Privacy Policy

1. Introduction

This Privacy Policy explains how Mostly Tiny Ltd ("we", "us", "our") collects, uses, shares and protects your personal data when you use mostlyqr.com, and the rights you have over that data. It applies to personal data for which we act as the controller. Effective date: 2026-10-07.

2. Who we are and how to contact us

Mostly Tiny Ltd is the controller responsible for your personal data. You can contact us about this policy, or to exercise your rights, at privacy@mostlytiny.io.

Studio M, Hackney Depot, 5 Sheep Lane, London E8 4QS, United Kingdom

3. Our representative in the European Union

Mostly Tiny Ltd is established in the United Kingdom. We are appointing a representative in the European Union under Article 27 of the EU GDPR and will name them here. Until then, people in the EU can contact us directly at privacy@mostlytiny.io.

4. Personal data we collect

We collect: information you provide directly (for example account details (name, email); the QR codes, short links, hosted pages and forms you create (destinations and content); Batch QR details (see below); scan analytics about the people who scan your codes (see "Scan data we hold for you"); payment and billing details; product usage; and, only with your consent, how you arrived (see "How we learn where visitors come from")); information collected automatically when you use mostlyqr.com, such as your IP address, device and browser type, pages viewed, and cookie identifiers; and, where relevant, information we receive from third parties.

We collect personal data in the categories above for the purposes set out in this policy.

5. Where we get your data

Where we do not collect personal data directly from you, we obtain it from sources such as our service providers, analytics and advertising partners, publicly available sources, and other third parties you have authorised to share it.

6. How and why we use your data

We use your personal data to: provide, operate and improve mostlyqr.com and our services; create and manage your account; respond to enquiries and provide support; personalise your experience; send service and, where permitted, marketing messages; keep the service secure and prevent fraud; and comply with our legal obligations.

7. Scan data we hold for you

When someone scans a MostlyQR code or opens an mqr.sh link on a paid plan, we record for the code's owner: the time; the country and region (not the city); the type of browser, operating system and device (not the full browser identification string); the browser's preferred language; the referring page; an approximate location derived from the IP address and rounded to about 1 km; a salted one-way hash of the IP address, used to count unique scans; and how the scan was routed. We do not store the IP address itself. If a person chooses to share their location on a hosted page, we store it rounded to the same ~1 km. On the free plan we keep only a scan count and the time of the last scan.

We process scan data and form submissions on behalf of the code's owner, who is the controller, under our Data Processing Agreement. If the owner connects an integration — their own webhook, or Meta's Conversions API — we send scan events to that recipient on their instruction; it is their recipient, not ours. If the owner has set a webhook to receive exact location, a location the scanner chose to share is forwarded to it unrounded (we do not store it). If you scanned a code, contact the business that published it first.

8. Batch QR details

A Batch QR code gives each person or product in a list its own code. The details you add to each one — for example a name, title or photo, which can appear on that person's profile page — are held on behalf of the account owner, who is the controller, under our Data Processing Agreement. Profile pages are not listed in search engines and their addresses cannot be guessed.

When the owner deletes a person or their account, those details are erased. When a batch is archived, its details are erased 30 days later. An erased person's code keeps working, but points to the batch's archive page and shows none of their details. If you are in someone's batch, contact the business that created it first.

9. How we learn where visitors come from

Fathom Analytics counts visits to mostlyqr.com without cookies and without identifying you, including which website, campaign or AI assistant referred a visit. In the UK we rely on the statistical-purposes exception in the Privacy and Electronic Communications Regulations. You can object at any time by switching off "Analytics" in Cookie settings, which turns Fathom off for your browser.

We also keep our own anonymous daily totals of visitors who arrive from an advert: how many land, open our editor, sign up and buy, by ad platform and landing page. The ad platform and page name travel in the web address of our own pages; nothing is stored on or read from your device, no cookie is used, and the totals are never linked to you or your account. Because no storage on your device is involved, this counting continues whatever you choose in Cookie settings.

If you accept Analytics or Marketing cookies, our site also remembers in your browser how you first and most recently arrived (campaign tags, the referring site and the page you landed on) and attaches it to your account when you sign up, so we can see which channels bring us customers. If you do not accept, we keep none of this. The one exception is a referral code, if you followed a friend's referral link: we keep it only to credit that referral.

When you sign up, subscribe or cancel, our servers record that event against your account in PostHog (EU), to measure how our business is doing. We rely on our legitimate interests for this; you can object by emailing privacy@mostlytiny.io.

10. Emails we send you

We email you what you need to use MostlyQR: sign-in links, receipts, billing and security notices, and messages about your account. These are part of the service, so you cannot turn them off while your account is open.

We may also send you tips and offers about MostlyQR (onboarding tips, a note when you reach a free-plan limit, and a note if you cancel). The sign-up form has a box for these, ticked by default: untick it and we never send them. In the UK this is the "soft opt-in" in regulation 22 of the Privacy and Electronic Communications Regulations; our lawful basis under the UK GDPR is our legitimate interest in telling customers about the product they signed up for, and you can object at any time.

We email you about other Mostly Tiny products (MostlyPDF, MostlySign, MostlyPrivacy, MostlyRender and Vekta) only if you asked us to, by ticking a box that is never ticked for you, either when you sign up or later in a product. Our lawful basis is your consent. We send at most one such email a month across all of them.

Every marketing email says why you are getting it, has an unsubscribe link, and supports your email app's one-click unsubscribe button. One click stops that kind of email; the linked preferences page lets you choose exactly what you get, or stop all marketing email from every Mostly Tiny product at once. You can also change this in your Mostly Tiny account at id.mostlytiny.io/settings. Withdrawing is as easy as agreeing, and never affects service email.

To show we had your agreement, we record each choice: which box, the exact wording you saw, when, and a keyed one-way hash of your IP address. We store your choices against a one-way hash of your email address. If an address bounces permanently or a message is reported as spam, we stop all marketing email to it. Our do-not-email list keeps only that hash, never your address, so it continues to protect you after you close your account.

11. Our legal bases for processing

Where the EU or UK GDPR applies, we process your personal data on one or more lawful bases under Article 6: your consent; the performance of a contract with you; compliance with a legal obligation; protection of vital interests; the performance of a task in the public interest; or our legitimate interests (or those of a third party), except where overridden by your interests or rights.

Where we rely on legitimate interests, these include operating and securing our services, understanding how they are used, and limited marketing — you may object at any time. Where we process special categories of personal data under Article 9 (for example health or biometric data), we do so only with your explicit consent or another condition permitted by law.

12. Who we share your data with

We share personal data with: service providers and processors who operate mostlyqr.com on our behalf (for example Google Firebase and Google Cloud: hosting, sign-in, database, functions (where, see "Where your data is stored"); Cloudflare: security and approximate location for mqr.sh scan links; Stripe: payments; Fathom Analytics: cookie-free statistics; PostHog (EU): product analytics; Resend: email; Google Safe Browsing and Web Risk: malware/phishing checks on QR destinations; and our own Mostly Tiny services MostlyID, MostlyPrivacy, MostlyRender and Vekta; the unpkg and jsDelivr CDNs and Google Fonts, which serve code and fonts to your browser in the dashboard and so see its IP address), who may only use it on our instructions; professional advisers, payment providers, and law-enforcement or regulators where required; and parties to a corporate transaction such as a merger or acquisition. We do not sell your personal data for money.

13. Advertising and measuring our adverts

We may advertise MostlyQR on Google, on Microsoft Advertising (Bing, Microsoft Copilot and partner sites) and in ChatGPT. Only if you accept "Marketing" cookies do we load those platforms' tags and, when you arrive from one of our adverts, keep the click identifier the platform added to the link (gclid, gbraid or wbraid for Google; msclkid for Microsoft; oppref for ChatGPT).

If you then subscribe, we tell only the platform whose advert you clicked that it led to a purchase: the click identifier, the time, the value and currency, and — for matching — your email address as a one-way SHA-256 hash. We never send your raw email address, the QR codes you create or your scan data.

Our legal basis is your consent. You can withdraw it at any time in Cookie settings: we then delete the click identifier from your browser and report nothing further, including for a subscription that starts after you withdrew.

Google receives this data under the Google Ads Data Processing Terms (as our processor for enhanced conversions, and as an independent controller for its advertising services); Microsoft and OpenAI receive it as independent controllers. Their privacy notices: policies.google.com/privacy, privacy.microsoft.com/privacystatement and openai.com/policies/privacy-policy. All three are in the United States; transfers rely on the UK Extension to the EU-US Data Privacy Framework where the recipient is certified, and otherwise on the UK International Data Transfer Addendum to the EU Standard Contractual Clauses.

14. International data transfers

Some of our service providers are located outside your country, including outside the EEA, the UK or Australia. Where we transfer personal data internationally we rely on a lawful transfer mechanism — such as an adequacy decision, the EU Standard Contractual Clauses (with the UK International Data Transfer Addendum where relevant), or another safeguard permitted by law — and take steps to keep your data protected. Details are available on request at privacy@mostlytiny.io.

15. Where your data is stored

MostlyQR runs on Google Cloud and Firebase: database in the EU (eur3 multi-region: Belgium and the Netherlands, with a witness replica in Finland); server functions in the UK (europe-west2, London); uploaded logos, images and print assets in the United States (us-east1).

Sign-in uses Firebase Authentication, which Google runs only in the United States, and a Mostly Tiny account you sign in with is held by Mostly Tiny ID, whose database is in the United States. Our website is served from Google's global network (Firebase Hosting).

Transfers from the UK to the EU are approved under UK law, which treats transfers to EEA states as approved (Data Protection Act 2018, Schedule 21). Transfers to Google LLC in the United States rely on the UK Extension to the EU-US Data Privacy Framework (and, for data under the EU GDPR, on the EU-US Data Privacy Framework), to both of which Google LLC is certified. If you are in the EU, your personal data reaches our servers in the UK under the European Commission's adequacy decision for the UK (Implementing Decision (EU) 2021/1772, as amended by Implementing Decision (EU) 2025/2574).

16. How long we keep your data

We keep personal data only as long as necessary for the purposes described in this policy, after which we delete or anonymise it. The criteria we use to set retention periods include the nature and sensitivity of the data, the purpose of processing, and our legal, accounting and reporting obligations (account data until you delete your account; Batch QR details as set out in "Batch QR details"; scan analytics for the account's lifetime, within your plan's limits; how you arrived (if you consented) for the account's lifetime; billing records as tax law requires; and a reported advertising conversion for as long as the subscription it relates to).

17. How we protect your data

We use appropriate technical and organisational measures — including encryption in transit, access controls and regular review — to protect personal data against loss, misuse and unauthorised access. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

18. Cookies and similar technologies

We use cookies and similar technologies on mostlyqr.com. For the cookies we use, their purpose and duration, and how to control them, see our Cookie Policy.

19. Automated decision-making

We do not make decisions producing legal or similarly significant effects about you based solely on automated processing, including profiling, unless permitted by law. Where we ever do, we will tell you, explain the logic involved, and offer the right to obtain human review.

20. Children’s privacy

mostlyqr.com is not directed to children. We do not knowingly collect personal data from children below the age of digital consent that applies to them (16 under the GDPR, subject to lower national ages down to 13), and we do not knowingly sell or share the personal information of consumers we know to be under 16. If you believe a child has given us data, contact us at privacy@mostlytiny.io and we will delete it.

21. Your rights under the GDPR

If the EU or UK GDPR applies to you, you have the right to: be informed; access your personal data; have inaccurate data rectified; have your data erased; restrict processing; data portability; and object to processing, including to direct marketing. Where processing is based on consent, you may withdraw it at any time without affecting processing carried out beforehand.

To exercise any of these rights, contact us at privacy@mostlytiny.io. We will respond within one month, which we may extend by up to two further months for complex or numerous requests, telling you within the first month. You also have the right to lodge a complaint with your data protection supervisory authority.

22. UK supervisory authority

If you are in the UK, the UK GDPR and the Data Protection Act 2018 apply, and you may complain to the Information Commissioner’s Office (ICO) at ico.org.uk.

23. How to complain to us

If you are unhappy with how we have handled your personal data, email privacy@mostlytiny.io with "Complaint" in the subject. We will acknowledge your complaint within 30 days, look into it, and tell you the outcome without undue delay. You can also complain to the Information Commissioner's Office at any time.

24. If you are in the United States

We do not sell personal information. Measuring our adverts, described above, can count as "sharing" under some US state privacy laws; it happens only if you accept Marketing cookies, and we treat a Global Privacy Control signal from your browser as a refusal. To ask what we hold about you, or to have it corrected or deleted, email privacy@mostlytiny.io.

25. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version here with a new effective date and, where changes are significant, take reasonable steps to notify you.

26. Contact us

For any privacy question, request or complaint about how we handle your personal data, contact Mostly Tiny Ltd at privacy@mostlytiny.io.

Studio M, Hackney Depot, 5 Sheep Lane, London E8 4QS, United Kingdom