Privacy policy

1. Who is responsible?

Afvallen en Afblijven, Chamber of Commerce (KvK) no. 89513908, is the controller within the meaning of the General Data Protection Regulation (GDPR). Questions about privacy? Email privacy@afvallenenafblijven.nl.

2. What data do we process?

• Contact details: your first name and email address.
• Intake data: your answers in the questionnaire, such as your goal, sex, age, height, weight, target weight, activity level, eating pattern, allergies and preferences, where you train, experience and injuries.
• Health data (special categories of personal data): weight and height, any pregnancy, eating disorder, medical conditions, medication, injuries, your check-ins and your weekly weigh-ins.
• Data from connected health apps (optional): only if you connect an app or device: your daily step count, active calories and active minutes, your workouts (type of sport, start time, duration and calories) and your body weight. This is also health data. See section 5.
• Order and payment details: what you have ordered, amounts, the status of your subscription and (via Stripe) your payment method and billing details. We do not receive full bank account or credit card numbers. If you came to us through an advert, we also store the campaign details from the link (such as the source and campaign name) and the landing page with your order.
• Your plans: the nutrition and workout plans we create for you.
• Technical data: data needed to keep the website running securely (such as server logs) and, only with your consent, analytics and marketing data via cookies.
• Website usage (without cookies): which pages and questionnaire steps a visit views and how long a page is open, the type of device (mobile, tablet or computer), the language, the campaign details from the link and the website you came from (only its name, e.g. google.com). For this we use a random visit number that is only stored in your browser tab (sessionStorage) and disappears when you close the tab. We do not store your IP address and do not track you on other websites. If "Do Not Track" or "Global Privacy Control" is switched on in your browser, we do not measure anything. If you place an order, we link the measurement of that visit to your order.
• Messages: what you send us via the contact form, email, the withdrawal function or a guarantee request.
• Customer service: short notes about contact you have had with us, and an overview of the emails we sent you (type, subject and time, not the content), so that we can check whether an email arrived.

3. For what purposes and on what legal basis?

4. How is your plan put together?

To put your plan together, we use software from Anthropic (the language model Claude). For this, we send your first name, your intake answers (including the relevant health data), your calculated daily targets and, where applicable, your check-in and the data from connected health apps (see section 5) to Anthropic. We do not send your email address or payment details. Anthropic processes this data as a processor on our behalf and, under its commercial terms, does not use it to train its models.

Based on your answers, our system automatically decides whether we can create a plan (for example, not in the case of pregnancy or underweight). Do you disagree with such an outcome? Then please get in touch with us; a person will then review your situation again.

5. Connections with health apps

You can connect a health app or device, such as a smart scale or sports watch, to your account. This is completely optional. We only receive data if you connect an app yourself under My plans → My details and tick a separate box to give your explicit consent to the processing of this health data (Art. 9(2)(a) GDPR). You can withdraw your consent at any time by disconnecting the app in the same place.

What data do we receive?

• your daily step count, active calories and active minutes;
• your workouts: type of sport, start time, duration and calories;
• your body weight, for example from a smart scale.

We do not receive or store your heart rate, sleep, location or GPS routes, menstrual data or any other health data, even if the app holds it.

What do we use it for?

• to adjust your calorie target to how active you actually are;
• to show whether and how much you train (training adherence) and what it yields in your progress charts;
• to pre-fill your weekly weigh-in and your check-in for you;
• as context when we create your next plan. We then process this data in the same way as your check-in, including via Anthropic (see section 4).

How does the connection work?

• Withings (smart scales and the Withings Health Mate app): you connect directly via Withings' own login page. Withings is a French company.
• Other apps and devices, such as Apple Health (iPhone), Health Connect (Android), Garmin, Fitbit/Google, Oura, Polar, Samsung Health and others: we connect these via the health data platform Junction (Vital Technologies Inc., US), which acts as a processor on our behalf. We use Junction's EU data region. Transfers to the US are based on the EU-US Data Privacy Framework and/or the European Commission's standard contractual clauses.
• Apple Health: data from Apple Health can only be read on the iPhone itself. That is why you install Junction's companion app on your iPhone and enter a one-time pairing code in it that you see on our website.

Security, disconnecting and retention

We store the access tokens for your connections in encrypted form. If you disconnect an app, we immediately stop collecting data and immediately delete the health data we received through that connection. Otherwise, we keep this data for as long as the other data in your account (see section 7).

6. Who do we share data with?

We never sell your data. We only share it with parties we need in order to provide our service:

• Anthropic (US) – software for putting your plan together (processor).
• Stripe (Ireland/US) – payments, subscriptions and invoices. Stripe is itself responsible (controller) for part of the processing; see Stripe's privacy policy.
• Vercel (US) – hosting the website; the website runs in a data centre in Frankfurt (processor).
• Neon (US) – the database in which your data is stored encrypted, in a data centre in Frankfurt (processor).
• Vimexx (Netherlands) – our domain name and email, including sending your plans, login links and confirmations (processor).
• Junction (Vital Technologies Inc., US) – only if you connect a health app: collecting your data from apps and devices such as Apple Health, Health Connect, Garmin and Fitbit, via Junction's EU data region (processor).
• Withings (France) – only if you connect a Withings scale or Withings Health Mate: we then receive your data directly from Withings, via the connection you set up yourself with your Withings account.
• Google (Analytics) and Meta – only if you give your consent via the cookie banner.

We conclude a data processing agreement with our processors. If data is transferred to a country outside the European Economic Area (such as the US), this is done on the basis of the EU-US Data Privacy Framework or the European Commission's standard contractual clauses, with additional safeguards where necessary. We may also disclose data if we are legally required to do so.

7. How long do we keep your data?

• Intake data, health data and plans: for as long as you are a customer, and for 12 months after that so that you can look back at your plans. After that, we delete them. Earlier deletion is possible on request.
• Data from connected health apps: like your other health data, for as long as you are a customer and for 12 months after that. If you disconnect an app, we immediately delete the data from that connection.
• Completed questionnaire without an order: up to 30 days.
• Invoice and payment details: 7 years, due to the statutory tax retention obligation.
• Contact messages: up to 12 months after they have been dealt with.
• Customer service notes: like your intake data, for as long as you are a customer and for 12 months after that.
• Overview of emails sent: 12 months.
• Website usage (without cookies): 13 months.
• Newsletter: until you unsubscribe.

8. Security

We take appropriate technical and organisational measures, such as encrypted connections (HTTPS), encrypted storage with our hosting provider, logging in with personal links of which we only store an encrypted version (hash), encrypted storage of the access tokens for connected health apps, and restricted access to data. Notice something that isn't right? Report it via privacy@afvallenenafblijven.nl.

9. Your rights

You have the right to:

• access your data and receive a copy;
• have incorrect data corrected;
• have your data erased (insofar as we are not legally required to keep it);
• have the processing restricted or object to it;
• have your data transferred (data portability);
• withdraw your consent at any time. If you withdraw your consent to the processing of health data, we can no longer create new plans for you. Processing carried out before then remains lawful. You withdraw your consent for a health app connection by disconnecting the app (see section 5); we will then simply create your plans without that data.

Send your request to privacy@afvallenenafblijven.nl. We will respond within one month. Do you have a complaint about how we handle your data? Let us know; you can also lodge a complaint with the Autoriteit Persoonsgegevens (the Dutch Data Protection Authority).

10. Minors

Our service is intended only for people aged 18 and over.

11. Changes

We may amend this privacy policy. The most recent version can always be found on this page. We will inform you by email of any important changes.