Who We Are
Hipafy is a compliance documentation software platform operated by a registered sole trader (egyéni vállalkozó) under Hungarian law. Our services are accessible at hipafy.com.
For the purposes of the EU General Data Protection Regulation (GDPR), Hipafy acts as the data controller in respect of personal data collected through the website and account registration process. Where Hipafy processes data on behalf of its customers (such as practice information entered into the compliance assessment), Hipafy acts as a data processor.
This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have over it. It applies to all visitors to hipafy.com and all users of the Hipafy platform.
What Data We Collect
2.1 Account and Registration Data
When you create a Hipafy account, we collect:
- Full name and professional title
- Email address
- Practice name and type (e.g. therapy, dental, chiropractic)
- State of practice (US state)
- Phone number (optional)
- Password (stored in hashed form — we never store plaintext passwords)
2.2 Assessment and Compliance Data
When you complete the Hipafy compliance assessment, we collect your answers to questions about your practice operations, including:
- EHR and practice management software in use
- Telehealth platform in use
- Approximate staff count
- Communication methods used with patients
- Existing BAA and policy status
- Device and network practices
This data is operational and practice-level only. We do not collect, require, or store patient names, patient health records, clinical notes, diagnoses, treatment information, or any other patient-level Protected Health Information (PHI).
2.3 Training and Certificate Data
When a staff member completes the Hipafy training module, we collect:
- Staff member name (as entered by the user)
- Quiz score and completion date
- Certificate ID generated on completion
2.4 Payment Data
Payment processing is handled by Stripe, a third-party payment processor. Hipafy does not receive, store, or have access to your full payment card number, CVV, or bank account details. We receive from Stripe only a tokenized reference, the last four digits of your card, card type, and billing address for invoicing purposes.
2.5 Usage and Technical Data
When you use the Hipafy platform or visit hipafy.com, we automatically collect:
- IP address (anonymized after 30 days)
- Browser type and version
- Operating system
- Pages visited and time spent
- Referring URL
- Session duration and interaction data
This data is collected through privacy-respecting analytics tools and is used in aggregate form to improve the platform. We do not use advertising trackers or share this data with advertising networks.
2.6 Communications Data
If you contact us by email, through our support system, or through any contact form, we collect the content of your message and your contact details. We retain support correspondence for up to 3 years.
2.7 Data You Provide About Others
When you enter staff member names for training certificates, you are providing limited personal data about third parties. You are responsible for ensuring you have the right to provide this data and that affected individuals are informed of their rights under applicable privacy law.
How We Use Your Data
| Purpose | Data used | Legal basis |
|---|---|---|
| Creating and managing your account | Account data | Contract performance |
| Generating your compliance documentation | Assessment data | Contract performance |
| Processing payments and issuing invoices | Account data, payment reference | Contract performance, legal obligation |
| Delivering the training module and certificate | Training data | Contract performance |
| Sending transactional emails (receipts, reminders, updates) | Email address, account data | Contract performance, legitimate interest |
| Responding to support enquiries | Communications data | Legitimate interest |
| Improving the platform and user experience | Usage data (aggregated) | Legitimate interest |
| Complying with legal obligations (tax, accounting) | Account data, payment data | Legal obligation |
| Protecting against fraud and misuse | Usage data, account data | Legitimate interest |
| Marketing emails (optional) | Email address, name | Consent |
We do not use your data for automated decision-making that produces legal or similarly significant effects, and we do not build individual profiles for advertising purposes.
Legal Bases for Processing (GDPR)
Under the GDPR, we must have a valid legal basis for processing personal data. The legal bases we rely on are:
- Contract performance (Article 6(1)(b)): Processing necessary to provide the Services you have contracted for, including generating documentation, managing your account, and processing payments.
- Legal obligation (Article 6(1)(c)): Processing required to comply with applicable law, including tax law (NAV requirements in Hungary), invoicing obligations, and data breach notification requirements.
- Legitimate interests (Article 6(1)(f)): Processing for our legitimate business interests, including fraud prevention, security, platform improvement, and responding to support requests, where these interests are not overridden by your privacy rights.
- Consent (Article 6(1)(a)): For optional processing such as marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.
As Hipafy processes only operational practice data and not patient PHI, the special category data provisions of Article 9 GDPR are not ordinarily engaged. If you inadvertently provide data that could constitute special category data, please contact us so we can handle it appropriately.
Data Sharing and Third Parties
5.1 Service Providers (Sub-processors)
We share your data with the following categories of trusted third-party service providers who process data on our behalf:
| Provider type | Purpose | Location |
|---|---|---|
| Payment processor (Stripe) | Processing subscription payments securely | USA (SCCs in place) |
| Email delivery (Brevo/Sendinblue) | Transactional and marketing emails | EU |
| Website hosting (Netlify) | Serving the Hipafy website | USA (SCCs in place) |
| Analytics provider | Privacy-respecting usage analytics | EU (where possible) |
| Invoicing software (Billingo) | Generating Hungarian-compliant invoices | Hungary (EU) |
All sub-processors are contractually bound to process data only for the specified purpose, to implement appropriate security measures, and to comply with GDPR requirements.
5.2 Legal Disclosure
We may disclose your data where required by law, including in response to valid legal process from competent authorities in Hungary or the United States, or to protect the rights, property, or safety of Hipafy, our customers, or others.
5.3 Business Transfers
In the event of a merger, acquisition, or sale of all or substantially all of our business assets, your data may be transferred to the successor entity. We will notify you of any such transfer and the privacy practices of the successor before your data is transferred.
5.4 No Sale of Data
Hipafy does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We do not permit advertising networks to access user data from the Hipafy platform.
International Data Transfers
Hipafy is based in Hungary (EU). When we transfer personal data to service providers located outside the European Economic Area (EEA), including to the United States, we ensure appropriate safeguards are in place in accordance with Chapter V of the GDPR.
For transfers to the United States, we rely primarily on Standard Contractual Clauses (SCCs) approved by the European Commission, as well as the EU-US Data Privacy Framework where applicable providers are certified.
For US-based customers: your data may be processed and stored on servers located in the United States or the European Union. By using the Services, you acknowledge that your data may be transferred across borders as described in this Policy.
Data Retention
| Data type | Retention period | Reason |
|---|---|---|
| Account and assessment data | Duration of subscription + 30 days | Service provision; deletion after export window |
| Training completion records | Duration of subscription + 30 days | Certificate audit trail |
| Payment and invoicing records | 8 years from transaction date | Hungarian and EU tax law requirements |
| Support communications | 3 years from last contact | Dispute resolution and legitimate interest |
| Usage analytics data | 13 months (aggregate only after 30 days) | Platform improvement; GDPR best practice |
| IP addresses | 30 days then anonymized | Security; anonymized thereafter for analytics |
| Marketing consent records | Until consent withdrawn + 3 years | Evidence of consent; legal obligation |
When your Subscription terminates, we will retain your data for 30 days to allow you to export Documentation. After that period, account and assessment data is permanently deleted. Payment and invoicing records are retained for the period required by Hungarian tax law (8 years).
Cookies and Tracking
8.1 What We Use
Hipafy uses a minimal set of cookies and similar technologies. We do not use advertising or cross-site tracking cookies.
| Cookie type | Purpose | Consent required? |
|---|---|---|
| Session cookie | Keeps you logged in during your session | No (strictly necessary) |
| Security cookie | CSRF protection and fraud prevention | No (strictly necessary) |
| Preference cookie | Remembers your toggle settings (e.g. annual/monthly pricing) | No (functional) |
| Analytics cookie | Privacy-respecting usage analytics (no personal fingerprinting) | Yes |
8.2 Managing Cookies
You can manage cookie preferences through our cookie consent banner when you first visit the site. You can also manage cookies through your browser settings. Disabling strictly necessary cookies will prevent the platform from functioning correctly.
Your Rights Under GDPR
If you are located in the EU, EEA, or UK, you have the following rights regarding your personal data:
| Right | What it means | How to exercise |
|---|---|---|
| Access | Request a copy of the personal data we hold about you | Email privacy@hipafy.com |
| Rectification | Request correction of inaccurate or incomplete data | Update in account settings or email us |
| Erasure | Request deletion of your data (subject to legal retention obligations) | Email privacy@hipafy.com |
| Restriction | Request that we limit processing of your data in certain circumstances | Email privacy@hipafy.com |
| Portability | Receive your data in a structured, machine-readable format | Use the export feature in your account or email us |
| Objection | Object to processing based on legitimate interests or for direct marketing | Email privacy@hipafy.com or unsubscribe link |
| Withdraw consent | Withdraw consent for any processing based on consent (e.g. marketing) | Unsubscribe link or email privacy@hipafy.com |
| Complaint | Lodge a complaint with the Hungarian supervisory authority (NAIH) | See Section 14 |
We respond to all rights requests within 30 days. In complex cases we may extend this by a further 60 days, in which case we will notify you within the initial 30-day period. We will not charge a fee for reasonable requests.
Hungarian supervisory authority: Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH) — ugyfelszolgalat@naih.hu — naih.hu
California Residents — CCPA Rights
If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the CPRA grants you additional rights:
- Right to know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for collection, and the categories of third parties with whom we share it.
- Right to delete: You may request deletion of personal information we have collected, subject to certain exceptions.
- Right to correct: You may request correction of inaccurate personal information.
- Right to opt out of sale or sharing: Hipafy does not sell or share personal information for cross-context behavioral advertising. No opt-out action is required.
- Right to non-discrimination: We will not discriminate against you for exercising any CCPA right.
To exercise any of these rights, contact us at privacy@hipafy.com. We will respond within 45 days. We may verify your identity before fulfilling a request.
Categories of personal information collected in the preceding 12 months: identifiers (name, email, IP address); commercial information (subscription and payment history); internet activity information (usage data); professional information (practice type, state, EHR vendor). We have not sold or shared personal information in the preceding 12 months.
Children's Privacy
The Hipafy platform is intended for use by healthcare professionals and practice staff who are adults (18 years of age or older). We do not knowingly collect personal data from children under 18. If we become aware that we have inadvertently collected personal data from a child, we will delete it promptly. If you believe we may have collected data from a child, please contact us at privacy@hipafy.com.
Security
Hipafy implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:
- Encryption of data in transit using TLS 1.2 or higher
- Encryption of data at rest
- Hashed and salted password storage
- Access controls limiting data access to authorized personnel on a need-to-know basis
- Regular security reviews and vulnerability assessments
- Contractual security obligations imposed on all sub-processors
No security system is impenetrable. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by GDPR Article 33. Where the breach is likely to result in a high risk to you, we will notify you directly without undue delay as required by GDPR Article 34.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email at the address associated with your account and by posting the updated policy on our website with a new effective date at least 14 days before the changes take effect.
Your continued use of the Services after the effective date of any update constitutes acceptance of the revised policy. If you do not agree to the updated policy, you must stop using the Services and may request deletion of your data.
Contact and Complaints
For any questions about this Privacy Policy, to exercise your rights, or to report a data protection concern:
Email: privacy@hipafy.com
Subject line: "Privacy Request — [your name]"
Response time: Within 30 days
If you are not satisfied with our response, you have the right to lodge a complaint with the competent data protection supervisory authority:
Hungarian authority (NAIH):
Nemzeti Adatvédelmi és Információszabadság Hatóság
Email: ugyfelszolgalat@naih.hu
Website: naih.hu
For US residents: You may also contact the data protection authority in your state, or the Federal Trade Commission (FTC) at ftc.gov for matters relating to privacy and consumer protection.