Privacy Policy

1 Data controller

The controller of your personal data ("we", "us") is:

Necogi, obrt za računalne usluge, owner Ivan Biliškov
Obala kralja Tomislava 8, 21215 Kaštel Lukšić, Croatia
OIB (tax no.): 14923986443 · MB (reg. no.): 98551884
Data protection contact: info@necogi.com

2 Summary

3 Data that stays on your device

Everything you enter into the app is stored only locally on your device. We do not receive it or process it on our servers.

Where it is stored:

On iOS the database is in a shared container (App Group) so the home-screen widget can show today's doses.

If you enter data about other people (e.g. family members or doctors), you are responsible for making sure they are aware of it.

Device backups: if you use iCloud or Google whole-device backup, app data may be included depending on your device settings. This is outside our control.

4 Data we process

4.1. Technical communication on app start

When the app starts, it connects to our sign-in service (Clerk) and subscription service (RevenueCat) to check sign-in state, load prices and check subscription status. This transmits technical data: IP address, an anonymous installation identifier, device and operating system type and version, app version and language. No health data is transmitted.

• Legal basis: legitimate interest (Art. 6(1)(f) GDPR) — proper functioning of the app and subscription.

4.2. User account (optional)

An account is needed only for MeDo Pro.

• Data: email address; if you sign in with Apple or Google — the name and account identifier that service passes to us (Apple lets you hide your email address); session data (IP address, device type, sign-in time).
• Purpose: sign-in, linking your subscription to your account, abuse prevention.
• Legal basis: performance of a contract (Art. 6(1)(b)); for security — legitimate interest (Art. 6(1)(f)).
• Processor: Clerk, Inc. (USA).
• Retention: until you delete your account.

Your health data is not linked to your account and is not stored on any server.

4.3. MeDo Pro subscription

• Payment is processed by Apple (App Store) or Google (Google Play) as independent controllers. We never see your card details.
• Subscription management (RevenueCat): your account identifier, transaction identifiers, purchased product, purchase and expiry dates, trial status, store country and platform.
• Legal basis: performance of a contract (Art. 6(1)(b)).
• Processor: RevenueCat, Inc. (USA).
• Retention: while your account exists; after account deletion see section 8.

4.4. AI document and medication analysis (MeDo Pro)

When you choose AI analysis of a document or scan a medication box:

• What is sent: the photo or PDF you selected and technical instructions for the model (e.g. response language). The document may contain information visible on it (e.g. name, insurance number, diagnosis). We do not send any other data from the app (profile, medication list, appointments, dose history, insurance).
• Data path: your device → our server (Vercel, Frankfurt region, EU) → OpenAI API (USA) → result back to your device.
• Our server does not store images or results — it only forwards them. Server logs contain only the request type, status and duration.
• OpenAI does not use data sent via the API to train models and keeps it for up to 30 days for abuse monitoring, after which it is deleted.
• Results are stored only on your device.
• Legal basis: your explicit consent (Art. 9(2)(a) and Art. 6(1)(a) GDPR), which you give in the app before first using AI.
• Withdrawing consent: at any time in Profile → AI Features. Withdrawal does not affect the lawfulness of processing before it; after withdrawal AI features are unavailable.

To prevent abuse, the number of AI requests per user is limited.

4.5. AI service usage statistics

When you use AI, our server records technical events linked to your account identifier: analysis started, succeeded or failed, feature type, model used, number of tokens processed, duration, error code and rate-limit hits. Failed sign-in attempts are recorded without an identifier.

• We do not record image content, analysis results or any health data.
• Purpose: service reliability, cost monitoring and abuse prevention.
• Legal basis: legitimate interest (Art. 6(1)(f)). You have the right to object (section 10).
• Processor: PostHog (data stored in the EU, Frankfurt).
• Retention: up to 12 months.

Within the app itself we use no behavioural analytics, advertising identifiers or tracking tools.

4.6. Feedback and support

When you contact us via the "Feedback & Support" feature or by email:

• Data: your email address, the message and — only if you include it — the app version and operating system name and version. The message is sent through the email app on your device to podrska@necogi.com.
• Legal basis: legitimate interest (Art. 6(1)(f)) — answering your request and improving the app.
• Retention: as long as needed to resolve your request, at most 2 years.

Please do not include health data in your messages.

4.7. Website medo.codeasy.com

The website uses no cookies, analytics or third-party services; fonts are served from our own domain. Our hosting provider (Vercel) briefly logs technical access data for security (IP address, time, requested page).

• Legal basis: legitimate interest (Art. 6(1)(f)) — security and operation of the website.

5 Actions you start yourself

The following actions send data from your device only when you start them, to a destination you choose. We do not receive this data.

6 Recipients and processors

We have data processing agreements with our processors. We do not sell, rent or trade your personal data.

7 Transfers outside the EU

Clerk, RevenueCat and OpenAI process data in the USA. Vercel and PostHog process data in the EU but are headquartered in the USA. Transfers are based on the EU-U.S. Data Privacy Framework, for recipients certified under it, or on the European Commission's Standard Contractual Clauses (Art. 46 GDPR).

8 Retention

9 Security measures

10 Your rights

Send requests to info@necogi.com. We will reply within one month.

Deleting your account does not cancel your subscription — cancel it in App Store or Google Play settings.

Automated decision-making (Art. 22): we make no decisions based solely on automated processing. AI only extracts data from a document, which you then review.

11 Children

MeDo is intended for people aged 16 and over (Art. 8 GDPR). Parents or guardians may use multiple profiles to manage their children's health data and take responsibility for doing so. We do not knowingly collect data from children under 16.

12 Supervisory authority

You have the right to lodge a complaint with a supervisory authority, in particular in your EU country of residence. In Croatia:

Croatian Personal Data Protection Agency (AZOP)
Selska cesta 136, 10000 Zagreb
azop.hr · azop@azop.hr

13 Changes to this Privacy Policy

We will notify you of significant changes in the app. If a change concerns processing that requires your consent, we will ask for your consent again before continuing that processing.

The Croatian version is the original; in case of discrepancy, the Croatian version prevails.

14 Contact

Necogi, obrt za računalne usluge, owner Ivan Biliškov
Obala kralja Tomislava 8, 21215 Kaštel Lukšić, Croatia
Email: info@necogi.com