My GMI Privacy Policy

Introduction

This Privacy Policy explains how Dcentric Health Ltd ("we," "our," "us") collects, uses, discloses, and protects your personal data in relation to the My GMI app. Dcentric Health Ltd is a company formed under the laws of Cyprus with registration Number ΗΕ 391425. The My GMI app is a mobile application commissioned by the German Medical Institute (https://gmi.com.cy/) and developed by Dcentric Health Ltd. Dcentric Health Ltd is responsible for all development and securely stores all personal data collected through the app. We are committed to complying with the General Data Protection Regulation (GDPR) and ensuring the confidentiality and security of your data.

By using the My GMI app ("the App"), you agree to the terms of this Privacy Policy.

The My GMI app allows you to automatically download and store health data to your device through a direct connection with your healthcare provider, GMI. The health data you download on your device may not reflect your complete medical history and should not be used as a substitute for your official medical records.

Data Controller

Dcentric Health acts as the Data Controller for the personal data processed through the App. If you have any questions or concerns about this policy, please contact us at: aria@myaria.health 

Furthermore, you can contact the Data Protection Officier of the German Medical Institute at: DPO@goc.com.cy

What we collect

We may collect and process the following types of personal data:
1. Personal Identification Information: Name, email address, phone number, date of birth, gender, passport and/or national ID number and GESY number.
2. Health Information: Data you provide related to symptoms, health conditions, or treatments (e.g., ePROs).
3. Usage Data: Information about your use of the App, including device identifiers, IP addresses, and analytics data.
4. Communications: Information from support requests or correspondence.

Sources of Data

The data processed within the MyGMI app is obtained from two main sources:

1. Data Provided by the German Medical Institute (GMI):
Certain personal and medical data is shared with the MyGMI system directly by GMI based on your instructions and consent, such as appointment history, basic health records, or administrative details, in accordance with their internal policies and your patient relationship with them.

2. Data Provided Directly by You:
Additional information may be collected directly from you through the MyGMI app. This includes, but is not limited to, data entered during registration, health questionnaires or surveys you complete, symptom tracking, appointment requests, and other interactions within the app.

This dual-source approach allows for a more complete and personalised experience while ensuring that you remain in control of the information you choose to share through the platform.

How we use your data

We use your data for the following purposes:
1. To provide you with the products and services you request
2. To improve the App’s services.
3. To facilitate participation in research studies - if consented to by you.
4.  To communicate with you, including updates and notifications.
5.  To comply with legal and regulatory requirements. 

MyGMI does not perform automated analysis or profiling to assess your health status. 

Legal basis for processing

We process your data based on:
1. Consent: Where you have explicitly consented (e.g., joining a study).
2. Performance of a Contract: To deliver the App’s services.
3. Legal Obligations: Compliance with applicable laws.
4. Legitimate Interests: For security, fraud prevention, or improving our services.

Data sharing

We may share your data with:
1. Service Providers: Third parties who assist in delivering the App’s services (e.g., hosting, analytics).
2. Legal Authorities: If required by law or to protect our rights.

International data transfers

If your data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or equivalent mechanisms.

Data retention

We retain your data only as long as necessary for the purposes outlined in this Privacy Policy or as required by law. Specific retention periods include:
- Health data: Retained for the duration of the study or service, then securely deleted or anonymized.
- Account data: Retained until account deletion.

Your rights

Under GDPR, you have the following rights:
- Access: Request a copy of your personal data.
- Correction: Correct any inaccurate or incomplete data.
- Erasure: Request deletion of your data ("right to be forgotten").
- Restriction: Limit the processing of your data.
- Portability: Obtain your data in a machine-readable format.
- Objection: Object to data processing based on legitimate interests.
- Withdraw Consent: Withdraw consent at any time.

To exercise these rights, contact us at the email provided above.

Data security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, or destruction. These measures include encryption, secure servers, and regular audits.

Cookies and tracking

The App may use local storage or analytics tools (similar to cookies) to improve user experience and understand how the app is used. You can manage tracking settings through your device.

Updates to this policy

We may update this Privacy Policy periodically. Any changes will be posted within the App, and we encourage you to review it regularly.

Complaints

If you have concerns about our data processing practices, you have the right to lodge a complaint with your local Data Protection Authority.

Latest Update: 16th July 2025

By continuing to use the My GMI app, you acknowledge that you have read and understood this Privacy Policy.