Document Verification & Data Processing Policy

1. Who we are

Hemodona operates an online community platform that helps connect people who need blood with individuals who voluntarily register as blood donors in North Macedonia, Albania, and Kosovo.

For questions about this Policy or your data, contact us via WhatsApp at +389 75 828 001 or +389 75 828 100.

2. Nature of the service — important disclaimers

Hemodona is a voluntary information and matching platform only. We are not a hospital, clinic, blood bank, transfusion centre, laboratory, emergency service, ambulance service, medical device manufacturer, or licensed healthcare provider.

We do not collect, store, process, cross-match, or supply blood or blood products. We do not provide medical advice, diagnosis, treatment, transfusion services, or emergency care. Any decision to donate blood, request blood, contact a donor, travel, or undergo medical procedures is made solely by you and/or licensed medical professionals, and never by Hemodona.

Verification of uploaded documents by Hemodona staff is an administrative consistency check only. It is not a laboratory blood-type determination, not a clinical diagnosis, and not a guarantee that a donor is medically fit to donate or that any contact will result in a successful donation.

3. Voluntary participation and eligibility

Registration as a donor and submission of donation records are entirely voluntary. You may choose not to register or upload documents.

You must be at least 18 years old and legally capable of entering into this Policy. By submitting a form, you represent that you meet these requirements. We do not knowingly collect documents from children under 18. If you believe a minor has submitted data, contact us so we can delete it.

4. What you upload and what we process

Depending on the form you use, we may process:

• Identity and contact data: full name, personal identification number, phone number(s), country, and city.
• Health-related data you declare: claimed blood type.
• Blood type verification documents: files (for example images or PDFs) that you upload to support your claimed blood type (such as a donation card, lab result, or similar document you choose to provide).
• Donation verification documents: files uploaded to evidence a blood donation you report.
• Technical and operational data needed to run the platform (for example timestamps, verification status flags, and internal notes created by reviewers).

5. Special category / sensitive data

Blood type and documents that reveal blood type or donation history are sensitive health-related data. Personal identification numbers are also sensitive identifying data under applicable privacy laws.

By uploading documents and submitting a form, you give your explicit, informed, and freely given consent to Hemodona processing this sensitive data for the purposes described in this Policy. You may withdraw consent as described below, understanding that withdrawal may prevent verification or continued listing as a donor.

6. Purpose of processing

We process uploaded documents and related data only to:

• Verify, to a reasonable administrative standard, that the blood type you claim appears consistent with the document you uploaded.
• Decide whether to approve, reject, or request further information about your donor registration or donation record.
• Activate or withhold public listing of your donor profile after verification.
• Prevent fraud, impersonation, forged documents, and misuse of the platform.
• Comply with legal obligations and defend our legitimate interests in operating a safer donor community platform.

7. How human verification works

Uploaded documents are reviewed by authorised Hemodona personnel (real human reviewers), not by the general public. Reviewers may view your document, compare it with the information you submitted, and mark your registration or donation as verified or not verified.

Reviewers may create limited internal notes needed for the decision. Reviewers are instructed to access documents only for verification purposes and not to copy, download for personal use, share externally, or retain documents beyond the process described in this Policy.

Hemodona may refuse registration or verification at its sole discretion, including where a document is unclear, incomplete, unreadable, inconsistent, suspicious, unrelated, or otherwise inadequate.

8. Storage, security, and access

Blood type and donation documents are stored on private application storage that is not publicly accessible via the website. Access is restricted to authorised administrators and systems needed to operate verification.

We apply reasonable technical and organisational measures to protect documents against unauthorised access, alteration, disclosure, or destruction. No method of electronic storage is perfectly secure; you acknowledge residual risk inherent in internet transmission and digital storage.

Do not upload documents containing more personal data than necessary. Where possible, redact unrelated sensitive information (for example addresses or unrelated medical history) before upload, provided the document still clearly supports the claimed blood type or donation.

9. Retention and deletion of documents

Verification documents are retained only for as long as needed to complete the verification decision.

After a registration or donation is approved (verified), Hemodona deletes the uploaded document file from storage. After deletion, we retain the factual outcome of verification (for example that your blood type was verified, and your non-document profile data needed to list you as a donor), but not the document file itself.

If a submission is rejected or abandoned, we delete the related document within a reasonable period after the decision or inactivity, unless we must retain it temporarily to investigate fraud, abuse, or legal claims.

Deletion means we remove the file from active storage used by the application. Residual copies may temporarily exist in encrypted backups or disaster-recovery systems until those backups rotate in the ordinary course. We do not use backup copies to continue verification or to rebuild deleted documents for operational use.

Once a document is deleted, Hemodona generally cannot return a copy to you because it no longer holds the file. Keep your own originals.

10. What remains visible after verification

If your donor registration is verified and active, selected profile information may be shown publicly on Hemodona so people in need can find and contact donors. This may include your name, blood type, country, city, phone number(s), and donation-related indicators.

Your uploaded verification documents themselves are not published on the public website.

By registering, you expressly consent to public display of the profile fields described above and to being contacted by third parties through the contact details you provide. Hemodona does not control how third parties use information obtained from the public listing.

11. Your representations and warranties

By uploading any document, you represent and warrant that:

• You are the person identified in the document, or you have all legal rights and consents needed to upload it.
• The document is authentic, unaltered in any misleading way, and not forged, fabricated, or obtained unlawfully.
• The blood type and other information you submit are true and accurate to the best of your knowledge.
• Uploading and our processing of the document will not violate any law, medical confidentiality duty owed by you, or third-party right.
• You understand that Hemodona’s verification is administrative only and does not replace medical testing or professional judgement.

12. Prohibited conduct

You must not upload forged, stolen, or misleading documents; impersonate another person; register with false blood type or identity data; attempt to access another person’s documents; scrape or misuse donor contact details for spam, harassment, commercial advertising, or unlawful purposes; or interfere with verification systems.

We may remove listings, refuse service, preserve evidence, and report suspected criminal activity to competent authorities where appropriate.

13. No guarantees; limitation of liability

To the maximum extent permitted by applicable law, Hemodona provides the platform and verification process “as is” and “as available”, without warranties of any kind, whether express, implied, or statutory, including merchantability, fitness for a particular purpose, accuracy, non-infringement, or uninterrupted availability.

Without limiting the foregoing, Hemodona does not warrant that a verified listing means a donor is available, reachable, willing, medically eligible, infection-free, or correctly blood-typed in a clinical sense; that contacting a donor will produce blood; or that any medical outcome will be achieved.

To the maximum extent permitted by law, Hemodona and its operators, reviewers, affiliates, and agents shall not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for loss of life, health, data, profits, goodwill, or opportunity, arising out of or related to use of the platform, document uploads, verification decisions, public listings, contacts between users and third parties, failed donations, delayed care, or reliance on any information shown on the platform — whether based in contract, tort (including negligence), strict liability, or otherwise — even if advised of the possibility of such damages.

To the maximum extent permitted by law, Hemodona’s total aggregate liability arising out of or relating to document processing or this Policy shall not exceed EUR 50 (fifty euros) or the minimum amount that cannot be excluded under mandatory law, whichever is higher.

Nothing in this Policy excludes or limits liability that cannot be excluded or limited under mandatory applicable law (including liability for death or personal injury caused by proven gross negligence or wilful misconduct where such exclusion is prohibited).

14. Indemnification

You agree to indemnify, defend, and hold harmless Hemodona and its operators, reviewers, affiliates, and agents from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or related to: (a) documents or information you upload or submit; (b) your breach of this Policy or of law; (c) your interactions with third parties who contact you through the platform; (d) any allegation that your documents or data infringe rights or are inaccurate, forged, or unlawfully disclosed; and (e) medical or personal decisions made by you or others in connection with blood donation or requests for blood.

15. Third-party contacts and medical risk

People seeking blood may contact donors directly using publicly listed phone numbers. Hemodona is not a party to those communications or to any donation arrangement. You assume all risks of being contacted, including inconvenience, emotional distress, and any decision to donate or not donate.

Blood donation and transfusion involve medical risks that must be managed exclusively by licensed healthcare professionals and authorised blood establishments. Hemodona has no responsibility for screening, testing, collection, storage, cross-matching, transfusion, or aftercare.

16. Your privacy rights

Subject to applicable law, you may request access to personal data we hold about you, correction of inaccurate data, deletion of your donor profile where legally permitted, restriction of processing, and withdrawal of consent for future processing of verification documents.

Withdrawing consent or requesting deletion of your profile may result in removal of your public listing. If a verification document has already been deleted under Section 9, we cannot restore it.

To exercise rights, contact us via the WhatsApp numbers listed above. We may need to verify your identity before acting on a request. We may refuse requests that are manifestly unfounded, excessive, or where retention is required by law or for establishing, exercising, or defending legal claims.

17. International use

The platform is intended for use in connection with North Macedonia, Albania, and Kosovo. If you access the service from elsewhere, you do so on your own initiative and are responsible for compliance with local laws. Document storage and review may occur on infrastructure and by personnel located in jurisdictions that support platform operations.

18. Changes to this Policy

We may update this Policy from time to time. The “Last updated” date at the top will change when we do. Continued use of document upload or registration features after an update constitutes acceptance of the revised Policy. For material changes, we may also provide additional notice on the website where reasonably practicable.

19. Governing law and disputes

This Policy and any dispute arising out of document uploads, verification, or related data processing shall be governed by the laws of the Republic of North Macedonia, without regard to conflict-of-law principles, except where mandatory consumer or data-protection rules of your country of residence cannot be waived and therefore also apply.

Courts competent in North Macedonia shall have jurisdiction, without prejudice to any mandatory right you may have to bring proceedings in your place of residence where such right cannot be excluded by agreement.

20. Severability and entire agreement

If any provision of this Policy is held unenforceable, the remaining provisions remain in full force and effect. Where a limitation is only partially enforceable, it shall be enforced to the maximum extent permitted.

This Policy, together with any on-form consent you provide when submitting documents, constitutes the entire agreement between you and Hemodona regarding document verification and related data processing, and supersedes prior statements on that subject. Failure to enforce any provision is not a waiver.

21. Acceptance

By checking the consent box on the registration or donation form and submitting documents, or by otherwise uploading documents to Hemodona, you acknowledge that you have read this Policy, understand it, and agree to be bound by it, including the sensitive-data consent, public listing terms, disclaimers, liability limitations, and indemnification provisions above.