Privacy Notice

Version 1 · 4 October 2026

Who we are. EXEVIO d.o.o. (EXEVIO Ltd.), Vukovarska 6, Rijeka, Croatia, MBS 040306757, OIB 53022148424, runs RxPH. Email contact@rxph.app, telephone +63 967 210 9267. Data Protection Officer: Dino Budimilić, dpo@rxph.app.

What this notice covers. The data we hold about doctors and clinics who use RxPH, and people who write to us. Patients' records are not covered here: we hold them for the patient's doctor, and the doctor's own privacy notice covers them.

What we hold, why, and on what basis

What Why Basis
Your email address, and which version of the Subscriber Terms and the Data Processing Agreement you accepted, and when Your account, and signing you in with a code sent to that address and a passkey. There is no password Our contract with you
Your licence check: profession, first, middle and last name, PRC licence number, date of birth, and one to three photos of a government ID that shows your date of birth. Also our decision, its reason, and our reviewer's notes Checking by hand, against the PRC register, that you are a licensed physician before your account opens Our contract with you. After you close your account we keep it because we have a legitimate interest in being able to show the check was made against a real person
The date your licence is valid until, who looked it up and when, and the reminders we sent you about it Keeping you able to write only while your licence is valid, and reminding you before it runs out Our contract with you
Your profile: the name printed on your documents, credentials, specialty, clinic name, address, hours and phone numbers, PRC licence, PTR and S2 numbers, your signature image, and your logo if you upload one They are printed on your prescriptions and other documents, and shown to your patients Our contract with you
The photo from your PRC register record, which our reviewer copies when we check your licence, so we can show you your card and ask about the doctor wall. Your answer, and when you gave it. If you say yes: your name, credentials, specialty and that photo on rxph.app Showing on rxph.app which doctors use RxPH Showing you on the wall: your consent, which you can take back in Settings at any time. Keeping the photo so we can ask you: our legitimate interest
Billing: your Stripe customer and subscription numbers, plan, status, the end of your paid period, and any free access we gave you and until when Taking payment, and your invoices Our contract with you, and our legal duty to keep tax records
Why you left, if you tell us when you close your account: the reason you pick and anything you write Making RxPH better Our legitimate interest in improving RxPH. It is optional
What you write to us at contact@rxph.app or dpo@rxph.app Answering you Our contract with you, or our legitimate interest in answering you
Your IP address, briefly, and your sign-in sessions Slowing down repeated wrong sign-in codes, and keeping accounts secure Our legitimate interest in keeping RxPH secure
Your passkeys: the public half of each (it opens nothing on its own) and the name of the device it was made on, such as "iPhone · Safari" The second step of signing in, and telling you which device a sign-in is asking for Our contract with you

Under Philippine law, your PRC licence and its status, your date of birth and your ID photos are sensitive personal information. For them we rely on your consent, which you give by accepting the Subscriber Terms, whose clause 3 describes the licence check, and again when you send your licence details and ID for checking. After you close your account, we keep them for the times under How long, so that we can show the check was made if a claim arises.

We never see your card number. Stripe takes the payment and holds your card, billing address and any TIN you give at checkout.

We do not use tracking, analytics or advertising, we do not profile you, and we do not sell data.

Who sees it

Where it is kept

On servers in Falkenstein, Germany, in the European Union, with an encrypted backup copy, updated every hour, on a storage device we control in the Philippines. Stripe is in Ireland. Postmark is in the United States, under Standard Contractual Clauses.

How long

What How long
The record of your licence check: your name, PRC licence number, our decision, who checked and when 10 years after you close your account
Your ID photos, date of birth, and the photo for the doctor wall For as long as your account exists, even after you close it
Your account, profile, billing records and why you left Until two years after you close your account
Invoices and tax records 11 years, as Croatian tax law requires
What you write to us Two years after the last message
Security records At most 12 months, longer for one connected to an incident

What is printed on a prescription you issued stays on it for as long as the prescription is kept, as the Data Processing Agreement says.

Your rights

You can ask to see your data, correct it, erase it, limit how we use it, object to how we use it, take a copy in a format that moves to another system, and take back your consent where we rely on it. You can download your account data and correct your profile yourself in RxPH. For anything else, write to contact@rxph.app or to our Data Protection Officer at dpo@rxph.app. We answer within one month.

You can complain to AZOP, the Croatian Personal Data Protection Agency (azop.hr), or to the National Privacy Commission of the Philippines (privacy.gov.ph).

Changes

When this notice changes, we publish the new version here with its date, and we email you about any change that affects you.