Privacy Policy

In summary

Wellby stores the data needed to show your progress and provide the features you choose to use. We do not sell your data. We share only what is necessary with Meta to measure our advertising, and only if you allow it — never health data.

Data we store

Account data: email address and authentication credentials. Your password is processed by the authentication service and cannot be read by us.

Profile data: display name, sex (if provided), date of birth, height, weight, country, goal, activity level and dietary restrictions. This data allows us to calculate and personalise targets.

Usage data: meals and foods, weight progress, workouts, sets and loads, water intake, fasting, challenges and achievements.

Conversations with Wellby: the messages you type or speak, the responses and the memory Wellby keeps to understand you better (for example, what you prefer to eat or what you find most difficult), linked to your account.

GPS workout data: when you choose to record a workout route on your iPhone or watch, we store the route points (coordinates and time), altitude, distance and pace associated with that workout. The route is recorded only during the workout, including when the screen is off, and you can disable recording for each workout.

Group data, when you participate: group name, participants, workout posts, attached photographs and messages.

Why we use data and our legal basis

We process account, profile and usage data to perform our contract with you: to create and protect your account, calculate targets, display history, synchronise your records, manage your subscription and provide the features you request.

The connection to Apple Health or Health Connect is activated only when you choose it and authorise it in the system interface. Optional artificial intelligence analyses ask for permission before sending a photograph or PDF document to Google.

We may process minimal technical data to prevent fraud, protect the app, diagnose failures and improve reliability on the basis of our legitimate interests, after balancing your rights. We also process data when necessary to comply with a legal obligation or defend legal claims.

With your consent, we measure the effectiveness of Wellby advertisements as described under “Advertising measurement”. You may withdraw your consent at any time without affecting processing carried out before withdrawal.

Health data

Weight, nutrition, hydration and workout information may reveal sensitive information about your health. This data is stored on your device and on our servers, with access linked to your account.

If you connect Apple Health on iPhone or Health Connect on Android, Wellby requests read access to your workouts and stores the summary of each one: activity type, start, end, duration, energy, distance and source app or device, when available. When you open an imported workout, Wellby also reads the measurements of that workout that you authorised and that the source app or watch recorded (route, heart rate, steps, cadence, power, elevation gain, laps, temperature and humidity, among others) and stores them with that workout, in your account, to show them to you. In Health Connect, the route of each workout is read only after you authorise it in the system window. Wellby only reads from Health Connect; it does not write to it. Data obtained from Apple Health and Health Connect is used only to provide these features: it is not sold, not used for advertising and not sent to artificial intelligence services.

When you start a workout in the Wellby app for Apple Watch, the watch asks for permission to create that workout in Apple Health and read heart rate and active energy during the session. Wellby stores the duration, energy and average heart rate in your history, when available, together with the exercises, sets, repetitions and loads you recorded. If you choose to record the route, the watch uses its GPS and sends the route to Wellby, which stores it with that workout. The Wellby app for Wear OS watches works in the same way: during a workout you start, it reads heart rate, calories and distance from the watch sensors and, if you choose, the route from its GPS, and sends them to Wellby, which stores them with that workout.

These connections are optional. You can stop synchronisation in Wellby Settings and change permissions in the iPhone Health settings or in Health Connect on Android. Signing out removes local data from that device. Deleting your account starts the deletion of associated data from our servers.

Photographs and artificial intelligence

When you choose to analyse a meal, label or workout sheet, the content is sent to Google through the paid version of the Gemini API to produce the requested result. Google acts as a business data processor. Under the terms of the paid service, it does not use prompts, files or responses to improve its products; it may retain limited logs for security, abuse prevention and legal compliance.

Meal photographs used only for analysis are not stored by Wellby after processing. We may retain minimal metadata showing that an analysis occurred in order to apply usage limits and investigate failures. You should not send documents containing another person’s personal data or information that is not necessary. The result is automated, may contain errors and should be reviewed by you before use.

When you communicate with Wellby by text or voice, the message and the context needed to respond (your profile, recent meals, workouts and weights, routines and Wellby memory) are sent to OpenAI through its paid API and, alternatively, to Google (Gemini). Under the terms of the paid services, these providers process the data only to respond and do not use it to train their models. Voice messages are transcribed by Google; Wellby does not store the audio, only the transcript. Your location and routes are never sent to artificial intelligence services.

If you request a route (for example, a 5 km circuit starting from your location), your location is sent to the openrouteservice routing service, which returns possible routes. The request does not include your account data.

Services we use

We use Supabase for authentication, database and storage; OpenAI and Google for conversations with Wellby and optional artificial intelligence analyses; Google also for voice transcription; openrouteservice to suggest routes; Resend to send access-code and account-recovery emails; RevenueCat to manage subscription status; Expo to deliver communications you authorise; Meta to measure Wellby advertisements if you allow it; and Apple or Google to process payments and distribute the app. These providers receive only the data required for their respective functions and are subject to applicable terms, security measures and data-protection obligations. We do not send health data to RevenueCat.

Barcode searches may query Open Food Facts, a public collaborative database. The query originates from your device and does not include your account data.

International data transfers

The Wellby controller is established in Brazil, and some providers may process data in Brazil, the United States or other countries. The European Union currently recognises Brazil as providing an adequate level of data protection. Meta may transfer data to the United States under the mechanisms described in its data policy. For other transfers covered by the GDPR, we use adequacy decisions, standard contractual clauses approved by the European Commission or another valid legal mechanism, as applicable.

Automated decision-making

Wellby uses calculations and artificial intelligence to suggest targets, estimate foods and structure imported content. These results support the requested features but do not produce legal decisions or similarly significant effects concerning you. You can correct data, reject suggestions and decide what to record or follow.

Security and incidents

We apply technical and organisational measures appropriate to the risk, including account-based access controls, encrypted connections and database access restrictions. No system is completely immune to incidents. If a personal data breach occurs that risks your rights, we will comply with the assessment, recording and notification obligations required by law.

Notifications

There are two types, and they work differently.

Reminders — water, workouts, fasting, rest between sets and achievements — are created and displayed by your device. They do not pass through our servers, and we have no record of whether you received them.

Communications are sent by us and fall into two categories. Notices — important changes, new features and service failures — are sent to people who allow notifications on their device. Promotions — discounts and campaigns — are sent only to people who expressly request them, and we store the date of that request. You can turn either category off at any time in Wellby Settings.

In either case, we store on our server an identifier for the app installation on that device (a system-provided "token"), the device operating system and the date it was last seen. This identifier does not contain your name, email address or health data, but it is linked to your account.

Delivery is handled by Expo’s notification infrastructure, which receives that identifier and the message text. We also store whether each communication was accepted or delivered on each device so that we can understand delivery failures.

You can turn notifications off completely in your system settings. When you sign out, the identifier for that device is removed from our server.

Advertising measurement

Wellby advertises on Facebook and Instagram. When you first open the app, we ask whether you allow us to measure those advertisements. If you refuse, nothing is sent to Meta.

If you allow it, the Meta SDK (Meta Platforms Ireland Limited) integrated into the app sends Meta information about installation, app openings and account creation, together with an installation identifier, technical device information and, if you authorise it at system level, the device advertising identifier. The start of a free trial and subscriptions, including value and currency, are reported to Meta by RevenueCat and associated with the same installation identifier. Meta uses this data to tell us which advertisements led to installations and subscriptions and to show Wellby advertisements to people who are more likely to be interested, in accordance with its own terms and data policy.

We never send Meta your name, email address, weight, meals, workouts, photographs or other health data.

On iPhone, the decision is made through the system tracking prompt. If you refuse, nothing is sent to Meta. You can change your choice at any time in Settings → Privacy or in iPhone Settings. When you sign out, the choice is deleted from that device and will be requested again.

How long we retain data

Profile, nutrition, weight, health, workout, challenge and group data is retained while your account is active because it is needed to provide the service and display your history.

When you delete your account, personal data is removed from the active database and photographs are deleted from storage as soon as the request is completed. Any identifiers that may exist in technical subscription receipts are anonymised. Protected residual copies may remain in backups for up to 30 days, without ordinary use, until they are replaced by the backup cycle.

Your Wellby conversation history, its stored memory and recorded routes are retained while your account is active and are deleted with it. Technical metadata from artificial intelligence analyses and notification delivery records are retained for 12 months. Installation identifiers that do not contact the service for 6 months are deleted. Support requests are retained for 24 months after resolution.

The minimum records needed to evidence subscriptions, benefits and transactions are retained for 5 years. A longer period is used only when required by a legal obligation or ongoing proceeding. Effectively anonymised data that can no longer identify a person may be used for statistics and service improvement.

Your rights

You can view and correct various data in Settings and delete your account within the app. You may also request access, correction, deletion, restriction, portability or objection to processing, and withdraw consent, by contacting support@mywellby.app. We may request reasonable information to confirm your identity and will respond within the legal time limit. Some rights depend on the legal basis and circumstances of the processing.

If you believe your rights have not been respected, you may lodge a complaint with the Portuguese Data Protection Authority (CNPD) or with the supervisory authority in the European Union country where you live or work.

Children

Wellby is not intended for anyone under 16, and we do not knowingly collect data from people we know to be under 16.

Changes to this policy

If there is a material change to the data we store or how we use it, we will provide notice before the change takes effect.