Privacy policy

Key points at a glance

• The controller is DoctoNex GmbH i. G. in Frankfurt am Main.
• The website and platform run on servers in Germany. For secure delivery, we also use Cloudflare.
• On the platform, facilities see your profile without your name. They never see your documents. Your profile is verified by our shareholder VMed.Pro AG in Switzerland.
• Google Analytics and Microsoft Clarity only run if you consent in the cookie banner. You can change this at any time via “Cookie settings” at the bottom of every page.
• We only use what you send us via forms to process your enquiry. We do not sell data.
• You have the right of access, rectification, erasure and objection at any time. Write to [email protected].

Part B of this privacy policy also applies to the platform app.doctonex.de (account, profile, documents).

Part A: website doctonex.de

1. Controller

DoctoNex GmbH i. G.
Oberlindau 5, 60323 Frankfurt am Main
Managing directors: Dr. Francesco De Meo, Luca de Miranda
Email: [email protected]

2. Hosting in Germany

We operate the website and the platform on our own servers at Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, in data centres in Falkenstein and Nürnberg. Hetzner processes technically necessary data such as your IP address so that the pages reach you. A data processing agreement under Art. 28 DSGVO is in place with Hetzner. Hosting does not involve any transfer of data to countries outside the EU.

The legal basis is our legitimate interest in secure and reliable operation (Art. 6 Abs. 1 lit. f DSGVO).

3. Secure delivery via Cloudflare

For name resolution (DNS), encrypted connections and protection against attacks and overload, we use Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. All requests to doctonex.de and our other addresses (app.doctonex.de, api.doctonex.de, supabase.doctonex.de, full.doctonex.de) pass through Cloudflare's network. Only email traffic does not pass through Cloudflare. For this, Cloudflare processes your IP address, date and time, the address requested and technical details about your browser and device. The platform's content continues to be stored only in Germany.

Cloudflare may transfer data to the USA. Cloudflare is certified under the EU-US Data Privacy Framework, for which there is an adequacy decision of the European Commission (Art. 45 DSGVO). A data processing agreement under Art. 28 DSGVO is in place with Cloudflare. The legal basis is our legitimate interest in secure and fast delivery (Art. 6 Abs. 1 lit. f DSGVO).

4. Server logs

Operating the website and the platform generates technical logs on our servers, for example about errors, sign-ins and access. They may contain your IP address, date and time and technical details about your device. We use them only to ensure security and to find errors.

• Before logs reach our monitoring system, we shorten IP addresses and mask email addresses, names and access keys. There, we delete them after 7 days.
• We automatically delete all other logs on our servers after 14 days at the latest.
• We do not keep a log of all page views.

We only keep logs for longer if a security incident needs to be investigated. The legal basis is our legitimate interest in secure operation (Art. 6 Abs. 1 lit. f DSGVO).

5. Cookies, browser storage and your consent

On your first visit, a banner asks whether you allow statistics and analytics services. You have two equivalent options: “Accept all” or “Necessary only”.

Necessary. Without these entries, the website and platform do not work as intended. They are stored only in your browser; we do not transfer them to third parties. The legal basis is § 25 Abs. 2 Nr. 2 TDDDG and Art. 6 Abs. 1 lit. f DSGVO.

• Your choice in the cookie banner: website, your browser's storage. We remember your decision on statistics and analytics, with the date. Duration: 12 months, after which we ask again.
• Language: platform, your browser's storage; after signing in, in your account. We use it to show the platform in your language. Duration: until you change the language.
• Entries in tools: website, your browser's storage. We remember your most recent entries, for example in the Karriereplaner. Duration: until you clear your browser storage.
• Session for personal preview access (“dx_full”): full.doctonex.de only, cookie, not readable by scripts or third parties. Access to the full website for invited guests; on every page view, we use it to check whether your access is still valid. Duration: no more than 7 days and never beyond the end of your access; deleted immediately when you sign out.

On the website, the language is part of the address (for example /en/ or /pt/); we store nothing for this.

Statistics and analytics. Google Analytics and Microsoft Clarity (sections 6 and 7) only load after you consent. The legal basis is your consent (§ 25 Abs. 1 TDDDG, Art. 6 Abs. 1 lit. a DSGVO).

You can withdraw or change your consent at any time with effect for the future. To do so, click “Cookie settings” at the bottom of any page.

6. Google Analytics

With your consent, we use Google Analytics 4 from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics sets cookies and records how you use the website: pages visited, time spent, where the visit came from, device, browser and approximate location (country, region). We only see aggregated analyses, not individual people. According to Google, Google Analytics 4 does not store full IP addresses.

The data may be transferred to Google LLC in the USA. Google is certified under the EU-US Data Privacy Framework (Art. 45 DSGVO). We delete the data after 14 months. The legal basis is your consent (Art. 6 Abs. 1 lit. a DSGVO, § 25 Abs. 1 TDDDG).

7. Microsoft Clarity

With your consent, we use Microsoft Clarity from Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Using cookies, Clarity records how you interact with the website, for example clicks, scrolling and mouse movements. This produces heatmaps and recordings of individual visits, which we use to improve the website. Clarity only runs on the website, never on the platform app.doctonex.de. Entries in form fields and text on the page are masked.

The data may be transferred to Microsoft Corporation in the USA. Microsoft is certified under the EU-US Data Privacy Framework (Art. 45 DSGVO). Recordings are deleted after 30 days, aggregated analyses after 13 months at the latest. The legal basis is your consent (Art. 6 Abs. 1 lit. a DSGVO, § 25 Abs. 1 TDDDG).

8. Contact and forms

If you write to us or use a form, we process your details in order to handle your enquiry. We store the forms on our servers in Germany. We send replies from our email inbox (see section 9).

• Email. Data: name, email, message, optional details. Purpose: to answer your enquiry. Legal basis: Art. 6 Abs. 1 lit. b DSGVO if it concerns a contract, otherwise lit. f. Deletion: 6 months after the matter has been dealt with.
• “Register interest for free” (doctors). Data: name, email, country of degree, current status. Purpose: to inform you when the platform launches and show you the right starting point. Legal basis: Art. 6 Abs. 1 lit. b DSGVO (your request prior to a contract). Deletion: 6 months after the platform launches, or earlier at your request.
• “Arrange a call” (facilities). Data: name, facility, email, message; optionally phone and a request for advance preview access to the full website. Purpose: to prepare and hold the call. Legal basis: Art. 6 Abs. 1 lit. b and f DSGVO. Deletion: 12 months after the last contact.
• “Request a package” (facilities, full website). Required: chosen package (GP Practice or Planning), facility, contact person, email; optional: phone, type of facility, number of sites, number of medical positions, desired start, message. Purpose: to review the request, agree the package and offer with you and prepare the contract. Legal basis: Art. 6 Abs. 1 lit. b DSGVO (your request prior to a contract). Deletion: 12 months after the last contact; if a contract is concluded, Part B applies.
• “Contact” (full website). Required: your role (for example doctor, facility, press, partner, investor), name, email, message; depending on your role, facility, organisation or media outlet; optional: phone, country of study, type of partnership, subject, appointment. Purpose: to answer your enquiry. Legal basis: Art. 6 Abs. 1 lit. b DSGVO if it concerns a contract, otherwise lit. f. Deletion: 12 months after the last contact.
• “Request a preview”. Data: name, organisation, role, email, phone, subject. Purpose: to review the request and grant personal access. Legal basis: Art. 6 Abs. 1 lit. b and f DSGVO. Deletion: 12 months after access ends.

Confirmation and protection against misuse. After you submit a form, you receive a confirmation by email; our team receives a message with your enquiry. To prevent automated misuse of the forms, when you submit a form we use a secret key to derive a value from your IP address from which the IP address cannot be reconstructed, and use it to limit the number of requests per hour. We delete this value after 30 days. The legal basis is our legitimate interest in secure operation (Art. 6 Abs. 1 lit. f DSGVO).

Access log for previews. If you are given personal access to the full website, we log your access (who, when, which pages). This is how we protect confidential content. The legal basis is our legitimate interest in protecting our trade secrets (Art. 6 Abs. 1 lit. f DSGVO). We delete the logs 12 months after access ends.

Without the required information in a form, we cannot process your enquiry. There is no other obligation to provide data on the website.

We only send emails with news or offers if you have separately agreed to this and confirmed your address.

9. Email and office applications

For email, calendar and documents, we use Google Workspace from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Automatic emails from the website and the platform are also sent through it. Google processes the content only on our behalf (Art. 28 DSGVO). A transfer to Google LLC in the USA is possible; Google is certified under the EU-US Data Privacy Framework (Art. 45 DSGVO). The legal basis is Art. 6 Abs. 1 lit. b and f DSGVO.

10. Technical support

Technical support for the website and platform is provided by Entrega Contínua Consultoria em Agilidade e Transformação Digital Ltda., Rua dos Guajajaras 910, Sala 1620, 30180-106 Belo Horizonte/MG, Brazil. The team works from Brazil and may access data in the course of development, maintenance and troubleshooting; the data itself remains on our servers in Germany. Entrega Contínua acts exclusively on our instructions and is contractually bound to confidentiality (Art. 28 DSGVO). For Brazil, there is an adequacy decision of the European Commission dated 27.01.2026 (Art. 45 DSGVO).

11. Fonts

The fonts on this website are stored on our own servers. No data is transferred to third parties such as Google Fonts when they load.

12. Recipients and countries at a glance

• Hetzner Online GmbH: hosting. Location: Germany.
• Cloudflare, Inc.: DNS, encryption, protection against attacks. Location: worldwide, including the USA. Basis: Data Privacy Framework.
• Google Ireland Ltd.: analytics (only with consent), email. Location: EU, including the USA. Basis: Data Privacy Framework.
• Microsoft Ireland Operations Ltd.: analytics (only with consent). Location: EU, including the USA. Basis: Data Privacy Framework.
• Entrega Contínua Ltda.: technical support. Location: Brazil. Basis: adequacy decision for Brazil.
• VMed.Pro AG: verification of profiles (platform only, Part B). Location: Switzerland. Basis: adequacy decision for Switzerland.
• Stripe Payments Europe, Ltd.: payments, once paid services start (Part B, section B13). Location: EU, including the USA. Basis: Data Privacy Framework.

We do not pass on data unless this privacy policy says so, you have consented or we are legally obliged to do so. We do not sell data.

13. No automated decisions

On the website, we do not make any decisions about you that are based solely on automated processing (Art. 22 DSGVO). The website's tools, for example the Karriereplaner, give guidance based on the information you enter. You decide for yourself.

The tools run their calculations in your browser. Before you register, we do not send your entries to our servers. If you click “Register” in the Karriereplaner, we pass your answers (for example country of degree, preferred federal state) to the registration page so that you do not have to enter them again.

14. Your rights

You have the right to:

• Access to your data (Art. 15 DSGVO)
• Rectification of inaccurate data (Art. 16 DSGVO)
• Erasure (Art. 17 DSGVO)
• Restriction of processing (Art. 18 DSGVO)
• Data portability (Art. 20 DSGVO)
• Withdrawal of consent with effect for the future (Art. 7 Abs. 3 DSGVO)

To do so, write to [email protected]. We reply within one month.

Your right to object (Art. 21 DSGVO)

If we process data on the basis of our legitimate interest (Art. 6 Abs. 1 lit. f DSGVO), you can object at any time on grounds relating to your particular situation. We will then no longer process the data unless there are compelling legitimate grounds or the processing serves to establish, exercise or defend legal claims. You can object to advertising at any time without giving reasons. An email to [email protected] is sufficient.

15. Complaint to a supervisory authority

You can lodge a complaint with any data protection supervisory authority, in particular in the country where you live. The authority responsible for us is the Hessische Beauftragte für Datenschutz und Informationsfreiheit, Gustav-Stresemann-Ring 1, 65189 Wiesbaden.

16. Changes and language versions

We update this privacy policy when our website or the legal situation changes. The version published here applies. This policy is available in German, English and Portuguese. The German version is authoritative.

Part B: platform app.doctonex.de

Part B applies in addition to Part A to everyone who has an account on the platform: doctors, users from facilities and partners. The controller is DoctoNex GmbH i. G. (Part A, section 1).

B1. Doctors' accounts and profiles

When you register, we process your name, your email address, your password (encrypted), your language and the details you provide in your profile: for example country where you obtained your degree, specialty, professional experience, language level, status of your recognition procedure, preferred federal states and start date. We use them to provide you with your account, the Karriereplaner, the Weiterbildungsplaner and the other services under the terms of use.

The legal basis is the contract with you (Art. 6 Abs. 1 lit. b DSGVO). We need the required fields to plan your path; without them, you cannot use the platform.

B2. Documents and CV

You can upload documents, for example ID, diplomas, certificates and language certificates. We use them to keep your checklist up to date and to verify your profile. If you upload your CV, the platform reads it automatically and pre-fills your profile; you check and change the details yourself.

We delete the copy of your ID as soon as your identity has been verified. We only keep a record that, and when, your identity was verified.

Only you, the responsible doctonex team and VMed.Pro AG (for verification) see your documents. Facilities never see your documents. Your documents are stored encrypted in protected storage; every access is logged.

B3. Karriereplaner and estimates

Based on your details and the authorities' rules, the platform calculates your next steps, deadlines and an estimate of when you are likely to be able to work as a doctor. Facilities in the pool also see this estimate. It is based on fixed rules, not on a comparison with other people. The platform does not automatically make decisions that have legal effects on you (Art. 22 DSGVO); the decision to hire is always made by the facility.

B4. Verification by VMed.Pro AG

Every profile is verified by our shareholder VMed.Pro AG, Feldstrasse 5, 8853 Lachen SZ, Switzerland. At launch, this is a digital check of your details and uploaded documents, for example whether they are complete and consistent with each other. We are gradually expanding the scope of the verification. If we make enquiries with authorities for this purpose, we only do so with your power of attorney (section B5). For the verification, VMed.Pro has access to your details and documents from the time you register. VMed.Pro acts exclusively on our behalf and on our instructions (Art. 28 DSGVO) and does not use the data for its own purposes. For Switzerland, there is an adequacy decision of the European Commission (Art. 45 DSGVO).

B5. Enquiries with authorities

If you give us a power of attorney, we or VMed.Pro ask the competent authority about the status of your procedure, for example missing documents, exam dates and results. We use this information to keep your plan up to date and to verify your profile (Art. 6 Abs. 1 lit. b DSGVO). You can revoke the power of attorney at any time.

B6. Visibility to facilities

Verified facilities see your profile without your name, photo and contact details. If a facility sends a contact request and you agree, we pass your name and contact details on to that facility (Art. 6 Abs. 1 lit. b DSGVO). From then on, the facility is itself responsible for this data. It has undertaken to use the data only to fill a position, not to pass it on and to delete it no later than six months after a rejection.

You can switch off visibility in your profile at any time. We store when you switched it on or off and which requests you agreed to.

B7. Partners

If you chose a partner when registering, we store this choice with the date. Your partner sees how far along your path you are; your documents only if you share them (Art. 6 Abs. 1 lit. b DSGVO). If your partner is based outside the EU and the countries with an adequacy decision, we safeguard the transfer with the European Commission's standard contractual clauses (Art. 46 DSGVO). You can obtain a copy on request.

B8. Facility accounts

For users from facilities, we process name, role, business contact details and information about the facility, its sites, its needs and its positions. We verify the facility before activating it. The legal basis is the contract with the facility and our legitimate interest in a verified group of facilities (Art. 6 Abs. 1 lit. b and f DSGVO).

B9. Emails and messages

We send messages about your account and your path, for example deadlines, requests from facilities or security notices, because they are part of the service (Art. 6 Abs. 1 lit. b DSGVO). We only send emails with tips and offers with your consent (Art. 6 Abs. 1 lit. a DSGVO, § 7 UWG), which you can withdraw at any time via the link in every email or in your account. Sent via Google Workspace (Part A, section 9).

B10. Reports and appeals

We handle reports of illegal content and appeals against our decisions in accordance with the Digital Services Act (Art. 6 Abs. 1 lit. c DSGVO). For this, we store the report, your contact details and our decision.

B11. Security

We log sign-ins with IP address, failed sign-in attempts and access to documents in order to protect the platform and your data (Art. 6 Abs. 1 lit. f and Art. 32 DSGVO). We delete the sign-in log after 14 days. doctonex staff sign in with two-factor authentication. We back up the database daily, encrypted, on servers in Germany; backups are overwritten after six months at the latest.

B12. Platform service providers

For the platform, we use the same service providers as for the website (Part A, sections 2, 3, 9 and 10): Hetzner (hosting in Germany), Cloudflare, Google Workspace and Entrega Contínua, plus VMed.Pro AG for verification and, once paid services start, Stripe (section B13). Google Analytics and Microsoft Clarity do not run on the platform.

B13. Paid services and payments

We expect to offer paid services, for example Plus and Guidance for doctors or packages for facilities, from 1 January 2027. If you book such a service, we process your name, your email address, your billing address, the service booked, term, amount, date and payment status in order to perform the contract and issue invoices (Art. 6 Abs. 1 lit. b DSGVO) and to comply with statutory retention obligations (Art. 6 Abs. 1 lit. c DSGVO). For Guidance, this also includes your messages to your contact person and notes on conversations.

For payment, we use Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland. You enter your card or account details directly with Stripe; we do not receive them in full. Stripe processes some payment data as an independent controller, for example to prevent fraud and to meet its own legal obligations; Stripe's privacy policy applies to this. Stripe may transfer data to the USA; Stripe is certified under the EU-US Data Privacy Framework (Art. 45 DSGVO).

B14. Retention period

• Account and profile: as long as you use your account.
• Account without sign-in: after 24 months without signing in, we set your account to inactive; it then no longer appears in the pool. The next time you sign in, it becomes active again. After a further 36 months without signing in, we anonymise it.
• Copy of ID: until identity verification is complete.
• If you delete your account: your profile disappears from the pool immediately; we delete or anonymise your personal data within 30 days.
• Records of consents, introductions and settings: 3 years after the end of the year in which the account ends (limitation period, § 195 BGB).
• Logs: sign-ins and server logs for no more than 14 days; access to documents 12 months.
• Invoices and accounting records: 8 years; commercial books and annual financial statements: 10 years (§ 147 AO, § 257 HGB).

B15. Anonymous analyses

From the paths of doctors on doctonex, we create anonymous analyses, for example how long a step takes in a federal state or what it costs. We use them to improve the Karriereplaner and the estimates for everyone. Anonymous data cannot be traced back to you and does not fall under the GDPR (DSGVO).

B16. Your rights

Your rights under Part A, section 14, apply, including the right to object, as does the right to lodge a complaint under section 15. You can change or delete many details directly in your profile. On request, you receive your data as a file.