Effective date: 23 September 2026 · Last updated: 10 October 2026
The short version
Haviora helps you bring wellness records, device readings and daily check-ins together. Some of this is health-related information, which we treat as sensitive. We only process health information and share it with our AI provider if you give explicit permission, and you can withdraw that permission at any time in the app. We do not sell your data or use health information for advertising. You can delete your account in the app.
Who we are
Haviora (the iPhone app and the website at haviora.app) is operated by David Ajanjan trading as RIDDEC TECHNOLOGYS, a sole establishment licensed by the Dubai Department of Economy and Tourism under license no. 1051098, with its business address at Office O-3402, Burj Al Salam Trade Center First, Dubai, UAE ("Haviora", "we", "us"). We are the controller of the personal information described in this policy.
Contact: hello@haviora.app (privacy, support and account-deletion requests).
EU representative (GDPR Article 27): Riddec Estonia OÜ, registry code 12273772, Laeva 1, 10111 Tallinn, Estonia, hello@haviora.app. Individuals and supervisory authorities in the EU/EEA may contact our representative on any question about our processing.
Information we handle
- Account and profile
- Email address, authentication information, name, and profile details you provide such as age, goals, preferences and health-related notes. If you use Sign in with Apple or Google, the identifiers and profile details that provider shares.
- Records you enter
- Check-ins, mood and energy, meals and nutrition, workouts, weight, medications and medication logs, reminders, reflections, goals and any lab values you choose to enter.
- Connected-device readings
- With your permission, supported Apple Health or Oura readings such as sleep, activity, workouts, heart rate and heart-rate variability. What is available depends on your device, permissions and recorded history.
- AI conversations and outputs
- Your requests, the relevant context sent with them, coach messages, generated plans and reviews, and feedback you choose to submit.
- Photos
- A meal or menu photo you choose to submit for analysis, with your request or portion description.
- Service and subscription records
- Account and device identifiers, sign-in sessions, notification tokens and preferences, subscription status and transaction records, sync data, usage counts, and security and abuse-prevention records.
- Permission records
- Your consent and permission choices, their version and timestamps. These contain no health values, messages or photos.
- Support
- Your email address, message and any attachments when you contact us.
Why we use it and our legal basis
| Purpose | Information used | Legal basis (EU/UK GDPR) | Legal basis (UAE PDPL) |
|---|---|---|---|
| Create and run your account, sync your records across devices | Account, records, service records | Performance of our contract with you (Art. 6(1)(b)) | Performance of a contract |
| Health features: storing and showing health-related records, trends and device readings | Records, device readings, profile health notes | Your explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) | Your explicit consent |
| AI features: coaching, plans, reviews, meal and menu photo analysis, including sharing with our AI provider | Request, relevant records and readings, photos | Your explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) | Your explicit consent |
| Care sharing with a clinician you approve | The information that feature provides | Your explicit consent (Art. 9(2)(a)) | Your explicit consent |
| Memberships, trials and allowances | Subscription and transaction records, usage counts | Performance of contract | Performance of a contract |
| Haviora membership invitations and optional promotional notifications | Membership status, app visits, invitation impressions/dismissals and notification preferences; not health readings | Legitimate interests for limited in-app invitations; consent for promotional push notifications | Legitimate service interests where permitted; consent for promotional notifications |
| Verification, password-reset and service emails; reminders you set up | Email, notification tokens, preferences | Performance of contract | Performance of a contract |
| Security, fraud and abuse prevention; keeping the service reliable | Service and security records | Our legitimate interests in protecting users and the service (Art. 6(1)(f)) | Necessary to protect the service and users |
| Optional diagnostic reports after an app error | Error category and platform only | Your consent (you choose to send) | Your consent |
| Answering support and privacy requests | Support correspondence | Performance of contract; legal obligation for privacy requests | Performance of a contract; legal obligation |
| Tax, accounting and legal compliance | Transaction records | Legal obligation (Art. 6(1)(c)) | Compliance with law |
We do not sell your information, share it for third-party advertising, or use health information to target membership promotions. We may show Haviora membership invitations based on account and app-usage information. Promotional push notifications require a separate opt-in and can be turned off in Settings. We do not make automated decisions about you that have legal or similarly significant effects (such as employment, insurance or credit decisions).
Your health-data and AI choices
The app asks two separate questions before health features start:
- Health processing: permission for Haviora to process your health-related information.
- AI sharing: permission to send relevant information to our AI provider, Anthropic, for AI features.
Both are off until you switch them on. Each choice is recorded with its version and date, and if we materially change what a permission covers, we ask again. You can change either one at any time in Settings → Privacy & data → Health data & AI sharing.
- If you turn off AI sharing, AI coaching, plans, reviews and photo analysis stop, and menu sharing turns off. Manual tracking continues to work.
- If you turn off health processing, health features and new device imports pause, and any care-team access you approved is revoked.
- Withdrawing a permission does not affect processing already carried out, and cannot recall a request already sent to a provider. Your stored history stays until you delete it or your account; deleting data and signing out remain available at all times.
Menu comparisons use a separate, feature-specific permission, which you can turn off in What to order. Device access and photo submission are also controlled separately.
AI features and photos
AI coach replies, plans, reviews and photo analysis are generated by Anthropic (Claude). Requests go through our servers, and Anthropic receives only the information the feature needs, which may include sensitive health information:
- Coach and plans: your request and relevant profile, goals, health readings, workouts, meals, check-ins, active medication information, reflections and conversation history.
- Menu comparison: your menu photo and request, food preferences, and relevant nutrition, sleep, recovery, check-in, workout, profile and medication context.
- Meal-photo analysis: the food photo and portion description. The result is not saved as a meal unless you choose to save it.
- Safety and quality checks: an additional automated AI check may review input and output. This is an automated check, not clinical validation.
Before a menu image is analysed, it is resized and its location metadata is removed. We do not store menu images or menu comparisons on our servers. Please avoid photographing faces, documents or other unrelated private details.
Anthropic processes this information as our service provider under a data processing agreement. Its commercial training policy says that API content is not used for model training without explicit permission. We do not submit your health records as model-training feedback.
We do not claim zero data retention. Under Anthropic's standard API retention policy, inputs and outputs are normally deleted within 30 days. Legal requirements and usage-policy investigations can extend this: flagged inputs and outputs may be kept for up to two years, and safety classification scores for up to seven years. This provider retention is separate from deleting your Haviora account.
AI output is generated automatically and is not reviewed by a medical professional.
Apple Health and Oura
You decide whether to connect a source. Apple Health access is controlled on your iPhone. Oura connects through Oura's own authorisation, and we never see or store your Oura password. Readings you import are stored in your Haviora account so they appear on all your signed-in devices.
To manage connections, go to Settings → Connected devices; you can also revoke access in Apple Health or at Oura. Disconnecting stops future imports but does not delete readings already saved. To delete those, delete the records or your account.
Information from Apple HealthKit is never used for advertising or marketing and is never sold or shared with data brokers or information resellers.
Who receives information
We share information only with the service providers below, each limited to the information its role requires and bound by contract to protect it:
| Provider | Role | Location |
|---|---|---|
| Render | Backend hosting and account database | Service and database hosted in Frankfurt, Germany; provider based in the USA |
| Anthropic | AI generation, photo analysis and automated safety checks | USA |
| Apple, RevenueCat | App Store purchases and subscription management. We never receive your full card number. | USA |
| Oura; Apple Health (on your device) | Device connections you authorise | Per provider |
| Resend | Verification and password-reset emails | USA |
| Expo, Apple Push Notification service | Delivering notifications. Reminders are designed not to show health readings or medication details on your lock screen. | USA |
| Google Workspace | Our email inbox | Global processing; we do not promise EU-only storage or processing |
| MailerLite | Website launch list: storing sign-ups and sending the confirmation and launch emails | Data stored in the European Union; may be processed in other countries with safeguards |
| Cloudflare | Website delivery and security (IP address, requested URL, browser information) | Global |
| USDA FoodData Central | Food lookups (no personal health profile is sent) | USA |
Care sharing: if you approve a clinician, they can see the information that feature shares with them. They handle that information under their own responsibilities as a separate controller. You can review or revoke access in Settings → Care sharing; revoking access stops future access but cannot erase copies they already hold.
We may also disclose information where the law requires it, to protect the rights and safety of people or the service, or as part of a merger or acquisition, which would be subject to equivalent protections and notice to you.
International transfers
We are based in the United Arab Emirates, and our providers operate in the EU, the USA and other countries. Whenever we transfer personal information to a country that does not provide an adequate level of protection, we use appropriate safeguards:
- From the EU/EEA/UK: the European Commission's Standard Contractual Clauses (with the UK Addendum), or the EU–US Data Privacy Framework where the recipient is certified.
- Under UAE law: transfers permitted by the PDPL, based on adequate protection or contractual safeguards.
You can request a copy of the relevant safeguards from hello@haviora.app.
How long we keep information
- Account, health history, saved conversations and plans
- While your account exists, unless you delete individual records. Removed from our primary database when account deletion successfully completes. Provider copies and backups are handled separately.
- Backups
- Render documents a rolling recovery window of three days on Hobby workspaces or seven days on higher plans, and seven days for Render-managed logical exports. These periods do not apply to separately downloaded copies or legal holds; deleting an account does not immediately remove it from backups.
- Operational records
- Account-linked AI-usage and notification-delivery records remain until account deletion or earlier removal. Fixed-period automatic cleanup is not currently enabled. Hosting providers apply their own log-retention terms.
- Security and abuse-prevention records
- Account-linked records remain until account deletion or earlier removal; necessary incident or legal evidence may be retained separately. Fixed-period automatic cleanup is not currently enabled.
- Short-lived tokens and sign-in records
- Between 24 hours and 30 days after expiry.
- Permission records
- Versioned choices and timestamps are retained with your account and removed from our primary database when the account is deleted. Backup retention is separate.
- Provider-cleanup requests
- The identifiers or credentials needed to request provider deletion or revocation are held in an encrypted retry queue until the request succeeds or an operator resolves it. Successful processing removes that payload; minimal completion receipts expire after 30 days. Failed requests are not silently discarded.
- Transaction and tax records
- For the period required by applicable accounting and tax law. Apple and RevenueCat maintain their own transaction records under their terms; account deletion does not cancel a subscription.
- Support correspondence
- Kept to handle your request and any necessary follow-up, dispute or legal obligation. There is currently no automated mailbox-expiry schedule. Contact hello@haviora.app to request removal.
- Menu images and comparisons
- Not stored on our servers. Temporary files may remain in your device's cache until the system clears them.
Our providers keep their own copies under their own retention terms, as described above. Render's backup documentation explains its recovery windows and export retention. We restrict backup use to recovery; erasure requests must be reapplied before recovered records return to normal service. A provider deletion request is not a guarantee that every backup or legally retained copy is immediately erased.
Security
We use encryption in transit, access controls and least-privilege access to protect your information. Your data is not end-to-end encrypted, because our servers and the AI features you request need access to relevant information. No system is perfectly secure; if a breach affects you, we will notify you and the authorities as the law requires.
Your rights
Depending on where you live, you can ask to access, copy, correct or delete your personal information; restrict or object to its processing; receive it in a portable format; and withdraw consent at any time (this does not affect processing already carried out).
Many of these can be done directly in the app:
- Delete your cloud account: Settings → Privacy & data → Remove data → Delete cloud account.
- Clear this device only: Remove data → Clear downloaded data & sign out.
- Other requests: email hello@haviora.app. We may need to verify your identity. Never email us your password or a verification code.
We will respond within one month, or within the period applicable law requires.
Complaints: you can complain to the data protection authority in the EU/EEA country where you live or work, or where the alleged infringement took place. In the UAE, you can contact the UAE Data Office. We would appreciate the chance to resolve your concern first.
Age
Haviora is for adults aged 18 and over. The app asks you to confirm your age before health features start. If you believe a person under 18 has given us information, contact hello@haviora.app and we will delete it.
Launch list (website email sign-up)
What we collect. If you join the Haviora launch list on haviora.app, we collect the email address you enter and a record that you asked to be on the list, including the time and IP address of your sign-up and of your confirmation. We do not ask for health information on this form.
Why. To email you when Haviora launches. We first send one email asking you to confirm your sign-up, then one email when Haviora launches. We do not use your email for advertising and we do not sell it.
Who handles it. Your email is stored and sent by our email service provider, MailerLite, which acts on our behalf. MailerLite states that its data storage centre is in the European Union. Its data processing terms allow it to process data in other countries with appropriate safeguards. Haviora is operated by David Ajanjan trading as RIDDEC TECHNOLOGYS, Dubai, UAE.
How long we keep it. Until you unsubscribe or ask us to delete it, then we remove it.
Your choices. Every email has an unsubscribe link. You can also email hello@haviora.app and ask us to remove or delete your address.
Separate from the app. The launch list is separate from any Haviora app account. Joining it does not connect your email to any health or wellness data.
Questions. hello@haviora.app
Website and cookies
The haviora.app website does not use advertising cookies, advertising trackers or website analytics. The launch list form on the home page is provided by MailerLite. It may store cookies or similar data in your browser that it needs to work, such as an identifier and a record that the form was submitted, and MailerLite counts form views and sign-ups. Cloudflare may set strictly necessary security cookies. Inside the app, local storage is used for your records, preferences and offline changes.
Changes to this policy
If we change this policy in a material way, we will notify you in the app or by email before the change takes effect, and ask for fresh permission where the law requires it. The effective date at the top shows when this version took effect.
Updated 10 October 2026.