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Privacy Notice for Clinics

Version 05.10.2026

Privacy Notice

This Privacy Notice explains how Mojo Innovation AG (“Mojo”, “we”, “us”) processes personal data when you use evooia (the “Service”), including our website, web app, and mobile app.

1) Who we are

Provider: Mojo Innovation AG, Beethovenstrasse 41, 8002 Zurich, Switzerland
Contact: info@evooia.com

2) Roles: Controller vs Processor

evooia is used by professional and business customers (e.g., clinics, studios, agencies, self-employed professionals) and may involve patient/client data.

A) Patient/client data in the Service

For patient/client data processed within the Service (e.g., images, related metadata, messages/attachments, notes), our Customer (the practitioner/clinic/studio/agency) typically acts as Data Controller, and we act as Data Processor processing data on the Customer’s instructions (see our separate Data Processing Addendum (DPA)).

B) Provider operations

For data we process to operate our business and the Service (e.g., account administration, billing, security, support, product improvement), we may act as Data Controller.

C) US customers subject to HIPAA

Where our Customer is a covered entity under the U.S. HIPAA rules, we act as a business associate for Protected Health Information processed in the Service and will sign a Business Associate Agreement on request.

3) What data we collect and why

3.1 Account and administration (Practitioners / staff)

Data: name, email address, login/authentication data, account settings, support communications.
Purpose: create and manage accounts, provide support, secure the Service.
Legal basis (where applicable): performance of contract; legitimate interests (security, fraud prevention, service operation).

3.2 Images and related metadata (Patients/clients)

Clinical images are personal data and may constitute special-category data under GDPR and sensitive personal data under Swiss data protection law. Where images are shared in pseudonymized form, direct identifiers (such as name and date of birth) are removed and replaced with a coded reference; clinical attributes such as age, sex, and treatment information are retained as necessary for the purpose. Pseudonymized images remain personal data under GDPR.

Images may be used for the following purposes, subject to the clinic’s configuration and the patient permissions obtained by the clinic:

Purpose Consent required Legal basis
Treatment documentation No, covered by the treatment relationship Art. 9(2)(h) GDPR / FADP Art. 31(2)(a)
Education & training Yes, separate opt-in Art. 6(1)(a) + Art. 9(2)(a) GDPR
Marketing Yes, separate opt-in Art. 6(1)(a) + Art. 9(2)(a) GDPR

For education & training and for marketing, patients can additionally choose to share images only in de-identified form (e.g., masking of the eyes and mouth).

Patients may withdraw consent for any optional purpose at any time for future processing by contacting the clinic or, where available, through the app.

Data: images captured in the app, and related metadata generated by the Service (e.g., timestamps and technical metadata).
Purpose: enable core Service features such as secure storage, viewing, automatic alignment and capture guidance, and workflow support. The Service generates technical values from images (e.g., alignment, pose, framing, exposure). These values are used for image alignment and comparison. They are not used to identify or recognize any individual and are not used as a biometric identifier.
De-identification through masking: the mobile app may allow practitioners and patients to apply masking to selected facial regions directly on the device in order to create a de-identified version of an image for preview or export. This masking is performed locally on the device.
Sharing control: patients/clients control whether and how their content is shared with Customer staff, subject to how the Customer configures the Service and applicable professional/legal requirements.
Legal basis (where applicable): performance of contract; where required for sensitive data, applicable legal basis under Customer’s responsibility (explicit consent or healthcare-related basis).

3.2a Model training and research use by Mojo Innovation AG

Mojo Innovation AG does not use patient images to train or improve models, and does not receive image data for research purposes.

Non-identifying technical measurements derived from photos, such as landmark coordinates and how accurately two photos line up, are used to improve the accuracy of the alignment feature. The images themselves are not used for this, and these measurements do not identify a patient.

If this ever changes, it would require the Customer to enable it and the patient's explicit consent (Art. 9(2)(a) and Art. 6(1)(a) GDPR), and both would be informed before any such processing begins.

3.3 Messaging (if enabled)

Data: message content (text, images, attachments), timestamps, sender/recipient identifiers.
Purpose: facilitate communication and coordination.
Legal basis (where applicable): performance of contract; where required for sensitive data, applicable basis under Customer’s responsibility.

3.4 Product analytics (PostHog)

Data: usage/event data (e.g., feature usage, page/screen events, device/app technical signals), which may include identifiers such as internal user IDs and pseudonymous identifiers; for practitioner/staff accounts also the email address of the account and the identifier of the associated clinic. We also use aggregated clinic-level metrics that do not identify individual patients for account management and user communications.
Purpose: improve the Service, understand usage, fix issues, and improve stability.
Legal basis (where applicable): legitimate interests; consent where required (e.g., website analytics/cookies depending on jurisdiction and configuration).

3.5 Diagnostics

Data: crash reports and performance metrics (typically pseudonymized where possible).
Purpose: troubleshooting, stability, quality improvement.
Legal basis (where applicable): legitimate interests.

3.6 Payments (Stripe)

Data: billing/contact details and payment-related information handled by our payment processor.
Purpose: subscription billing, payments, receipts, fraud prevention.
Legal basis (where applicable): performance of contract; legal obligation (accounting).

3.7 Support requests

When you submit a support request in the app, we identify you so our team can help you. This links your account to the usage and diagnostic data. We use this data solely to process your request.

3.8 Notifications

We send notifications to keep your team informed about your account and about evooia, for example service notices and new features. You can change your choices at any time under Account > Notifications or in your iOS settings (legal basis: our contract and our legitimate interest in keeping you informed). Notifications never contain patient data.

4) Service providers (subprocessors / processors)

We use established service providers to operate the Service:

We require service providers to protect personal data and use it only to provide their services to us.

5) Cookies & tracking

Our website and web app may use cookies or similar technologies for:

You can manage cookies via your browser settings and, where available, our cookie/consent controls. Disabling certain cookies may affect functionality.

6) Where we process data

We use cloud infrastructure hosted in Switzerland (Microsoft Azure Switzerland).
Some service providers (e.g., PostHog in Frankfurt, EU) may process certain identifiers and metadata outside Switzerland depending on how those services operate.

Where required, we rely on appropriate safeguards for international data transfers.

7) Data retention

We retain personal data only as long as necessary for the purposes described above, or as required by law.

Typical retention approach:

8) Data security

We use appropriate technical and organizational measures designed to protect personal data, including encryption in transit and at rest (where supported), access controls, and backups. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

9) Your rights

Depending on your location and applicable law, you may have rights such as:

You can always contact us first. You also have the right to contact a data protection authority.

For patient/client data processed on behalf of a Customer, requests may need to be handled through the Customer (as Controller).

10) Changes to this Privacy Notice

We may update this Privacy Notice from time to time. If changes are material, we will provide notice (e.g., in-app notice or email). Continued use of the Service after the effective date of an updated notice indicates acceptance where permitted by law.

11) Contact

Questions or requests: