Privacy notice
Gesundheitsdatenraum Schweiz
1. Controller
The controller for processing personal data in data2u is Verein Gesundheitsdatenraum Schweiz (GdS), c/o Ernst Hafen, Hochstrasse 95, 8044 Zürich, Switzerland, UID CHE-434.667.859. Contact: privacy@gesundheitsdatenraum.ch.
2. Processors
GdS uses the following processors under contractual instructions and confidentiality obligations:
- Infomaniak Network SA, Rue Eugène-Marziano 25, 1227 Les Acacias, Switzerland, for hosting: the app's servers, database, document storage and backups, in Infomaniak's data centres in Switzerland. The AI-assisted recognition of document details (such as title, author and date) also runs on these servers; documents are not sent to an outside AI service.
- Health Info Net AG (HIN), Seidenstrasse 4, 8304 Wallisellen, Switzerland, for secure email: requests for your records and the authorization go to providers through HIN Mail, providers can return documents the same way, and the upload link you request in the app is sent to you through HIN Mail as well.
- Didit Identity Spain, S.L., Calle Nápoles 227, P. 1, 08013 Barcelona, Spain, privacy@didit.me, for identity verification.
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Google Workspace of the data2u.ch domain, sender info@data2u.ch), for three kinds of email to you: sign-in codes, password-reset links and a copy of your signed authorization.
- 650 Industries, Inc. (Expo), USA, for delivering push notifications, through Apple's and Google's notification services. Notifications contain only general text such as "New health data has been received", never health data.
Until 30 September 2026, 44ai AG, Industriestrasse 78, 4600 Olten, Switzerland, provided the AI structuring of documents. Since then documents are no longer sent to 44ai AG.
3. What we process
Depending on the features you use, this includes account and contact details, identity and verification evidence, health documents that you request or upload, authorization and signature evidence, device and security logs, and support communications.
4. Why we process it
We process data to create and secure your account, verify that you are the person requesting records, obtain health documents from providers on your instructions, store and display them to you, add technical metadata and AI-assisted structure, operate the service, and respond to support requests.
5. Your authorization
Before requesting records, the app shows a Vollmacht identifying you and GdS. Didit verifies your identity. You may review the authorization and provide an electronic signature in the app. The resulting PDF includes the verified identity, consent and technical evidence. It is a simple electronic signature (SES), not a qualified electronic signature (QES).
6. Storage and transfers
Your account, your documents and their backups are stored in Switzerland. Data leaves Switzerland only for these steps: identity verification (Didit, Spain), sending emails (Google) and delivering push notifications (Expo, USA, through Apple and Google). For transfers to a country without adequate data protection, GdS applies the safeguards required by applicable data-protection law and records the relevant transfer information.
7. Security
Connections to the app, the upload portal and our servers are encrypted (TLS). Infomaniak stores our database and documents encrypted at rest: block storage runs on an encrypted Ceph cluster (LUKS) and object storage has encryption enabled (Infomaniak Public Cloud); Infomaniak manages these keys. Access to production systems is restricted to the people who operate the service. We rely on certified providers for hosting and for email with healthcare providers:
- Infomaniak's information security management system is certified to ISO/IEC 27001, and its data centres are in Switzerland (Infomaniak trust center).
- HIN's information security management system has been certified to ISO/IEC 27001 since 2016 and was recertified in 2025 (HIN certification).
These certifications belong to our providers. data2u itself is not certified.
8. Retention and deletion
We retain data only for as long as needed for the stated purposes, legal obligations, dispute handling, and security. You may request access, correction, deletion, restriction, or a copy of your data, and may withdraw consent for future processing where applicable. Contact privacy@gesundheitsdatenraum.ch.
9. Updates
We may update this notice as the pilot evolves. The date above identifies this version; earlier versions stay available online.
10. Contact
Verein Gesundheitsdatenraum Schweiz (GdS)
c/o Ernst Hafen
Hochstrasse 95
8044 Zürich, Switzerland
privacy@gesundheitsdatenraum.ch