Privacy Policy

Last revised 31.05.2026

I. Data Controller

The data controller for personal data processed in connection with the operation of the digital platform imago.tg is Imago LLC, registered at 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, Delaware, USA (File Number: 10415156). Contact: hello@imago.tg.

Imago operates a digital platform facilitating communication between Users and independent healthcare professionals (“Providers”). Healthcare Providers act as independent data controllers with respect to personal data processed in connection with the provision of medical services, including clinical decision-making, diagnosis, treatment, and medical record keeping. Imago does not control medical purposes or means of clinical processing.

II. Purposes of Processing

We process your data for the following purposes:

  • Account Management: To create, maintain, and administer user accounts and platform access.

  • Facilitating Healthcare: To enable communication with independent Providers and facilitate the exchange of information necessary for consultations, care coordination, and administrative support.

  • Payment Processing: To manage billing, subscriptions, and transaction processing via secure third-party payment service providers.

  • Quality Assurance: To monitor and improve platform functionality, including recording of audio or video interactions where consent is obtained.

  • Security: To prevent fraud and ensure Site integrity. 

III. Legal Basis for Processing

  • Contractual Necessity (Art. 6(1)(b) GDPR): To provide platform services requested by the User.

  • Health Data (Art. 9(2)(h) GDPR): Health data may be processed in the context of healthcare services provided by independent Providers.

  • Legal Obligation (Art. 6(1)(c) GDPR): Where processing is required to comply with applicable laws.

  • Legitimate Interest (Art. 6(1)(f) GDPR): For security and internal administration, including platform security, fraud prevention, and internal administration.

IV. International Data Transfers

Imago LLC is based in the United States. Our data processing infrastructure is hosted within the European Economic Area (EEA). However, in individual cases, your personal data may be accessed or transferred outside the EEA — including to the United States — by Imago personnel, contractors, or subcontractors, to the extent necessary for the purposes described in this Policy.

Where such access or transfer occurs to a country not recognized by the European Commission as ensuring an adequate level of protection, Imago relies on appropriate safeguards under the GDPR, in particular Standard Contractual Clauses adopted by the European Commission (Implementing Decision (EU) 2021/914), to ensure your data receives a level of protection essentially equivalent to that guaranteed within the EEA.

V. Data Sharing

We share data with:

  • Providers: To facilitate your medical care. 

  • Pharmacies/Labs: If required for prescriptions or tests. 

  • Payment Processors: To process subscription and transaction payments.

  • Technology and Hosting Providers: To ensure platform functionality and data security.

Data is shared only to the extent necessary for service provision or legal compliance.

VI. Data Retention

Imago retains personal data:

  • for the duration of the User’s account,

  • as necessary for contractual and legal purposes,

  • in accordance with applicable limitation periods.

Retention of clinical medical records is determined by the relevant Provider acting as independent controller.

VII. Your Rights

Under applicable data protection laws, including the GDPR, Users have the right to:

  • access personal data,

  • request rectification or erasure,

  • restrict or object to processing,

  • data portability,

  • withdraw consent where processing is consent-based,

  • lodge a complaint with an EU supervisory authority.

VIII. Security

We implement industry-standard encryption to protect your electronic communications and personal health information.

IX. Gender Identity and Sensitive Health Data

Where relevant to the provision of healthcare services, Users may voluntarily provide information relating to gender identity, gender transition, hormonal treatment, or related medical or psychosocial matters. Such information constitutes special category personal data under applicable data protection laws.

Imago processes this data solely for the purpose of facilitating healthcare services, coordinating communication with independent Providers, ensuring service safety, and complying with legal obligations.

Independent Providers process such data under their own professional responsibility and applicable healthcare confidentiality rules.

Imago applies enhanced safeguards to such data, including:

  • strict access limitation,

  • purpose limitation,

  • confidentiality obligations,

  • secure technical infrastructure,

Users are not required to provide gender identity information unless necessary for healthcare services they choose to access.