Privacy policy
- First published
- This version effective since
- Last updated
This policy explains what personal data Liv processes, why, on what legal basis, who receives it, where it is processed, how long we keep it, and what rights you have. Next to each part of the text is a plain-language summary (above it on small screens). The summaries help you find your way; the full text is what applies.
1. Who is responsible
This policy applies to the website liv.health, the Liv web app, the Liv mobile apps for iOS and Android, our events and all related services (together, the "Services"). The controller within the meaning of Art. 4(7) of the General Data Protection Regulation ("GDPR") is:
Liv Longevity Labs UG (haftungsbeschränkt), Kolonnenstraße 8, 10827 Berlin, Germany. Registered at Amtsgericht Charlottenburg, HRB 262707 B. Managing director: Amer Hamzeh. Email: privacy@liv.health.
For every question about your data and for every request to exercise your rights, write to privacy@liv.health.
2. What data we process
Depending on which Services you use, we process the following categories of personal data:
- Account data: name, email address, date of birth, biological sex, language, and, if you sign in with Google or Apple, the basic profile data that provider shares with us.
- Wellness data you enter or connect: measurements such as weight, body composition, blood pressure, heart rate, heart-rate variability, VO2 max and grip strength; questionnaire answers, goals and plans. In the mobile app, only if you allow it, we read the measurement types you release from Apple Health or Google Health Connect, including in the background, and store them in your Liv account.
- Test results: epigenetic results from TruDiagnostic, blood-panel results from Remi Health, and measurements taken at a Liv event or by a partner you book through Liv (for example VO2 max or grip strength), together with the reports, scores and recommendations we derive from them.
- Sample collection details: when you confirm that you collected a sample, the collection date and the conditions you record (fasting, time of day, menstrual-cycle day, alcohol, illness, hard exercise, and a free-text note).
- LivAI Chat conversations: the messages you write, the answers LivAI Chat gives, conversation titles, and any rating or feedback you leave on an answer.
- Purchase data: products and plans bought, amounts, promo codes used, billing and shipping address, and a Stripe customer identifier. Card details are entered directly with Stripe; we never see or store your full card number.
- Marketplace and booking data: products you buy from partners, appointments you book, and whether an appointment took place, was cancelled or missed.
- Kit identifiers: the three-word Liv kit ID (for example quiet-cedar-dawn) printed on your test kit and linked to your account.
- Circles: the circles you create or join and the people you invite by email.
- Communication data: emails and messages you send us, and your email preferences.
- Usage and device data: IP address, device and browser type, operating system, language, pages and screens viewed, actions taken in the Services, and error reports.
- Partner account data: if you manage a partner profile on our marketplace, your name, email address, role, and any photo or text you publish on that profile.
Our legal counsel classifies the data you share with Liv as wellness data rather than health data within the meaning of Art. 9 GDPR, because Liv provides wellness and lifestyle information, not diagnosis or treatment. We nevertheless protect all of it with the same care.
3. What we do not do
- We do not sell your personal data.
- We do not buy data about you from data brokers.
- We do not use your measurements, test results or LivAI Chat conversations to target advertising, on our Services or anywhere else.
- We do not access your device location.
- We do not collect biometric identifiers such as face or fingerprint data.
4. Purposes, legal bases and retention
For each purpose we list the legal basis under Art. 6(1) GDPR and how long we keep the data. Where we rely on legitimate interests (Art. 6(1)(f) GDPR), the interest is named in the table.
To provide the Services you use:
- Purpose
- Providing your account and the Services: sign-in, profile, measurements, results, reports, plans and Circles.
- Legal basis
- Performance of a contract, Art. 6(1)(b).
- Retention
- Until you ask us to delete your account.
- Purpose
- Running tests: shipping kits, registering samples with our lab partners and importing results, including measurement reports from events and partner sessions.
- Legal basis
- Performance of a contract, Art. 6(1)(b).
- Retention
- Until you ask us to delete your account.
- Purpose
- Operating LivAI Chat (section 5).
- Legal basis
- Performance of a contract, Art. 6(1)(b).
- Retention
- Conversations: until you delete them or your account.
- Purpose
- Payments, invoices and accounting.
- Legal basis
- Performance of a contract, Art. 6(1)(b); legal obligation, Art. 6(1)(c).
- Retention
- Up to 10 years, as required by § 257 HGB and § 147 AO.
- Purpose
- Marketplace purchases and bookings with partners (section 7).
- Legal basis
- Performance of a contract, Art. 6(1)(b).
- Retention
- Until you ask us to delete your account; invoices as above.
- Purpose
- Service emails: sign-in codes, order, shipping and booking confirmations, reminders.
- Legal basis
- Performance of a contract, Art. 6(1)(b).
- Retention
- Delivery logs are deleted by our email providers after a limited period.
- Purpose
- Support and answering your requests.
- Legal basis
- Performance of a contract, Art. 6(1)(b); legitimate interests, Art. 6(1)(f): helpful support.
- Retention
- Up to 3 years after the request is closed.
| Purpose | Legal basis | Retention |
|---|---|---|
| Providing your account and the Services: sign-in, profile, measurements, results, reports, plans and Circles. | Performance of a contract, Art. 6(1)(b). | Until you ask us to delete your account. |
| Running tests: shipping kits, registering samples with our lab partners and importing results, including measurement reports from events and partner sessions. | Performance of a contract, Art. 6(1)(b). | Until you ask us to delete your account. |
| Operating LivAI Chat (section 5). | Performance of a contract, Art. 6(1)(b). | Conversations: until you delete them or your account. |
| Payments, invoices and accounting. | Performance of a contract, Art. 6(1)(b); legal obligation, Art. 6(1)(c). | Up to 10 years, as required by § 257 HGB and § 147 AO. |
| Marketplace purchases and bookings with partners (section 7). | Performance of a contract, Art. 6(1)(b). | Until you ask us to delete your account; invoices as above. |
| Service emails: sign-in codes, order, shipping and booking confirmations, reminders. | Performance of a contract, Art. 6(1)(b). | Delivery logs are deleted by our email providers after a limited period. |
| Support and answering your requests. | Performance of a contract, Art. 6(1)(b); legitimate interests, Art. 6(1)(f): helpful support. | Up to 3 years after the request is closed. |
Only with your consent:
- Purpose
- Newsletter, event and product-update emails.
- Legal basis
- Consent, Art. 6(1)(a).
- Retention
- Until you unsubscribe.
- Purpose
- Web analytics and session recordings on the website (section 9).
- Legal basis
- Consent, Art. 6(1)(a) together with § 25(1) TDDDG.
- Retention
- Until you withdraw consent; recordings up to 90 days.
- Purpose
- Measuring our advertising (section 9).
- Legal basis
- Consent, Art. 6(1)(a) together with § 25(1) TDDDG.
- Retention
- Until you withdraw consent.
| Purpose | Legal basis | Retention |
|---|---|---|
| Newsletter, event and product-update emails. | Consent, Art. 6(1)(a). | Until you unsubscribe. |
| Web analytics and session recordings on the website (section 9). | Consent, Art. 6(1)(a) together with § 25(1) TDDDG. | Until you withdraw consent; recordings up to 90 days. |
| Measuring our advertising (section 9). | Consent, Art. 6(1)(a) together with § 25(1) TDDDG. | Until you withdraw consent. |
Based on our legitimate interests or a legal obligation:
- Purpose
- Monitoring and improving the quality of LivAI Chat answers (section 5).
- Legal basis
- Legitimate interests, Art. 6(1)(f): answers that are correct and safe.
- Retention
- Up to 400 days.
- Purpose
- Product analytics in the mobile app and server-side usage events (section 9).
- Legal basis
- Legitimate interests, Art. 6(1)(f): understanding which features work so we can improve them.
- Retention
- Until you ask us to delete your account.
- Purpose
- Error monitoring, security and bot protection.
- Legal basis
- Legitimate interests, Art. 6(1)(f): a working and secure service.
- Retention
- Up to 90 days.
- Purpose
- Understanding how sample-collection conditions affect results, so we can make our tests more reliable.
- Legal basis
- Legitimate interests, Art. 6(1)(f): reliable tests.
- Retention
- Until you ask us to delete your account.
- Purpose
- Legal obligations and defending legal claims.
- Legal basis
- Legal obligation, Art. 6(1)(c); legitimate interests, Art. 6(1)(f).
- Retention
- For the statutory period or until the claim is resolved.
| Purpose | Legal basis | Retention |
|---|---|---|
| Monitoring and improving the quality of LivAI Chat answers (section 5). | Legitimate interests, Art. 6(1)(f): answers that are correct and safe. | Up to 400 days. |
| Product analytics in the mobile app and server-side usage events (section 9). | Legitimate interests, Art. 6(1)(f): understanding which features work so we can improve them. | Until you ask us to delete your account. |
| Error monitoring, security and bot protection. | Legitimate interests, Art. 6(1)(f): a working and secure service. | Up to 90 days. |
| Understanding how sample-collection conditions affect results, so we can make our tests more reliable. | Legitimate interests, Art. 6(1)(f): reliable tests. | Until you ask us to delete your account. |
| Legal obligations and defending legal claims. | Legal obligation, Art. 6(1)(c); legitimate interests, Art. 6(1)(f). | For the statutory period or until the claim is resolved. |
Where we rely on legitimate interests, you have the right to object (section 13).
5. LivAI Chat
LivAI Chat is an AI assistant in the Services. It answers questions about your measurements, results and goals, and to do so it can look up the data in your Liv account.
When you write to LivAI Chat, we send the following to Anthropic, PBC (San Francisco, USA), which runs the Claude language models that generate the answers: your message and the earlier messages in the conversation, your age and biological sex, and the measurements, results and focus areas LivAI Chat looks up to answer you. Anthropic processes this as our processor and, under our commercial terms, does not use it to train its models. A shorter model call generates a title for each conversation from its first messages.
We chose Anthropic because of how it builds its models. Anthropic trains Claude with a method it calls Constitutional AI: the model is given a written set of principles, its constitution, and during training it learns to judge and improve its own answers against those principles, guided by feedback that follows them rather than by human ratings alone. Anthropic publishes this constitution, so anyone, including us, can read the rules the model is trained to follow: to be genuinely helpful while being honest and avoiding harm.
For an assistant that reads your measurements and results, we think that matters more than anything else. We can check the principles behind its answers instead of taking them on trust. Anthropic is also organised as a public benefit corporation, which obliges it to weigh the public good alongside profit, and it does not train its models on the data we send. In our assessment, no other provider currently combines this openness with models of comparable quality, which is why we trust Anthropic more than any alternative.
Our long-term goal is to run our own models on infrastructure we control. We are not there yet. Until we are, we consider Anthropic the best available choice. If we change provider, we will update this policy before the change takes effect.
We record each LivAI Chat exchange in LangSmith, a monitoring service from LangChain, Inc., hosted in the EU. A record contains the conversation, the data LivAI Chat looked up, your Liv user ID, a one-way hash of your email address, and any rating or feedback you leave. We use these records to find errors and improve the quality and safety of answers, and keep them for up to 400 days.
Your conversations are stored in your Liv account so that you can return to them. You can delete any conversation at any time. Deleting it removes it from your account; monitoring records in LangSmith are removed when their retention period ends or when you ask us to delete your data.
Our team also uses an internal AI assistant, likewise powered by Anthropic, to answer support and operational questions. It can look up member data, including name, email address, date of birth and measurements, when a team member needs it to help you.
LivAI Chat gives general wellness information. It is not a medical device, does not diagnose or treat anything and does not replace a doctor. Answers can be wrong. In an emergency, call 112.
6. Circles
Circles let you share your Liv data with people you choose, such as your family. Everyone in a circle can see the profile, measurements, reports and test results of every other member, and can edit other members’ profiles and plans. We only process this sharing because you asked for it (Art. 6(1)(b) GDPR).
Only invite people you trust with this data. When you leave a circle, its members lose access to your data from that moment on.
7. Labs, measurement partners and marketplace partners
TruDiagnostic LLC (Lexington, Kentucky, USA) analyses epigenetic kits. It receives your blood sample, labelled only with your kit ID, together with your date of birth, biological sex, collection date and a random Liv user identifier. It does not receive your name, email address or postal address, and it cannot link the kit to you without information only Liv holds. TruDiagnostic processes this data for us and is additionally responsible for its own statutory laboratory records.
Remi Health GmbH (Knesebeckstraße 33–34, 10623 Berlin) processes blood-panel kits. To match your sample to you, Remi receives your first and last name, date of birth, sex, kit activation code and sample date, and sends the results back to us.
VentriJect ApS (Denmark) calculates your VO2 max from the measurement taken at a Liv event or a session booked through Liv, as our processor.
When you are measured at a Liv event or by a partner at a session booked through Liv, the partner or the maker of the measuring device sends us the measurement report. Our team matches each report to your booking and checks it before the results appear in your account.
Our marketplace partners (for example practices, clinics and product brands) are independent controllers for the services and products they provide to you. When you buy from a partner through Liv, the payment is made to the partner’s own Stripe account: a customer record containing your email address and your Liv user ID is created there, and the partner can see the purchase. Partners can also see the Liv products and services you have bought from them. When you book an appointment, the partner receives your name, email address, the service and the time. If you follow a partner’s link to their own website, their privacy policy applies there.
When your plan includes a partner product, such as RIISE supplements, we pass the partner the order details needed to fulfil it. Shipping carriers receive your name and shipping address to deliver your kit.
8. Service providers and where your data is processed
We use the following service providers. Unless the table says otherwise, they process data only on our instructions under a data processing agreement pursuant to Art. 28 GDPR. These providers process data in the EU or the European Economic Area:
- Provider
- Supabase, Inc.
- Purpose
- Database, sign-in and file storage for all account data
- Location
- Frankfurt, Germany
- Provider
- LangChain, Inc. (LangSmith)
- Purpose
- Quality monitoring of LivAI Chat
- Location
- EU
- Provider
- PostHog, Inc.
- Purpose
- Product analytics, session recordings, feature flags
- Location
- Frankfurt, Germany
- Provider
- Functional Software, Inc. (Sentry)
- Purpose
- Error monitoring
- Location
- Frankfurt, Germany
- Provider
- Stripe Payments Europe, Ltd.
- Purpose
- Payments; independent controller for payment processing
- Location
- Dublin, Ireland
- Provider
- Brevo (Sendinblue SAS)
- Purpose
- Newsletter, email preferences and purchase confirmations
- Location
- France
- Provider
- Usercentrics A/S (Cookiebot)
- Purpose
- Cookie consent management
- Location
- Copenhagen, Denmark
- Provider
- Apple Distribution International Ltd.
- Purpose
- Sign in with Apple; independent controller
- Location
- Cork, Ireland
- Provider
- Sanity AS
- Purpose
- Content management for our blog and website content
- Location
- Oslo, Norway
- Provider
- Remi Health GmbH
- Purpose
- Blood-panel analysis (section 7)
- Location
- Berlin, Germany
- Provider
- VentriJect ApS
- Purpose
- VO2 max calculation (section 7)
- Location
- Denmark
| Provider | Purpose | Location |
|---|---|---|
| Supabase, Inc. | Database, sign-in and file storage for all account data | Frankfurt, Germany |
| LangChain, Inc. (LangSmith) | Quality monitoring of LivAI Chat | EU |
| PostHog, Inc. | Product analytics, session recordings, feature flags | Frankfurt, Germany |
| Functional Software, Inc. (Sentry) | Error monitoring | Frankfurt, Germany |
| Stripe Payments Europe, Ltd. | Payments; independent controller for payment processing | Dublin, Ireland |
| Brevo (Sendinblue SAS) | Newsletter, email preferences and purchase confirmations | France |
| Usercentrics A/S (Cookiebot) | Cookie consent management | Copenhagen, Denmark |
| Apple Distribution International Ltd. | Sign in with Apple; independent controller | Cork, Ireland |
| Sanity AS | Content management for our blog and website content | Oslo, Norway |
| Remi Health GmbH | Blood-panel analysis (section 7) | Berlin, Germany |
| VentriJect ApS | VO2 max calculation (section 7) | Denmark |
These providers process data in the USA, fully or in part:
- Provider
- Vercel, Inc.
- Purpose
- Hosting of the website and web app; privacy-friendly page statistics without cookies
- Location
- USA (servers in Washington, D.C.); content delivered from Frankfurt
- Provider
- Anthropic, PBC
- Purpose
- AI models for LivAI Chat and our internal assistant
- Location
- USA
- Provider
- ActiveCampaign, LLC (Postmark)
- Purpose
- Sign-in codes, booking emails and newsletter confirmation links
- Location
- USA
- Provider
- Cloudflare, Inc. (Turnstile)
- Purpose
- Bot protection on sign-in forms
- Location
- USA
- Provider
- Google Ireland Limited
- Purpose
- Tag Manager, Google Analytics and Google Ads measurement (only with consent), web fonts, Google sign-in
- Location
- Ireland and USA
- Provider
- Reclaim.ai, Inc.
- Purpose
- Scheduling onboarding calls
- Location
- USA
- Provider
- Salesforce, Inc. (Slack)
- Purpose
- Internal order notifications, with email addresses masked
- Location
- USA
- Provider
- Luma (lu.ma)
- Purpose
- Event registration; independent controller when you register on lu.ma
- Location
- USA
- Provider
- TruDiagnostic LLC
- Purpose
- Epigenetic analysis (section 7)
- Location
- Lexington, USA
| Provider | Purpose | Location |
|---|---|---|
| Vercel, Inc. | Hosting of the website and web app; privacy-friendly page statistics without cookies | USA (servers in Washington, D.C.); content delivered from Frankfurt |
| Anthropic, PBC | AI models for LivAI Chat and our internal assistant | USA |
| ActiveCampaign, LLC (Postmark) | Sign-in codes, booking emails and newsletter confirmation links | USA |
| Cloudflare, Inc. (Turnstile) | Bot protection on sign-in forms | USA |
| Google Ireland Limited | Tag Manager, Google Analytics and Google Ads measurement (only with consent), web fonts, Google sign-in | Ireland and USA |
| Reclaim.ai, Inc. | Scheduling onboarding calls | USA |
| Salesforce, Inc. (Slack) | Internal order notifications, with email addresses masked | USA |
| Luma (lu.ma) | Event registration; independent controller when you register on lu.ma | USA |
| TruDiagnostic LLC | Epigenetic analysis (section 7) | Lexington, USA |
Some of these providers process data in the USA, or are US companies that may access data held in the EU. For transfers to the USA we rely on the EU-U.S. Data Privacy Framework (adequacy decision under Art. 45 GDPR) where the recipient is certified under it, and otherwise on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). You can request a copy of the safeguards at privacy@liv.health.
10. Mobile app permissions
The Liv app only asks for permissions it needs:
- Apple Health / Google Health Connect (optional): read access to VO2 max, resting heart rate, heart-rate variability, heart-rate recovery, blood pressure, weight, lean body mass and body fat, including in the background so your data stays current. Liv only reads this data, never writes to it, and stores it in your Liv account. You can revoke access at any time in your phone’s settings.
- Camera (optional): to scan your payment card at checkout. The image is processed on your device by Stripe’s payment form.
Data from Apple Health and Google Health Connect is never used for advertising or passed to data brokers.
11. Emails
We send service emails, such as sign-in codes, order, shipping and booking confirmations, and reminders, because they are part of the Services. When you create an account, your email address is stored with our email provider Brevo so that we can send these messages and manage your preferences.
Newsletters, event invitations and product updates are sent only if you have subscribed. When you subscribe, we first email you a link to confirm; only after you confirm do we add you to the list, together with when you confirmed, where you signed up and your language, so that we can show your consent. If you are on our blocklist and subscribe and confirm again, we lift the blocklist for the newsletter only. You can choose which emails you receive in Settings → Emails, and every newsletter contains an unsubscribe link. After you unsubscribe, we keep your email address on a blocklist so that you are not emailed again. This is based on our legitimate interest in respecting your choice (Art. 6(1)(f) GDPR).
13. Your rights
You have the right to:
- access the data we hold about you and receive a copy (Art. 15 GDPR);
- have incorrect data corrected (Art. 16 GDPR);
- have your data deleted (Art. 17 GDPR), except where we are legally required to keep it;
- restrict processing (Art. 18 GDPR);
- receive your data in a machine-readable format (Art. 20 GDPR);
- object to processing based on legitimate interests (Art. 21 GDPR), and to direct marketing at any time;
- withdraw any consent with effect for the future (Art. 7(3) GDPR);
- lodge a complaint with a supervisory authority (Art. 77 GDPR), for example the Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59–61, 10555 Berlin.
To exercise any of these rights, including deleting your account, email privacy@liv.health from the address linked to your account. We respond within one month.
14. Security
Data is encrypted in transit (TLS) and at rest by our hosting providers. Access to your data is restricted by database access rules, and only team members who need it for their work can access production data. We choose providers that meet recognised security standards. If a data breach puts your rights at risk, we will inform the supervisory authority and, where required, you, as set out in Art. 33 and 34 GDPR.
15. Minors
The Services are intended for adults aged 18 and over. If you believe that someone under 18 has given us their data, please let us know at privacy@liv.health and we will delete it.
16. No automated decisions
We do not make decisions based solely on automated processing that have legal effects on you or similarly significantly affect you (Art. 22 GDPR). Scores, reports and LivAI Chat answers are information for you, not decisions about you.
17. Changes to this policy
We update this policy when our Services, providers or the law change. The dates at the top show when this version took effect and when it was last updated. We will tell you directly about significant changes before they take effect.