Privacy Policy for NeuroRadX
This Privacy Policy describes how NeuroRadX processes personal data for its educational platform. The controller is based in Switzerland. The Swiss Federal Act on Data Protection (FADP/DSG) and its Ordinance (DPO/DSV) apply. The EU GDPR also applies where its territorial scope is met, for example when offering services to people in the EEA or monitoring their behaviour there. This Policy supplements our Terms of Use.
1. Data Controller
The controller responsible for processing your personal data is:
Andres PintaMusterstrasse 1
8004 Zürich
Schweiz
support@neuroradx.com
Further legal information is available in our Impressum. For data protection enquiries or to exercise your rights, contact us at the address or email above.
2. Scope and Relationship with the Terms of Use
Under Swiss law we process data lawfully, proportionately, transparently and for the purposes described here. Where a justification is required, it may arise from consent, an overriding private or public interest, or law (Art. 31 FADP). The GDPR legal bases stated below apply only where the GDPR applies.
This Privacy Policy applies to the NeuroRadX website, application, and related services. When you register for an account, purchase a plan (when available), or otherwise use the Service, we process personal data as described here and as necessary to perform our Terms of Use.
- Contract performance (Art. 6(1)(b) GDPR): Account creation, authentication, providing study features, support, and billing where applicable.
- Consent (Art. 6(1)(a) GDPR): Optional profile fields and, where required, specific checkout or marketing consents.
- Legitimate interests (Art. 6(1)(f) GDPR): Security, fraud prevention, service improvement, and essential technical operation, balanced against your rights.
3. Data We Process, Purposes, and Legal Basis
We process your personal data in the following categories:
3.1. Account, Access, and Subscription Information
Information required to create, approve, and manage your account and access level.
- Data collected: First name, last name, full name, email address, unique user ID (Firebase UID), account status (e.g. approved, pending, rejected), role (e.g. user, admin), access or subscription level (e.g. Trial, Evaluator, Premium, promotional access), subscription or access expiry date, coupon codes used at registration, account creation date, the IP address used to register, and a record of your acceptance of the Terms of Use and of your confirmation that you are at least 18 (date and versions of the Terms of Use and of this Privacy Policy in force at the time).
- Purpose: To create and secure your account, verify eligibility, authenticate you, manage access levels, prevent abusive registrations, document which version of our legal texts you accepted, and communicate with you about the Service.
- GDPR basis (where applicable): Art. 6(1)(b) GDPR – processing necessary for the performance of the contract (Terms of Use).
3.2. Optional Profile Information
Voluntary information you may provide to personalise your profile.
- Data collected: Country, institution, profile photo (stored in Firebase Storage), declared specialisation (e.g. student, resident), and profession.
- Purpose: To personalise your profile. We may use this data in anonymised and aggregated form for statistical analysis.
- GDPR basis (where applicable): Art. 6(1)(a) GDPR – your consent. You may withdraw consent at any time by removing this information from your profile or contacting us.
3.3. Activity and Progress Data
Data generated as you use the app, essential for the learning functionality.
- Data collected:
- Quiz sessions: History of study sessions, exam settings, scores, and which questions you answered correctly or incorrectly.
- User questions: Record of questions you interact with, including times seen, correct/incorrect answers, and mastery status.
- Bookmarked questions: Questions you have saved for future review.
- Question notes: Your personal annotations on specific questions. Do not include patient-identifying or third-party health data in notes (see Section 8).
- Seen facts: Record of which "Did you know..." facts you have seen.
- Purpose: To provide your personalised learning experience, track progress, identify strengths and weaknesses, and enable you to review your activity.
- GDPR basis (where applicable): Art. 6(1)(f) GDPR (legitimate interest). Our legitimate interest is to provide the core educational features of the Service.
3.4. Notifications, Support Messages, and Issue Reports
Data related to in-app communications and support.
- Data collected: In-app notifications (linked to your user ID), support messages you send us (subject, message text, your name and email address), and issue reports you submit (including question ID, problem type, description, your user ID, and any contact email you choose to add).
- Purpose: To deliver administrative messages, inform you about updates to reported issues, and process your support requests.
- GDPR basis (where applicable): Art. 6(1)(b) GDPR (contract) and Art. 6(1)(f) GDPR (legitimate interest in improving our content and support).
3.5. Payment and Billing Data (when paid plans are offered)
If you purchase a paid plan through our website, we or our payment provider may process billing-related data.
- Data collected: Billing status, transaction references, plan purchased, amount paid, currency, invoice metadata, and limited payment method details (e.g. last four digits or tokenised payment identifier). We do not store full payment card numbers on our servers.
- Purpose: To process payments, manage subscriptions, issue invoices where required, handle refunds, and comply with tax and commercial record obligations.
- GDPR basis (where applicable): Art. 6(1)(b) GDPR (contract) and Art. 6(1)(c) GDPR (legal obligation, e.g. tax and commercial retention).
Purchases through the Apple App Store or Google Play (when available) are processed by those platforms. We receive limited purchase confirmation data from the platform, not your full payment credentials.
3.6. Technical and Security Data
- Data collected: IP address, device type, browser or app information, operating system, approximate log timestamps, server logs (which may contain your user ID or email in error or security events), and a daily record of which questions were sent to your account, kept for 30 days to detect bulk copying of the question bank.
- Purpose: To ensure technical functionality, stability, security, abuse prevention, and troubleshooting.
- GDPR basis (where applicable): Art. 6(1)(f) GDPR (legitimate interest).
3.7. Cookies and Local Storage
We use Firebase session cookies for sign-in and local storage for your selected language, text size and appearance. A cookie remembers the sidebar state. We have not integrated advertising or cross-site marketing trackers.
Swiss data protection law and Art. 45c of the Telecommunications Act apply to cookies and similar storage. You can block or delete cookies and site storage in your browser; doing so may prevent sign-in or reset preferences. Where applicable law requires consent for non-essential storage or processing, it must be obtained before that use.
| Name | Type | Purpose | Duration |
|---|---|---|---|
| __session | First-party cookie (HTTP-only) | Keeps you signed in and lets the server verify your identity. | 72 hours |
| sidebar_state | First-party cookie | Remembers whether the sidebar is open or collapsed. | 7 days |
| firebaseLocalStorageDb | IndexedDB | Stores the Firebase Authentication sign-in state in your browser. | Until you sign out |
| appLanguage, appTextSize, theme | Local storage | Remembers your selected language, text size and appearance. | Until you change or delete it |
| neuroradx:daily-goal:v1 | Local storage | Remembers your daily question goal. | Until you change or delete it |
| nrx:report-draft:… | Local storage | Keeps unsent drafts of question issue reports. | Until you send or discard the report |
| platformNoticeLastShown:v1 | Local storage | Records the date a platform notice was last shown, so it appears at most once a day. | Until you delete it |
| loginFailCount, passwordChangeFreshLogin, platformNoticePending:v1 | Session storage | Counts failed sign-in attempts to decide when verification is required, and supports the mandatory password change and pending notices. | Until you close the tab |
| _GRECAPTCHA | Third-party cookie (Google) | Set by Google reCAPTCHA on registration, password reset and, when required, sign-in to distinguish people from bots. | Set by Google (see Google’s privacy policy) |
4. AI-Assisted Processing and Content Enrichment
NeuroRadX may use automated or AI-assisted tools to enrich educational content, discover scientific references, or improve internal workflows. This section describes how such processing relates to your personal data.
- Administrator content enrichment: Authorised administrators may use tools such as Google AI (Gemini) to enrich question text with scientific references. Only question content is processed in this workflow. We do not send your personal profile, notes, or activity data to Google AI for this purpose.
- User-facing features: If future features expose AI-assisted outputs directly to users, we will describe the relevant processing in an updated version of this Policy before launch.
- We do not make exclusively automated individual decisions with legal or similarly significant effects within Art. 21 FADP or, where applicable, Art. 22 GDPR. Security checks may block a registration or sign-in attempt; contact support for human review if this prevents access.
5. Data Recipients and International Transfers
Transfers from Switzerland are subject to Art. 16–17 FADP. We rely on an applicable Swiss adequacy decision or appropriate safeguards, such as recognised standard contractual clauses with Swiss adaptations. The Swiss–US Data Privacy Framework applies only to US recipients with an active certification covering the transfer; the EU–US framework alone is not a Swiss transfer basis. Where the GDPR applies, its Chapter V safeguards also apply. Contact us for information about safeguards applicable to your data.
We do not sell your personal data. We share data only with service providers who help us operate the Service, subject to appropriate safeguards:
- Google Firebase / Google Cloud provides authentication, database storage and hosting. The application server is configured in Germany. The Firestore database uses Belgium and the Netherlands, with a witness replica in Finland; Firebase Authentication processes data in the United States. This is not Switzerland-only hosting. Other Google services, global content delivery and support may involve additional processing locations described in Google’s service and subprocessor information.
- Algolia: Powers search functionality. We index question content, not personal user profiles. Algolia may process data in the EU or USA under appropriate safeguards.
- Google AI (Gemini): Used by administrators to enrich question content. Only question text not linked to identifiable users is processed, as described in Section 4.
- Email delivery (Google Workspace): Sends transactional emails such as account verification, password reset, organisation invitations and notices to organisation administrators. Google receives the recipient's email address and the message content. Firebase Authentication generates the one-time codes contained in verification and password-reset links.
- Your organisation: If you join an institution or scientific society (by invitation, registration code, or your email domain) and agree to progress visibility, authorised staff of that organisation can see the progress reports intended for learning supervision. They do not see your personal notes.
- For institutional checkout payments, Stripe processes contact, billing and payment data, including processing in Ireland and the United States. NeuroRadX stores customer, subscription and transaction identifiers and payment status, not full card details. Purposes are contract performance and compliance with applicable record-retention obligations. Where the GDPR applies, Art. 6(1)(b) and (c) apply. The international-transfer safeguards below also apply.
- Apple / Google (future in-app purchases): If in-app purchases are offered, those platforms process payment data under their own privacy policies.
Service providers acting as processors are engaged under Art. 9 FADP and, where applicable, Art. 28 GDPR. Some payment or platform providers also process data as independent controllers for their own legal duties; their privacy notices explain that processing.
Provider information on processing locations
Protection against automated abuse (reCAPTCHA)
Registration and, when required, sign-in use Google reCAPTCHA. IP addresses, browser and device information and interactions may be sent to Google, and information may be stored on or read from your device. Transfers to third countries, including the USA, may occur. See Google’s privacy policy for details of its processing.
Abuse prevention serves secure operation under the Swiss FADP. Where the GDPR applies, the basis is Art. 6(1)(f), subject to a balancing of interests. Device storage is also subject to Art. 45c of the Swiss Telecommunications Act and any applicable foreign consent requirements. If verification blocks access, contact support@neuroradx.com for assistance.
Google Privacy PolicyLearning modules, research and institutional access
If you participate in a learning study, we process the information requested in the participation form, versioned consent and learning and assessment results. The purpose, participation conditions and consent are explained before participation. Study administrators can export the designated study evaluations. With institutional access, authorised staff receive the progress reports intended for learning supervision under the sharing notice shown to you. Send access, deletion or consent-withdrawal requests to support@neuroradx.com; withdrawal does not affect the lawfulness of earlier processing.
If you delete your account: your pre- and post-test answers and the demographic data you gave for the study (position, experience, clinical background, language, institution, and whether you agreed to be contacted) are kept for the study analysis, under your participant code. Your name, email address, and profile are deleted, so the study data can no longer be attributed to you. If you want your study data deleted as well, write to support@neuroradx.com before deleting your account. Study data are kept only as long as the study and its scientific publication require and are used only in aggregated form, as described in the consent you gave.
6. Data Retention
- Account and progress data: Retained while your account is active. When you delete your account, we delete your profile (including the registration IP address and the record of your acceptance of the legal texts), progress, notes, bookmarks, notifications, support messages, and profile photo. Issue reports you submitted are kept without your name, user ID, or email address, because they concern question content. Study data are handled as described in the research section above.
- Backups: Database backups are kept for up to 90 days. Data you delete therefore disappears from backups within 90 days at the latest.
- Billing and accounting records: retained for applicable Swiss statutory periods, including ten years from the end of the financial year for records covered by Art. 958f of the Code of Obligations. Data outside retention duties is kept only as long as necessary for its purpose or legitimate legal claims.
- Server and security logs: Typically retained for up to 30 days unless longer retention is necessary to investigate security incidents or comply with law.
- Support messages and issue reports: Retained as long as needed to resolve the issue and improve the Service, and in any case deleted or anonymised as described above when you delete your account.
7. Security
We implement appropriate technical and organisational measures to protect your personal data, including encryption in transit (TLS), access controls, and secure authentication. Our infrastructure is hosted on Google Cloud Platform with industry-standard security practices. No method of transmission or storage is completely secure; please use a strong password and keep your credentials confidential.
8. Your Responsibilities and Special Categories of Data
This Service is for medical education and does not support processing identifiable patient data. Do not enter patient names, identifiers, health records or other sensitive personal data under Art. 5(c) FADP or Art. 9 GDPR in notes, reports or profiles.
If you believe you have submitted such data in error, contact us promptly so we can delete it.
9. Your Rights as a Data Subject
Under the FADP you may request access to your data (Art. 25), correction of inaccurate data and, where the legal conditions are met, deletion or cessation of processing (Art. 32). You may request delivery or transfer of data under Art. 28 where its conditions are met. Consent may be withdrawn for future processing; statutory retention duties and other lawful grounds remain unaffected.
Where the GDPR applies, you additionally have its rights of access, rectification, erasure, restriction, portability and objection (Art. 15–21), withdrawal of consent (Art. 7(3)) and complaint to a competent supervisory authority (Art. 77), subject to the conditions of those provisions.
You may report suspected breaches of Swiss data protection law to the Federal Data Protection and Information Commissioner (FDPIC/EDÖB). Civil-law remedies before the competent courts remain available.
FDPIC / EDÖBContact the controller in Section 1 to exercise your rights. Access requests under Swiss law are generally answered within 30 days; we will inform you within that period if more time is needed. Where the GDPR applies, its one-month period and extension rules apply. We may request proportionate identity verification.
10. Minors and Professional Audience
NeuroRadX is intended for medical students, residents, radiologists, neuroradiologists, neurologists, neurosurgeons, and other healthcare professionals or trainees. We do not knowingly collect personal data from children under 18. By registering, you confirm that you are at least 18 years old, consistent with our Terms of Use. If you believe we have inadvertently collected data from a person under 18, please contact us and we will delete it promptly.
11. Changes to This Policy
We may update this Privacy Policy to reflect legal, technical, or business changes. Immaterial changes may take effect upon publication. Material changes will be notified by updating this page and, where appropriate, by email or in-app notice at least 30 days before they take effect. The "Last updated" date at the top indicates the current version.
12. Contact
For any questions about this Privacy Policy or our data practices, please contact us at support@neuroradx.com or at the address in Section 1.