Mobcly Privacy Policy
Effective date: 17 October 2026. Version 1.1.
This policy explains what personal data Mobcly collects, why, who it is shared with, how long it is kept and what rights you have. It
covers the Mobcly web app (eyecare.mobcly.com), the Mobcly apps for Android and Windows, the online booking pages, our website
mobcly.com and our emails.
1. Who we are
Mobcly is provided by Mobcly OÜ, registry code 14065339, Mardi 6-209, 10113 Tallinn, Estonia (“Mobcly”, “we”, “us”).
- Privacy questions and requests: [email protected].
- Data protection officer: Jaan Arjasepp, reachable at the same address.
2. Two roles: the clinic’s data and our own
Mobcly is software for eye-care clinics and opticians. Our role depends on whose data it is.
- Patient records belong to the clinic. Clinics enter their patients’ details, examinations, prescriptions, images and appointments into Mobcly. The clinic decides what is recorded and why; it is the controller of that data. We store and process it only on the clinic’s instructions, as its processor, under the data processing terms in Annex A of our Terms of Service.
- Everything else is ours. This covers the accounts of clinic owners and staff, billing, our emails, security logs, error reports, usage statistics and visits to our website. For this data we are the controller, and most of this policy describes it.
3. If you are a patient, or booked a visit online
- Your records are kept by your clinic. The clinic decides what it records about you and is responsible for it. For a copy of your records, a correction or deletion, please contact your clinic. If you write to us instead, we pass your request to the clinic and help it answer.
- Booking online. On a clinic’s booking page you give your name, phone number and/or email address and the details of the visit. The clinic receives them. We send the booking confirmation and appointment reminders by email on the clinic’s behalf and in its name; the link in them lets you change or cancel the booking.
- Bot check. Booking pages use Cloudflare Turnstile to tell people from automated scripts (see §11).
- Clinics with an offline license keep their records only on their own devices. We never receive that data.
4. What we collect
| Data | Examples | Where it comes from |
|---|---|---|
| Account | Name, email address, password (stored only as a one-way hash), country, app language, role (owner or staff), when you accepted our terms and which version | You, at sign-up and in Settings |
| Google sign-in | Your Google account’s email, name and a Google user id | Google, if you choose “Sign in with Google” |
| Clinic profile | Clinic name, address, phone, public email, logo, working hours, booking page settings | You |
| Billing | Package, price, billing name and address, company tax id, payment history and invoices. Card details are entered on Stripe’s page; we never see or store card numbers. | You and Stripe |
| Patient records (as processor, see §2) | Patient name, date of birth, gender, contact details, eye examinations, prescriptions, exam images, notes, appointments | The clinic |
| Online bookings (as processor for the clinic) | The booker’s name, phone, email and visit details | The person booking on the clinic’s booking page |
| Security and access logs | Sign-ins and failed sign-ins, who viewed or changed which record and when, IP address | Our servers, automatically |
| Devices | A device identifier for activating the app, a device name, the last check-in time and IP address. On Android the identifier is made from the phone’s Android ID by a one-way hash, so the Android ID itself never leaves the phone; it stays the same if the app is reinstalled and changes after a factory reset. On Windows it is a random number. For each sign-in we also keep a one-way hash of the device identifier, so we can tell you when your account is used from a new device | The app and your browser |
| Emails | Which service emails were sent to you, your choice about news and offers (with the date and how you gave or withdrew it) | Our email system |
| Error reports | Technical details of a crash or error (app version, device type, the error itself). Personal data is not included on purpose. | The app and our servers (via Sentry) |
| Usage statistics | Which pages are opened, which form fields are touched (never what you type) and your account id | The web app and the apps (via PostHog, without storing anything on your device: see §11) |
| Website visits | Which pages of mobcly.com are opened and which buttons are clicked, the site you came from and any campaign tags in the link, your country (worked out from your IP address, which is not kept), device type and browser. Counted without cookies or any storage in your browser. | Our website mobcly.com (via PostHog) |
| Free guide requests | Your email address, whether you ticked the box for follow-up tips (and when), the campaign tags in the link you came from, and which guide emails we sent you | You, on mobcly.com/guide |
We do not collect your location, contacts, or anything from other apps. The Android app asks for the camera only to take exam photos, and for network access to sync.
5. Why we use it, and on what legal basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Creating your account, signing you in, providing the service and support | Contract |
| Storing and syncing the clinic’s patient records | Contract with the clinic; we act on its instructions (Art. 28). For health data the clinic’s own legal basis applies (Art. 9). |
| Billing, invoices and keeping accounting records | Contract; legal obligation (accounting law) |
| Service emails (verification codes, password reset, plan reminders, deletion notices) and security notices (password changed, sign-in from a new device, signed out elsewhere) | Contract; legitimate interests (account security) |
| Getting-started emails during the trial (tips on using Mobcly, a note from the founder) | Legitimate interests (helping a new customer use the service) |
| Sending the free guide you asked for on our website | Legitimate interests (sending you what you asked for) |
| News and offers by email, including the follow-up tips after the free guide | Your consent, which you can withdraw at any time (the unsubscribe link in every such email, a reply to it, or Settings) |
| Security: rate limits, lockouts, access logs, fraud prevention, one free trial per email address | Legitimate interests (keeping the service and the data in it safe) |
| Error reports and usage statistics to fix and improve Mobcly | Legitimate interests |
For customers in the Philippines, the matching grounds of the Data Privacy Act of 2012 apply in the same way: contract, legal obligation, legitimate interests and consent. For patients’ health information, the clinic’s own lawful basis applies.
We do not sell personal data, show advertising, or use patient records for anything except providing the service to the clinic. We do not use patient records to train artificial intelligence. We make no decisions about anyone by automated means alone, and we do no profiling.
6. Who we share it with
We use these service providers. For our own data they work for us; for the clinics’ patient records they are subprocessors, listed with their changes at mobcly.com/subprocessors. Each handles data only to provide its service, under a data processing agreement.
| Provider | What for | Where |
|---|---|---|
| Hetzner Online GmbH | Servers and database | EU (Finland) |
| Cloudflare, Inc. | Network security and speed, the bot check on public forms (Turnstile), storage of exam images and encrypted backups (R2, EU jurisdiction) | Global network; stored data in the EU |
| Sendinblue SAS (Brevo) | Sending emails | EU |
| Stripe Payments Europe, Ltd. | Payments and invoices | EU, with transfers to the US |
| Functional Software, Inc. (Sentry) | Error reports | EU (Germany) |
| PostHog, Inc. | Usage statistics | EU |
| Google LLC | Sign in with Google (only if you use it) | Global |
Stripe also uses payment data for its own legal duties and fraud prevention, and Google handles its sign-in, under their own privacy policies.
We may also disclose data when the law requires it (for example a court order), or to protect the rights and safety of our users. If our business is sold or merged, the data would pass to the new owner under this policy.
7. Transfers outside the EU
Some providers above are based in, or may access data from, the United States. Such transfers rely on the EU-U.S. Data Privacy Framework where the provider is certified, or on the European Commission’s Standard Contractual Clauses.
Clinics outside the EU, for example in the Philippines, store their data with us in the EU. Sending it back to them uses the same safeguards (Annex A of the Terms of Service).
8. Where your data is stored
- On our servers: in the EU. Exam images and backups are stored encrypted.
- On devices: the Mobcly apps keep a copy of the clinic’s records so the clinic can work offline. That copy is encrypted on the device. The clinic is responsible for the devices it uses: screen lock, operating-system disk encryption, and who has access.
- Offline license: the clinic’s records are kept only on its own devices and in the backups it makes. They never reach our servers.
9. How long we keep it
| Data | How long |
|---|---|
| Account, clinic and patient records | While the account is active. When the owner deletes the account, it is closed at once and everything is deleted for good after 30 days (until then the owner can restore it). |
| An account whose plan ended (not deleted) | 12 months after the plan ended. We email the owner before we delete it. |
| Backups | Overwritten within 30 days, so deleted data is gone from backups within about 60 days of a deletion request |
| Invoices and payment records | 7 years (Estonian accounting law) |
| Security and access logs | Up to 6 years. They contain no patient record content. |
| A one-way hash of a deleted account’s email | As long as its invoices, only to prevent repeated free trials |
| Expired sessions | 30 days after they end |
| Password-reset links | 7 days |
| Devices you signed in from (hashed) | 13 months after their last use |
| Unfinished sign-ups | 7 days |
| Free guide requests | 30 days after we sent the guide. If you asked for the follow-up tips: until you unsubscribe. An address that unsubscribed stays on our do-not-email list. |
| Error reports and usage statistics | Error reports 30 days (Sentry); usage statistics up to 12 months (PostHog) |
10. How we protect it
- Encryption: all connections use HTTPS. Passwords are stored only as strong one-way hashes, and the apps’ local database is encrypted.
- Accounts: repeated wrong passwords lock the account for a while. Changing or resetting a password ends every other session.
- Access: an access log records who viewed, changed, exported or erased which record. Only clinic owners can see the access log, erase records or export full records.
- Backups: encrypted before they leave the server.
No system is perfectly secure. If a breach affects personal data for which we are the controller, we tell the Estonian Data Protection Inspectorate within 72 hours where the law requires it, and the people affected when it is likely to put them at high risk. If it affects patient records, we tell the clinic, which notifies its own authority (for example the National Privacy Commission in the Philippines) and its patients, with our help (Annex A of the Terms of Service).
11. Cookies and storage on your device
- What the apps need to work: the web app stores a few items in your browser, such as your sign-in, language and unsaved drafts. These are essential and need no consent.
- Usage statistics (PostHog) in the web app and the apps keep nothing on your device: no cookie, no identifier in browser storage. Each event carries your account id while you are signed in.
- Our website mobcly.com stores nothing in your browser for its visit statistics.
- The bot check on public forms (Cloudflare Turnstile) may use technical data from your browser to tell people from automated scripts.
12. Your rights
You can ask us to:
- give you a copy of your personal data;
- correct it;
- delete it;
- restrict or object to how we use it;
- send it to you in a portable format.
Where we rely on consent, you can withdraw it at any time.
To delete your account: in the app or on the web, open Settings → Delete account. Or use our public page:
https://eyecare.mobcly.com/delete-account. A clinic owner’s request deletes the whole clinic account, after a 30-day period in which it
can be restored. A staff member’s request deletes only their own login.
Write to [email protected] for anything else. We answer within one month. We may ask you to confirm your identity first. Patients: see §3.
You can also complain to a data protection authority:
- Estonia: the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), www.aki.ee.
- Elsewhere: the authority where you live. For example, the National Privacy Commission in the Philippines.
13. Children
Mobcly is a professional tool for clinics and is not meant for anyone under 18. Clinics may record patients of any age; the clinic is responsible for having the right to do so, including any consent needed from parents or guardians.
14. Changes to this policy
We will publish any change here with a new effective date. If a change is significant, we will tell account owners by email or in the app before it takes effect.
15. Contact
Mobcly OÜ, Mardi 6-209, 10113 Tallinn, Estonia. Privacy: [email protected] (data protection officer Jaan Arjasepp). Everything else: [email protected].