Privacy policy

The data controller is V22 Media, VAT number 02905201204, registered office Via Verdi 20, 40026 Imola (BO), Italy.

For anything concerning your personal data, write to studio@v22media.com. We have not appointed a Data Protection Officer, as we are not required to.

• —Producing and sending your classification — performance of a contract you asked us to enter into, Article 6(1)(b). Without this data we cannot compute a result.
• —Keeping your submissions in your account — the same contractual basis: it is part of the service you requested.
• —Analytics cookies — your consent, Article 6(1)(a), given or refused in the cookie banner and withdrawable at any time.
• —Security and abuse prevention — our legitimate interest in keeping the service available, Article 6(1)(f).

We do not currently send marketing email. If that changes, we will ask for a separate, specific, opt-in consent at the point of collection — ticking the box to receive your report will never be treated as agreement to be contacted commercially.

MDClassify uses a rules-based software engine to analyse the answers you provide and identify the classification rule or rules that may apply in the jurisdiction you selected. The engine applies predetermined regulatory criteria drawn from the legislation of that jurisdiction; where several rules apply, it resolves the conflict by a predetermined criterion — the strictest rule prevails. It does not independently verify the accuracy, completeness or legal sufficiency of what you enter.

This is not automated individual decision-making within the meaning of Article 22. The processing does not make a decision about an identifiable individual, and produces no legal or similarly significant effect on one: what it assesses is a product. The output is informational and concerns the device, and it has to be read against the device's full intended purpose, its technical characteristics and the applicable regulatory framework.

Each provider below is bound by a data processing agreement and permitted to use your data only on our instructions. We do not sell personal data, and we do not share it for anyone else's marketing.

Your submissions are stored in the European Union. Where a provider may transfer data to the United States — email delivery and, if you consent to them, analytics — that transfer relies on the European Commission's Standard Contractual Clauses and, where applicable, the EU–US Data Privacy Framework.

You may obtain a copy of the safeguards in place for those transfers by writing to studio@v22media.com; we will send the relevant contractual clauses, redacted only where they contain commercial terms.

If MDClassify, or the business operating it, is transferred to another company — through a sale, merger or reorganisation — the data described in this policy may pass to the acquirer as part of that transfer. The acquirer would become the controller and would be bound by this policy until it lawfully notifies you of any change.

We will tell you before that happens, and you may ask us to delete your data beforehand.

Classification submissions and the contact details attached to them are deleted automatically 24 months after they are created. This is not a stated intention: a scheduled job removes them, and the retention period in our code is the same value published here.

The same period applies whether or not you sign in. If you keep an archive, that archive is part of the service you asked for and the retention runs from each submission; if you only wanted the report by email, the record is deleted on the same schedule without your having to ask. You can have it deleted sooner at any time — see 6.2.

This limit governs. Any commitment we make about keeping reports available during the beta operates inside it, not beyond it: nothing we promise commercially extends the period for which we hold your data.

Analytics data is retained for 14 months, the period configured in the Google Analytics property. Server logs, which may contain IP addresses, are kept for 30 days for security and debugging, then discarded.

You can ask us to delete your data before the period above expires, and we will do so unless we are required to keep it. See section 8.

This service is intended for professionals working with medical devices. It is not directed at children, and we do not knowingly collect data from anyone under 16. If you believe a child has provided us with personal data, write to studio@v22media.com and we will delete it.

Under the GDPR you may ask us to:

• —give you a copy of the personal data we hold about you;
• —correct anything inaccurate;
• —delete your data;
• —restrict how we use it, or object to processing based on legitimate interests;
• —provide your data in a portable, machine-readable format;
• —withdraw any consent, at any time, without affecting past processing.

Write to studio@v22media.com. We respond within one month. Exercising these rights is free, and we will not treat you differently for doing so.

If you think we have handled your data badly, you may complain to the Garante per la protezione dei dati personali, or to the supervisory authority of the EU country where you live or work.

No, but the questionnaire cannot work without the device information, and we cannot send a report without an email address. You can browse the whole site — including the regulatory guidance — without providing anything, and you can decline analytics cookies with no loss of functionality.

Data is transmitted over HTTPS and stored in a managed European database. The administration area is password-protected, and account sign-in uses single-use, time-limited links rather than stored passwords. No system is perfectly secure, and we do not claim otherwise; if a breach affects your rights, we will notify you and the supervisory authority as the GDPR requires.

Which cookies we set, what each does and how long it lasts is documented in the cookie policy. Nothing that is not strictly necessary is set before you consent.

If we change how we handle personal data we will update this page and the date at the top. Where the change is significant and affects data we already hold, we will make it visible on the site rather than relying on you to re-read this page.