Privacy Policy

This policy explains how MyXrayDose Limited ("MyXrayDose", "we", "us") collects, uses and protects personal information through the ViziCAL website, the customer portal, the web service and the ViziCAL desktop software. ## Who we are MyXrayDose Limited is a company registered in New Zealand (company number [PLACEHOLDER: NZ company number]). Our address is Parnell, Auckland. We are responsible for the personal information described here. Privacy questions or requests: info@myxraydose.com. [PLACEHOLDER: Privacy officer name or role.] Where your organisation uses ViziCAL, your organisation decides what records it keeps about its own equipment and staff. For those records we act on its behalf (under the GDPR, as its "processor"). ## What we collect **Account and contact details** - Name, work email, phone number, organisation and role. - Sign-in security information: a hashed copy of your password (never the password itself), two-factor settings, and hashed recovery codes. - Invitations you send or receive. **Organisation and billing details** - Organisation name, address and billing contact. - Orders, licences, invoices, purchase-order numbers, coupons and web service renewals. - Card payments are made on Stripe's payment page. We do not see or store card numbers. **Workstation and display information** The desktop software sends us details about the computers and displays it is licensed on: - A processor identifier (CPU ID) used to tie a licence to one computer. - The computer name and the location you enter in the software. - Display make, model and serial number, and graphics card. - Status reports from the software. These can include log text, which may contain computer and Windows user names. **Calibration and quality-assurance (QA) results** - Calibration and QA measurements, pass/fail results, visual check answers, comments and PDF reports. - The name of the person who performed each check. - Files your users attach to records. **Enquiries** What you send through the contact, partner, pricing, demo and trial forms, and the IP address it came from. **Security and activity logs** - Sign-ins: time, IP address and browser type. - An audit log of changes, including who made them. - A record of every time our support staff or your distributor views your account on your behalf. - Licence activations: time, IP address and software details. **Cookies** We only use cookies that are needed to sign you in and keep your session secure. See the [Cookie notice](/cookies). ### Patient information ViziCAL checks display equipment. It is not designed to collect information about patients, and the website and software do not ask for it. Please do not put patient details in comments, location names or attached files. ## How we use it - To provide the portal, web service and software, including licence checks and storing your records. - To process orders, take payments, send invoices and run web service renewals. - To support you, including viewing your account when you or your distributor ask us to help. - To keep accounts and systems secure, and to investigate misuse. - To send service emails, such as invitations, password resets, overdue-check alerts and reports. - To reply to enquiries. - To meet our legal obligations, such as tax and accounting records. We do not sell personal information. We do not use it for advertising, and we do not use advertising or analytics cookies. [If you plan to send marketing emails, add what you send, the legal basis and how to opt out. Otherwise state that you don't.] ## Ask ViziCAL AI The desktop software and the ViziCAL website include an optional assistant, Ask ViziCAL AI. When you use it: - Your question, and earlier messages in the same conversation, are sent through our server to Anthropic, which provides the AI model. - On the website, only what you type is sent. In the desktop software, if you agree, a summary of your display, graphics card, measurements and ViziCAL settings is also sent. The software removes identifying details before sending it. - We do not store your questions, the summary or the answers. We only log whether it worked and how long it took, and in the desktop software which computer asked. On the website, your IP address is held in memory for a day to limit how many questions can be asked, and isn't saved. - Anthropic processes the request in the United States. [Confirm Anthropic's data retention and use terms for API customers and summarise them here.] Don't type personal or patient information into the assistant. ## Who can see it - **People in your organisation**, according to their role (Customer Admin, Technical or View Only). - **Your distributor**, if your organisation is supported by one. Distributor staff can see your account and help you. Every time they view it as one of your users, it is logged and shown to your Customer Admins. Your Customer Admin can switch this access off. - **Our staff**, to provide support and run the service. Their access is logged in the same way. - **Service providers** that process data for us. They are listed on our [sub-processor page](/subprocessors). - **Others where the law requires it**, for example a court order or a tax authority. ## Where it is stored All customer data, including the database, calibration reports and uploaded files, is stored on our own server. It is hosted by Crazy Domains in their Sydney data centre in Australia. We do not use a content delivery network or any other third-party storage service. Each night an encrypted backup is made on the server and then copied off it to backup storage at [PLACEHOLDER: backup storage provider and country]. The backup is encrypted before it leaves the server, so the provider cannot read it. Some service providers process data in other countries (see the [sub-processor page](/subprocessors)). ## How we protect it - Connections to the website and the software use TLS 1.2 or 1.3. - Passwords are stored only as hashes. Two-factor sign-in is required for our staff and distributor users, and is available to every customer user. [Once released: organisations can also require it for all their users.] - Secrets such as two-factor keys and licence keys are encrypted at rest. - Access is based on roles. Each organisation only sees its own data, and each distributor only sees its own customers. This is enforced on the server. - The database is only reachable from the server itself. The server has a firewall and installs security updates automatically. - Sign-in attempts are rate-limited, and accounts are locked for a time after repeated failures. ## How long we keep it - **Account, organisation and technical records**: while your organisation uses ViziCAL. Technical records are kept for 1 year after the organisation is closed or its subscription ends, then deleted. Account details are kept for 10 years. - **Closing an account**: a Customer Admin can ask us to close the organisation. When we close it, users are signed out and can no longer sign in, and the records are kept. We may first make a full copy of the organisation's records and reports for you. We can reopen a closed organisation, and reactivate a dormant one within a year. [PLACEHOLDER: State when, and how, closed organisations' records are finally deleted.] - **Releasing a licence**: when a licence is released from a computer, we put that computer's history (records, reports and attachments) into a ZIP file, check it, and email it to your Customer Admins. The ZIP is also kept in your portal. Only then is the history deleted, so the licence can be used on a new computer. [PLACEHOLDER: State how long licence history ZIP files are kept.] - **Invoices and orders**: for at least 7 years, for New Zealand tax records. [PLACEHOLDER: Lawyer to confirm.] - **Enquiries**: 10 years. - **Security and audit logs**: [PLACEHOLDER: retention period]. - **Backups**: nightly database backups are kept for 14 days, then deleted. ## Your rights You can ask to see the personal information we hold about you, and ask us to correct it. You can also ask us to delete it where we don't need to keep it. Many details can be changed yourself in the portal. Email info@myxraydose.com. We will reply within 20 working days. We may need to confirm who you are first. If a request is about records your organisation controls, we may pass it to your organisation's Customer Admin. ### New Zealand We follow the Information Privacy Principles in the Privacy Act 2020. If you are not happy with our response, you can complain to the Office of the Privacy Commissioner (privacy.org.nz). ### Australia [PLACEHOLDER: Lawyer to confirm whether the Australian Privacy Act 1988 applies to us.] Where it does, we follow the Australian Privacy Principles. You can complain to the Office of the Australian Information Commissioner (oaic.gov.au). ### European Union and United Kingdom If the GDPR or UK GDPR applies to you, you also have the right to: - object to, or ask us to restrict, how we use your information; - receive your information in a portable format; - withdraw consent, where we rely on consent; - complain to your local data protection authority (in the UK, the Information Commissioner's Office). Our legal bases are: - **Contract**: to provide the service and process orders. - **Legitimate interests**: to keep the service secure, support customers and improve the software. - **Legal obligation**: for tax and accounting records. - **Consent**: for sending your system summary to Ask ViziCAL AI. Your information is stored in Australia. The European Commission has not made an adequacy decision for Australia. Where we transfer EU or UK personal information outside the EU or UK, we use [PLACEHOLDER: Standard Contractual Clauses / the UK International Data Transfer Agreement or Addendum]. [EU/UK representative, if one is needed.] ### United States Some US states give residents rights to know, correct and delete personal information. We do not sell or share personal information for targeted advertising. To make a request, email info@myxraydose.com. [PLACEHOLDER: Lawyer to confirm which state laws apply.] ## Privacy breaches If a privacy breach is likely to cause serious harm, we will tell the people affected and the Privacy Commissioner as soon as we can, as the New Zealand Privacy Act requires. We will also meet the breach notification rules of other countries where they apply to us, such as the GDPR's 72-hour rule. If we hold the data for your organisation, we will tell your organisation without undue delay. ## Children ViziCAL is for businesses and professionals. It is not meant for children. ## Changes to this policy We may update this policy. We will change the date at the top and, for important changes, tell Customer Admins by email or in the portal. Effective date: [PLACEHOLDER: effective date, e.g. 1 December 2026].