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Privacy policy

Last updated: 25 April 2026

1. Who we are

Clinq ("we", "us", "our") provides booking, messaging, and payment software to UK general practitioner (GP) practices. The service is operated from clinq.online.

For patient-related personal data, the GP practice using our software is the data controller under the UK GDPR, and we act as a data processor on their behalf. For data we collect directly from practice staff who use our dashboard (e.g. their login credentials), we are the data controller.

2. What data we process

On behalf of the GP practice, we process:

  • Patient WhatsApp profile information (display name, profile picture, phone number).
  • Messages exchanged between the patient and the practice.
  • Booking details: appointment type, requested time, intake form responses (typically full name and date of birth).
  • Payment metadata (Stripe payment identifiers; we do not store card numbers).
  • Media files (e.g. images, documents) the patient sends to the practice via WhatsApp.

For practice staff who use the dashboard we process: name, email address, hashed password, two-factor authentication secret, IP address and basic device metadata for session security.

3. Lawful basis

Patient data is processed on the lawful basis the GP practice relies on for providing healthcare to that patient — typically "provision of health or social care" under Article 9(2)(h) UK GDPR, with consent for the use of the WhatsApp channel.

Staff data is processed under our legitimate interest in operating the service, and where necessary for contract performance.

4. Where data is stored

Application data is stored on encrypted databases hosted on infrastructure located in the United Kingdom. Patient personal identifiers are encrypted at rest with per-practice keys.

Media files are stored on Cloudflare R2 in UK/EU regions, or on the practice's own R2 bucket if they have configured one.

WhatsApp messages transit through the Meta WhatsApp Cloud API. Payment data is handled by Stripe Inc. and Stripe Payments UK Ltd. Transactional email is sent via Resend. These sub-processors have their own privacy policies which apply to their handling of the data.

5. Sub-processors

  • Meta Platforms Ireland Ltd. — WhatsApp Business messaging.
  • Stripe Inc. / Stripe Payments UK Ltd. — payment processing.
  • Cloudflare, Inc. — media storage (R2) and DNS/edge.
  • Resend, Inc. — transactional email.
  • Hostinger International Ltd. — server hosting (UK region).
  • Heydoc Ltd. (Semble) — clinical record system, where the practice has connected its Semble account.

6. Retention

Patient messages, bookings, and media are retained for as long as the GP practice instructs us to retain them, in line with their own clinical record retention policy. On request from the practice we will delete or export the data.

Staff account data is retained while the account is active and for up to 90 days after account closure for audit and dispute resolution.

7. Your rights

Under UK GDPR you have rights of access, rectification, erasure, restriction of processing, portability, and to object to processing. For patient data, please direct your request to the GP practice, who as data controller will instruct us. For staff account data, please email privacy@clinq.online.

For the specific procedure to request deletion of your data, see our data deletion instructions.

You can also lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

8. Security

We take appropriate technical and organisational measures to protect personal data: encryption at rest, TLS in transit, two-factor authentication for staff logins, per-tenant isolation of patient data, and least-privilege access controls.

9. Cookies

We use strictly necessary cookies for session management on the staff dashboard and for fraud prevention on the patient booking pages (Google reCAPTCHA v3). We do not use advertising or analytics cookies that require consent.

10. Changes to this policy

We will update the "last updated" date above when we make changes. Material changes will also be communicated to practice administrators by email.

11. Contact

Questions about this policy: privacy@clinq.online.