Privacy Policy

Last updated: May 6, 2026

1. Who We Are

This Privacy Policy explains how Best Devhub SRL, fiscal code 40844165, with its registered address at Sat Miroslavesti nr. 97A, Prahova, Romania, Cod 107486 ("MoleMap", "we", "our", or "us") collects, uses, stores, and protects personal data when you use the MoleMap mobile application, website pages, and related services (collectively, the "Service").

For privacy-related questions or requests, you can contact us at contact@merced.ro.

2. What Data We Collect

Depending on how you use MoleMap, we may collect the following categories of personal data:

• Account Information: name, email address, login details, and profile information you provide during registration or profile setup.
• Health-Related Content: photos of moles and skin lesions, body region mappings, Fitzpatrick skin type selections, monitoring history, and AI-generated analysis or comparison results associated with your account.
• Usage and Device Data: app usage patterns, feature interactions, basic device information, technical logs, and error diagnostics.
• Payment and Subscription Data: subscription status, purchased plans, billing events, renewal dates, transaction references, and limited payment-related metadata provided by our payment processor, Paddle. We do not store full card numbers.
• Support Communications: information you send to us when you contact support, including emails and issue descriptions.

3. Why We Use Your Data

We use personal data to:

• create and manage your account;
• provide AI-powered mole analysis, tracking, and comparison features;
• store your monitoring history and support progress tracking over time;
• process subscriptions, payments, renewals, cancellations, and billing support requests;
• maintain security, detect fraud or misuse, and protect the integrity of the Service;
• improve app performance, reliability, and features;
• communicate with you about your account, purchases, updates, and support matters; and
• comply with legal, regulatory, tax, accounting, and enforcement obligations.

4. Legal Bases for Processing

Where GDPR or similar laws apply, we rely on one or more of the following legal bases:

• Performance of a contract: when processing is necessary to provide the Service, manage your account, deliver purchased features, or respond to your requests.
• Legitimate interests: when processing is necessary to secure, improve, support, and operate the Service, provided those interests are not overridden by your rights.
• Consent: where we ask for your consent, including where sensitive or health-related data requires it under applicable law.
• Legal obligation: where processing is necessary to comply with applicable law.

5. Health-Related and AI Processing

MoleMap may process images and related health-oriented content that you choose to upload in order to generate AI-assisted visual tracking and comparison outputs. This information may be considered sensitive personal data under certain laws. We process this type of data only for the purpose of providing the Service to you, improving reliability and safety, and maintaining your monitoring history, subject to applicable law.

Before an AI analysis is started, the app asks for your permission and explains what information will be sent. When you consent to AI analysis, the mole photo selected for analysis, the related mole record identifier, and optional profile information such as Fitzpatrick skin type may be sent from MoleMap servers to Google Gemini AI, provided by Google LLC, to generate an informational visual tracking report.

AI-based outputs are generated automatically and may be incomplete or inaccurate. They are provided for informational tracking and educational self-assessment only. MoleMap is not a medical device and does not provide medical advice, diagnosis, treatment, cancer detection, melanoma detection, or emergency services. Always consult a qualified doctor or dermatologist for medical evaluation and treatment guidance.

6. Sharing of Personal Data

We do not sell your personal data. We may share personal data only as reasonably necessary with:

• Payment processors, including Paddle: to process subscriptions, renewals, cancellations, payments, and billing-related events;
• AI service providers, including Google LLC / Google Gemini AI: to process mole photos and related analysis context only when you request and consent to AI analysis;
• Technical service providers: to support app functionality, hosting, storage, analytics, security, and diagnostics;
• Professional advisers and authorities: where necessary to enforce our rights, comply with legal obligations, or respond to lawful requests; and
• Corporate counterparties: if we are involved in a merger, acquisition, restructuring, financing, or sale of assets, subject to appropriate confidentiality safeguards.

7. International Transfers

Some of our service providers may process personal data outside your country of residence. Where required by law, we take appropriate measures to ensure that international data transfers are protected by suitable safeguards.

8. Data Retention

We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to maintain your account, provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements.

Account data and monitoring content are generally retained while your account remains active. After account deletion, we will delete or anonymize personal data within a reasonable period, except where continued retention is required by law, necessary for legitimate recordkeeping, fraud prevention, tax/accounting obligations, or dispute resolution.

9. Security

We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. However, no system can be guaranteed to be completely secure, and you use the Service at your own risk.

10. Your Rights

Depending on your location and applicable law, you may have the right to:

• access the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of your personal data;
• object to or request restriction of certain processing;
• request data portability where applicable;
• withdraw consent where processing is based on consent; and
• lodge a complaint with a competent data protection authority.

To exercise any of these rights, contact us at contact@merced.ro. We may request reasonable verification of your identity before acting on a request.

11. Children's Privacy

MoleMap is not intended for use by children under 16. We do not knowingly collect personal data directly from children under 16 without appropriate authorization where required by law.

12. Account Deletion

You can request deletion of your MoleMap account and associated data here: https://www.merced.ro/molemap/delete-account.html

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we may notify you through the app, on our website, or by other reasonable means. The updated version becomes effective when posted unless stated otherwise.

14. Contact

If you have any privacy-related questions, data requests, or complaints, contact us at contact@merced.ro.