Privacy Policy
1. Who we are
Open Health is provided by Magnify Sight SRL, Bucharest, Romania, registered with the Romanian Trade Register under J2008018718403 (EUID ROONRC.J2008018718403), fiscal code (CUI) RO24696008 (“we”, “us”). We are the data controller for the personal data described here.
Contact for any privacy question or request: privacy@magnify.ro.
2. What data we process
Account data
Your name, email address, the versions of the Terms and this Policy you accepted and when. Your password itself is never stored: we keep only a one-way Argon2id hash used to check your login, plus encrypted keys (see section 3).
Encrypted file contents
The content of every file you upload is encrypted on your device with AES-256-GCM before upload. We store only the encrypted data and cannot read it.
Record and family information stored readable on our servers
To list, sort and share your records, the following is stored without end-to-end encryption (it is protected in transit with TLS and on our servers by access controls):
- record title, category (for example “lab result”), file type, file size, upload date, and a SHA-256 fingerprint of the encrypted file;
- names of family groups; names, relationship to you and dates of birth of family members you add;
- for share links you create: the record shared, category, stated purpose, expiry, view limits and view count.
Record titles and categories can reveal information about health. Avoid putting details in titles that you would not want stored in readable form.
People who open a share link
If you create a share link that requires identification, the person opening it (for example a doctor) is asked for their name, clinic, email address and purpose, and we record this together with their IP address, browser user-agent and the time of access, so that you can see who accessed your record.
Security and audit data
We keep a tamper-evident, signed audit log of events such as record access, share creation and revocation, and consent changes. It contains identifiers, event types, content fingerprints and timestamps — not file contents. Our servers also log technical request data (IP address, time, requested endpoint, status) for security and abuse prevention.
App update checks
The app checks for updates through Expo’s update service, which receives your IP address, device platform and app version. No account or health data is sent.
3. How your files are protected
A key derived from your password on your device (PBKDF2-SHA256, 600,000 iterations) unlocks your personal data key, which in turn unlocks a separate key for each record. Keys are stored on our servers only in encrypted (“wrapped”) form; the key derived from your password never leaves your device. Because of this, if you forget your password and lose your recovery codes, we cannot recover your files.
4. Why we process data (legal bases)
| Purpose | Legal basis (GDPR) |
|---|---|
| Providing your account, storing and organising your records, sharing on your instruction | Contract – Art. 6(1)(b); for health-related data, your explicit consent – Art. 9(2)(a), given when you create your account and add records |
| Recording who opened a share link | Legitimate interest in letting you control access to your records – Art. 6(1)(f) |
| Security logs and audit trail | Legitimate interest in security and abuse prevention – Art. 6(1)(f) |
| Keeping a record of your acceptance of these terms | Legal obligation / accountability – Art. 6(1)(c), Art. 7(1) |
You can withdraw consent at any time by deleting the relevant records or your account. Withdrawal does not affect processing that already took place.
5. Who receives data
- People you choose to share with, through share links you create and can revoke.
- Hetzner Online GmbH (Germany) — hosts our servers, databases and encrypted file storage in Nuremberg, Germany, under a data processing agreement.
- Expo / 650 Industries, Inc. (USA) — app update delivery, as described above. Transfers rely on the EU–US Data Privacy Framework and/or Standard Contractual Clauses.
- Google — if you email us, your message is handled through our Google Workspace mailbox.
- Authorities, only where the law requires it. We can only ever hand over encrypted file contents, which we cannot decrypt.
We do not sell personal data and do not use advertising, analytics or tracking SDKs.
6. Where data is stored
Your account data, records and audit logs are stored in the European Union (Germany). The only transfer outside the EU is the app-update check described above.
7. How long we keep data
| Data | Retention |
|---|---|
| Account, records, family information | While your account exists. After you delete your account it is deactivated immediately and permanently erased within 30 days. |
| Database backups | Up to 14 days, then overwritten |
| Share links and access records | Until the link expires or is revoked, plus 30 days; deleted with your account |
| Login sessions | Up to 7 days (refresh tokens); 30 days for biometric unlock on a device |
| Server request logs | Up to 90 days |
| Audit log | Kept to preserve the integrity of the log. Entries reference an internal user ID, event type, fingerprint and time — never your name, email or file content. |
8. Your rights
Under the GDPR you have the right to access, rectify, erase, restrict and object to processing of your data, the right to data portability, and the right to withdraw consent. In the app you can export your data (Settings → Export, including FHIR R4 format), edit records and delete your account (Settings → Delete account). For anything else, email privacy@magnify.ro; we reply within one month.
You may also complain to the Romanian data protection authority, ANSPDCP (dataprotection.ro), or the authority in your EU country of residence.
9. Children and family members
Accounts are for adults. You may add family members, including children, only if you are legally entitled to manage their health information, and you are responsible for informing them where appropriate.
10. Security
All traffic uses TLS. Servers are access-restricted and monitored. No system is perfectly secure; if a breach affecting your data occurs, we will notify you and the authority as required by law.
11. Changes
If we change this policy materially, we will update the version above and notify you by email or in the app before the changes take effect.