClinic adopted operational policy: 15 years from last consultation unless a longer legal/regulatory obligation or active dispute requires longer |
| Audit logs | CloudClinic adopted operational policy: 15 years from audit event unless a longer legal/regulatory obligation or active dispute requires longer |
| Doctor and staff account data | Duration of subscription + 1 year after closure |
| System and session logs | 90 days |
The periods above reflect CloudClinic's adopted operational policy and do not state that every record category is independently legally required to be retained for 15 years. Data is not permanently deleted without the account holder's explicit request, except as required by law or after the applicable retention period expires.
6.Who Has Access
| Party | Access level |
|---|---|
| The treating physician | Full access to their own clinic's patients and documents |
| Authorized clinic staff | Limited access, scoped to patients assigned by the physician; no access to sensitive documents by default |
| CloudClinic platform operator | Access only for system maintenance, support, bug resolution, security, privacy, and legal compliance; privileged/operator access should be logged or otherwise auditable according to the applicable workflow |
| Supabase, Netlify, and Resend | As infrastructure processors/sub-processors for database/authentication/storage, hosting, scheduled functions, and transactional email delivery |
| Advertisers, data brokers, or other third parties | None. Patient data is never sold, rented, or shared for commercial purposes. |
7.Sensitive Personal Information
Medical records, diagnoses, medications, and DDE assessments are sensitive personal information under RA 10173. DDE reports, drug dependency assessments, and rehabilitation records are automatically flagged as sensitive and restricted to physicians with the view_sensitive_documents permission. Staff accounts cannot access sensitive documents without explicit physician authorization.
8.Document Verification
CloudClinic generates a unique verification QR code for each issued document. The public verification page shows only the document type, issuing physician, issue date, and a partially obfuscated patient identifier (e.g., "J. Santos"). Full patient information is not publicly disclosed through the verification system.
9.Your Rights Under RA 10173
| Right | What it means |
|---|---|
| Access | Request a copy of your personal data held by CloudClinic |
| Correction | Request correction of inaccurate or outdated data |
| Erasure | Request deletion of your data, subject to legal retention requirements |
| Portability | Receive your data in a machine-readable format |
| Object | Object to processing in specific circumstances |
| Withdraw consent | Where processing is consent-based, withdraw that consent at any time |
| Complaint | Lodge a complaint with the National Privacy Commission (NPC) |
Patients with portal access can submit data export/access and erasure requests directly from the Patient Portal's "Privacy & My Data" section. Access requests may be fulfilled automatically where the portal supports it; erasure requests are reviewed because clinical records, audit history, and legal obligations may limit immediate deletion. For any other request, or if you don't have a portal account, email cloudclinic.ph@gmail.com — subject line: "Privacy Request — [Your Name]". We will respond within 15 business days.
10.Data Breach Procedure
In the event of a personal data breach, we will assess the scope within 24 hours of discovery. If the breach poses a real risk of serious harm, we will notify the National Privacy Commission (NPC) within 72 hours as required by RA 10173, and will notify affected data subjects without undue delay.
11.Cookies and Tracking
CloudClinic does not use advertising cookies, third-party trackers, or behavioral analytics. Browser storage, where used, is limited by the browser-storage boundary above and must not become a persistent sensitive clinical database. No data is shared with advertising networks or data brokers.
12.Updates to This Policy
We may update this Privacy Policy to reflect changes in law, regulatory requirements, or platform features. We will notify registered users of material changes by email. Continued use of CloudClinic after an update constitutes acceptance of the revised Policy.
Contact
Privacy Officer / Data Controller: CloudClinic
Email: cloudclinic.ph@gmail.com — subject line: "Privacy Request — [Your Name]"
National Privacy Commission (NPC)
Website: privacy.gov.ph
Helpline: (02) 8234-2228
Controlled Pilot / Private Beta
CloudClinic is currently used in a controlled pilot / private beta context. Features, workflows, support processes, and legal/privacy materials may be refined as the pilot reveals practical needs. CloudClinic is not an emergency service and must not be relied upon for emergency medical response.