Version privacy-policy@2026-08-09 · Effective [PLACEHOLDER]
[PLACEHOLDER — legal entity] (“OWN Health”, “we”) is the controller of the personal data described here (Art. 4(7) GDPR).
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.
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.
| Purpose | Art. 6 basis | Art. 9 basis |
|---|---|---|
| Create and run your account | Contract, Art. 6(1)(b) | — |
| Store and display your health record | Contract, Art. 6(1)(b) | Explicit consent, Art. 9(2)(a) |
| Risk scores, prevention plans, daily tasks | Contract, Art. 6(1)(b) | Explicit consent, Art. 9(2)(a) |
| Send data to AI providers for insights, chat, document reading | Consent, Art. 6(1)(a) | Explicit consent, Art. 9(2)(a) |
| Import metrics from Apple Health / Google Fit | Consent, Art. 6(1)(a) | Explicit consent, Art. 9(2)(a) |
| Health reminders and notifications | Contract, Art. 6(1)(b) | Explicit consent, Art. 9(2)(a) |
| Payments and subscriptions | Contract, Art. 6(1)(b) | — |
| Accounting records | Legal obligation, Art. 6(1)(c) | — |
| Marketing email | Consent, Art. 6(1)(a) | — |
| Product analytics | Consent, Art. 6(1)(a) | — |
| Security and abuse prevention | Legitimate 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.
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.
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):
| Recipient | For | Location |
|---|---|---|
| Amazon Web Services | Hosting, database, file storage | European Union |
| OpenAI | AI insights, chat, reading uploaded documents | United States |
| Google / Firebase | Push notifications, Google sign-in | United States |
| Apple | Sign in with Apple | United States |
| SendGrid | United States | |
| RevenueCat | Subscriptions | United States |
| ElevenLabs | Voice features | United 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.
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.
| Data | Kept for |
|---|---|
| Your account and health record | While your account exists |
| After you delete your account | Erased within 14 days |
| Login sessions | 45 days; 7 days after sign-out |
| Notification delivery records | 90 days |
| Health reminder history | 180 days |
| AI usage records | Linked to you 180 days, then anonymised |
| Payment and accounting records | As tax law requires, identity removed |
| Data export archives | 48 hours |
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).
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.
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.