Privacy Policy
Last updated: 2026-10-06
1. Data controller
The controller for data collected through this website and for platform account management is Bluix Group LTD, a company incorporated in England (United Kingdom). Contact: info@protue.com.
The United Kingdom benefits from a European Commission adequacy decision (Art. 45 GDPR). Platform data is stored on servers located in the European Union (Germany). The only exception are the artificial intelligence features described in section 6, which send part of the data to Anthropic, in the United States.
2. Roles: controller and processor
- Browsing data, contact requests and accounts: Bluix Group LTD acts as controller.
- Data about patients, assisted persons and workers uploaded by client organisations (including health data under Art. 9 GDPR): each organisation is the controller; Bluix Group LTD acts as processor under Art. 28 GDPR, based on a Data Processing Agreement (DPA) with each organisation. To exercise rights over such data, please contact the controlling organisation.
3. Data processed and purposes
- Contact data submitted through website forms: handling of the request and commercial follow-up (Art. 6.1.b and 6.1.f).
- Account data (credentials, roles, access logs): provision of the subscription service (Art. 6.1.b).
- Billing data: contractual and tax obligations (Art. 6.1.b and 6.1.c).
- Technical and security logs (pseudonymised IP addresses, audit trail): platform security (Art. 6.1.f).
4. Special categories of data (Art. 9 GDPR)
The platform is designed to process health data on behalf of controlling organisations (medical transport, care plans, clinical documents, prescriptions). Measures include: encryption at rest and in transit, per-tenant data isolation, role-based access control, auditing of every document access, encrypted backups, secure erasure procedures (crypto-shredding) and support for the controllers' DPIAs.
5. Sub-processors and recipients
- Netcup GmbH (Germany) — production hosting of the platform, the video conferencing server and the transcription server (EU).
- Hetzner Online GmbH (Germany) — email, storage of encrypted video recordings and ancillary services (EU).
- Anthropic (Anthropic Ireland, Limited; data is stored in the United States) — artificial intelligence features described in section 6.
- Stripe Payments Europe, Ltd. — card payment processing.
- Creem — subscription management as merchant of record, where active.
- TOPefekt s.r.o. (BulkGate, Czech Republic) — delivery of notifications and verification codes by SMS (EU).
- A-Cube s.r.l. (Italy) — transmission of electronic invoices to the Italian Exchange System (SdI), where active (EU).
- OpenStreetMap Foundation (United Kingdom) — maps on the access point pages: the visitor's browser loads the map from OpenStreetMap servers, which receive the IP address; the map position of an organisation's address is computed with OpenStreetMap's Nominatim service.
An up-to-date list of sub-processors is available on request at info@protue.com. We do not sell or share personal data with third parties for marketing purposes.
6. Artificial intelligence features (Anthropic)
Two platform features use Anthropic's models through its API:
- Automatic check of a transport request, before it is sent: Anthropic receives only the part of the request without identifying data (no names, exact addresses, phone numbers, documents or notes), i.e. the answers about the transport conditions, and the result of the automatic rules.
- Summary of telemedicine sessions and consultations: Anthropic receives the transcript of the session, only if the professional requests the summary for that session and the person has consented to transcription and summary. Before sending, tax codes, phone numbers, email addresses, dates of birth, street addresses, prescription and health card numbers are removed from the text; names spoken during the session remain in the text. Together with the transcript, Anthropic receives the type of visit, the professional's profession and specialty, and the chronic conditions recorded for the person.
The transfer to the United States is based on the European Commission's standard contractual clauses, included in the data processing addendum (DPA) of Anthropic's commercial terms. Anthropic deletes data received through the API within 30 days, except data flagged by its automated safety systems, which it keeps for up to 2 years; by default it does not use data received through the API to train its models.
7. Video visits, recording and transcription
Video visits go through Protue's video conferencing server (Jitsi Meet, on a Netcup server in Germany). A session is recorded only if the professional enables, for that session, recording, transcription or summary, and the person has given consent.
The recording is encrypted on the video conferencing server and stored encrypted on Hetzner (Germany); the plaintext copy on the video conferencing server is deleted. Only the platform holds the key to decrypt it.
Transcription is performed by a Protue server (Whisper, on the video conferencing server): the audio is not sent to external providers and the audio file is deleted as soon as the text is saved. If the professional did not ask to keep the video, the recording is deleted after transcription; if they asked for the summary without the full transcript, the full text is deleted once the summary is written.
8. Retention
Contact data is kept no longer than 24 months from the last interaction. Account and billing data is kept for the duration of the contract and the applicable statutory periods. Data processed on behalf of organisations is retained according to the controller's instructions and deleted or returned at contract termination.
9. Data subject rights
Under Arts. 15-22 GDPR you may exercise your rights of access, rectification, erasure, restriction, portability and objection by writing to info@protue.com. You may also lodge a complaint with your supervisory authority. For data processed on behalf of a controlling organisation, requests will be forwarded to the competent controller.
10. Changes
Any changes to this notice will be published on this page with the updated date.