Privacy policy Wellbeinn
1. Identity of the data controller
- Company name: Wellbeinn Performance, S.L. (hereinafter, "Wellbeinn").
- Tax ID (CIF): B-16407355
- Registered office: P.I. Les Pedreres C/ Primer de maig 11, 03610 Petrer, Alicante, Spain.
- Company registration: Commercial Registry of Alicante, Sheet A-199979, IRUS 1000444260360, Electronic Folio Entry 3
- Data protection contact: privacy@wellbeinn.com
Wellbeinn complies with Regulation (EU) 2016/679 ("GDPR") and with Spain's Organic Law 3/2018, of 5 December ("LOPDGDD").
2. Scope and informational nature
This Policy is informational in nature and describes how Wellbeinn processes personal data in connection with:
- The Wellbeinn mobile application for iOS and Android (the "App").
- The use of the Wellbeinn V8 wearable and other connected devices in the Wellbeinn ecosystem, which communicate with the App via Bluetooth Low Energy (BLE).
- The wellbeinn.com website in relation to registration, support and account communications.
Reading this Policy does not, on its own, replace or constitute the explicit consent required for the processing of health data. Such consent is obtained through a separate, specific and unambiguous affirmative action within the App.
Wellbeinn retains evidence of consent given and of its withdrawal, including user identifier, date and time, exact version of the text accepted, language and authorised purposes (Art. 7.1 GDPR), in accordance with the retention periods in §6.
Express statement. Wellbeinn does not sell your personal data, does not share them with data brokers or advertising networks and does not use them for third-party advertising. The only disclosures to third parties envisaged in this Policy are (i) the data processors listed in §7, who act on our instructions, and (ii) organisations you expressly authorise on a case-by-case basis pursuant to §7 bis.
3. Personal data we process
3.1 Identity and account data
First name and surname, email address, password (stored as a one-way hash managed by our identity provider; Wellbeinn does not access the plaintext), optional profile photo, federated sign-in identifiers when you choose to register with Google, and a unique internal identifier assigned by our system.
We also process the status of the personalisation options you enable (§4 bis.2) and of the authorisations to organisations you grant (§4 bis.4), viewable from Profile → Legal & Privacy.
3.2 Health-related data — special category (Art. 9 GDPR)
Through the Wellbeinn V8 wearable, other connected devices and data you provide to calibrate the service, we process biophysiological and activity information: cardiovascular metrics (heart rate and variability, HRV/RMSSD), sleep and rest data, oxygenation and skin temperature indicators, physical activity parameters, and a basic health profile (date of birth, biological sex, weight and height). This list is indicative: the App may process these and other similar wellness and health data within the purposes described in this Policy, with the same legal classification and level of protection.
The derived indicators the App calculates from these data — sleep quality, recovery, vitality, activation, stress, sleep efficiency and other aggregate physiological-state indicators — are likewise considered health-related data (Art. 9 GDPR) and receive the same reinforced level of protection, legal basis and retention periods as the raw data.
These data are stored at high temporal resolution because this is necessary to compute the indicators the App offers you, and they are kept in your personal account. They are not disclosed to third parties unless you expressly authorise it through the function described in §7 bis. They are deleted in accordance with §6.
Wellbeinn does not process biometric data within the meaning of Art. 4.14 GDPR.
3.3 Device data
Device identifier, model and firmware version, Bluetooth identifier (on Android this may be a persistent public MAC address; on iOS it is typically a rotating UUID issued by the operating system), battery status and connection/disconnection events.
3.4 Technical and usage data
App installation identifier, operating system and version, phone model and device language, technical error and event logs, and timestamps of actions performed within the App.
Note on advertising tracking and analytics. The App does not integrate third-party advertising analytics SDKs: we do not carry out advertising profiling, we do not share data with advertising networks and we do not use third-party cookies. We do use product analytics tools (Amplitude) and stability/observability diagnostics tools (Firebase Crashlytics), described in §7, for the purpose of improving the App and never for advertising purposes. Product analytics (Amplitude) is activated only with the consent of Option 2 "Personalisation and analytical improvement" (§4 bis.2); crash diagnostics (Firebase Crashlytics) is carried out on the basis of legitimate interest (Art. 6.1.f) in ensuring the stability and security of the service. We do not build profiles for third-party advertising purposes and we do not share your data with advertisers. If you enable Option 3 (§4 bis.2), we use a segment tag derived from your indicators to personalise our own commercial communications; that processing is described in full in that Option.
3.5 Data derived from use of the AI Coach assistant
When you use the conversational assistant described in §7 ter, we process the content of your queries and the generated responses, together with the indicators from your account used as context to produce the response.
The retention period for these conversations is set out in §6.
Data you declare to the assistant (§3.5): limitation, goal, context and preferences. Retained for as long as you keep your account open or until you modify or delete them, with reconfirmation every 12 months.
3.6 Archetype and segment tag
Based on your derived indicators, the App assigns you an archetype (a wellness-behaviour group) and a segment tag. Both derive from health data and receive the same level of protection under Art. 9 GDPR.
They are only used for commercial communication purposes if you expressly enable Option 3 (§4 bis.2).
4. Legal bases for processing
| Data category / processing | Legal basis | Reference |
|---|---|---|
| Identity, account, device, technical | Performance of a contract | Art. 6.1.b GDPR |
| Health data (Art. 9), including derived indicators — core service | Explicit consent | Arts. 6.1.a and 9.2.a GDPR |
| AI Coach assistant (§7 ter) | Performance of a contract + explicit consent for the health data used as context | Arts. 6.1.b, 6.1.a and 9.2.a GDPR |
| Commercial communications without health data (Option 1) | Separate and revocable consent | Art. 6.1.a GDPR + Art. 21 LSSI |
| Personalisation and analytical improvement (Option 2) | Separate and revocable consent | Arts. 6.1.a and 9.2.a GDPR |
| Communications based on health data (Option 3) | Separate and revocable explicit consent | Arts. 6.1.a and 9.2.a GDPR + Art. 21 LSSI |
| Disclosure to authorised organisations (§7 bis) | Explicit, organisation-specific and revocable consent | Arts. 6.1.a and 9.2.a GDPR |
| Support and legal obligations | Legal obligation / legitimate interest | Arts. 6.1.c and 6.1.f GDPR |
| Retention of consent evidence | Duty to demonstrate consent | Art. 7.1 GDPR |
Explicit consent for health data is requested in a separate and unambiguous manner within the App, distinct from acceptance of the Terms and Conditions. You may withdraw it at any time, without this implying closure of your account and without affecting the lawfulness of prior processing (Art. 7.3 GDPR). Withdrawal will result in the immediate suspension of the capture of new health data and, at your choice, the retention or deletion of those already stored.
4 bis. Mandatory acceptances, options and authorisations
Wellbeinn applies the principles of Art. 4.11 and Art. 7.4 GDPR: consent must be freely given, specific, informed and unambiguous, and consents for different purposes are collected separately.
4 bis.1 Mandatory acceptances
| # | Acceptance | Legal basis |
|---|---|---|
| 1 | Terms and Conditions of Service | Art. 6.1.b GDPR |
| 2 | Privacy Policy | Arts. 13 and 14 GDPR |
| 3 | Explicit consent for the processing of health data | Arts. 6.1.a and 9.2.a GDPR |
Refusal of any of the three prevents use of the App. This is not an abusive condition: the nature of the service — a companion app for a physiological measurement device — makes it materially impossible to operate without processing health data.
No other acceptance is a condition of access to the service. You may use the App with all options in §4 bis.2 disabled and without any authorisation under §4 bis.4.
4 bis.2 Personalisation options
These are strictly voluntary and do not condition the use of the App. They are presented as separate checkboxes, in their own block, after the mandatory acceptances, and are disabled by default. You may enable or disable them at any time from Profile → Legal & Privacy, without penalty or loss of functionality.
Option 1 — Marketing communications
"I would like to receive personalised wellness tips and Wellbeinn news by email."
- Legal basis: Art. 6.1.a GDPR + Art. 21 LSSI.
- Purpose: sending commercial communications with wellness tips, product news and offers from the Wellbeinn ecosystem.
- Data used: account identifiers and email address. With this option alone, your health data are not used to segment mailings. If you wish to receive communications tailored to your indicators, you must also enable Option 3.
- Withdrawal: from Profile → Legal & Privacy or via the unsubscribe link in each communication.
- Effect on the service: none.
Option 2 — Personalisation and product improvement
"I would like to help Wellbeinn improve my experience by analysing how I use the App, on an aggregate basis, without my data being shared with third parties for analytics purposes."
- Legal basis: Arts. 6.1.a and 9.2.a GDPR.
- Purpose: aggregate analysis of App usage and derived-indicator behaviour to improve the service, calibrate algorithms and study internal cohorts.
- Data used: derived indicators and App usage patterns.
- Scope: analyses are carried out exclusively on internal cohorts and their results are not disclosed to third parties. They are not used to draw conclusions about individual users. This option is independent of sharing with organisations (§7 bis).
- Withdrawal: from Profile → Legal & Privacy. This will stop the inclusion of new data in analyses.
- Effect on the service: none.
Option 3 — Communications based on my health data
"I agree that Wellbeinn may use my health data to send me personalised communications and campaigns. This is optional and I can unsubscribe at any time."
- Legal basis: Arts. 6.1.a and 9.2.a GDPR (explicit consent for a special category) + Art. 21 LSSI.
- Relationship with Option 1: this option only determines how communications are personalised, not whether they are sent. If Option 1 is disabled you will not receive commercial communications, so this option will have no effect.
- Not offered to users under 18 (§10).
- Purpose: to tailor the content, timing and frequency of our commercial communications to your wellness profile, so that you receive content relevant to your specific situation rather than generic communications.
- Data used: your email address, your internal account identifier, the archetype the App assigns to you and the segment tag derived from your indicators (§3.6).
- How the archetype is generated: through automated processing of your derived indicators that assigns you to a behaviour group. This constitutes profiling (Art. 4.4 GDPR) and does not produce legal effects or significantly affect you (Art. 22 GDPR): its only effect is which commercial communication you receive.
- Who runs the campaign: the Wellbeinn marketing team, through the platform identified in §7, which processes the data on behalf of Wellbeinn as a data processor (Art. 28 GDPR).
- Withdrawal: from Profile → Legal & Privacy or via the unsubscribe link in each communication. This stops the sending of new segmented communications and the transmission of new tags to the campaign pipeline. Data already transmitted are deleted in accordance with §6.
- Effect on the service: none. Disabling this option does not condition access to any functionality or any commercial offer.
4 bis.3 Without active options
If you do not enable any personalisation option, your health data will be processed solely to provide the core service: receiving, storing and displaying your metrics and derived indicators, and responding to your AI Coach queries. The legal basis combines Art. 6.1.b and Art. 9.2.a GDPR (mandatory acceptance no. 3).
4 bis.4 Authorisations to organisations
Authorisations for an organisation to access your data (§7 bis) do not form part of the personalisation options block and are not requested during registration. They are granted one by one, at your initiative, and require you to expressly select which types of data you make available to that particular organisation.
Each authorisation constitutes an independent consent (Arts. 6.1.a and 9.2.a GDPR), is recorded separately and is revoked separately.
5. Purposes of processing
- Provide the core service: receive, store and display your physiological, health and activity metrics.
- Calculate derived indicators from raw device data (see §5 bis).
- Pair and maintain the connection with your devices.
- Manage your account: registration, authentication, password recovery.
- Handle your support requests and incidents.
- Improve our products through aggregate analysis (only if you enable Option 2, §5.6).
- Comply with legal obligations.
- Provide the AI Coach assistant (§7 ter).
- Personalise our commercial communications (only if you enable Option 3).
- Make certain data available to an organisation you authorise, when that functionality is available (§7 bis).
- Retain evidence of consents given and withdrawn (Art. 7.1 GDPR).
5 bis. Derived indicators, profiling and non-medical nature
The indicators for sleep quality, recovery, vitality, activation, stress and other aggregate physiological-state indicators are calculated through automated processing of your health data, which constitutes profiling of physiological state (Art. 4.4 GDPR). They are governed by the same legal basis as the raw data.
These calculations do not make decisions that produce legal effects or significantly affect you (Art. 22 GDPR): they are personal information displayed on your device. They are only used to personalise commercial communications if you expressly enable Option 3, and they are never disclosed to third-party advertising networks.
On ceasing this processing. It is inseparable from the provision of the service: without it, the App cannot offer its core functionality. If you wish to cease it, the options are to stop using the App or to delete your account, which entails the deletion of the associated data in accordance with §6.
The App and devices in the Wellbeinn ecosystem are not medical devices within the meaning of Regulation (EU) 2017/745 (MDR). They are not intended to diagnose, prevent, clinically monitor, treat or alleviate diseases, and they do not replace the judgement of a healthcare professional. If you experience any symptoms or have health concerns, please consult a doctor.
5.6. Scope of the Option 2 analysis
The analysis referred to in purpose 6 — which is only carried out if you enable Option 2 — is performed on an aggregate basis, on internal cohorts, and is not used to draw conclusions about individual users.
Statistical results that are effectively anonymous within the meaning of Recital 26 GDPR, because they do not reasonably allow re-identification, may be retained after the exercise of the right to erasure, since they are no longer personal data. Any results that do not meet this condition are deleted along with the rest of your data.
If in the future Wellbeinn wishes to process pseudonymised data for secondary research or statistical purposes, it will do so only on the basis of additional specific consent or of the safeguards of Art. 89 GDPR, subject to a prior Data Protection Impact Assessment and a defined retention period, and will inform you beforehand.
6. Retention periods
| Data | Period |
|---|---|
| Active account data | For as long as you keep your account open |
| Health and device data associated with the account | For as long as you keep your account open |
| After an account deletion request | Deletion within a maximum of 30 calendar days |
| Technical and access logs | 12 months, on the basis of legitimate interest in the security and integrity of the service (Art. 6.1.f GDPR) |
| Archetype and segment tag in the campaign pipeline | For as long as Option 3 is active. Deletion within 30 calendar days of deactivation or account deletion |
| Authorisations to organisations (organisation, scope, activation, revocation) | For as long as the authorisation is active + 4 years as evidence of consent |
| AI Coach conversation history | Maximum 12 months from each conversation |
| Consent audit log (version accepted, date and time, language, purposes, withdrawals) | 4 years from withdrawal of consent or from account deletion (Art. 7.1 GDPR) |
Cross-conversation context memory. To avoid asking you again what you have already told it, and to avoid suggesting activity incompatible with a limitation you have declared, the assistant retains a limited set of data that you expressly declare: a physical or activity limitation, your goal in your own words, your life context and your preferences.
Only what you expressly declare is retained: the assistant does not infer or record its own conclusions about your health from the conversation. You can view, modify or delete these at any time from the App. The retention period is set out in §6.
Once the retention periods have elapsed, data are deleted or irreversibly anonymised.
Why the consent log survives account deletion. If we also deleted the evidence that you consented, we would be unable to demonstrate to you or to the supervisory authority that the processing was lawful. This log contains only the consent trail — identifier, date, version, purposes — not your health data, which are deleted within 30 days.
Note on the service model. The service is currently free of charge and without in-app purchases. Wellbeinn may introduce a paid subscription model in the future; this does not alter the retention periods described herein.
7. Processors, independent controllers and sub-processors
| Provider | Service | Role | Location |
|---|---|---|---|
| Google Ireland Limited (Firebase / Google Cloud) | Authentication, Firestore, Storage, Cloud Functions and Cloud Logging | Processor (Art. 28 GDPR) | European Economic Area — region europe-west3
|
| Google LLC | "Sign in with Google" | Independent controller of the identity service | USA — Adequacy Decision 2023/1795 (EU-US Data Privacy Framework) |
| Language model provider | Generation of AI Coach assistant responses (§7 ter) | Processor (Art. 28 GDPR) | Outside the European Economic Area, with the safeguards indicated in §8 |
| Amplitude, Inc. | Product usage analytics (aggregate usage events), activated only with the consent of Option 2 "Personalisation and analytical improvement" (§4 bis.2) | Processor (Art. 28 GDPR) | USA — Adequacy Decision 2023/1795 (EU-US Data Privacy Framework); alternatively Standard Contractual Clauses (Decision 2021/914) |
| Google Ireland Limited / Google LLC (Firebase Crashlytics) | Crash reports and App stability diagnostics (technical error logs), on the basis of legitimate interest (Art. 6.1.f) | Processor (Art. 28 GDPR) | USA — Adequacy Decision 2023/1795 (EU-US Data Privacy Framework); alternatively Standard Contractual Clauses (Decision 2021/914) |
| Klaviyo, Inc. | Sending and segmentation of commercial communications (Options 1 and 3) | Processor (Art. 28 GDPR) | USA — Adequacy Decision 2023/1795 (EU-US Data Privacy Framework) and Standard Contractual Clauses |
| User-authorised organisations | Access to data the user authorises them to access (§7 bis) | Independent data controller | Depending on each organisation; disclosed to you before you grant authorisation |
Data measured by the Wellbeinn V8 wearable are transmitted locally via Bluetooth between the device and your phone.
What it remembers. In addition to the conversation history (§6), the assistant uses as context the data you have declared pursuant to §3.5. It does not retain its own inferences or clinical labels.
For transfers to third countries without an adequacy decision we apply the Standard Contractual Clauses (Decision 2021/914) together with the necessary supplementary measures in accordance with the Recommendations 01/2020 of the European Data Protection Board.
7 bis. Sharing with organisations authorised by you
This functionality is not currently available in the App. When it is activated, it will operate as described below, and this Policy will be updated to reflect its launch.
The App will allow you to authorise an organisation — sports club, coach, healthcare professional, company or other entity — to access certain data in your account. The function will be strictly voluntary, disabled by default and activated solely at your initiative.
How it will work. From the "Add access" screen you will enter a code or scan a QR code provided by the organisation. You will be shown who that organisation is and why it is requesting your data, and you will select which types of data you wish to make available to it (for example: sleep and rest, recovery, physical activity). The authorisation will not take effect until you confirm it.
Who will receive the data and in what capacity. The organisation you authorise will act as an independent data controller: it will determine on its own account what it uses the data for and will be accountable for that use to you and to the supervisory authorities. Wellbeinn will not give it instructions or control that subsequent use.
Before enabling any access, Wellbeinn will enter into a contract with each organisation requiring it to: limit use to the stated purpose, apply appropriate security measures, not reuse the data for other purposes, not disclose them to third parties, address the rights you exercise before it, notify any security breach and delete the data upon termination of the relationship or upon your revocation of the authorisation.
Legal basis. Your explicit consent, specific to each organisation (Arts. 6.1.a and 9.2.a GDPR). It will not be a blanket consent and will not be requested during registration.
What data will be shared. Only the types you have selected. Types you have not selected will not be shared, nor will your identity data beyond the name associated with your account, nor the content of your conversations with the AI Coach.
How to revoke. You may revoke any authorisation at any time from the App. Revocation will take effect immediately: the organisation will no longer be able to access your data and will be contractually required to delete any downloaded data within a maximum of 30 days. Revocation will not affect the lawfulness of prior access (Art. 7.3 GDPR) and will have no effect on your account.
Record-keeping. Wellbeinn will retain evidence of each authorisation and each revocation (user identifier, organisation, data types, date and time, version of the text accepted) in accordance with §6.
7 ter. Conversational assistant (AI Coach)
The App incorporates a conversational assistant that answers your queries about wellness, rest and training.
How it works. When you submit a query, Wellbeinn transmits to the language model provider identified in §7 the text of your query and the account data necessary to contextualise the response, limited to the minimum required for that purpose.
Role of the provider. It acts as a data processor (Art. 28 GDPR): it processes the data on behalf of Wellbeinn and in accordance with our instructions, without being able to use them for its own purposes.
Important limitation. AI Coach responses are for guidance and general information only. They do not constitute medical advice, diagnosis or prescription, may contain errors and do not replace the judgement of a healthcare professional. The disclaimer in §5 bis applies in full.
Your conversation data. See §3.5 and §6.
8. International transfers
As a general rule, your data are stored on servers located in the European Economic Area.
Where a provider processes data from the USA — the federated identity provider, the language model provider and the campaign platform — the transfer basis will be, as a preference, the Adequacy Decision 2023/1795 (EU-US Data Privacy Framework), to the extent that the provider is certified under the framework. Alternatively, and for third countries without an adequacy decision, the Standard Contractual Clauses (Decision 2021/914) will apply with the necessary supplementary measures.
Organisations outside the European Economic Area (§7 bis). When the functionality is available and an organisation is established in a third country, Wellbeinn will arrange the transfer through Standard Contractual Clauses incorporated into the contract with that organisation.
If exceptionally it is not possible to apply such safeguards, the transfer may only rely on your explicit consent under Art. 49.1.a GDPR, in which case you will be expressly informed, before giving it, that the destination country does not have an adequacy decision or adequate safeguards, and of the risks this entails for your data: among others, the possible absence of an independent supervisory authority, of effective rights of access and rectification and of judicial remedies equivalent to those in the European Economic Area.
9. Your rights
You may exercise the following rights:
- Access to the data we process about you.
- Rectification of inaccurate or incomplete data.
- Erasure ("right to be forgotten"), subject to the exceptions in Art. 17.3 GDPR.
- Objection to processing. For derived indicators, see §5 bis.
- Restriction of processing.
- Portability in a structured, commonly used and machine-readable format.
- Not to be subject to automated individual decision-making with significant effects (Art. 22 GDPR).
- Withdraw consent given for the processing of health data, for any personalisation option or for any authorisation to an organisation, without retroactive effect and at no cost.
9.1 How to exercise your rights
Exercise is free of charge (Art. 12.5 GDPR).
- From the App: in Profile → Legal & Privacy you can view the version of the documents you have accepted and enable or disable each personalisation option. From your account settings you can request account deletion.
- By email to privacy@wellbeinn.com, stating the right you wish to exercise. To verify your identity we will preferably use the email address associated with your account. Only if there are reasonable doubts (Art. 12.6 GDPR) may we request additional, proportionate and minimal information; a copy of your ID is not required by default.
We will respond within a maximum of one month, extendable by a further two months in complex cases, informing you of the extension and its reasons (Art. 12.3 GDPR).
9.2 Complaint to the supervisory authority
You may lodge a complaint with the Spanish Data Protection Agency (AEPD), C/ Jorge Juan 6, 28001 Madrid — www.aepd.es.
If you reside in another EU Member State, you may also lodge a complaint with the supervisory authority in your country of residence.
10. Minors
Wellbeinn requires a minimum age of 16 to use the App.
Although Art. 7 LOPDGDD sets the default legal threshold at 14, Wellbeinn applies a more conservative policy of 16 for consistency with the more restrictive regulations of other Member States and as a precaution given the sensitivity of the data processed.
Commercial communications based on health data. Option 3 (§4 bis.2) is not offered to users under 18. Users aged 16 to 18 may use the App normally and enable Options 1 and 2, but their health data will not be used to segment commercial communications.
If we detect that a minor below the applicable threshold has registered: (i) we will suspend the account immediately, (ii) we will request parental verification through a secure channel, and (iii) we will delete the account and associated data if verification is not completed within 30 days.
11. Data security
We apply technical and organisational measures appropriate to the level of risk, including but not limited to:
- Encryption of communications in transit (TLS 1.2+).
- Encryption at rest on storage servers.
- Granular security rules that allow each user to read and write only their own information (access control by user identifier).
- Storage of credentials using one-way hash functions managed by the identity provider.
- Audit log of consents given and withdrawn in the App, including the exact version of the text accepted.
In the event of a security incident affecting your data and posing a high risk to your rights, we will notify you without undue delay (Art. 34 GDPR), by email and/or in-app message, indicating the nature of the breach, the approximate categories and volumes of data affected, the likely consequences and the measures taken. We will report the breach to the AEPD within 72 hours (Art. 33 GDPR).
12. Cookies and identifiers
The App does not use cookies or equivalent advertising tracking technologies. Only strictly necessary technical identifiers are used (session token, installation identifier). The wellbeinn.com website may use session cookies and, where applicable, measurement cookies, in accordance with the site's cookie policy.
13. Changes to this Policy
We may update this Policy to reflect legal or technical changes. The version and date are shown in §14, and the history in §15.
Material changes include, among others: the incorporation of new categories of data, the introduction of new processors or sub-processors in third countries, the modification of purposes or legal bases and changes affecting your rights.
When we publish a version with material changes, the App will show you an acceptance screen on your next login. You will need to accept the three mandatory items in §4 bis.1 again to continue using the service; the voluntary options will be offered again, but you may continue without enabling any of them.
14. Version and date
- Version: 1.0.7
- Effective date: 2 September 2026
- Available languages: Spanish, English. The English version is a courtesy translation; in the event of any discrepancy, and unless the consumer protection laws of the user's country of residence provide otherwise, the Spanish version shall prevail.
15. Version history
| Version | Date | Material changes |
|---|---|---|
| 1.0.7 | 02/09/2026 | New paragraph in §3.5 on the assistant's context memory (data declared by the user: limitation, goal, context and preferences). New row in §6 for the retention period of such data. New block in §7 ter detailing what the assistant remembers and that it does not retain its own inferences or clinical labels. |
| 1.0.6 | 19/08/2026 | New Option 3 (communications based on health data). New section on sharing with organisations (§7 bis, functionality not yet available). New AI Coach assistant section (§7 ter). Expansion of the processors table. New retention periods. Correction of clauses that stated non-sharing with third parties and absence of profiling. |
| 1.0.5 | 29/04/2026 | Previous version |
