Privacy Notice for the BodyWision App and Website

1. Controller and contact

The controller is BodyWision GmbH, Alserstrasse 20/12, 1090 Vienna, Austria. Data protection enquiries: office@bodywision.com; technical support and data export: support@bodywision.com.

This notice applies to the app, website, in-app subscriptions and related communications. BodyWision serves to aid understanding, maintain personal health records and prepare for medical consultations; it does not replace medical advice, diagnosis or treatment.

2. What data we process and for what purposes

The Articles referred to below are Articles of the General Data Protection Regulation (GDPR).

The data originate from users, their records and integrations they have authorised, and, for purchases, from Apple or Google. Technical data are generated during use. Section 6 applies to family profiles.

Account and health data are also processed for manual record management under the free-of-charge BodyWision Free tier. Requested AI features require separate explicit consent under Section 4. Previous proofs of purchase may continue to be retained after a switch to Free in accordance with the retention rules in this notice.

Necessary account and operational data are required to provide the respective service. Providing an email address is voluntary; you can also register without providing your email address. Providing health information is voluntary. Without the necessary health information and consents, the relevant features are unavailable. A purchase or acceptance of the Terms does not replace consent. We do not carry out automated decision-making producing legal effects or similarly significantly affecting individuals within the meaning of Article 22 GDPR.

3. Encryption and storage

The health record is stored in encrypted form on the device. For cloud synchronisation and backups, its contents are transmitted and stored using end-to-end encryption; the keys are protected on the user's side. Unless you enable the option described below, the BodyWision team cannot view these stored record contents in plain text. This is distinct from the temporary AI processing described in Section 4 and the account and purchase data processed to operate the service.

The optional app setting labelled in German “Zusätzliche Hilfe durch BodyWision erlauben” (“Allow additional help from BodyWision”) activates the operator code. The “sichere Zugang zur Unterstützung bei der Wiederherstellung” described in the app (“secure access to assist with recovery”) enables BodyWision Support to reset your backup password when needed. This also makes it technically possible to log into your account and view the content accessible there, including health data. Enabling this option serves to restore access to your account and requires your explicit consent (Article 6(1)(a) and Article 9(2)(a) GDPR). You can change the option in the app settings.

The app infrastructure, stored health records, cloud synchronisation and backups are operated within the European Union (EU). Encryption in transit, access restrictions and access permission controls protect the processing.

4. AI processing and withdrawal of consent

For AI features, we use Microsoft Foundry (Azure), including Azure OpenAI, with processing in EU regions. For each request, selected record contents and contextual information are temporarily transmitted in plain text to the Azure service through the BodyWision backend. This context may be extensive; however, the entire record is not used. BodyWision does not transmit the contents directly to OpenAI.

During regular AI processing, inputs and responses are not stored by Azure as content logs or as persistent conversational memory. BodyWision does not store them permanently in its backend or use them for advertising, general product analytics or model training. Saved AI results form part of the encrypted record. Under its Azure terms, Microsoft does not use the contents to train general AI models without our express permission; we do not grant such permission.

Microsoft performs security checks to detect and investigate potential misuse. Where there are indications of breaches of usage rules, selected inputs and responses may be stored for abuse review and, where necessary, inspected by authorised Microsoft personnel in the European Economic Area (EEA). This review is not used for model training.

You can withdraw your AI consent in the app settings. This resets the app on your device, after which the app can no longer be used, including under BodyWision Free. No further AI requests will be made. This does not automatically cancel an existing store subscription.

You may request deletion of your account and associated data as described in Section 10.

5. Monthly and annual subscriptions through Apple and Google

Purchases, payments and subscription management take place exclusively through the Apple App Store or Google Play Store. BodyWision does not receive credit card or bank account details for payment processing. No additional subscription management service is used.

We store Pro status, expiry date and proof of purchase together with the BodyWision account, including any email address provided for that account. To verify purchases, we process transaction/order identifiers or verification tokens supplied by the store, product and subscription period details, and notifications of renewal, cancellation or refund. Depending on the proof of purchase, this may also include the price, currency and store country. These data are used to allocate and verify the entitlement to use the services.

Apple and Google process store, payment and device data as independent controllers under their respective privacy notices. BodyWision does not transmit health records or AI content to them for purchase processing. Account deletion and cancellation of a store subscription are separate processes.

6. Family profiles and Apple Health

Individual accounts are reserved for adults. For family profiles, we receive profile and health data from the person managing the profile. Processing requires valid explicit consent from the individual concerned or a person legally authorised to represent them for that purpose. Persons managing profiles must make this Privacy Notice available; our own information obligations remain unaffected. Individuals concerned may exercise their rights directly with us.

Apple Health/HealthKit data are processed only after access to the respective data categories has been authorised. This device permission can be revoked in the device settings and does not replace any required consent to health data or AI processing.

7. Website and usage analytics

We do not use external advertising or marketing tracking services in the app. Technical analysis follows data minimisation principles and uses aggregated data wherever possible. We do not use medical content for general product analytics or advertising.

The website is delivered and secured through Cloudflare. This involves processing, in particular, IP addresses, browser/device information, page views and access times. The legal basis is Article 6(1)(f), our legitimate interest in securely operating the website. Necessary storage of language and privacy preferences supports the requested use of the website (Section 165(3) of the Austrian Telecommunications Act 2021, TKG 2021). These settings remain stored locally until deleted, changed or technically renewed.

With consent, we use Google Analytics for audience measurement and Google Ads and Meta Pixel for campaign measurement. Google Ireland Limited and Meta Platforms Ireland Limited receive, in particular, online identifiers, technical connection data, page views, advertising referral information and interactions such as clicks on download links; they may combine these with their own data. The legal bases are Article 6(1)(a) GDPR and Section 165(3) TKG 2021. Optional services are activated only after consent has been given. Consent can be changed or withdrawn through the privacy settings.

Health records, in-app chats and AI content are not transmitted to these marketing services.

In Google Analytics, the configured retention period is two months for event data and 14 months for user data and key event data. New user activity restarts the retention period for the user identifier. Data whose retention period has expired are removed during the monthly deletion cycle; standard aggregated reports are not subject to these periods.

TikTok Pixel

With your consent, we use the TikTok Pixel on our general home, pricing and download pages to measure and improve our TikTok advertising. We record page visits and redirects to the Apple App Store or Google Play, including the selected platform. A store click does not establish an installation, registration or in-app purchase.

The providers are TikTok Technology Limited, The Sorting Office, Ropemaker Place, Dublin 2, D02 HD23, Ireland, and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, EC1A 9HP, United Kingdom. TikTok receives technical browser and device information, IP address, page address, referring page, and advertising and cookie identifiers. The click identifier ttclid may attribute a visit to an advertisement. TikTok may combine this information with its own data, such as a TikTok account, and use it to measure, optimise and personalise advertising.

Our configured events transmit only the store platform (iOS or Android) as an additional parameter. We do not transmit form values, contact details, health records, in-app chats or AI content through these events. The website does not use manual Advanced Matching.

The legal bases are your voluntary consent under Article 6(1)(a) GDPR and Section 165(3) TKG 2021. Without consent, the pixel is not loaded; the website and store links remain available. You may withdraw consent at any time through “Privacy settings” in the footer with effect for the future. We request fresh consent when adding TikTok.

TikTok may use first-party and third-party cookies, in particular _ttp, ttclid and ttcsid cookies. According to TikTok, these expire no later than 13 months after being set or last used. TikTok retains event data for a maximum of 18 months under its Business Products (Data) Terms.

Collection and transmission of event data and measurement reports are subject to joint controllership under Article 26 GDPR in accordance with Part B of TikTok's agreement. We are responsible in particular for information, consent and technical integration; TikTok enables data subject rights for the data it processes. TikTok acts as an independent controller for its further purposes. You may exercise your rights against either controller. Information about TikTok's processing, legal bases and rights is available in TikTok's Privacy Policy; TikTok can be contacted through its privacy form.

8. Newsletters and contact

For sending, statistical analysis and personalised communications in connection with newsletters and product information you have subscribed to, we process first and last names, email addresses, subscription, delivery and usage data, including individually attributable open and click tracking, and evidence of consent through Brevo. The legal bases are Article 6(1)(a) GDPR and Section 174 TKG 2021. You can unsubscribe using the unsubscribe link or by contacting us. Requested administrative communications are handled separately from advertising.

Newsletter data are not linked to the contents of your encrypted health record. Record contents and AI requests are not transmitted to Brevo. According to Brevo, its databases are stored within the EU.

Brevo automatically deletes transactional email logs after one month. Previews of new transactional emails are not stored. These settings do not apply generally to newsletter contacts and campaign histories.

Support addresses technical and organisational matters. Please do not send health records through ordinary email or WhatsApp. If you use the WhatsApp Business channel we offer, WhatsApp Ireland Limited also processes communications and usage data as an independent controller under its Privacy Policy. Email remains available as a contact channel.

9. Service providers and transfers to third countries

In addition to the providers mentioned above, contracted hosting, backup, IT security and email service providers receive the data necessary to perform their tasks. Processors are engaged in accordance with Article 28 GDPR. Public authorities and professional advisers subject to duties of confidentiality receive data only where required by law or necessary to establish, exercise or defend specific legal claims.

Website, communications and store services may involve processing data outside the EEA, in particular in the United States. Transfers by us require an applicable adequacy decision or appropriate safeguards, in particular EU standard contractual clauses together with any necessary supplementary measures. Copies of the safeguards used may be requested through our data protection contact. Processing by the stores as independent controllers is governed by their privacy notices.

TikTok describes global processing in its Privacy Policy, including servers in the United States, Malaysia and Singapore and limited remote access by group companies. TikTok states that it relies on applicable adequacy decisions or EU standard contractual clauses; copies may be requested through the privacy form referenced there. Processing is not limited to the EEA.

10. Retention, deletion and export

After 24 consecutive months of inactivity, we delete the account, its associated user data and the health record stored by BodyWision. Automatic deletion due to inactivity does not take place while a paid entitlement to use the services remains in force. The period runs from the last use of the app; each subsequent use restarts the period. For existing accounts, the period begins no earlier than the date on which this provision takes effect.

Rights to earlier erasure remain unaffected. Deletion may be requested through the app's contact feature or by email; a complete data export is also available without Pro through support@bodywision.com. Where necessary, we verify the requester's authority. Deleted content may remain for up to three months in encrypted backups that are unavailable for ongoing use, after which it is deleted or overwritten. Copies you have exported yourself are outside our control.

Only necessary evidence is retained beyond these periods: business records relevant for tax purposes are generally retained for seven years under Section 132 of the Austrian Federal Fiscal Code (BAO) (Article 6(1)(c)); evidence relating to specific legal claims is retained until it is no longer needed, in particular upon expiry of applicable limitation periods or conclusion of ongoing proceedings (Article 6(1)(f), legitimate interest in establishing, exercising and defending legal claims). For health data, an additional exception under Article 9 GDPR is required, in particular Article 9(2)(f). This does not justify a general extension of the retention period for the health record.

Support data are deleted once the enquiry has been resolved unless there is a specific need to retain evidence. Necessary records of consent and suppression are retained only for as long as required for accountability and to honour an unsubscribe request. Shorter technical retention periods are governed by the information in Sections 4, 7 and 8.

11. Your rights

Subject to the conditions of the GDPR, you have rights of access, rectification, erasure, restriction of processing and data portability. Consent may be withdrawn at any time with effect for the future; this does not affect the lawfulness of processing carried out before withdrawal. Requests may be sent to office@bodywision.com.

Right to object: You may object to processing based on legitimate interests on grounds relating to your particular situation. You may object to direct marketing at any time without giving reasons; that processing will then cease.

Complaints may be lodged with a data protection supervisory authority, in particular in the country of your habitual residence, place of work or the place of the alleged infringement. In Austria, this is the Austrian Data Protection Authority.

We will inform you of material changes as required by law. Any necessary new consent will be obtained separately; an amendment to this notice does not replace that consent.