Draft, not final legal advice. This page describes, in plain language, what the VisualSnow client, evaluator, and research portals actually do with data today. It is a starting point for the project's data protection documentation — it has not been reviewed by a lawyer or Data Protection Officer, and it does not replace the Participant Information Sheet, Informed Consent Form, or Data Processing Agreement used in the clinical pilot's ethics-approved process.

Privacy Policy

Draft — last updated 2026

1. Who is responsible for this data

The client, evaluator, and research portals at client.visualsnow.app, evaluate.visualsnow.app, and research.visualsnow.app are operated by Entropy Vector Group S.R.L., acting as data controller for account and case data processed through these portals. This is separate from the VisualSnow mobile/VR/web simulator apps, which store data only on your own device and do not send anything to these portals unless you choose to export and upload it yourself.

2. What data these portals collect

Unlike the simulator apps, the portals are server-based, because their purpose is to let a patient share data with a clinician and, in aggregate and anonymized form, with researchers. Concretely, the portal backend stores:

• Account identity: when you sign in with Google, we store your Google account ID, email address, display name, and avatar image so the system knows who you are and what role (patient, clinician, researcher, admin) you have.
• Uploaded symptom exports: the export file you upload from the simulator app (containing your logged symptom entries) is encrypted in your browser, with a one-time password, before it is uploaded. We only ever store the encrypted file — we do not see or keep the password. You share that password with your clinician yourself (email, phone, in person); without it, the file cannot be opened, including by us.
• Derived case data: an anonymized case ID, entry counts, date ranges, and a computed risk score derived from your uploaded data, used to display your case in the clinician workflow.
• Consult records: notes exchanged between you and a reviewing clinician about your case, and the status of that review (pending, assigned, reviewed, closed).

The research portal only ever operates on the anonymized, aggregated case data above — it is not given your name, email, or account identity.

3. Why we process this data

The legal basis for processing is your explicit consent, given when you create an account and upload data through the client portal, in the context of the clinical research pilot described in the project's ethics-approved protocol. If you are participating as part of that clinical pilot, the Participant Information Sheet and Informed Consent Form you received (or will receive) take precedence over this page and describe your rights in more detail.

4. Who can see your data

• You can always see your own account and uploaded data.
• A clinician you are matched with (or who reviews the consult queue) can see your uploaded case data and risk score, and can exchange notes with you about it.
• Researchers using the research portal only see anonymized, aggregated data across many cases — not your account identity.
• An administrator can manage accounts and invitations, but this is an internal, non-public role (the admin portal is not publicly accessible).
• We do not sell data or share it with advertisers. We do not use it for any purpose beyond the clinical review and research workflow described here.

5. Where data is stored

Data is stored using Cloudflare's infrastructure (database and file storage) under the visualsnow.app domain. Session identity is handled via signed, HTTP-only cookies. Uploaded case files are stored encrypted (see §2) — the storage provider itself cannot read their contents. No separate backup copies are described here beyond the provider's standard infrastructure durability — if you need details for a Data Processing Agreement or DPIA, contact us (below).

6. Your rights

You can ask us at any time to:

• Tell you exactly what data we hold about your account and uploaded cases
• Correct inaccurate account information
• Delete your account, uploaded exports, and associated case/consult data
• Withdraw from the clinical pilot, per the Informed Consent Form's withdrawal process, with no consequences to you

To exercise any of these rights, contact [email protected].

7. Not medical advice

These portals support research and clinical review — they are not a diagnostic tool and do not replace a consultation with a qualified healthcare professional. Risk scores, correlations, and other computed values shown in the portals are exploratory and have not been clinically validated.

8. Contact

Questions about this policy, or about the clinical pilot's data handling more broadly, can be sent to [email protected].