Privacy Policy

Version 1.1, dated 19 September 2026

1. About this policy

GetWella is a health tracking and personalised wellbeing insights service. This policy describes what personal data is processed when you use the service, for what purposes, on what legal basis, and for how long.

It describes the service as it actually operates on the date above, and is updated when the processing changes.

This policy is published in English and German. When the app or website is set to Arabic, French, Portuguese, Russian or Spanish, the English version is shown.

2. Controller and contact

⚠️ Interim statement. The full identification of the controller within the meaning of Art. 4(7) GDPR is being finalised and will be completed in this policy.

GetWella is a health tracking and personalised wellbeing insights service. For privacy questions, requests, and to exercise your rights, contact the GetWella Team at support@getwella.com.

3. What data we process

Account data. Email address and a cryptographically hashed password. The password is never stored in plain text. If you sign in with Apple or Google, the name and email address that service provides (with Apple, this may be a private relay address).

Profile data. Name, date of birth, gender, language preference, country, and onboarding answers about goals and preferences.

Health data. Daily entries covering energy, stress, sleep duration and quality, mood, weight, waist measurement, meals, cravings, symptoms, cycle-related information, and free-text notes.

Fasting data. Start, end, duration, difficulty rating and notes for fasting periods.

Device data from Apple Health. Only if you actively connect it — see section 7.

Meal photos. If you use photo meal identification, the photo you take. It is sent through our server to OpenAI to identify the meal (section 8). GetWella does not store the photo.

Food searches and barcodes. When you scan a barcode or search for a food, the barcode number or the words you search for, with your app language and country, are sent from your device to Open Food Facts (section 9).

AI conversation data. Your questions to the AI companion and the answers generated in response.

Photo identification count. A record that you used photo meal identification — your account identifier and the time — used only to apply the daily limit.

Device and connection data. Your device's IP address, identifiers for your installation of the app, your device model, operating system, app version and language settings, as received by the services the app contacts in order to work — see sections 9 and 14.

Consent records. The time, subject and version of consents you give or withdraw.

Communication preferences. Your settings for service and product email.

Payment-related data. Subscription status. Full card details are never stored on GetWella systems; they are processed solely by Stripe.

Usage data. On the website only: pages visited and features used, in a privacy-configured form — see sections 9 and 14.

4. Purposes

• Providing, operating and securing the service, including your account and sign-in
• Displaying your own entries and their history
• Detecting relationships in your data and producing personalised insights
• Answering your questions and identifying meals from photos through the AI-assisted features — where you have agreed to it (section 8)
• Looking up food information when you scan a barcode or search for a food
• Limiting photo meal identification to a daily number of uses, because each use has a cost
• Delivering updates to the app
• Sending necessary service messages and — where you have separately consented — product email
• Handling subscriptions and payments, where enabled
• Improving the quality, reliability and clarity of the service
• Demonstrating that consent was given and withdrawn

5. Legal bases

Account, sign-in and provision of the service. Art. 6(1)(b) GDPR — processing necessary to perform the user agreement. We rely on this basis also for the food lookups you start (Open Food Facts), the reading of text on a food label you scan (Google ML Kit), and delivering app updates (Expo).

Health data. Art. 9(2)(a) GDPR together with Art. 6(1)(a) GDPR — your separate, explicit consent for the purposes in section 6. Health data is not processed on the basis of a legitimate interest.

AI-assisted features. Art. 6(1)(a) GDPR and, for health data, Art. 9(2)(a) GDPR — your separate consent to AI processing, given in the app or on the website before anything is sent (section 8).

Product and marketing email. Art. 6(1)(a) GDPR — your separate consent, withdrawable at any time via the unsubscribe link in every such email or in settings. Service messages necessary to perform the agreement reach you regardless.

Security, abuse prevention and operational stability. Art. 6(1)(f) GDPR — legitimate interest in a secure and functioning service. We rely on this basis also for the daily limit on photo meal identification, and for the app's contact with RevenueCat at each start (section 14).

Consent records. Art. 6(1)(c) GDPR — meeting the demonstration obligation under Art. 7(1) GDPR.

Product analytics. Art. 6(1)(f) GDPR — our legitimate interest in improving and stabilising the service. Our own product analytics (PostHog) runs on the website only, stores nothing on your device, and receives no health data.

6. Health data and explicit consent

What you record about how you feel, your cycle, your sleep, your weight and related subjects is health data, and therefore a special category of personal data under Art. 9 GDPR.

This data is processed solely on the basis of your explicit consent, given at registration separately from your other agreements. That consent covers:

• storing your entries in your account,
• displaying your history and the relationships derived from it.

Sending your data to OpenAI for the AI-assisted features needs a separate consent — see section 8.

You can withdraw this consent at any time (section 13). Without it the health-related features cannot be provided; you can still hold and delete an account.

7. Apple Health and device data

Connecting Apple Health is optional and must be actively started by you. You also grant permission separately in your device's operating system.

If you connect it, GetWella reads the data types you have approved from Apple Health — in particular activity, sleep, body measurements, heart rate and related values.

• GetWella only reads. No data is written back to Apple Health.
• This data is health data and is processed on the basis of your explicit consent (section 6).
• It is used to display information in the app and — only if you have agreed to AI processing (section 8) — as context for the AI-assisted features.
• Disconnecting stops any further import. Data already imported remains in your account until you delete it or your account.
• Disconnecting inside GetWella does not by itself revoke the permission granted in your operating system. You manage that in your device settings.

8. AI-assisted features and their limits

GetWella's AI-assisted features — photo meal identification, the AI companion that answers your questions, and the personalised insights in your report — are provided by OpenAI.

We ask first. Before anything is sent to OpenAI, the app (or, for the insights in your report, the website) explains what will be sent and asks for your agreement. Nothing is sent to OpenAI until you agree. Your agreement is recorded with the version of this policy; when the policy's version changes, we ask again.

What is sent to OpenAI:

• for photo meal identification: the photo you take, and your app language;
• for the AI companion: your question, your recent conversations with it, and context from your logged data — up to the last 90 days of check-ins and notes, food, drinks, water, exercise, fasting, symptoms and their notes, and readings from Apple Health if you connected it — together with profile information such as your age, height, weight and goal weight, menopause status, activity level and goals, and your language and country;
• for the insights in your report: for the weekly insight, a pattern found in your logged data with its figures, and profile information such as your menopause status and language; for the one-time insight after your first week, the same kind of context as for the AI companion.

What is not sent: your name, your email address, or your account identifier.

Where and for how long. OpenAI processes this data in the United States (section 10). OpenAI keeps data it receives through its API under its own terms for API customers; the retention period that applies to our account has not yet been confirmed. GetWella does not store your meal photos. The AI companion's answers are stored in your account so you can see your conversation history; they are deleted with your account.

If you do not agree, or later withdraw. The AI-assisted features stay off and nothing is sent to OpenAI. Everything else in GetWella keeps working. The free AI question each day remains available to you whenever you choose to agree. You can agree or withdraw at any time in the app's settings, and on the website where the insights in your report are shown. Withdrawal does not affect data sent before it.

Limits. The output is supportive information. It is not a medical diagnosis, not a treatment plan, not an emergency service, and not a substitute for advice from a doctor. In a medical emergency, contact your local emergency number (112 in Germany and the EU).

9. Recipients and service providers

We share your data only with the following service providers, and only as needed to operate GetWella. Where these providers act as processors, they act solely on our instructions under the relevant agreements.

Expo also uses device information it receives, such as your IP address, for its own purposes as an independent controller, under its own privacy terms.

Sign-in with Apple or Google. If you choose to sign in with Apple or Google, that service confirms your identity under its own terms and tells us your name and email address. If you sign in with Apple, we also keep a token from Apple so that GetWella's access can be revoked with Apple when you delete your account.

Apple. Apple provides the distribution platform for the iOS app and manages the Apple Health permissions on your device. Apple receives no Apple Health data from GetWella. Apple's own privacy terms apply to its processing.

We do not sell, rent or trade your personal data. We do not use it for advertising.

10. International transfers

United Kingdom and Singapore (Supabase). Application data is stored on Supabase infrastructure in London, United Kingdom. By decision of 19 December 2025 the European Commission found that the United Kingdom provides an adequate level of data protection (valid until 27 December 2031), so the storage location needs no separate safeguard. ⚠️ Our processor, however, is Supabase Pte. Ltd., established in Singapore. The transfer to that company is covered by the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/914, Module 2 — controller to processor), which form part of the data processing agreement.

United States (OpenAI). Our contracting party is OpenAI Ireland Ltd., established in Ireland. Where OpenAI Ireland Ltd. transfers personal data to recipients outside the European Economic Area — in particular to the United States — it does so on the basis of the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR), which form part of the data processing agreement concluded with OpenAI. Processing takes place via endpoints in the United States; no EU data residency is configured.

Other providers processing in the United States. Vercel (Vercel Inc.), Resend (Plus Five Five, Inc.), Stripe (Stripe, LLC) and PostHog (PostHog Inc.) also process personal data in the United States. Each of those transfers takes place on the basis of the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/914, Module 2 — controller to processor), which form part of the data processing agreements concluded with them. ⚠️ Stripe and PostHog additionally name the EU-US Data Privacy Framework as an available transfer mechanism.

RevenueCat (RevenueCat, Inc., United States). Its data processing agreement, incorporated into its customer terms, includes the European Commission's Standard Contractual Clauses (Modules 2 and 3). Where RevenueCat processes the data has not been confirmed.

Expo (650 Industries, Inc., United States). Our data processing agreement with Expo is in force. Expo names the EU-US Data Privacy Framework as its transfer mechanism, and states that the European Commission's Standard Contractual Clauses (Module 2) are incorporated through its terms of service. Where Expo processes the data has not been confirmed.

Google (ML Kit). Where Google processes the data sent when a label is scanned has not been confirmed. Google offers no separate data processing agreement for ML Kit; its use is governed by the ML Kit Terms and the Google APIs Terms of Service.

Open Food Facts is a non-profit association in France. No transfer outside the European Union takes place.

11. Retention

Account and health data. For as long as your account exists. When you delete your account — in the app's settings, or in your account settings on the website — this data is deleted immediately: it is removed from our live database in the same operation, not queued or scheduled for later removal. This covers your profile, all daily entries, fasting, food and drink records, symptoms, device readings, AI conversations, insights, saved meals and your photo identification count.

Photo identification count. Each record is deleted once it is 30 days old, or with your account if that comes first. The deletion runs once a day, so a record can remain for up to one more day; if a day's run fails, the next run deletes it.

Meal photos. Not stored by GetWella. For OpenAI's retention, see section 8.

What is not covered by that deletion. For completeness:

• Consent records — see below.
• Internal access-log entries recording that an administrator viewed an account. These contain only an account identifier — no name, no email address and no health data.
• Technical sign-in records held by our authentication provider. These contain an account identifier and no email address or content.

Consent records. These are retained after your account is deleted, because we are legally required to demonstrate that consent was given. Retention period: three years from the end of the calendar year in which the deletion took place (tracking the standard limitation period under § 195 BGB). They are deleted once that period has passed.

Payment and transaction data. Where payments have been processed, the associated records are subject to commercial and tax retention obligations; Stripe retains transaction data under the rules applying to Stripe.

Data held by our service providers. Outside our own database, the providers listed in section 9 retain data under their own retention rules — in particular Stripe (customer and payment records), PostHog (product-usage events), OpenAI (section 8), and Expo, RevenueCat, Google and Open Food Facts (what the app sends them, section 9). If you want data removed from a provider we work with, write to support@getwella.com and we will pass the deletion request to the provider concerned.

Backups and technical logs. Deleted data can persist for a limited period in routine system backups and server logs held by our infrastructure providers, where it is overwritten in the ordinary course of operation. We do not restore backups in order to recover deleted accounts.

12. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection to processing based on legitimate interest (Art. 21).

You can export your health data as a CSV file at any time, free of charge. This feature remains free permanently.

To exercise your rights, contact support@getwella.com. We respond within one month of receipt; for complex requests this may be extended by up to two further months, and we will tell you if it is.

Right to complain. You have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your residence, place of work, or the place of the alleged infringement (Art. 77 GDPR).

13. Withdrawing consent

You can withdraw your consent at any time.

• Withdraw consent to AI processing in the app's settings, or on the website where the insights in your report are shown. From then on nothing is sent to OpenAI.
• Withdraw consent to health-data processing by writing to support@getwella.com. We action the withdrawal on receipt and confirm it to you.
• Withdraw consent to product email via the unsubscribe link in any such email, or in settings.

Withdrawal is not tied to deleting your account. Deleting your account remains separately available. Withdrawal does not affect the lawfulness of processing carried out before it.

14. Cookies and similar technologies

Website. GetWella uses only technically necessary cookies — in particular for sign-in and for your language choice. No advertising or tracking cookies are used.

We use PostHog for product analytics on the website. It stores nothing on and reads nothing from your device and sets no cookies.

No health data is sent to PostHog. Only neutral product events are recorded, without their contents — no symptoms, cycle information, Apple Health readings, weight, sleep, fasting or meal data, no notes, and no questions or answers from the AI feature.

App. The app stores your data on your device so that it works offline and syncs with your account. It contains no advertising, and none of our own product analytics. It does contact other services in order to work:

• Expo, each time the app starts, to check for updates — with an identifier for your installation and your IP address;
• RevenueCat, each time the app starts, before you sign in — with the device information listed in section 9;
• Google (ML Kit), when you scan a food label — with usage events and an identifier for your installation, but not the image or the text;
• Open Food Facts, when you scan a barcode or search for a food;
• OpenAI, through our server, only after you have agreed to AI processing (section 8).

15. Security

Data is encrypted in transit (TLS) and at rest. Access to production systems is restricted. We apply recognised technical and organisational measures. Absolute security of transmission over the internet cannot be guaranteed.

16. Changes to this policy

We update this policy when the processing changes. For significant changes we will notify you by email or through a notice in the app. The date above indicates the current version. When the version changes, the app and website ask again for your agreement to AI processing.

17. Contact

GetWella Team — support@getwella.com