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 the Prognia platform and all associated products and services: the Prognia network and the apps Ward, Suture and Osler, our websites, and our apps for Apple devices where available (the "Services"). One Prognia account gives you access to 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 (free or paid).
• Subscribe to a paid Subscription Plan.
• Use the Prognia network, including your profile, connections, the feed, messages, voice and video calls, Spaces and their classrooms, the Rota calendar, the library and games.
• Use Ward, including its study tools, AI Features, medicines database, guidelines, clinical cases and calculators.
• Use Suture, including its documents, drawings, voice notes, image atlas and AI Features.
• Use Osler.
• Connect an external AI assistant to your account through our MCP connection.
• Receive communications from Prognia.
• Contact us for support or with enquiries.
• Book a meeting with us on one of our pages for organisations.

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

• Full name.
• Email address.
• Password (stored as a cryptographic hash only — we never store your password in plain text).
• Profile details you provide, such as a profile photo, country, institution, professional role or stage of training (for example medical student, resident or specialist), specialty, study year and exam goals. You declare these details yourself; Prognia does not verify them.
• Account preferences and settings.

3.2 Subscription and billing data

• Which plan (Free, Pro or Max) you have for each of Ward, Suture and Osler, and whether you are billed monthly or yearly.
• Billing date and subscription history.
• Payment method details: these are processed directly by Stripe, Inc. Prognia does not store your full card number, CVV, or other sensitive payment card details. We receive only a payment confirmation and a tokenised payment reference from Stripe.
• If you subscribe through Apple's App Store: Apple processes the payment, and we receive your subscription status through RevenueCat. We do not receive your payment card details or your Apple ID password.
• If you buy as a business: the business details you enter at checkout, such as a company name, address and VAT number.

3.3 Usage and activity data

• Features accessed and actions taken within the Services.
• Study activity, such as flashcard reviews and their review history (including history imported from Anki), quiz answers and results, AI-graded answers, clinical case attempts, study goals and study streaks.
• Your knowledge profile: which topics you have seen and how well you know them, built from your activity in Ward, Suture and Osler.
• Levels, coins, streaks and badges shown in your Prognia Passport.
• Search queries entered within the platform.
• Guidelines, articles, medicines and other items you view, save or rate.
• Time and frequency of use.

3.4 Content you create and share

• Posts, comments, reactions, polls, photos, videos and stories you share in the Prognia network.
• Messages you send in direct and group conversations and in Spaces, including attachments and voice messages, and classroom content such as announcements, questions and answers, and assignments.
• Calls: who took part, when, and for how long (your call history). The audio and video of a call are streamed live through our calls provider and are not recorded or stored by us.
• Calendar events in Rota, including the guests you invite and their responses.
• Ward content: decks, cards, questions and playlists you create or import (including Anki decks with their media and review history), and the ratings and reports you submit.
• Suture content: documents, notes, drawings and handwriting, uploaded files, images and PDFs, voice notes and their transcripts, and documents others share with you.
• Osler: the questions you ask and the answers you receive (your conversation history).

3.5 Communications data

• Email address used to receive transactional communications (password resets, subscription confirmations, receipts and billing notices).
• Email address and marketing communication preferences, if you have opted in to marketing communications.
• The content of any messages you send to us via email or support channels.
• If you join a waitlist on our website: your email address, your country and the app you are interested in, so that we can let you know when it becomes available to you.

3.6 Technical and device data

• IP address.
• Browser type and version.
• Device type and operating system.
• Time zone and language settings.
• Pages visited within the Services, timestamps, and referring URLs.
• Session identifiers and authentication tokens.
• A push notification token for your device, if you allow notifications in our apps for Apple devices.
• Crash and error reports (such as the error, app version, device model and operating system), collected by our own reporting system rather than by a third-party analytics or crash-reporting service.

3.7 Cookie and tracking data

We use only strictly necessary cookies and similar technologies: to keep you signed in across the Services, and to remember choices you make, such as your language, country, currency or light or dark theme. We do not use analytics, advertising or tracking cookies, and no third-party analytics or advertising software runs in the Services. See Section 10.

3.8 If you book a meeting with us

When you book a meeting on one of our pages for organisations, we collect your name and email address, the organisation you choose (and, if you add one that is not in our directory, its country and website), the time you pick, anything you write in the booking form, and the email addresses of any guests you add. We use them to hold and prepare the meeting and to reply to you. The booking calendar is provided by Cal.com, Inc.

Cal.com receives these details, and your IP address and browser details when the calendar loads, and processes them in the United States under the EU-US Data Privacy Framework, with Standard Contractual Clauses as a fallback (Sections 8 and 9). We process them on the basis of our legitimate interest in answering a business enquiry (Section 5) and keep them for 24 months after our last contact (Section 7).

The booking calendar loads from Cal.com only after you choose to open it, with “Next” or with “Book a call for …” at the top of the page. Cal.com then sets strictly necessary cookies (a security cookie from its provider Cloudflare, __cf_bm, for 30 minutes, and a session cookie, uid, that holds the time you pick) and stores your time-zone preference and a reservation key in your browser. No advertising or analytics cookies are set.

We collect personal data in the following ways:

• Directly from you: when you register for an account, complete your profile, create or share Content, send messages or make calls, subscribe to a plan, contact us, or otherwise interact with the Services.
• Automatically: when you use the Services, we automatically collect technical and usage data through server logs, session tracking, and necessary cookies.
• From third parties: we may receive limited data from Stripe, and from Apple through RevenueCat, in connection with payments (for example, confirmation of a payment or of your subscription status); from Apple or Google if you choose to sign in with them (your name and email address, which with Sign in with Apple may be a private relay address); and from other Users, for example when someone adds you to a Space or invites you to an event.

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 11 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.
• To provide and operate the Services — the Prognia network, Ward, Suture and Osler — and to keep you signed in across them with one account.
• To deliver your messages, calls, posts and shared Content to the people you choose, and to show your profile to other Users according to your settings.
• To personalise the Services, for example by suggesting colleagues, institutions and Spaces based on your profile, and by building a knowledge profile from your Ward study results, Suture notes and Osler questions that shapes what we suggest you study next.
• To provide the AI Features you use: we send the text (and, for speech-to-text, the audio) needed for each request to the AI providers listed in Section 8. To make your own Ward, Suture and Osler content searchable across the apps, we also create a search index of it, which involves sending its text to an AI provider.
• To process subscription payments and manage your billing relationship via Stripe, or via Apple and RevenueCat for App Store purchases.
• To deliver transactional communications, including account confirmations, payment receipts and password reset emails, and push or in-app notifications that you have not switched off.
• 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.
• To review reports about Content or behaviour, and to moderate the Services.
• To comply with applicable legal obligations, including tax and accounting requirements.
• To respond to your enquiries and support requests.
• To enforce our Terms of Service and other applicable policies.

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 in your account settings, your access to all the Services ends immediately and your personal data is permanently deleted 30 days later, except where we are required by law to retain it for longer (for example, financial transaction records under Dutch tax law). Deleting your account does not cancel a subscription you bought through Apple's App Store; see Section 7 of our Terms of Service.

Prognia does not sell your personal data to third parties. We share personal data only in the following circumstances:

8.1 Service providers (data processors)

We engage the following third-party service providers who process personal data on our behalf, under written data processing agreements:

In our apps for Apple devices, some AI features run on your device using Apple's on-device models; the data for those requests is not sent to an AI provider.

When you ask Osler a question, search terms based on your question are also sent to public medical databases to find sources, such as PubMed (US National Library of Medicine), Europe PMC, Cochrane, ClinicalTrials.gov, DailyMed, openFDA, the European Medicines Agency, RxNorm and the WHO ICD-11 service. These services receive the search terms, not your name or account details.

When you remove the background of an image in Suture, your browser may download the removal model from the servers of IMG.LY in Germany, which then receive your IP address. The image itself is not sent to IMG.LY.

8.2 Other users and services you choose

Content you share is visible to the people you share it with, according to the audience you choose: for example your connections or the members of a Space for a post, the participants of a conversation or call, the collaborators on a Suture document, anyone with the link, or all Users for public Ward content. Your profile is visible to other Users according to your settings. If you use Ask Osler in a conversation, the answer is posted in that conversation under your name.

If you connect an external AI assistant (such as Claude or ChatGPT) to your account through our MCP connection, that assistant can read and change your Ward and Suture content on your instructions. Its provider receives that data and handles it under its own terms and privacy policy. If you subscribe to your Rota calendar in another calendar app, that app retrieves your events through a private link, and anyone who has that link can see those events.

8.3 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 or security incidents.

8.4 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 is based in the Netherlands and stores your account data and the Content you create in the EU, in the Frankfurt (Germany) region of our database provider, Supabase. However, some of our service providers are located in the United States and other countries outside the European Economic Area (EEA), so personal data we share with them is transferred outside the EEA.

When we transfer personal data outside the EEA, we ensure that an appropriate safeguard is in place to protect your data, in accordance with GDPR Chapter V. For transfers to the United States and other third countries, we rely primarily on Standard Contractual Clauses (SCCs) adopted by the European Commission (Commission Implementing Decision (EU) 2021/914), supplemented where necessary by additional technical and organisational measures.

Each of our US-based service providers (Vercel, Stripe, Apple, RevenueCat, Resend, Google, Anthropic, OpenRouter, OpenAI, Upstash, LiveKit and Cal.com, and any future providers) has entered into data processing agreements with Prognia that incorporate the applicable SCCs, or is certified under the EU-US Data Privacy Framework. You may request a copy of the relevant transfer safeguards applicable to your personal data 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.

We use only strictly necessary cookies and similar technologies, which are required for the Services to function or to remember a choice you make: for example, session cookies to keep you signed in across the Services, and cookies that remember your language, country, currency or light or dark theme. These cookies do not require your consent.

We do not show advertising in the Services, we do not use analytics, advertising or tracking cookies, and we do not run third-party analytics or advertising software in the Services. If that ever changes, we will update this Policy first and ask for your consent before placing any such cookie on your device.

On our pages for organisations, the booking calendar loads from Cal.com only after you choose to open it, with “Next” or with “Book a call for …”. Cal.com then sets strictly necessary cookies (a security cookie from its provider Cloudflare, __cf_bm, for 30 minutes, and a session cookie, uid, that holds the time you pick) and stores your time-zone preference and a reservation key in your browser. No advertising or analytics cookies are set.

You can delete or block cookies in your browser settings. If you block strictly necessary cookies, parts of the Services, such as signing in, will not work.

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 information directly through your account settings.

11.3 Right to erasure

You have the right to request that we delete your personal data in certain circumstances, for example where the data is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies. Please note that we may be required to retain certain data by law (for example, financial records). You can delete your account yourself in your account settings; otherwise, we will delete or anonymise eligible data within 30 days of a valid erasure request.

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)), including profiling. 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, including profiling related to direct marketing. 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, including profiling, that produces legal effects or similarly significant effects on you. Prognia does not make any such automated decisions about users.

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, pages visited, features accessed.
• Audio or visual information: photos, videos, voice messages and voice notes that you upload or record. Calls are streamed live and are not recorded by us.
• Professional or employment-related information: the professional role, stage of training, institution and specialty you add to your profile.
• Inferences drawn from the above: your knowledge profile, and the colleagues, institutions, Spaces and study material we suggest to you.

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 without your consent. 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.
• Right to Limit Use of Sensitive Personal Information: where we process sensitive personal information (such as your account log-in details), we use it only to provide the Services and to keep your account secure.

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.

13.1 Our approach

You must be at least 16 years old to create a Prognia account. 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. The Services are intended for students and professionals in medicine and healthcare, and we do not knowingly collect personal data from anyone below the applicable minimum age.

13.2 US users under 13 — COPPA

The Services are not directed to children under 13, and children under 13 may not create an account. If we learn that we have collected personal data from a child under 13, we will delete it.

Parents or legal guardians who believe that a child below the applicable minimum age has created an account may contact us at medical@prognia.nl. We will investigate and, where appropriate, delete the account and its data.

13.3 EU/EEA users below the digital age of consent

In the Netherlands, the digital age of consent under GDPR Article 8 is 16, which is also our minimum age. In other EU member states, this age ranges from 13 to 16. Parental consent does not allow someone below our minimum age to register.

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 (Transport Layer Security / HTTPS).
• Cryptographic hashing of passwords (passwords are never stored in plain text).
• Row-level security policies in our database that limit each request to the data the signed-in account is allowed to access.
• Access controls limiting access to personal data to authorised personnel only, on a need-to-know basis.
• Storage of your account data and Content in the EU (Frankfurt, Germany).
• 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, including links to scientific articles, medical databases, and external 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.