Privacy Policy

1. Controller

The controller within the meaning of the GDPR and other data protection provisions is:

2. Data Protection Officer

Because we process health data (special categories of personal data), we assume that the appointment of a data protection officer under § 38 BDSG is required.

3. Legal Bases for Processing

We process personal data only on one of the following legal bases, depending on the respective purpose:

• Consent (Art. 6(1)(a), Art. 9(2)(a) GDPR): e.g. for processing health data, analytics and marketing cookies, and optional features.
• Performance of a contract (Art. 6(1)(b) GDPR): to provide the account, subscriptions (Pro/Elite), blood panels, and the supplement store.
• Legal obligation (Art. 6(1)(c) GDPR): e.g. commercial and tax retention obligations.
• Legitimate interest (Art. 6(1)(f) GDPR): e.g. IT security, fraud prevention, and technical operation of the platform.

4. Processing Activities

Account creation and management

When you register, we process your name, email address, and credentials. The legal basis is performance of a contract (Art. 6(1)(b) GDPR).

Orders and payments

For subscriptions, blood panels, and supplement orders, we process order, invoicing, and payment data. Payments are handled via Stripe; full card data is not stored on our systems.

Server log files and security

When you access the platform, technical access data (e.g. IP address, time, requested resource) is processed. The legal basis is our legitimate interest in IT security and stability (Art. 6(1)(f) GDPR).

Support and communication

When you contact us, we process the information you provide to handle your request (Art. 6(1)(b) or (f) GDPR).

5. Health Data (special categories, Art. 9 GDPR)

Within the longevity and wellness features, the following health data may be processed:

• biomarkers and blood values from blood panels (e.g. lipids, metabolism, hormones, inflammation markers)
• calculated biological age and derived analyses
• data from wearables and CGM/glucose measurements (if connected)
• self-reported health, nutrition, and training data

Legal basis: explicit consent under Art. 9(2)(a) GDPR. Without this consent, the health-related features cannot be provided.

For the OCR of the blood-test documents you upload, the analysis of biomarkers and biological age, the AI coach, and the generation of training and nutrition plans, health data (including biomarkers, information on medical history, medications, and allergies) as well as blood-test documents you upload are transmitted to our AI processor Microsoft (Azure OpenAI Service). This processing takes place within the European Union (Microsoft's Sweden Central region / EU Data Zone); your data is not transferred to a third country for it. Details are set out in Section 12. For research questions in the coach, only de-identified, health- and identifier-free queries are sent to Perplexity in the USA; how this is technically enforced is described in Section 12. Three further features transmit health-related information to providers in the USA: food-photo recognition, and email and SMS/WhatsApp notifications. The details are set out in the highlighted note below the table in Section 6. The processing is based on your explicit consent under Art. 9(2)(a) GDPR.

Scope of the data transmitted and uploaded documents: We transmit only the data required for the respective feature. The text inputs for generating training and nutrition plans do not contain your name; in the AI coach your first name is transmitted so that the coach can address you personally. Documents you upload — in particular lab reports — are, by contrast, transmitted to the AI service exactly as you upload them: we do not redact or pseudonymise them beforehand. They may therefore contain all the details the laboratory printed on them, such as name, date of birth, address, insurance number, and the referring physician. If you do not want this, you can obscure identifying details yourself before uploading.

Wearable data (recovery, sleep, workouts, cycles, profile and body measurements) is — where you connect a device such as WHOOP, Oura, Garmin, or Fitbit — integrated via our processor Junction (formerly Vital). Connecting a device is optional and based on your consent; you can disconnect it at any time.

You can withdraw your consent at any time with effect for the future. The lawfulness of processing carried out before withdrawal remains unaffected.

6. Processors and Recipients

We use the service providers named individually below. Where they process personal data on our behalf, this is done on the basis of a data processing agreement pursuant to Art. 28 GDPR. For each provider the table states the purpose, the data categories transmitted, the location of processing and — for processing outside the EU — the safeguard relied on.

On the safeguards for third-country transfers: where a provider is certified under the EU-US Data Privacy Framework, the transfer is based on the European Commission's adequacy decision (Art. 45 GDPR). Otherwise we base it on the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR), which for most providers are incorporated through their data-processing or usage terms and are not signed separately. We will tell you which mechanism applies to which provider on request at support@inself.io.

Analytics, marketing, and chat services are only activated after your consent via the consent banner. Necessary providers (hosting, payment, wearable integration) are required for the performance of the contract or for the features you choose.

Content services without personal data

We transmit no personal data to the following services, only generic requests: ExerciseDB (accessed via RapidAPI) for the exercise library and exercise GIFs — only exercise names and paging parameters are sent — and Google Gemini in an internal editorial process for generating recipe images, which receives only generic recipe descriptions. Both requests run from our servers; the requesting IP address is ours, not yours.

Inactive and discontinued services

These services currently receive no personal data and are therefore not in the table: OpenAI (direct US access; AI processing has run via Microsoft Azure OpenAI in the EU since July 2026), Anthropic (AI assistant in support), Groq and Together AI (AI text generation), ElevenLabs (voice output; via Microsoft Azure AI Speech in the EU since August 2026), as well as Terra (alternative wearable integration) and Chance2Brand (planned EU fulfillment). For the planned lab fulfillment with Remi Labs the technical interfaces are prepared but switched off in the production environment; Remi Labs currently receives no data. Before it goes live we will conclude the required agreement on the processing of special categories of personal data and update this list.

This table is our authoritative disclosure of the processors we use. In addition, you can request the current version at any time at support@inself.io. We notify you of changes by updating this page.

7. Cookies and Consent Management

Details on the cookies used and their categories (necessary, functional, analytics, marketing) can be found in our Cookie Policy.

8. International Transfers

Some of the providers listed above process data outside the EU/EEA, in particular in the USA. This applies to Vercel, Perplexity, FatSecret, Spoonacular, Stripe (depending on the region), Shopify, Supliful, Twilio and Twilio SendGrid, Tawk.to, and Google (Sign in with Google and Google Maps Platform). The following, by contrast, stay in the EU: the AI processing of your health data and the coach's voice output via Microsoft (Azure OpenAI Service and Azure AI Speech, Sweden Central region), the primary database and file storage (Supabase, Frankfurt and Stockholm), the wearable integration (Junction via its EU endpoint), and product analytics (PostHog via its EU endpoint).

For transfers to the USA we rely — depending on the provider — on an adequacy decision of the EU Commission (EU-US Data Privacy Framework, where the provider is certified) or on the EU Commission's standard contractual clauses (Art. 46(2)(c) GDPR). Where health-related data is transmitted in the process — in food-photo recognition, in recipe search, and in email and SMS/WhatsApp notifications — we additionally rely on your explicit consent under Art. 49(1)(a) GDPR. Upon request, we will provide you with information on the appropriate safeguards.

9. Retention Period

We store personal data only as long as necessary for the respective purposes or as required by statutory retention obligations:

• account data: until the account is deleted
• health data (Art. 9 GDPR): until you withdraw your consent or delete your account. When you delete your account it is removed from our live systems immediately and permanently — there is no recovery or grace period. It may remain in our database backups for up to seven days: backups are created daily and automatically deleted after seven days.
• invoicing and accounting data: up to 10 years (commercial/tax obligations)
• server log files: generally short-term, then deleted or anonymized

10. Your Rights as a Data Subject

Under the GDPR, you have the following rights:

• Access (Art. 15 GDPR): information about the data stored about you.
• Rectification (Art. 16 GDPR): correction of inaccurate data.
• Erasure (Art. 17 GDPR): deletion of your data, unless retention obligations apply.
• Restriction (Art. 18 GDPR): restriction of processing.
• Data portability (Art. 20 GDPR): receipt of your data in a structured, commonly used, machine-readable format.
• Objection (Art. 21 GDPR): objection to processing based on legitimate interests.
• Withdrawal (Art. 7(3) GDPR): withdrawal of consent at any time with effect for the future.

11. Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to other remedies, 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 place of the alleged infringement.

12. Automated Analyses and AI

Inself uses algorithms and AI to create personalized analyses and recommendations (e.g. training, nutrition, and supplement plans). These serve wellness purposes only and do not constitute medical diagnosis or treatment. There is no solely automated decision with legal effect within the meaning of Art. 22 GDPR.

All AI features that process health data run via Microsoft (Azure OpenAI Service) in the EU (see below). Voice output for the coach likewise runs via Microsoft (Azure AI Speech) in the EU; ElevenLabs, the US service previously used for it, is no longer used. Perplexity receives only de-identified research queries with no health data and no identifying reference; how this is technically enforced is described below. The services previously used — Groq, Together AI and Anthropic — no longer receive any data. Details of the data categories transmitted in each case can be found in the table in Section 6.

AI processing via Microsoft Azure OpenAI Service (EU)

The following features use AI models that we operate via Microsoft's Azure OpenAI Service:

• extracting values from the blood-test documents you upload (OCR)
• analysing biomarkers and biological-age indicators
• generating personalised nutrition, training, sleep/recovery, and supplement guidance through the AI coach

Microsoft acts as our processor for this. When you use an AI feature, the data required for it — including special categories of personal data under Art. 9 GDPR (health data) — is transmitted to this service in order to generate the result. Microsoft's data processing agreement (Microsoft Products and Services Data Protection Addendum, Art. 28 GDPR, including the EU standard contractual clauses) is incorporated via the Azure agreement; it is not signed separately.

Location of processing: exclusively within the European Union (Microsoft's Sweden Central region / EU Data Zone). Your data is not transferred outside the EU for this processing.

Not used to train AI models: Microsoft does not use your prompts or the generated outputs to train or improve its own models.

Retention at Microsoft: Microsoft may retain the data sent to the service for up to 30 days solely for security and abuse-monitoring purposes, after which it is deleted. How long we ourselves retain your results is described in Section 9 (Retention Period).

Data minimisation: We transmit only the data needed for the respective feature. Documents you upload are, however, transmitted unaltered and may contain the identifying details printed on them by the laboratory — see Section 5 for details.

Legal basis: your explicit consent under Art. 9(2)(a) GDPR, together with Art. 6(1)(b) GDPR for providing the features you have chosen.

Research questions via Perplexity (USA)

If you ask the coach about current studies, current research or current developments, that one question is answered by Perplexity with source citations. To ensure no health data leaves the EU for this, the path is technically tightly bounded:

• Structured health and profile data is never transmitted. Technically, only two items may go along: your display language and your selected goal (e.g. longevity). All other fields — such as biomarkers, medications, allergies or age — are dropped before sending, and an upstream check aborts the request if they were present nonetheless.
• Your free-text question is de-identified before transmission: specific values and identifying details are removed and the question is generalised.
• If a question cannot be generalised safely, it is not sent to Perplexity but answered by our AI processor in the EU (Microsoft Azure OpenAI Service). In case of doubt, processing therefore ends in the EU.

Perplexity acts as a processor for us on the basis of its API terms of service; the data processing agreement under Art. 28 GDPR, including the EU standard contractual clauses (Modules 2 and 3), is incorporated through them and is not signed separately. The content transmitted is not used to train AI models.

13. Changes to This Privacy Policy

We update this privacy policy if processing or the legal situation changes. The version published on this page applies.