Datenschutzerklärung

This policy explains what personal data Gemut collects when you use the Gemut app for iPhone and the website gemut.health, why we need it, who processes it for us and what you can do about it. Gemut works with health data, so we try to be exact. If anything here is unclear, write to support@gemut.health.

1. Who we are

Gemut is provided by Innolex Corp. s.r.o., Budovcova 188/1, 130 00 Praha, Czech Republic (“Gemut”, “we”, “us”). We are the controller of your personal data under the EU General Data Protection Regulation (GDPR). You can reach us at support@gemut.health.

2. What we collect

Your account

• Your email address and password. The password is stored only in encrypted (hashed) form by our sign-in provider; we never see it.
• If you sign in with Apple: the identifier, name and email address Apple shares with us. The email can be a private relay address that Apple creates for you.
• The name you enter, the language of the app, and a record of your consents: when you accepted our Terms and this policy, consented to the processing of your health data and to AI processing, and whether you want product updates by email.

Your profile

What you tell us when you set up the app or later in your profile: your health goal, sex, date of birth, height, weight and weight goal, body fat and muscle percentage, activity level, sleep schedule, diet and food allergies, country and units. The app fills in your country from your iPhone’s region setting; you can change it. You can skip every question except your name, sex and date of birth.

Your test results and documents

• The files you upload, with their file names: PDFs, photos and camera scans of lab reports and of other medical reports, such as urine or stool tests and ultrasound or MRI reports. They usually show your name, date of birth and results, the name of the laboratory or clinic and sometimes a doctor’s name.
• What Gemut reads from them: test names, values, units, reference ranges and dates, and the text of findings, conclusions and recommendations, with a translation into your language.
• What Gemut works out from them: a status for each value, a score for each test, your Gemut Age, calculated indexes such as HOMA-IR, AI-written reviews of a test, and how your values change from test to test.

What you do in the app

• Your conversations with Noa, in Health and in Mental mode, and their titles.
• Your answers to the daily question, for example your stress level that day, the daily insights Gemut writes for you, and the days of your streak.
• Your protocol: the supplements, rules and nutrition that Gemut suggests, with its health score and age estimate, and the supplements and medication you add yourself.
• A log of important actions in your account, such as uploads, exports, changes to your supplements and deletion requests.

Purchases

The app uses our subscription provider RevenueCat to check whether you have Gemut Plus. When the app starts, it connects to RevenueCat with a random identifier, which is linked to your account’s identifier once you sign in. If you subscribe, Apple takes the payment, and through RevenueCat we receive the product you bought, its price and currency, the dates of purchase, renewal and cancellation, and transaction identifiers. We never receive your payment card details.

Messages to us

When you write to us, we keep your email and our reply. An email started from “Report a bug” in the app includes the app version, the iOS version and the model of your iPhone; you can remove them before sending.

Technical data

When the app or the website connects to our servers, our hosting providers record technical data such as your IP address, device type, operating system, app version, the time of the request and any errors, and the identifier of your account when you are signed in. When something goes wrong, our server logs can also contain parts of the data being processed, for example values read from a document or the text of a message. We use these logs to keep Gemut secure and working. The app also stores in your profile the identifiers used for advertising measurement — the AppsFlyer identifier for this install, your device identifier for apps (IDFV), your advertising identifier (IDFA) if you allow tracking, and the IP address of the request — so that a purchase can be matched to the advertising it came from. Section 7 says who receives them.

On the website

• We count visits to gemut.health with Vercel Web Analytics. It sets no cookies, stores nothing on your device and does not identify you: we see totals such as page views, referring sites, countries and device types. It runs on every page, whatever you answer to the cookie notice.
• Your answer to the cookie notice is saved in your browser so that we do not ask again. Our Cookie Policy has the details.
• If you joined our waitlist or newsletter on an earlier version of this website, your email address is kept in our database or with our email provider, Resend. Write to us to have it deleted; a newsletter email also has a link to unsubscribe.
• Links to the App Store take you to Apple’s website, where Apple’s privacy policy applies.

3. What we do not collect

• We do not collect your location (only your country, as described above), your contacts, recordings from your microphone or data from Apple Health.
• The app uses the camera only when you scan a document, and your photo library only to pick the photos you choose or to save a card you made.
• We do not build a profile of you from other companies’ apps or websites, and Gemut shows no advertising. The app does measure which advertising brings people to Gemut, which involves device identifiers and, only with your permission, your advertising identifier: section 7 says exactly what that means.
• We do not sell your data, and we do not use your health data for advertising.

4. How we use your data

• To run your account and sign you in.
• To read your documents and show your results, statuses, trends, Gemut Age and indexes.
• To let Noa answer your questions, and to write reviews of your tests, daily insights and your protocol.
• To provide Gemut Plus and check whether your subscription is active.
• To answer your messages and fix problems.
• To learn which advertising brings people to Gemut (section 7).
• To keep Gemut secure, prevent abuse (for example with limits on uploads and messages) and meet our legal obligations.
• To email you about your account, for example when you schedule its deletion, and, only if you agreed, to send occasional product updates.

We do not make decisions about you that have legal or similarly significant effects based solely on automated processing (Article 22 GDPR). Statuses, scores and explanations in Gemut are information, not a diagnosis.

5. Legal bases

• Your explicit consent (Article 9(2)(a) GDPR) for your health data: your health profile, documents, results, conversations with Noa, daily answers and protocol. You give it when you create your account. The app also asks you separately to agree to AI processing (section 6).
• Our contract with you (Article 6(1)(b)) for your account and your subscription.
• Our legitimate interests (Article 6(1)(f)) in keeping Gemut secure and working: security, abuse prevention, troubleshooting, website statistics, and measuring which advertising brings people to Gemut when that is done without your advertising identifier. You can object to this processing.
• Legal obligations (Article 6(1)(c)) for accounting and tax records and for answering lawful requests from authorities.
• Your consent (Article 6(1)(a)) for product update emails.
• Your consent (Article 6(1)(a)) for your advertising identifier (IDFA). iOS asks for it separately, with the App Tracking Transparency request, and you can withdraw it at any time in iPhone Settings → Privacy & Security → Tracking. If you say no, measurement continues without it.

You can withdraw a consent at any time by writing to us. Gemut cannot work without your health data and without AI processing, so if you withdraw either of these consents, we delete your account and its data as described in section 9. Withdrawal does not affect processing that took place before it.

6. AI processing

Gemut uses AI to read your documents and to write explanations: Noa’s answers, reviews of your tests, daily insights and your protocol.

Anthropic (Claude)

Gemut sends Anthropic the files you upload, so that they can be read. With every message you send Noa in Health mode, it also sends your profile (your name, age, sex, height, weight, body fat and muscle percentage, goal, activity, sleep, diet and food allergies, and country), your results with the names of your tests, laboratories and clinics, the conclusions of your reports, earlier reviews of your tests, your answers to the daily question and your conversation. Reviews of your tests, daily insights and your protocol are written from the same kinds of data; if you kept a diary in Gemut’s web app, your daily insight also uses its recent entries. In Mental mode Noa receives only your conversation, not your profile or results.

Anthropic processes this data only to produce the result for you. Under its commercial terms it may not train models on it. It deletes the data within 30 days, unless it must keep it longer to enforce its usage policy or to comply with the law. Our contract is with Anthropic Ireland, Limited; the processing takes place with Anthropic, PBC in the United States.

Voyage AI

To find relevant passages in our library of medical and scientific sources, Gemut sends Voyage AI the text of your latest message to Noa, in Health and in Mental mode. Nothing else from your account goes with it, but the message itself can contain a result, for example when you send a suggested question such as “Tell me about my vitamin D result of 62 nmol/L”. Voyage AI does not keep this text and does not use it to train models.

AI can be wrong. Check values against your original document. Nothing in Gemut replaces a doctor: see our Medical Disclaimer and Terms of Service.

7. Who processes your data

We use these service providers. Each processes data only on our instructions and under a data processing agreement, except where this section says otherwise.

• Supabase: database, file storage and sign-in. Your data is stored in Frankfurt, Germany.
• Vercel: hosting of the app’s server, which runs in Frankfurt, and of the website, with Vercel Web Analytics.
• Anthropic and Voyage AI: AI processing, as described in section 6.
• RevenueCat: managing subscriptions bought in the App Store.
• AppsFlyer: advertising measurement in the app (see below).
• Meta: advertising measurement in the app, through the Facebook SDK (see below).
• Resend: sending emails about your account, and keeping the newsletter list.
• Our email provider: the mailbox that receives your messages to support@gemut.health.

Advertising measurement

To learn which advertising brings people to the Gemut app, the app uses AppsFlyer (AppsFlyer Ltd., Israel, with processing in the EU) and Meta (Meta Platforms Ireland Ltd., through the Facebook SDK).

AppsFlyer receives: a device identifier for apps (IDFV), the app version, the iOS version, the IP address, your account’s internal identifier, and app events — install, app opens, sign-up, onboarding started and completed, first lab panel added, your answer to the tracking request, paywall shown, purchase started or cancelled, free trial started, subscription started and its price.

Meta receives through the Facebook SDK: the install and app opens, with the device identifier for apps (IDFV), the app version, the iOS version and the IP address; and, forwarded to it by AppsFlyer, sign-up, free trial started and subscription started with its price.

Both receive your advertising identifier (IDFA) only if you allow tracking in iOS (App Tracking Transparency). Neither ever receives lab results, health data, Noa conversations or files. The app shows no advertising. You can withdraw permission at any time in iPhone Settings → Privacy & Security → Tracking.

AppsFlyer processes this data on our instructions and under a data processing agreement. Meta decides for itself how it uses what the Facebook SDK sends it, so each of us is responsible for our own part of that processing, and Meta’s own privacy policy applies to its part.

Apple processes data as an independent controller when you buy through the App Store or sign in with Apple; Apple’s privacy policy applies to that processing.

We disclose data to an authority or a court only when the law requires it, and only after checking that the request is lawful. If Gemut’s business is sold or merged, your data passes to the new owner under this policy, and we will tell you. Apart from the providers and the advertising-measurement partners named in this section, we share your data with no one else.

When you share a report or a card from the app, it is made on your iPhone and goes only where you send it.

8. Where your data is stored

Your account, profile, results, documents and conversations are stored in the EU, in Frankfurt, Germany. Some processing takes place outside the EU, mainly in the United States: AI processing by Anthropic and Voyage AI, subscription checks by RevenueCat, emails sent through Resend, and parts of our hosting providers’ logs. Several of our providers are US companies (Anthropic, Voyage AI, RevenueCat, Vercel, Supabase and Resend). AppsFlyer is an Israeli company and processes our events on servers in the EU; Israel has its own adequacy decision from the European Commission. Meta Platforms Ireland is in the EU and passes data to Meta in the United States under its own safeguards. When personal data goes outside the European Economic Area, it is protected by the European Commission’s adequacy decision for the EU–U.S. Data Privacy Framework, where the provider is certified under it, or by the Commission’s Standard Contractual Clauses.

9. How long we keep your data

• Your account and everything in it: as long as your account exists.
• Uploaded documents: as long as your account exists, including files that could not be read. To delete a test or a file sooner, write to us.
• Conversations with Noa: until you delete them in the app, or your account. A review of a test stays with the test, also after you delete the conversation in which it was written.
• At AI providers: as described in section 6.
• Purchase records: RevenueCat keeps your purchase history, linked to your account’s identifier but not to your name or email, also after your account is deleted, for accounting and tax.
• Advertising identifiers: the identifiers kept in your profile — the AppsFlyer identifier, IDFV, IDFA and the last IP address — stay as long as your account exists and are erased with it. What AppsFlyer and Meta have already received, they keep under their own terms.
• Emails with us: as long as we need them to deal with your request and keep a record of it.
• Waitlist and newsletter addresses: until you unsubscribe or ask us to delete them.
• Technical logs: for a short time, usually days, at most a few weeks.

Deleting your account

In the app, go to More → Settings → Legal & data → Delete my account. Your account is erased 30 days later. Until then you can cancel the deletion: sign in and choose Cancel deletion. After 30 days we erase your account and the data in it: your profile, results, documents, conversations, protocol and the log of actions in your account. We keep a record that an account with this identifier was deleted, and the purchase records described above. Copies in our encrypted backups disappear as the backups are replaced, within 30 days.

Deleting the app does not delete your account. Deleting your account does not cancel a subscription bought in the App Store: cancel it in your Apple ID settings.

10. Your rights

Under the GDPR you have the right to:

• access your data and get a copy. In the app, More → Settings → Legal & data → Export my data saves your profile and results as a file. For anything else, such as your documents or conversations, write to us;
• correct your data, in your profile in the app or by writing to us;
• delete your data: delete conversations in the app, delete your account (section 9), or write to us to delete a single test or file;
• restrict processing, and object to processing based on our legitimate interests;
• take your data to another service (data portability);
• withdraw your consent at any time, by writing to us (see section 5 for what this means);
• complain to a supervisory authority: in the Czech Republic, the Office for Personal Data Protection (Úřad pro ochranu osobních údajů, uoou.gov.cz), or the authority where you live or work.

Write to support@gemut.health. We answer within one month. To protect your data we may ask you to write from the email address of your account.

11. Security

• Connections to Gemut are encrypted (HTTPS), and your data is encrypted at rest.
• Our servers and database check that every request comes from the owner of the data. Your documents are kept in private storage, and links to open them work only for a short time.
• Only the people who run Gemut can access production data, and only to provide the service, for example to fix a problem you reported.

No system is perfectly secure. If a breach puts your data at risk, we will tell you and the supervisory authority as the law requires.

12. Children

Gemut is for adults: you must be at least 18 to use it. We do not knowingly collect data from children. If we learn that a child has an account, we delete it.

13. Changes to this policy

We may update this policy. We will change the date at the top and, before significant changes take effect, tell you in the app or by email.

14. Contact

Innolex Corp. s.r.o.
Budovcova 188/1, 130 00 Praha, Czech Republic
support@gemut.health