The Loretta App is operated by Loretta Health UG, a company incorporated in Germany with registered office in Berlin (the "Controller", "we", "us").
Data Protection Officer (DPO): Daniel Townsend reachable at mail@loretta.care.
Under Article 27 GDPR no EU representative is required as we are established in Germany.
This policy explains how we process personal data when you download, install, or use the Loretta App. The Loretta App is a wellness and prevention tool. It is not a medical device under Regulation (EU) 2017/745 (MDR). It does not diagnose, treat, cure, or prevent disease and is not a substitute for medical advice from a qualified healthcare professional.
Separate policies apply to our website (loretta-health.com) and to our enterprise product Loretta WorkIntelligence. This policy does not cover them.
The detail follows in later sections. This summary is provided for clarity and does not replace it.
| Topic | Detail |
|---|---|
| What we collect | Account data, self-reported health information, wearable and sensor data you choose to share, and risk scores generated by our models |
| Why | To provide the App, generate your prevention insights, secure the service, and (with your consent) improve our models |
| Legal basis | Your explicit consent under Art. 9(2)(a) GDPR for health data; contract under Art. 6(1)(b) for account data; legitimate interest under Art. 6(1)(f) for security |
| Where data is stored | Loretta-controlled servers located in the European Union (Germany) |
| Sharing | Limited processors only (cloud infrastructure, analytics, support). No advertising. No sale of data. No data brokers. |
| Your rights | Access, rectification, deletion, restriction, portability, objection, and withdrawal of consent at any time |
We rely on the following legal bases under the GDPR. Where the processing concerns health data, we additionally rely on the conditions in Article 9(2) GDPR.
| Purpose | What we do | Legal basis |
|---|---|---|
| Provide the App | Create your account, authenticate you, sync your data across your devices | Art. 6(1)(b) contract |
| Process health data to generate insights | Run risk models, produce digital twin states, return prevention recommendations | Art. 9(2)(a) explicit consent |
| Security and abuse prevention | Detect intrusions, prevent fraud, maintain audit logs | Art. 6(1)(f) legitimate interest |
| Product improvement and model training | Use pseudonymised or aggregated data to improve our models | Art. 9(2)(a) explicit, separate, opt-in consent |
| Compliance with legal obligations | Tax, accounting, statutory record retention | Art. 6(1)(c) legal obligation |
| Customer support | Respond to your enquiries | Art. 6(1)(b) contract or Art. 6(1)(f) legitimate interest |
Before we process any health data we ask you to give explicit, informed consent through a layered in-App consent screen. We record the time, the version of this policy, and the specific purposes you consented to.
You can withdraw consent at any time in the App under Settings → Privacy → Consents, or by emailing mail@loretta.care. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. If you withdraw consent for the core health processing, we will no longer be able to provide the App's prevention features, and your account may be deactivated on request.
All personal data is processed on servers physically located in the European Union. Primary storage infrastructure is operated by IONOS Group SE (Germany). LLM-powered chat features are processed on infrastructure operated by Scaleway SAS (France). Voice chat functionality is processed by Mistral AI SAS (France). Each of these sub-processors acts under a data processing agreement in accordance with Art. 28 GDPR. We do not transfer personal data outside the European Economic Area (EEA) for routine processing.
If a sub-processor in a third country becomes necessary in the future, we will only do so on the basis of a Commission adequacy decision under Art. 45 GDPR or, where unavailable, Standard Contractual Clauses under Art. 46 GDPR together with appropriate supplementary measures, and we will update this policy.
We share personal data only with carefully selected processors acting on our documented instructions under Art. 28 GDPR. Categories include:
We do not sell personal data. We do not share personal data with advertising networks. We do not share personal data with data brokers. We do not use your health data for marketing.
Loretta's broader research and platform infrastructure uses federated learning, where models are trained without raw personal data leaving the controlled environment. The consumer App does not at present participate in such federated training. If we introduce that capability, it will be opt-in, governed by a separate consent flow, and described in an updated version of this policy.
Where we conduct or contribute to scientific research, we comply with the Gesundheitsdatennutzungsgesetz (GDNG, in force 26 March 2024), the European Health Data Space Regulation (EHDS, in force 26 March 2025), Art. 9(2)(j) GDPR, and § 27 BDSG. Any secondary use of your data for research will be either fully anonymised or carried out on the basis of an additional legal authorisation, and you will be informed in advance.
| Category | Retention |
|---|---|
| Account data | Until you delete your account, plus up to 30 days for backups |
| Health and wellness data | Until you delete it in-App, or until account deletion |
| Risk scores and inferred outputs | Until source data is deleted; recomputed on change |
| Crash and diagnostic logs | Maximum 90 days |
| Audit and security logs | Up to 12 months |
| Invoices and accounting records | 10 years (§ 147 AO, German Fiscal Code) |
Under the GDPR you have the following rights:
To exercise any right, contact mail@loretta.care. We respond within one month (extendable by two further months for complex requests, with notice). All in-App rights actions (export, deletion) are also available under Settings → Privacy.
You also have the right to lodge a complaint with a supervisory authority. Our lead supervisory authority is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59-61, 10555 Berlin, mailbox@datenschutz-berlin.de.
We apply appropriate technical and organisational measures under Art. 32 GDPR. These include:
The Loretta App is not directed at and may not be used by anyone under 16. We do not knowingly process the personal data of children under 16. If you believe a child has provided us with personal data, please contact mail@loretta.care and we will delete it.
Loretta uses AI and statistical models to generate risk scores and prevention recommendations. These outputs are decision-support tools. They do not produce legal or similarly significant effects within the meaning of Art. 22 GDPR. You retain full control over whether and how to act on any output.
Our models are developed in accordance with the EU AI Act (Regulation (EU) 2024/1689). Where applicable obligations apply, including for high-risk AI systems, we will comply within the regulatory timelines, including the December 2027 deadline for high-risk system requirements.
The App itself does not use browser cookies. It uses a small number of software development kits (SDKs) for crash reporting, push notifications, and pseudonymous product analytics. Non-essential SDKs are disabled by default and only activated after you give consent on first launch. You can review and change your choices at any time under Settings → Privacy → Tracking & analytics.
Apple App Store and Google Play require us to declare data collection practices on the store listing. Those disclosures are summaries; this policy is the authoritative document. Where any inconsistency arises, this policy prevails.
We may update this policy from time to time. Material changes will be notified in-App with a clear summary at least 30 days before they take effect. The current version is always available in the App and at loretta-health.com/legal/privacy.
Loretta Health UG
Donaustraße 43 12043
Berlin, Germany
Email: mail@loretta.care