1. Who is the controller

For personal data that iPeeWell d.o.o. processes for the management of its own contractual relationship, billing, support and security, the controller is iPeeWell d.o.o., Celovška 14, 3000 Celje, Slovenia, registration number 9609237000, VAT ID SI94301786, info^udiflow.com.

When UDIFlow processes personal data that the Client enters into/for its organization, the Client is the controller and iPeeWell is the processor under the DPA. This policy does not replace the Client’s own privacy policy towards its persons.

2. Data and purposes

We process the following categories of data:

• identification and contact data of business users (name, username, business email address, role and permissions);
• company, contract, account and support communication data;
• security and audit data (successful/failed logins, time, security events, technical data and IP address when recorded in the security log);
• limited internal error logs: source and predefined error type, static technical message, path without parameters, internal request identifier, application version, time, number of attempts and resolution information; this log does not record the content of forms or documents, passwords/tokens, IP address or user identifier.
• data that the user voluntarily sends when requesting support or when a password is forgotten.

We use necessary session cookies to ensure the login function and protect against fraudulent requests. The browser only stores user theme and font size settings locally and, when selected by an authorized administrator, the active company identifier. The access token is stored only in the memory of the open tab and is not retained after the tab is closed. These settings are not intended for advertising or profiling.

We use the data for the conclusion and execution of the contract, support, billing, account and service protection, detection of abuse, fulfillment of legal obligations and assertion/defense of legal claims. The legal basis is the execution of the contract, the legitimate interest of a safe and reliable service or legal obligation, where applicable.

UDIFlow is not intended for the entry of patient health data or other special types of personal data. The subscriber is responsible for not entering them unless otherwise specifically agreed in writing with the Provider and appropriate measures are taken.

3. Recipients, location and transfer

Production data and backup copies are currently on servers owned by iPeeWell d.o.o. Email services are currently provided by Webtasy d.o.o., Dunajska 110, 1000 Ljubljana, Slovenia. Data is not intentionally transferred outside the EEA. If the location or provider of production data, backup copies or email changes, the Provider will update the relevant documentation prior to the change and apply applicable protective measures for the transfer.

We may disclose data to authorized processors, accounting/consulting contractors, if necessary, and authorities when required by law. When iPeeWell acts as a processor for the Client, processing, instructions from the Client, sub-processors, assistance with individual requests, and refund or deletion are also regulated in a Data Processing Agreement (DPA). We do not sell personal data.

4. Retention

We retain user account, support, and Client data for the duration of the contract and, as a rule, for up to one month after termination or a justified request for deletion, unless longer retention is required by law. We retain accounting and tax records to the extent and for the periods required by law. We retain security logs only for as long as is reasonably necessary for security and auditability. Internal error groups are automatically deleted after 90 days (the setting is technically limited to 7 to 365 days).

5. Security

We use reasonable technical and organizational measures, including role-based access management, authentication, logging of significant changes, session management, data separation by organization, limited internal error log without user input content, and transmission protection when the service is installed over HTTPS. No system is completely secure; the user must protect their password and device and immediately report suspected misuse.

6. Rights and contact

The individual has the right to access, rectification, erasure, restriction, objection and portability, where the law allows. The request is sent to info^udiflow.com; we verify the identity and respond within the statutory deadline. The individual may file a complaint with the Information Commissioner of the Republic of Slovenia or with the competent supervisory authority of the country of habitual residence/work.

7. UDIFlow Mobile Application

UDIFlow Mobile is a native Android and iOS application and a wrapper around the UDIFlow web service. UDIFlow is a business application for UDI-based traceability, inventory management and product recalls. It is not intended to collect patient health data, diagnose, treat or monitor patients.

When using the mobile application, user account and organization data, login and MFA data, sessions and security, UDI codes, receipts, issues, inventory, warehouses, quarantine, suppliers, subscribers, recalls, accounting references, audit history, and files or photos that the user intentionally selects or captures may be processed. The mobile wrapper may log limited diagnostic events, camera or file selection errors, and technical exceptions; it does not log passwords, access tokens or the full content of documents. Business data and documents entered through the application may contain personal data for which the Subscriber’s organization is the controller.

The Android CAMERA permission is only used when the user initiates a UDI code scan or explicitly chooses to take a photo of a delivery note, invoice, or other document. The app does not use the camera for advertising, background monitoring, or location tracking. The user can deny the camera permission and use manual input or file selection where the individual feature allows it.

The camera is an optional feature of the device. The app does not require the camera for installation or basic use; permission is only requested after choosing to scan or take a photo of a document. The app does not use the camera continuously in the background, and file access is only requested when the user selects a file or confirms the captured document.

UDIFlow Mobile may use Google Play services Code Scanner or ML Kit to scan codes. Google states that the processing of the barcode image and result occurs on the device, and that Code Scanner does not store the image or scan result on Google servers. However, Google Play services or ML Kit may process technical data about the device, the app, and the installation for diagnostics, usage analytics, model updates, or compatibility. The scanned code is returned to the UDIFlow form for the user to review and submit.

Files and photos that the user intentionally selects or captures are forwarded to the UDIFlow web service and may be stored with the corresponding receipt, issue, or other business record. The user should not take photos or upload data that is not necessary for the business record. The mobile wrapper stores non-login settings locally, such as server address, language, theme, font size, and always-on display settings; passwords are intentionally not stored in these settings. If the offline queue is enabled, receipt data and associated files may be stored in a protected local browser cache until synced; the queue is limited to receipts. On each Android launch, the application clears the login cookies and requires a new login, and the queue, if enabled, is available for later syncing.

The mobile wrapper logs limited diagnostic events and errors to the local application log. It is designed not to log passwords, access tokens, or the entire contents of documents. The application does not use advertising cookies or behavioral profiling and does not sell personal data.

WebView uses necessary session mechanisms to verify the user and protect claims. Access tokens are intentionally not stored in the mobile application settings file. The application supports password and MFA when enabled by the organization; sessions can be canceled by the administrator. Business records are available to authorized users based on company, role, and repository permissions. Google Play services and ML Kit may process technical data about the device, application, and installation for diagnostics and analytics, as documented in their documentation; image and result processing in Google Code Scanner occurs on the device.

The client determines the retention of its business records, taking into account the contract, legal requirements, and instructions. We retain invoice, support, billing, and security data for as long as necessary for the contract, security, legal obligations, and claims. Temporary captured files are retained only until the selection is completed and uploaded to the form. UDIFlow is a business application and is not intended for children.

The mobile application does not allow for public self-registration. User accounts are created and managed by an authorized administrator of the company or UDIFlow service. A user may submit a request for access, correction, or deletion to their company administrator or to info^udiflow.eu; deletion may be restricted due to legal, accounting, audit, security, or contractual retention obligations. Before publishing, the owner must verify that this process and any required account deletion path in the application correspond to the final application and the responses in the Data safety form in the Play Console.

This section is part of this UDIFlow Privacy Policy and is the complete privacy description for the mobile application; there is no separate policy for the mobile application.

8. Changes

We may update this policy due to changes in the service, processing, or law. The published version will include the date of the update. The Slovenian version prevails over the informative English translation.

Različica: 0.3 – 7. september 2026