Privacy Policy
Last updated: . This policy applies to the app “My Lifestyle: Habit Planner” (iOS and Android) and the website my-lifestyle.app. It is written for the Swiss Federal Act on Data Protection (FADP) and, where it applies, the EU General Data Protection Regulation (GDPR).
In short
Your account, your health profile, your lab reports, your own plans (“My plans”) and your day plans, routines, areas and journal are stored on our own servers in Switzerland so they are available on all your devices. Reminders are scheduled by each device itself and stay on it. A lab report is only sent to Google Gemini to read its values after you have explicitly agreed to that in the app. There is no advertising, no tracking and no analytics.
1. Controller
Schweizerpunkt GmbH
Gotthelfstrasse 41
8172 Niederglatt, Switzerland
Email: [email protected]
2. Data stored on our server
The following data is stored on our server and linked to your account:
- Account data: name, email address, password (stored only as a salted hash, never in plain text), and the account identifier from Apple or Google if you sign in with them.
- Consents: the time at which you gave your consent to the processing of health data and, separately, your consent to the AI processing of lab reports (see section 5).
- Health profile (optional): date of birth, fitness profile, preferences and medications, as far as you enter them.
- Lab reports and values (optional): the report files you upload (PDF, image or Word document), values you enter manually, values read automatically from a report (see section 6), and the values you have checked and confirmed yourself.
- My plans: the multi-week plans you create in the app (name, dates, phases, items, notes). They are synchronised between your devices. When you delete a plan, we keep only its random identifier for 180 days so that your other devices can remove it as well; the content is deleted immediately.
- Day plans, routines and journal: your routines and areas (name, type, order and reminder settings), your day plans (items with their reminder settings, completion and skipped routines, the plan items you removed from a day), your daily notes, evening check-ins and journal entries. They are synchronised between your devices; each device also keeps its own copy so the app works offline.
- Tips and polls: your “helpful” markers on tips and your answers to community polls. Other users only ever see aggregated poll results, and only once a minimum number of answers has been reached.
- Sessions: a hash of your sign-in token and its expiry date (sessions expire after 30 days).
- Technical data: IP address, time and type of request in server logs, kept for at most 30 days for security and troubleshooting.
3. Data stored only on your device
The following data is stored only in the app’s storage on your device and is not transmitted to us: the reminders scheduled on your device (notifications and snoozes) and a reminder or duration you change on a single item of one of your own plans, the quarterly plan wizard with any documents you attach to it, the offline copy of your plans and day plans, and, if you add one, your personal Google Gemini API key (kept in the protected keychain or keystore of your device). The reminder settings of your routines, areas and day plan items are synchronised with them (section 2); each device schedules its own reminders from them. The data listed here leaves your device only if you export it yourself.
Device backups: your operating system may include the app’s data in your own device backup. On Android, the app allows the system backup, so this data can be part of your Google device backup if it is turned on in your settings; on iPhone, it can be part of your iCloud or computer backup. These backups are managed by Google or Apple under your account and settings, not by us.
4. Purposes and legal bases
- Providing your account, synchronising your plans, day plans and journal, polls and tips: performance of the contract with you (GDPR Art. 6(1)(b)).
- Health data (health profile, medications, lab reports and values): only with your explicit consent (GDPR Art. 9(2)(a) and Art. 6(1)(a); under the FADP, these are sensitive personal data processed with your express consent).
- Reading lab reports with AI (Google Gemini): only with your separate explicit consent (same legal basis).
- Security, abuse prevention and server logs: our legitimate interest in a secure service (GDPR Art. 6(1)(f)).
We do not sell your data, do not use it for advertising and do not create profiles for marketing.
5. Your consents and how to withdraw them
The app asks for two separate consents, and we record the time of each:
- Health data: before you use your account, the app explains which health data is stored and asks for your explicit consent. The account features cannot be used without it. You withdraw this consent by deleting your account (section 11) or by writing to us; you can also change or clear your profile entries at any time.
- AI processing of lab reports: before a report is sent to Google Gemini for the first time, the app asks for this separate consent. You can withdraw it at any time in your profile; after that, no further reports are sent to Google and you can still enter values manually. Values that were already read stay in your account until you delete them with your account.
Withdrawal applies to the future; it does not affect processing that took place before.
6. Reading lab reports with Google Gemini
You can always enter values manually without any AI. If you upload a report and ask the app to read it, and only after you have given your AI consent, the following happens:
- Our server sends the report file to Google Gemini, an AI service of Google LLC (USA). For Word documents only the text extracted from the file and its file name are sent. Your name, email address, profile and other account data are not sent with it, but the report itself may show personal details printed on it (for example your name or date of birth).
- Gemini only transcribes what is printed on the report: values, units, reference ranges, flags, the date and the name of the laboratory. It is instructed not to interpret or assess anything. The app then marks values outside the printed reference range. The results are stored with your report as values that were read automatically. You check them against the original and confirm or correct them; only confirmed values count as verified.
- My Lifestyle does not diagnose, does not give medical advice and is not a medical device. Automatically read values can be wrong or incomplete.
With our server key: we use Google’s paid Gemini API. Under Google’s terms for the paid API, Google does not use the content to train or improve its products; Google may keep it for a limited time, for example to detect abuse, as set out in Google’s terms.
With your own key: if you store your own Gemini API key in the app, the app sends it to our server with the request. Our server uses it only for that one request, keeps it in memory only and never stores or logs it. The request then runs under your own Google account and Google’s terms for your key. With a free-of-charge key, Google’s terms may allow Google to use the content to improve its products and to have it reviewed by people; check Google’s terms before you use a free key for health documents.
7. Sign in with Apple or Google
When you sign in with Apple, we receive an account identifier and, the first time, your name and your email address or an Apple relay address. When you sign in with Google (offered only if it is available on the server), we receive your email address, your name and an account identifier. The privacy policies of Apple and Google apply in addition. When you delete your account, we also ask Apple to revoke the link to your Apple ID.
8. Service providers and recipients
- Hosting: our server and database are operated by Schweizerpunkt GmbH on its own hardware in Switzerland.
- Cloudflare, Inc. (USA, global network): all connections to my-lifestyle.app and api.my-lifestyle.app pass through Cloudflare. Cloudflare terminates the encrypted connection (TLS), protects against attacks and forwards the traffic through an encrypted tunnel to our server. In doing so, Cloudflare processes your IP address and the content of the requests on our behalf.
- Google LLC (USA): Gemini, for reading lab reports with your consent (section 6), and Google Sign-In if you use it.
- Apple Inc.: Sign in with Apple if you use it.
- Apple and Google also distribute the app through their stores under their own privacy policies.
We do not pass your data on to anyone else, unless we are legally required to do so.
9. Transfers outside Switzerland and the EU
Your data is stored in Switzerland. Cloudflare and Google may process data in the USA and in other countries. For these transfers we rely on the certification of these companies under the EU-US Data Privacy Framework and the Swiss-US Data Privacy Framework and/or on the EU Standard Contractual Clauses (with the amendments required for Switzerland) contained in their data processing terms.
10. Security
All connections are encrypted with TLS. Report files are stored outside the public web area and can only be retrieved by your signed-in account. Passwords and sign-in tokens are stored only as hashes. On your device, your session is kept in the protected keychain or keystore.
11. Retention and deletion
- We keep your data for as long as your account exists.
- You can delete your account at any time in the app (Profile → “Delete account”). Your account and all data stored for it on our server, including your plans, your synced day plans, routines, areas and journal, and all uploaded report files, are deleted immediately. The app also removes everything it stores for your account on that device, including scheduled reminders and your personal Gemini key. On your other devices, the app’s local data stays until you uninstall the app there.
- Without the app, you can request deletion as described on Delete your account; we then delete everything promptly, at the latest within 30 days.
- Identifiers of deleted plans (without content) are kept for 180 days, server logs for at most 30 days. Backup copies of the server roll off after 14 days at the latest.
12. Your rights
Under the FADP and, where applicable, the GDPR, you have the right to:
- access the data we hold about you and receive a copy;
- correct it (you can edit your profile and correct automatically read values in the app);
- delete it (see section 11) and to restrict or object to its processing;
- data portability: the export in the app saves your day plans, journal and lab values as a JSON file, and each of your plans can be exported as JSON; on request we send you a complete copy of your server data, including your synced day plans, routines, areas and journal, in a machine-readable format;
- withdraw your consent at any time (section 5).
To exercise these rights, write to [email protected]. You also have the right to lodge a complaint with a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch), in the EU the data protection authority of the country where you live or work.
13. No advertising, tracking or analytics
The app contains no advertising, no tracking and no analytics or advertising SDKs, and it has no in-app purchases. The website uses no tracking or advertising cookies and loads no external scripts; Cloudflare may set a technically necessary security cookie to protect against attacks. The app does not read data from Apple Health or Health Connect.
Contact form on this website: if you write to us with the contact form on my-lifestyle.app, we store your name, your email address, the optional website or product URL and your message on our servers in Switzerland to answer your request. Your IP address is only stored as a keyed hash, to protect the form against abuse and to limit the number of messages. If email delivery is set up, the message is also forwarded by email to our support address. We delete this data after 12 months at the latest.
14. Age
My Lifestyle is intended for adults. Please do not use it if you are under 18.
15. Changes
We update this policy when the app or the legal situation changes and show the date of the last change at the top. You can always find the current version at my-lifestyle.app/privacy. The German version is available at my-lifestyle.app/de/datenschutz.