Privacy Policy

Version privacy-policy@2026-08-09 · Effective [PLACEHOLDER]

1. Who we are

[PLACEHOLDER — legal entity] (“OWN Health”, “we”) is the controller of the personal data described here (Art. 4(7) GDPR).

2. What this app does with your health

OWN Health reads the health information you give us and the metrics your phone or watch records, and uses them to estimate your risk for specific conditions, suggest daily actions, and answer your questions. Some of that work is done by artificial intelligence systems operated by a company in the United States.

None of it is medical advice or a diagnosis. It does not replace a doctor.

3. What we collect

Identity and account. Email, name, password (stored only as a cryptographic hash), the identifier your Apple or Google account gives us, language, time zone, device details, and the IP address and browser agent of your sessions.

Health data — special category under Art. 9(1). Date of birth, gender, ethnicity, pregnancy status, height and weight; diagnosed conditions and ICD-10 codes, allergies, chronic illnesses, family history; medication and dosage, vaccinations, check-ups, insurance; symptoms you log; laboratory reports you upload and every biomarker extracted from them; metrics imported from Apple Health or Google Fit; your journal entries, questionnaire answers and conversations with our AI assistant.

Ethnicity also reveals racial or ethnic origin. We collect it only because several risk models are calibrated by ethnic group. You may leave it blank.

Usage and technical. Notification tokens and delivery records, login streaks, subscription and payment records, referral codes, request and error logs.

4. Why we process it, and on what legal basis

PurposeArt. 6 basisArt. 9 basis
Create and run your accountContract, Art. 6(1)(b)
Store and display your health recordContract, Art. 6(1)(b)Explicit consent, Art. 9(2)(a)
Risk scores, prevention plans, daily tasksContract, Art. 6(1)(b)Explicit consent, Art. 9(2)(a)
Send data to AI providers for insights, chat, document readingConsent, Art. 6(1)(a)Explicit consent, Art. 9(2)(a)
Import metrics from Apple Health / Google FitConsent, Art. 6(1)(a)Explicit consent, Art. 9(2)(a)
Health reminders and notificationsContract, Art. 6(1)(b)Explicit consent, Art. 9(2)(a)
Payments and subscriptionsContract, Art. 6(1)(b)
Accounting recordsLegal obligation, Art. 6(1)(c)
Marketing emailConsent, Art. 6(1)(a)
Product analyticsConsent, Art. 6(1)(a)
Security and abuse preventionLegitimate interests, Art. 6(1)(f)

Legitimate interests assessment for security logging. We keep session and request records to detect account takeover and abuse. The data identifies a session rather than a person’s health, is kept for a short defined period, and users reasonably expect a health app to defend their account. We consider this not overridden by your rights. You may object under Art. 21.

Withdrawing consent stops the purpose it covered, without affecting what we did lawfully before (Art. 7(3)). Withdraw any optional purpose in the app’s privacy settings; it takes effect at once. The three required purposes cannot be withdrawn while the account exists, because the product does not function without them — deleting your account withdraws them all.

5. Automated processing

We calculate condition risk scores and daily recommendations automatically, and AI systems write insights and answer your questions. These produce information and suggestions for you. They do not make decisions with legal or similarly significant effects: nothing here determines access to insurance, credit, employment or treatment, and we do not share scores with insurers or employers. You can ask us to explain any score and to have a person review it.

6. Who we share it with

We do not sell your personal data, and we do not share it with insurers, employers or advertisers. We use these service providers, each acting on our instructions under a contract required by Art. 28(3):

RecipientForLocation
Amazon Web ServicesHosting, database, file storageEuropean Union
OpenAIAI insights, chat, reading uploaded documentsUnited States
Google / FirebasePush notifications, Google sign-inUnited States
AppleSign in with AppleUnited States
SendGridEmailUnited States
RevenueCatSubscriptionsUnited States
ElevenLabsVoice featuresUnited States

Transfers outside the EEA. Your health data is stored in the European Union. Some of it is transferred to the United States when AI features process it, relying on [PLACEHOLDER — EU–US Data Privacy Framework adequacy decision under Art. 45 and/or Standard Contractual Clauses under Art. 46(2)(c)]. You may request a copy of the safeguards. If you refuse the AI processing purpose, your data is not sent to the United States for it.

7. Your rights

We answer within one month (Art. 12(3)), free of charge. Complex requests may take up to three months; we will tell you within the first month if so.

8. How long we keep it

DataKept for
Your account and health recordWhile your account exists
After you delete your accountErased within 14 days
Login sessions45 days; 7 days after sign-out
Notification delivery records90 days
Health reminder history180 days
AI usage recordsLinked to you 180 days, then anonymised
Payment and accounting recordsAs tax law requires, identity removed
Data export archives48 hours

9. How we protect it

Encryption in transit and at rest, an isolated database reachable only from the application, hashed passwords and session tokens, encrypted notification tokens, least-privilege access, and an audit record of every staff access to an individual’s data (Art. 32).

10. Children

OWN Health is not for people under [PLACEHOLDER — 16, or the age set by your Member State; Art. 8 permits 13–16]. We do not knowingly collect their data. Tell us if a child has registered and we will delete the account.

11. Changes

We will tell you before a material change takes effect and ask again for any consent it affects. The version at the top identifies the text you agreed to.