This Privacy Policy explains how personal data is processed through the non-clinical MedCMS educational website operated by Moebiusol S.R.L.
Effective date: 2026-05-05
Version: 1.0
Applies to: MedCMS public pages, educational articles, reserved reader access, account-linked reader features, and related website functions.
1. Scope
This Privacy Policy explains how personal data is processed in connection with the MedCMS website (the Site). It covers the Site as a non-clinical educational content platform for Oculus Vita and the same MedCMS legal website layer used for Oralert.
It does not describe clinical processing that happens in other Oculus Vita systems such as the mobile application, backend clinical services, HCP workflow systems, or screening workflows unless those systems directly interact with the Site.
2. Data controller
- Legal entity: Moebiusol S.R.L.
- Registered office: 227/A, Sat Lovrin, Comuna Lovrin, Timis, 307250, Romania
- Company registration number: J35/1166/2006
- Fiscal / tax identifier: CUI 18569034
- General contact:
This email address is being protected from spambots. You need JavaScript enabled to view it. - Privacy contact:
This email address is being protected from spambots. You need JavaScript enabled to view it.
If a different controller, customer controller, or joint-controller arrangement applies to a specific integrated service, that will be stated separately in the relevant service notice or agreement.
3. Personal data we process
The Site is designed to process a limited set of personal data needed to operate public and reserved educational content.
- Account and identity data: name, display name, email, username or account identifier, access roles, entitlement claims, locale, and account status signals.
- Technical and security data: IP address, browser and device information, operating system, timestamps, request logs, session identifiers, authentication events, and security logs.
- Contact data: name, email, message, and information you choose to provide in a website support request.
- Preference and operational data: content viewed, search/filter interactions, cookie preferences, saved-article preferences where enabled, and limited first-party operational analytics for reliability, availability, performance, and fault diagnosis.
4. What the Site is not intended to process
MedCMS is non-clinical. The Site is not intended to collect or store medical records, diagnostic results, screening workflow state, consultation notes, or PHI-bearing clinical submissions. Do not submit special-category health data, patient records, or sensitive clinical information through general Site forms or contact channels.
If such information is submitted by mistake, we may process it only to contain the issue, protect the data, redirect the request, delete or secure the data where feasible, and comply with legal obligations.
5. Purposes and legal bases
- Operate the Site and deliver requested content: contract or steps requested by you; legitimate interests in operating a secure educational website.
- Protect the Site and accounts: legitimate interests in platform security; legal obligation where security or recordkeeping duties apply.
- Handle support/contact requests: steps requested by you; legitimate interests in support and service improvement.
- Manage cookies and similar technologies: strictly necessary operation for essential technologies; consent for non-essential cookies or tracking where required.
- Comply with law and defend rights: legal obligation; legitimate interests in legal defense and governance.
- Operate usability and essential operational analytics: legitimate interests in maintaining a proportionate educational content service; consent where a feature depends on non-essential tracking.
6. Sources
We collect data directly from you, automatically from your browser/device, and from the approved identity service when you authenticate for reserved content. The Site is not a primary source of clinical data collection.
7. Recipients
We may share personal data with hosting and infrastructure providers, identity/authentication providers, CMS support vendors, communications processors, security/logging/monitoring providers, professional advisers, and competent authorities where required by law. We do not sell personal data or disclose it for unrelated third-party advertising.
8. International transfers
The Site is hosted by Moebiusol S.R.L. on operator-controlled private-cloud infrastructure in Romania. Core runtime hosting and storage are intended to remain primarily in Romania and, where applicable, within the European Economic Area.
Where personal data is transferred across borders, we apply safeguards required by applicable law, including adequacy decisions, standard contractual clauses, contractual/technical safeguards, or other lawful transfer mechanisms. This approach is intended to align with GDPR and similar privacy regimes, including relevant international and African data-protection laws where applicable.
9. Retention
We keep personal data only as long as necessary for the purposes described here. Session data is kept for the active session or a short security period. Security and access logs are retained for a limited security window. Contact/support requests are retained for handling and follow-up. Account-linked access data is retained while the account or entitlement remains relevant and for a reasonable security/audit period. Cookie preferences are retained as described in the Cookies Policy.
10. Security
We use proportionate technical and organizational measures, including access control, transport security, logging and monitoring, role-based reserved-content access, secure identity handoff, patching, and vulnerability management. No system is risk-free, but safeguards are applied for a non-clinical educational content platform.
11. Your rights
Depending on applicable law, including GDPR and similar laws, you may have rights to information, access, correction, deletion, restriction, objection, data portability, withdrawal of consent, and complaint to a competent supervisory authority. We may need to verify your identity before acting on a request.
To exercise rights, contact
12. Cookies
The Site uses cookies and similar technologies for security, sessions, preferences, and limited operational purposes. See the Cookies Policy.
13. Children
The Site is not intended for unsupervised account creation or general website submissions by children. If you believe a child has provided data inappropriately, contact us for review.
14. Complaints
Please contact us first at
15. Changes
We may update this Policy to reflect changes to law, Site configuration, service providers, or processing. Material changes will be indicated by an updated effective date and, where required, additional notice.
16. Contact
Privacy questions, requests, or complaints:
