Privacy Policy

The data controller is Pricefy Ltd, a company registered in England and Wales (company number 11256046, VAT number GB306388106), with registered office at 35 Ballards Lane, London N3 1XW, United Kingdom.

You can reach us about anything in this policy at info@refertio.com.

[Data Protection Officer: name and contact details, if one is appointed.]

This policy applies to the Refertio app for iOS and Android, the service behind it and the website at refertio.com.

Account data. Your name, your email address, your password (stored only as a one-way hash, never in readable form), your language, and the date and version of the terms and of the health-data consent you accepted.

Sign in with Apple or Google. If you choose one of them, the account identifier and the email address the provider shares with us.

Profiles. For each profile you create (for example you, your children or your parents): a name and, if you add them, date of birth and sex.

Medical records. The photos of your documents (JPEG or PNG), the text read from them, the details derived from that text (type of document, date, facility, doctor, laboratory values with unit and reference range) and the notes and corrections you add.

Devices. The name of each device signed in to your account and when it was last used, so that you can see them and sign them out.

Security codes. The six-digit codes we email you to verify your address or reset your password.

Website. The website sets only the technical cookies listed in our Cookie Policy. Our servers keep standard technical logs (IP address, date and time, requested page) to protect the service against abuse.

Providing the service, which means your account, your archive, reading your documents, search and your values over time. The legal basis is the contract between you and us (Article 6(1)(b) GDPR) and, for health data, your explicit consent (Article 9(2)(a) GDPR).

Service emails, such as verification codes, password resets and the message that your data export is ready. The legal basis is the contract.

Security, including technical logs and protection against unauthorised access. The legal basis is our legitimate interest in keeping your data safe (Article 6(1)(f) GDPR).

Legal obligations, for example keeping accounting records if paid plans are introduced (Article 6(1)(c) GDPR).

We do not use your data for advertising, we do not sell it and we do not use it to train artificial intelligence models.

You give your explicit consent to the processing of health data when you create your account. You can withdraw it at any time from the app settings. Withdrawing consent does not affect processing that took place before it, but without it we cannot keep providing the service. Before withdrawing, you can export your data.

When you create a profile for another person, such as a child, you confirm that you are entitled to manage their health data, for example as a parent or guardian, or with their permission.

Photos are read with automatic text recognition (Amazon Textract) inside the European Union. The type of document and the laboratory values are then recognised automatically, and you can correct them at any time. The original photo is never modified: it remains the reference for everything derived from it.

None of this produces decisions with legal or similarly significant effects on you (Article 22 GDPR). Refertio does not diagnose, treat or prescribe.

The feature that answers questions about your records is not available yet. Before we introduce it, we will update this policy and tell you which provider processes your data for it.

Your data is stored in the European Union on Amazon Web Services, in the Ireland region. Emails are sent from the Milan region. Data is encrypted at rest and in transit, and document files are never public: they can only be opened through temporary links created for you.

Amazon Web Services EMEA SARL processes data on our behalf under a data processing agreement. Any transfer to Amazon entities outside the European Union is covered by the Standard Contractual Clauses approved by the European Commission.

If you sign in with Apple or Google, the provider you choose also processes your data, as described in its own privacy policy.

We do not share your data with anyone else, unless the law requires us to.

Account, profiles and records: until you delete them or close your account. Deleting a record removes its photos and the data derived from them. Closing your account removes all of your data.

Data exports: the archive is deleted automatically when its download link expires.

Device sign-ins: each sign-in expires after 90 days, and expired sign-ins are deleted every day.

Security codes: valid for 15 minutes and for one use.

Backups and previous versions of files: kept for 7 days. Deleted data also disappears from them at the end of this period.

Technical logs: 14 days.

You have the right to access your data, to correct it, to have it erased, to restrict or object to its processing, to receive it in a portable format and to withdraw your consent at any time.

Many of these you can do yourself in the app: edit your records and profiles, export all your data with the original photos, and close your account. For anything else, write to info@refertio.com. We reply within one month.

You can also lodge a complaint with the Italian data protection authority, the Garante per la protezione dei dati personali, or with the authority of the country where you live.

Data is encrypted in transit and at rest. Document files sit in private storage and open only through temporary links. Each device signs in separately and can be signed out from the app. The app can be locked with Face ID, Touch ID or fingerprint, and its content is covered when it goes to the background. Access to production systems is limited to the people who run the service.

To create a Refertio account you must be at least 14 years old, and you confirm this in the app when you sign up. Under 14, consent to the processing of health data has to come from a parent or guardian, so a child does not get an account of their own: a parent or guardian creates a profile for the child inside their own account and manages the child's records from there.

When you create a profile for another person (a child, a parent, a partner), you confirm in the app that you are that person's parent or guardian, or that you have their permission to manage their records.

When we change this policy in a way that matters, we tell you in the app or by email before the change takes effect. If the change affects your consent, we ask for it again.