Privacy Policy

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This Policy explains what data the INVY app (iOS and Android) and the invy.health website collect, why, who we share it with, how long we keep it, and the rights you have. In short: we collect only what the app needs to work, we do not sell your data, we show no advertising, and we never use your health data for anything but the service itself. Everything can be deleted with one request inside the app.

1. Who is responsible for your data

The controller of your personal data is Sole Proprietor (FOP) Adriana-Viktoriia Mytsyk, 230a Kulparkivska St., Lviv, Ukraine ("INVY", "we"). Privacy questions: info@invy.health.

2. What data we collect

2.1. Account. Email address, password (stored only as a hash), name or nickname, avatar (optional), interface language, device time zone. When you sign in with Apple or Google: the provider's user identifier and email (for Apple this may be a private relay address such as @privaterelay.appleid.com; Apple shares your name only on the first sign-in).

2.2. Onboarding questionnaire. Sex, age (18 or older), height, weight, goal, symptoms, stress, activity and sleep levels, family history of diabetes, insulin resistance, pre-diabetes and, for women, PCOS. This is health data — a special category — processed only with your explicit consent.

2.3. Daily records. Meals (products, dishes, recognized names, nutrition, glycemic index and load, time), water, weight and other biometric values you enter manually or from lab results (glucose, HbA1c, insulin, HOMA-IR, lipid panel, etc.), medications and supplements (name, dose, schedule, intake log), workouts, streaks and achievements, the state of your panda tamagotchi.

2.4. Apple Health and Health Connect data. Only with your permission and read-only: steps, active (and on Android also total) calories burned, exercise time / exercise sessions, heart rate. Details in section 6.

2.5. Material for AI features. Meal photos, photos or PDFs of lab results, voice notes and the text of your INVY AI chat messages — when you send them yourself, and only after your separate consent to AI processing. Details in section 5.

2.6. Notifications. Device push token, platform, time zone, the history of notifications sent to you and your notification settings. Medication reminders are scheduled locally on the device.

2.7. Subscription. Your subscriber identifier in RevenueCat, plan type (Free / PRO), store (App Store / Google Play), subscription status and dates, billing events. We never receive or store payment card data — payments are processed by Apple and Google.

2.8. Technical data. IP address and standard request data in server logs (security and diagnostics; retention in section 8), device type and OS version as part of the push token. Crash reports: when the app crashes or hits an error, it sends Sentry a technical report — stack trace, device model, OS version, app version and update, internal user ID (no name, email, health records or IP address). For native-code crashes Sentry may derive an approximate location (country, region, city) from the connection's IP address; the IP address itself is not stored. Crash reports can be switched off: Settings → Privacy & data → "Crash reports". The app contains no third-party analytics SDKs and no advertising identifiers. Product analytics: the app and our server record usage events (for example: a screen or the paywall was opened, a meal was logged, a notification was opened, a trial started or was cancelled) with the time and simple parameters — such as the meal type, its calories and glycemic index, the paywall source or the subscription plan; never photos, voice recordings, lab results or chat messages. Events are stored on our own servers, linked to your account, used only to understand and improve INVY, and never shared with third parties, used for advertising or for tracking you across other apps. To object to product analytics, write to support@invy.health.

2.9. Website invy.health. Session and language cookies; Microsoft Clarity and Google Analytics 4 only after you accept the cookie banner, with IP anonymisation and no ad personalisation. The website collects no health data.

3. Why we process your data

We do not use your data for advertising, build advertising profiles, sell your data, or share it with data brokers, insurers, employers or lenders.

We process data under the Law of Ukraine "On Personal Data Protection" and, for users in the EU/EEA and the UK, the GDPR / UK GDPR:

5. AI processing: what we send and to whom

Some INVY features are performed by third-party AI providers. We send data to them only after your separate explicit consent to AI processing, and only when you trigger the feature yourself (send a photo, file, voice note or message) or when a feature listed below is enabled:

Consent. Before you first use any AI feature, the app shows what data goes to which provider and asks for your separate permission ("Allow" / "Not now"). Without consent the AI features are unavailable — except the emergency guidance in the chat, which is produced without AI; everything else in INVY works as usual. You can withdraw consent at any time: Settings → Privacy & data → "AI data processing". After a withdrawal we send nothing more to the AI providers and the monthly "Conclusion" is not produced; this does not affect processing before the withdrawal.

Rules:

6. Apple Health (HealthKit) and Health Connect data

7. Who we share data with (processors)

We share data only with processors acting on our instructions under a data processing agreement:

Every processor must provide at least the level of protection described in this Policy. We disclose data to no other third parties except where the law requires it (a lawful request from a public authority) or with your separate consent.

8. How long we keep data

9. Account deletion and export

Delete your account in the app: Settings → Account → Delete account. This irreversibly deletes the account, the questionnaire, all records (meals, water, biometrics and labs, medications, workouts, achievements), chat history and AI results, push tokens and notifications, Apple/Google sign-in identifiers and sessions. If you have already uninstalled the app, send a request from the email registered on the account to info@invy.health or use invy.health/en/delete-account. A PRO subscription must be cancelled separately in the App Store / Google Play — deleting the account does not cancel it.

Take your data: the CSV export is available to any signed-in user — in the app: Settings → Account → Delete account, step "Take your data" (downloading deletes nothing). The CSV contains all records, the questionnaire, your account data (including when you consented to AI processing), the subscription and payment history, achievements, the INVY AI chat history, AI results (lab breakdowns, Conclusions) and AI requests, notifications and their settings, products you created and product-analytics events. Security records (the password hash, session and push tokens, one-time codes, email and notification delivery logs) are not exported, and the avatar is marked only as present — the image itself is provided on request. The PDF doctor report (Profile → Data → Export) is available with PRO. On request to info@invy.health we provide a machine-readable copy within 30 days.

Delete part of your data: individual records (meals, readings, medications, workouts) can be deleted in the app; health permissions in the OS settings.

10. Your rights

You have the right to: know what data we process and obtain a copy; correct inaccurate data (Profile → Personal data); erase data ("right to be forgotten"); restrict or object to processing; withdraw consent (without affecting prior lawful processing); data portability; lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or — for EU/EEA residents — with your national supervisory authority. We respond within 30 days.

11. Children

INVY is intended for people aged 18 and over; the app does not allow a lower age to be entered. We do not knowingly collect data from children. If you know that an account was created by someone under 18, write to info@invy.health — we will delete it within 24 hours.

12. Security

13. International transfers

Some processors (section 7) are located in the USA. For users in the EU/EEA and the UK, transfers rely on the EU Standard Contractual Clauses (SCCs) or the processor's Data Privacy Framework certification. For users in Ukraine, transfers comply with Art. 29 of the Law of Ukraine "On Personal Data Protection".

14. Changes to this Policy

We announce material changes by email and in the app at least 14 days before they take effect; if a change expands the processing of health data we will ask for fresh consent. The current version is always available in the app (Settings → Privacy & data) and at invy.health/en/privacy; the update date is shown at the top.

15. Contact