Privacy Policy

1. Data Controller

Viali UG (haftungsbeschränkt)
Bruder-Klaus-Str. 18, 78467 Konstanz, Germany
represented by the Managing Director Maurizio Betti
Commercial register: Amtsgericht Freiburg, HRB 730507
VAT ID: DE366970833
Email: info@viali.app · Phone: +49 (0)151 44995875 / +41 (0)77 421 2356

For patient data, the clinic is the controller; Viali UG processes these data only as a processor on the clinic's behalf under the Data Processing Agreement (DPA).

2. Data Collected

• Account & staff data: name, email address, role, hospital affiliation, and HR/employment records (contracts, work logs, absences)
• Patient data: contact details, appointments, clinical and treatment documentation, questionnaires, anesthesia records, vital signs, medication, and billing/invoicing data
• Job-applicant data (Careers): name, contact details, CV and application documents, and related assessment notes
• Log data: access and activity logs for system security
• AI log: for every request Viali sends to an AI provider, the text as transmitted (after de-identification) and the response are stored, with time, clinic, user and function; for images only a placeholder is stored (file type, size, checksum), never the image itself. Every call made through the AI connector is stored as well (function called, read or write, outcome of the call, the arguments passed and the response actually transmitted). Purpose: traceability and security. Retention: 6 months (183 days), then automatic deletion. Access to the logged texts: the clinic's administrators for their own clinic. For operation and security, Viali sees only technical metadata (e.g. time, function, model, status, cost); the texts themselves only within a Viali-Support-Zugang (support access) granted by the clinic. Every opening of a logged text is itself logged. The AI log is never passed to an AI provider or through the AI connector.

3. Purpose of Data Processing

• Provision of the clinic-management platform: clinical and anesthesia documentation, surgery scheduling, patient records and communications (CRM), and inventory management
• Invoicing and billing, including electronic medical invoicing where applicable
• Recruitment and staff/HR administration. The documents of an application at the stage “Offer” or “Hired” are visible read-only in the staff details of the person with the same email address at the same clinic, and only to people with access to applications; the documents are not copied.
• User authentication and access control
• Technical support: Viali staff access a clinic's data only when the clinic has allowed it for a limited time, or, in an emergency, read-only, for at most 2 hours and with immediate notice to the clinic. Every support access to a patient record is logged and visible to the clinic.
• AI-assisted features (e.g. document structuring, candidate-fit assessment, taking over vital values from monitor photos); for transmission to AI providers see Section 6
• Service quality improvement
• Compliance with legal retention requirements

4. Data Storage

• All data is stored on Exoscale servers in Switzerland
• Database: Exoscale PostgreSQL (Switzerland)
• Encryption: Data is encrypted at rest and in transit
• Regular automatic backups

5. Data Subject Rights

• Right of access: You have the right to know what data is stored about you
• Right to rectification: You can request correction of inaccurate data
• Right to erasure: You can request deletion of your data (subject to legal retention requirements)
• Data portability: You can request your data in a machine-readable format
• Right to object: You can object to data processing

6. Data Sharing

• Patient data is never sold; it is disclosed only to the sub-processors below, acting on Viali's instructions
• Processors: Stripe (payment processing), Exoscale (hosting & database, Switzerland), Resend (email delivery), VADIAN.NET AG (ASPSMS), Switzerland (SMS communications), Functional Software, Inc. (Sentry), USA (error and crash logs), Google Ireland Limited (font delivery; the IP address is transmitted)
• AI sub-processors: Anthropic PBC and OpenAI, L.L.C. (USA) and Mistral AI SAS (France), for AI-assisted features. Before transmission, personal data is removed from texts: known details (e.g. names, contact details) and typical patterns (e.g. dates, phone numbers, email addresses, AHV numbers) are replaced with placeholders, and a self-hosted de-identification service detects further personal details. If that service is unavailable, some features send nothing; the other features send the text after known details and typical patterns have been removed. Features that process no patient data (e.g. job advertisements, SOPs, website and marketing texts, product photos) send their content without these steps.
• Exception – monitor photos: when staff photograph a patient monitor to take over vital values, the image is transmitted to an AI provider. The clinic is responsible for ensuring that the monitor shows no information identifying the patient (e.g. name, date of birth, patient number) when it is photographed. Automatic capture of the monitor screen via HDMI is switched off. Voice input is converted to text on Viali's own server; the recording is not transmitted to an AI provider.
• AI connector: a user of the clinic may connect their own account with an AI assistant (e.g. Claude by Anthropic, ChatGPT by OpenAI) to Viali. What is retrieved through this connection goes into that account, under the responsibility of the clinic or the user and under that provider's terms. Anthropic and OpenAI are not Viali's sub-processors for this. Viali technically blocks patient data from the connector: its functions return no patient data, and every response is automatically checked for patient data before it is sent and withheld if any is found. The connection acts only within the current role of the person who set it up; every call is recorded in the AI log (Section 2), and the clinic can revoke connections at any time.
• International transfers: where a processor is located outside Switzerland/the EEA (e.g. US-based AI sub-processors), transfers are safeguarded by the EU Standard Contractual Clauses (SCCs) with the Swiss addendum and appropriate technical measures.
• All processors comply with GDPR requirements

7. DSG/GDPR Compliance

• Viali.app complies with Swiss Data Protection Act (DSG) and EU GDPR
• Data Processing Agreements (DPA) with all subprocessors
• Privacy by Design and Privacy by Default

8. Contact

For privacy questions, contact us at: info@viali.app