Privacy Policy
Last updated: September 24, 2026
1. Data Controller
HealthPhin is operated by PhinLabs (Markus Egolf), Glärnistr. 52b, 8712 Stäfa, Switzerland. Contact: [email protected]. This policy applies under the Swiss Federal Act on Data Protection (nDSG, effective since September 1, 2023) and the EU General Data Protection Regulation (GDPR).
2. Cookies and Browser Storage
We do not use cookies for advertising, analytics or tracking, and no analytics or advertising tools. To keep you signed in, the app stores a sign-in key and your settings in your browser or device storage; they are removed from the app when you sign out; the Apple Watch and the widget keep the last values shown until you sign in again or remove the app. Our network provider Cloudflare may set a strictly necessary security cookie to detect automated attacks.
3. Legal Basis and Consent
(a) Contractual necessity (Art. 6(1)(b) GDPR) to provide HealthPhin. (b) Explicit consent (Art. 9(2)(a) GDPR, Art. 6(7) nDSG) for processing your health data, given at registration by actively ticking the boxes; we store the time and version of your consent. (c) A separate consent for the AI features (see section 6); without it, no data is sent to AI services. (d) Legitimate interest (Art. 6(1)(f) GDPR) for security, troubleshooting and abuse prevention (server logs). You can withdraw any consent at any time: AI consent in the app under Settings → Privacy; consent to processing your health data there as well — because HealthPhin cannot work without this data, your account is deleted in that case. You can also send us your withdrawal by email.
4. Data We Process
(a) Account data: email address, name, password (hash only), optionally date of birth, gender, height, weight, time zone. (b) Health data: supplements and intake; blood values and uploaded lab reports; training; nutrition including photos of meals and labels; allergies and intolerances; body measurements; journal (sleep, energy, mood, free text); injuries and limitations you record; data from Apple Health and Apple Watch such as heart rate, resting heart rate, heart rate variability, blood oxygen, sleep, steps and workouts — only if you allow it in iOS. (c) Location data: GPS tracks of the tours you record. (d) AI data: conversations with Phin, coaching messages, analysis results, a short preview of each AI request (max. 200 characters) and usage for quota accounting; for voice output, the generated audio files and a short preview of the text read aloud (max. 120 characters). (e) Feedback you send us, including attached screenshots. (f) Technical data: IP address, time and requested address in server logs, device token for notifications, technical error reports from the app and watch.
5. Hosting, Transmission and Backups
The app, database and uploaded files are stored on a server of Hetzner Online GmbH in Nuremberg, Germany. Traffic is delivered through Cloudflare, Inc. (USA; DNS, proxy and DDoS protection), which processes connection data such as IP addresses under a data processing agreement with EU Standard Contractual Clauses. The connection between your device and Cloudflare is encrypted with TLS. Uploaded files can only be accessed by you (and by administrators for troubleshooting). Exception: product photos you upload when adding a product to the shared product database are visible to other signed-in users. Only the controller has access to the server. We create daily backups: on the server for up to 60 days, and on a backup server operated by the controller in Switzerland for up to 730 days (weekly copies only after 90 days). Backups are used exclusively to restore service after an outage.
6. AI Processing (Phin)
The AI features use language models by Anthropic (Claude) and the open model gpt-oss, both via Amazon Web Services Bedrock. gpt-oss is operated by AWS itself; no data is sent to OpenAI or Anthropic. Requests are processed in AWS data centers within the EU. To search our knowledge base, your question is also converted into numbers by an AWS model (Titan). A data processing agreement under Art. 28 GDPR is in place with AWS. Your data is never used to train AI models. The health data required for each function is transmitted — for conversations with Phin, analyses of blood work, photos and recipes, automatic coaching tips, the weekly review and the analysis of your feedback. All of this happens only with your AI consent. If you withdraw it in the settings, no further data is sent to AI services from that moment; all other features remain available.
7. Other Recipients
Besides Hetzner, Cloudflare and AWS, the following receive data, each only for the stated purpose: (a) ElevenLabs Inc. (USA) — Phin’s texts for voice output, only if you use voice output. (b) Zoho Corporation B.V. (EU) — sending emails such as password resets and the weekly review; your email address and the message content. (c) Apple Inc. (USA) — delivery of notifications to your iPhone; in the browser, if you turn on notifications there, your browser's push service (e.g. Google, Mozilla, Microsoft or Apple). The device token for notifications and the notification text are transmitted; notifications contain no health data. (d) Norwegian Meteorological Institute (MET Norway, Norway) — the center or start point of a recorded tour (to about 10 m) to retrieve the weather. (e) NASA Langley Research Center (USA) — for tours outside Switzerland, and in Switzerland when no weather station is nearby or its data is unavailable, the position rounded to about 1 km to retrieve past weather. From MeteoSwiss we only download public measurements and send no data. (f) Federal Office of Topography swisstopo (Switzerland) — the points of a tour in Switzerland to calculate elevation gain. (g) OpenStreetMap Foundation (United Kingdom) — when maps are shown, your device loads map images directly from there (IP address and map area); when you share a tour, the start position, rounded to about 1 km, is converted into a place name; the shared image omits the first and last 300 m of the route. (h) Product image providers (Open Food Facts, France, and the image servers of retailers and online shops) — when a product is shown, your device loads its image directly from there; your IP address and the requested image are transmitted, without any reference to HealthPhin. We host fonts ourselves. Switzerland and the United Kingdom have an EU adequacy decision. For recipients in the USA: Cloudflare is bound by EU Standard Contractual Clauses (see above). Requests to ElevenLabs and NASA are made by our server, not your device, and contain no account data such as your email or IP address — ElevenLabs receives only the text to be read aloud, NASA only the rounded position. Apple receives only the device token for notifications, without health content. We do not sell data or share it for advertising.
8. Retention and Deletion
Your data is stored as long as your account exists. When you delete your account in the settings, your data and uploaded files are removed from the database and the server immediately. They remain in the backups (section 5) until those retention periods expire; backups are not edited individually and are only used to restore service after an outage. AI conversations are deleted automatically after 90 days without activity, and the short preview of AI requests after 90 days as well. Server logs are overwritten continuously (size limit per service, and deleted with every new version), usually within a few days. Technical diagnostic data from the app and the Apple Watch is deleted after 90 days, as is the short preview of voice output; the voice audio files 90 days after their last use. If you join the waiting list on the website, we store only your email address to send you a confirmation link and later your access (legal basis: your consent). If you do not confirm the link, we delete the address after 30 days; confirmed addresses are deleted on request or when the waiting list ends.
9. Automated Analyses
HealthPhin analyzes your data automatically (for example recovery scores, coaching tips, blood value classification). No automated decisions with legal or similarly significant effects within the meaning of Art. 22 GDPR are made. All analyses are for information only and do not replace medical advice; you decide yourself.
10. Your Rights
You have the right of access (Art. 15 GDPR, Art. 25 nDSG), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR — in the app settings), data portability (Art. 20 GDPR — export of all data in the settings), restriction of processing (Art. 18 GDPR), objection to processing based on our legitimate interest, such as server logs (Art. 21 GDPR), and withdrawal of your consents (Art. 7(3) GDPR — AI consent in the settings; withdrawing consent to the processing of your health data means deleting your account, also in the settings; all others by email). Contact [email protected].
11. Right to Lodge a Complaint
You may lodge a complaint with a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch; in the EU your local data protection authority (Art. 77 GDPR).
12. Changes
We update this privacy policy when HealthPhin changes. We inform you about material changes in the app or by email. The current version is always available on this page.
Privacy inquiries: [email protected]