Introduction & Scope
CircleQ Co., Ltd. ("we") provides a cloud-based clinic and hospital management platform. This policy applies to all users — clinics, hospitals, staff, and patients using the Patient Portal.
Information We Collect
We collect four categories: (a) Account data — email, name, phone, role; (b) Clinic/organization data — business name, address, branches, finances; (c) Medical data — patient history, diagnoses, medication, lab results; (d) Usage data — access logs, IP, browser, device.
Purposes of Processing
To deliver the contracted service (store medical records, send LINE OA, issue receipts), improve the service (aggregated, de-identified analytics), comply with the law (retain records 5+ years per the Sanatorium Act), and maintain security.
Legal Bases
Under PDPA Section 24: (1) Consent — collecting sensitive patient data requires written consent; (2) Contract — data necessary to provide the service; (3) Legitimate interest — security logs, fraud prevention.
Disclosure to Third Parties
We disclose data only as necessary to: cloud providers (AWS/Cloudflare), AI provider (Anthropic — Zero Data Retention), payment provider (Omise), and regulators upon court order. We never sell your data.
Use of AI Services
The AI Clinical Assistant uses Anthropic's Claude with Zero-Data Retention — patient data is anonymized (names/IDs removed) before processing, results are returned without retention on the AI provider's side, and clinics can disable this feature.
Data Retention
Medical records: 5 years after last treatment per the Sanatorium Act · Financial/tax records: 10 years per the Accounting Act · User accounts: for the duration of service + 90 days after cancellation.
Your Rights
You have the right to access, correct, delete, object to, or restrict processing, plus the right to data portability and to withdraw consent at any time.
Security Measures
AES-256 encryption at rest and in transit (TLS 1.3) · audit logs for every access · Role-Based Access Control and Zero-Trust Architecture.
Cross-Border Transfers
Data is stored in Asia-Pacific data centers. Where cross-border processing occurs, we apply adequate safeguards as required by PDPA.
Cookies & Tracking
The website uses cookies for core functionality and analytics. See the Cookie Policy for details.
Minors
Where a patient is a minor, consent must be given by their legal guardian.
Changes to This Policy
We may update this policy from time to time and will notify you in advance of significant changes via in-app notification. Contact our Data Protection Officer (DPO): dpo@circleq.app
