Privacy policy
Last updated: 31 October 2026 · Version 2.7
This Privacy Policy explains how P4Q HEALTH S.L. ("Welleo", "we", "us") collects, uses, shares and protects personal information. It covers two different things, and they are kept apart on purpose:
- Part A — The Welleo online store. Everything you do at www.welleo.com: browsing, ordering, paying, shipping, returns, newsletters and advertising.
- Part B — The Welleo app and your health data. Everything the Welleo mobile app processes: test results, uploaded lab reports, facial-scan estimates, cycle data, your health profile and what you import from Apple Health, Health Connect or a wearable, plus a record of how the app is used and reports of when it crashes. Health data is never used for marketing or advertising.
Part C applies to both. If you only shop with us, Part A is the part that concerns you. If you use the app, both do.
Who we are and how to reach us
Data controller
P4Q HEALTH S.L.
Calle Nuestra Señora de la Guía 19, 48810 Alonsotegi, Bizkaia, Spain
Tax ID (NIF): B67665364
Registered in the Commercial Registry of Bizkaia, volume 6046, folio 66, sheet BI77644, entry 1
Data Protection Officer
For anything to do with your personal information, including the rights set out below, write to our Data Protection Officer at dpo@welleo.com or call +34 944 98 20 28. For orders, deliveries and everything else, hello@welleo.com.
Part A — The Welleo online store
The store at www.welleo.com is hosted on Shopify, which is what allows us to run it.
A1. Information we collect
- Contact details — name, billing address, shipping address, phone number, email address.
- Payment information — payment method, transaction details and payment confirmation. Full card numbers are handled by our payment providers and are not stored by us.
- Account information — username, password, preferences and settings.
- Transaction information — items viewed, added to cart or wishlist, purchased, returned, exchanged or cancelled, and your order history.
- Communications with us — what you write when you contact customer support, by email, in the app or on WhatsApp, and any photos or documents you attach.
- Device information — device, browser, network connection, IP address and similar identifiers.
- Usage information — how and when you interact with the store.
A2. Where it comes from
- Directly from you, when you create an account, order, or contact us.
- Automatically, from your device and through cookies and similar technologies — see A8.
- From service providers acting on our behalf.
- From partners such as payment and shipping providers.
A3. Why we use it, and on what legal basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Taking and fulfilling your order, payment, shipping, returns and exchanges, managing your account | Performance of a contract — Art. 6(1)(b) |
| Customer support and responding to you | Performance of a contract — Art. 6(1)(b); or legitimate interest — Art. 6(1)(f) |
| Marketing emails, promotions and personalised advertising | Consent — Art. 6(1)(a), withdrawable at any time. Where we email existing customers about similar products, legitimate interest — Art. 6(1)(f), with an unsubscribe link in every message |
| Security, fraud prevention and protecting the store | Legitimate interest — Art. 6(1)(f) |
| Invoicing, accounting and tax | Legal obligation — Art. 6(1)(c) |
| Establishing, exercising or defending legal claims | Legitimate interest — Art. 6(1)(f) |
A4. Marketing and advertising — and what it does not cover
We use store information only — your contact details, what you browsed, what you bought — to send marketing emails and to show you advertising for our products on the store and on other websites.
This never includes health data. Nothing described in Part B — no test result, no uploaded lab report, no facial-scan estimate, no cycle data, no health profile answer, and no fact derived from any of them — is used for marketing, for advertising, for audience building, or for any kind of use-based data mining. Health data is never transferred to advertising platforms, ad networks or data brokers, and is never sold.
You can withdraw marketing consent at any time using the unsubscribe link in any message, or by writing to dpo@welleo.com. Withdrawing it does not stop transactional messages about your orders or your account.
A5. Who we share store information with
- Shopify — hosting and operation of the store and checkout.
- Payment providers — to take and verify payment.
- Carriers and logistics providers — to deliver your order and handle returns.
- WhatsApp (WhatsApp Ireland Limited, part of Meta) — only if you write to us on WhatsApp. It carries your messages, anything you attach, your WhatsApp profile name and your phone number between you and our support team. Meta may process them in the United States, under the EU–US Data Privacy Framework, with the European Commission's Standard Contractual Clauses as the fallback. WhatsApp's own privacy policy also applies to your use of WhatsApp.
- Marketing and analytics partners — Meta, Google, TikTok and Klaviyo, to send campaigns and measure which adverts work, and Judge.me for product reviews. See A8 for what each one sets and when.
- Professional advisers, authorities and successors — where required by law, to enforce our terms, or in connection with a merger or similar transaction.
A6. Our relationship with Shopify
The store is hosted by Shopify, which collects and processes information about your access to and use of it in order to provide and improve the service. Information you submit to the store is transmitted to Shopify and may be processed in countries other than where you live. We also use Shopify features that draw on data from your interactions with our store, other merchants and Shopify itself. For those features Shopify is responsible for the processing, including for responding to requests about it. See the Shopify Consumer Privacy Policy and the Shopify Privacy Portal.
A7. How long we keep store information
| Category | Retention |
|---|---|
| Store account and profile | For as long as the account exists |
| Orders, invoices and accounting records | 6 years from the end of the financial year, as required by Spanish commercial and tax law |
| Customer support correspondence, including messages on WhatsApp | For as long as needed to deal with the matter and any claim arising from it |
| Marketing consent and unsubscribe records | Until you withdraw consent, plus the record of the withdrawal itself for as long as needed to honour it |
A8. Cookies and similar technologies
The first time you visit, a banner asks whether you accept cookies beyond the ones the store cannot work without. Declining is a single click, in the same place and with the same weight as accepting. Apart from the strictly necessary ones and the reviews (see Functional below), nothing is set until you choose, and if you decline, analytics and advertising cookies are not set at all.
To change your mind, open Manage preferences on the banner; if it is no longer showing, clearing this site's cookies brings it back. Your choice is remembered for one year, after which you are asked again.
| Category | What it does, and who sets it | How long |
|---|---|---|
|
Strictly necessary always active |
Keeps your basket and session; remembers your country and language (localization) and the currency shown (cart_currency); carries you through checkout and payment; and records the cookie choice you made. Set by Shopify (_shopify_essential carries the session) and, at checkout, your payment provider. We also keep welleo_locale_detected in your browser's local storage, only once you pick a language in the site's language selector, so the site opens in that language the next time you arrive. It stays until you clear your browser's site data. |
Session to 1 year |
|
Analytics only if you accept |
Counts visits and measures which pages and products are used, so we can improve the store. Shopify's own analytics cookie (_shopify_analytics; Shopify keeps the full list in its cookie policy). Microsoft Clarity — page analytics and session replay — is installed but switched off; if we turn it on it runs on this consent, like the rest of this row |
Session to 1 year |
|
Functional always active |
Shows customer reviews on product pages and remembers which you have seen. Set by Judge.me, which runs whether or not you accept, because the reviews are part of the page | Up to 1 year |
|
Marketing only if you accept |
Measures which advert brought you here, tells the platform when a visit became an order, and lets us show you our products again on those platforms afterwards — what is usually called retargeting. Set by Meta (Facebook and Instagram), Google (including YouTube and Google Tag Manager) and TikTok. Klaviyo, our email provider, also measures what you opened and clicked, and Shopify's own marketing cookie (_shopify_marketing) follows the same choice. None of these load at all until you accept |
Session to 2 years |
Some of this is sent from our servers, not from your browser. For Meta, Google, TikTok and Klaviyo we use Shopify's server-side sending as well as the browser tag: when you accept, the same events — a page viewed, a basket, an order — are forwarded from Shopify to those platforms directly. It is the same data for the same purpose, and it follows the same choice you made on the banner. It does mean a browser ad-blocker does not stop it; declining does.
Where it goes. Meta, Google, TikTok, Klaviyo and Microsoft are in the United States. When you accept marketing or analytics cookies, the data in this section is transferred there, under the European Commission's Standard Contractual Clauses or an adequacy decision for the country concerned. Decline and nothing in those two rows is collected or sent. This is separate from your health data, which stays in the European Union — see B6.
Other tools are installed on the store but switched off, and collect nothing while they are. If we ever turn one on, it runs on the consent for its row above, and this section names it before it starts collecting.
Two things that are not cookies but belong here. When you complete the wellness check and give us your email address, that address and the products we recommended are sent to Klaviyo, our email provider, so we can send you the result — the answers you gave are not sent, and Klaviyo sets no cookies on this store. And if you use Shop Pay, Shopify's accelerated checkout loads from shop.app and handles the payment session there.
Pages that embed a video use youtube-nocookie.com, which sets nothing until you press play. If you follow a link to another site, that site's own rules apply.
Part B — The Welleo app and your health data
This part governs the Welleo mobile app. Everything in B1 to B10 is special-category data concerning health under Article 9 GDPR, and we treat it that way. B11 covers two things the app records that are not health data.
B1. The health data we process
- Biomarker results — values from Welleo rapid tests read by the test reader, values you enter yourself, values read from lab reports you upload, and results recorded for you by a pharmacy or health professional.
- Uploaded lab reports — the PDF or photograph you upload, and the values read from it.
- Facial-scan estimates — heart rate, heart-rate variability, breathing rate, blood pressure and stress index, plus derived wellness indices. These are estimates, not measurements.
- Cycle data — period log, daily check-ins, flow and symptoms.
- Data from Apple Health, Health Connect and wearables — only if you connect them: heart rate, resting heart rate, walking heart rate, cardio recovery, heart-rate variability, breathing rate, blood oxygen, body temperature, basal body temperature, wrist temperature during sleep, blood pressure, blood glucose, sleep, steps, active energy, resting energy, exercise minutes, stand hours, floors climbed, time in daylight, distance, VO2 max, workouts (without their route), weight, body fat and lean body mass, and, with a separate consent, your period and flow entries. B4 says which source gives which.
- Health profile — height, weight, whether you smoke, whether you have diabetes, and whether you are treated for hypertension.
- Onboarding and wizard answers, and the recommendations derived from them.
- Supplement programmes and intake records.
- Appointments with pharmacies and health professionals, and your favourite pharmacies.
- Consents — which professional or organisation you have granted access to, to which categories of your record, and when.
- Access log — an append-only record of every access to your health record by a professional or organisation, which you can read in full inside the app.
- Notifications sent to you, and the categories you have muted.
We do not store your date of birth, and we do not store video from the facial scan.
B2. Legal basis
We process health data on the basis of your explicit consent under Article 9(2)(a) GDPR, together with Article 6(1)(a). Consent is asked for separately, per purpose and per source — connecting a pharmacy, granting a professional access to your record, or enabling a feature are each their own decision.
You can withdraw consent at any time in the app, under Profile → Privacy. Withdrawing a professional's or organisation's access stops any further access immediately; it does not undo accesses that already happened, and the access log keeps its record of them. Withdrawal does not affect the lawfulness of processing carried out before it.
Where we are required to keep something — for example a record needed to defend a legal claim — we say so, and we keep only that.
B3. What we never do with health data
We do not, under any circumstances:
- use health data for marketing, advertising, audience building, or any use-based data mining;
- serve you personalised or interest-based advertising based on health data;
- sell health data, or transfer it to advertising platforms, ad networks or data brokers;
- use health data to assess credit-worthiness, insurance eligibility, employment suitability or lending;
- store health data in iCloud or any consumer cloud backup service.
B4. How health data reaches us
- From you — values you enter, reports you upload, check-ins and period entries you record, answers you give.
- From you, when you contact support — a result, a photo of a test or a lab report you choose to send us by email, in the app's chat or on WhatsApp. It is kept with your support request (A7).
- From a Welleo test read by the reader — at home or at a participating pharmacy.
- From a health professional or pharmacy — results and appointments they record for you, where you have consented to that link.
- From the camera, during a facial scan — processed on your device, as described in B5.
- From Apple Health (iPhone) or Health Connect (Android) — only if you connect it, and only the types you allow on your phone's permission screen: heart rate, resting heart rate, heart-rate variability, breathing rate, blood oxygen, body temperature, basal body temperature, blood pressure, blood glucose, sleep, steps, active energy, distance, VO2 max, weight, body fat and lean body mass. From Apple Health the app can also read walking heart rate, cardio recovery, wrist temperature during sleep, resting energy, exercise minutes, stand hours, floors climbed and time in daylight. Your period and flow entries are imported only if you also turn on cycle import, which asks for its own consent. The app reads them on your phone and sends them to us, including, the first time, up to the previous 12 months. On iPhone, Apple Health can also wake the app in the background when it has new data, at most once an hour, so the app can send us what is new. It never writes anything to Apple Health or Health Connect.
- From a wearable, through Terra — only if you connect a device account such as Garmin, Polar or Withings, and only if you are 18 or over. You sign in to the device maker on Terra's page, and Terra sends us that account's daily summaries, sleep, body measurements and workouts (without their route). See B5 and B6.
B5. Who processes health data, and what they receive
| Recipient | What they process | Location |
|---|---|---|
| Our hosting provider | The Welleo database and object storage: all of the above | European Union (Spain) |
| Our CRM (operated by us) | The product and test catalogue, professional accounts, appointment logistics, and support requests. It does not receive your results from the app; it holds only what you choose to send us when you contact support (B4) | European Union (Spain) |
| Shen.AI — facial-scan technology | Nothing. The scan runs entirely on your device. Shen.AI receives only a short-lived licence token issued by our server. No video and no vital signs ever reach them | — |
| Google (Firebase Cloud Messaging) — push notifications | A device token and the notification text. Notification text never contains a result value | United States |
| Our email provider | Your email address and the message content. Emails never contain a result value | European Union (Ireland) |
| WhatsApp (WhatsApp Ireland Limited) — only if you write to us on WhatsApp | Your messages and anything you attach, which may include health data you choose to send, with your WhatsApp profile name and phone number | Meta's infrastructure, including the United States — see B6 |
| Apple Health / Health Connect — only if you connect them | Nothing from us. The app reads them on your phone and sends what it read to our servers, never to Apple or Google | — |
| Terra (Terra Enabling Developers Limited) — wearable connections, only if you connect one | Your access to the device account you connect, and the data it sends us (B4). Terra processes it for us, and also uses it for its own purposes — improving its service, developing products and research published only as aggregated or de-identified results — under its End User Privacy Policy, which you accept when you connect | United Kingdom and the Netherlands, with transfers to the United States — see B6 |
| Apple / Google — sign-in, where you choose it | Authentication only. No health data | United States |
| Map and geocoding providers — finding pharmacies near you | A location or an address. No health data | See B6 |
Qassay is not a third party. It is a brand of P4Q HEALTH S.L., the same company — a test strip read by the reader never leaves Welleo. And automated reading of uploaded reports is not switched on: today a report you upload is stored, and you enter the values from it yourself. If we ever enable automated reading, we will name the provider and where it operates in this section before a single report is sent to it.
B6. International transfers
Your health data is stored and processed inside the European Union — in Spain, with email delivery from Ireland. There are two exceptions, both described below: anything you choose to send us on WhatsApp, and data from a wearable you connect through Terra.
Apart from those two, the recipients outside the EEA receive no health data: sign-in with Apple or Google, which sees only authentication, and push notifications, whose text never carries a result. Those transfers rely on the European Commission's Standard Contractual Clauses or on an adequacy decision for the country concerned.
WhatsApp. If you write to us on WhatsApp, Meta may process your messages and attachments in the United States, including any health data you choose to send. That transfer relies on the EU–US Data Privacy Framework, with the Standard Contractual Clauses as the fallback. If you would rather your health data stayed in the European Union, contact us by email or in the app instead.
Terra. If you connect a wearable through Terra, Terra processes its data in the United Kingdom and the Netherlands, and may transfer it to the United States. The United Kingdom has an adequacy decision; the transfer to the United States relies on the Standard Contractual Clauses. Apple Health and Health Connect do not involve Terra: what the app reads there comes straight to our servers in Spain.
We will update this policy before any change to where your data is processed takes effect.
B7. How long we keep health data
| Category | Retention |
|---|---|
| Test results, facial-scan estimates, cycle data, health profile, supplement records | For as long as your account exists. Deleting your account deletes them |
| Data imported from Apple Health, Health Connect or a wearable | For as long as your account exists. Deleting your account deletes it. Disconnecting a source stops any further import, but keeps what was already imported, except for Oura, whose data is deleted when you disconnect it |
| Uploaded lab report files | 180 days from upload, or sooner if you delete it yourself. The values taken from a report are part of your health history and are kept separately, under the row above |
| Consents you give to professionals and organisations, and their withdrawal | For as long as your account exists. Deleting your account deletes them |
| Access log | For as long as your account exists. It is append-only: it cannot be edited, by you or by us |
| Appointments | For as long as your account exists. Deleting your account cancels your future appointments; past appointments are kept for now, as the paragraph below explains |
| Notifications sent, and the categories you muted | For as long as your account exists. Deleting your account deletes them |
| What you accepted when you signed up | Kept as the evidence of your consent (Art. 7(1) GDPR), including after your account is deleted: which documents you accepted, in which version, when and how, and that you declared you were at least the minimum age. It contains no contact details and no health data |
Deleting your account removes your health data from our systems — your results, scan estimates, cycle data, health profile, supplement records, uploaded reports, the consents you gave, the notifications we sent you and the access log — and cancels your future appointments. Two things survive it, as the table above says. The first is the record of what you accepted when you signed up, which contains no health data. The second is your past appointments, with any notes the professional made: we keep them for now while we confirm whether the law on clinical records requires the pharmacy or professional to keep them, and we will update this policy when that is decided. Disconnecting a professional or pharmacy does not delete anything — it stops their access from that moment on. The two are different actions with different effects, and the app says so at the point you take them.
Terra keeps its own copy for a short time. Terra usually deletes wearable data two days after collecting it and keeps it for at most six months, under its End User Privacy Policy. Deleting your Welleo account also ends your Terra connection.
B8. Security
- All traffic between the app and our servers is encrypted in transit (TLS).
- Uploaded lab reports are held in separate, private storage with no public address. They are served only through an authenticated request that has checked the record is yours.
- A professional can only see the categories of your record you have granted, and every access is written to the access log.
- Data used for testing and development is anonymised before it leaves production.
No system is perfectly secure, and information sent over the internet is never entirely without risk. If a breach affects your rights, we will notify you and the supervisory authority as Articles 33 and 34 GDPR require.
B9. Your rights over health data
In addition to the rights in Part C, the app gives you three of them directly:
- Delete your account and your data — Profile → Delete account → Confirm.
- Download everything we hold — Profile → Download my data, as a JSON file. A clinical export in FHIR R4 format is also available for sharing with a doctor.
- See who has looked at your record — the access log, in Profile → Privacy, together with the consents you have granted and a control to withdraw each one.
B10. Not a medical device, and not a diagnosis
The Welleo app is not a medical device, and nothing in it is a diagnosis.
Facial-scan values are wellness estimates, not clinical measurements. Neither they nor any other value in the app is used to decide a treatment, to select a clinical protocol, or to generate a referral. Results are presented for your own information and for a conversation with a health professional.
Always consult a doctor or pharmacist about your health. Never delay seeking medical advice, or disregard advice you have been given, because of something the app showed you. If you think you may have a medical emergency, contact the emergency services.
B11. How the app is used, and when it crashes
The app records two more things. Neither contains a health value, and both are kept apart from your health record.
What the app showed you, and what you tapped. On the Home screen and the recommendations screen, the app records which sections and cards were shown, in what position, which ones you tapped or opened, and when. It records the name of a section or card, such as "wellness score" or "recommendation 42", never what it displayed: no result, no value, and not the reason a card appeared. These records are linked to your account. Because a card's name can be matched to the recommendation it stood for, we hold them to the same rules as the rest of this part: they are never used for marketing or advertising, and never shared outside Welleo.
We use them for one thing: to see whether what the app puts in front of people is useful, such as whether a recommendation is ever opened or a section ever reached, and to improve what it shows. Today nothing in the app changes for you because of them. If that ever changes, this section will say so before it does.
Crash reports. When the app fails, it sends a report of what broke, where in the code, and on which version of the app and which kind of device. Crash reports are not linked to your account: the app never attaches your name, email address or account to them, and it strips ids, email addresses and the content of requests from the details it adds. They go to an error-tracking service we run ourselves, on the same hosting in Spain as the rest of the app. No outside company receives them.
| Record | Legal basis (GDPR Art. 6) | Retention |
|---|---|---|
| What the app showed you, and what you tapped | Legitimate interest — Art. 6(1)(f): knowing whether the app is useful, and improving it | 13 months, then deleted. Deleting your account deletes them sooner. They are included when you download your data (B9) |
| Crash reports | Legitimate interest — Art. 6(1)(f): keeping the app working | For as long as needed to find and fix the fault |
Because both rest on our legitimate interest, you can object to either at any time (C1) by writing to dpo@welleo.com.
Part C — Applying to both
C1. Your rights
Under the GDPR you have the right to:
- Access — obtain a copy of the personal information we hold about you.
- Rectification — have inaccurate information corrected.
- Erasure — have your information deleted.
- Portability — receive your information in a machine-readable format and have it transmitted to another controller.
- Restriction — ask us to limit how we use your information.
- Object — object to processing based on our legitimate interests, and object at any time to direct marketing.
- Withdraw consent — at any time, without affecting processing already carried out.
- Not be subject to automated decision-making that produces legal or similarly significant effects. We do not make such decisions.
Exercise any of these in the app where indicated, or by writing to dpo@welleo.com. We will respond within one month, extendable by two further months for complex requests, and we will tell you if we need the extension. We may need to verify your identity first. You may appoint someone to act for you; we will ask for proof of the authorisation. Exercising a right never costs you anything and we will never treat you differently for it.
C2. Complaints
If you are unhappy with how we handle your personal information, please write to dpo@welleo.com first — it is usually the fastest route to a fix.
You also have the right to lodge a complaint with a supervisory authority. In Spain that is the Agencia Española de Protección de Datos (AEPD), C/ Jorge Juan 6, 28001 Madrid — www.aepd.es. If you live elsewhere in the EEA, you may complain to your own national authority; the list is here.
C3. Children
Welleo is not intended for anyone under 16, and we do not knowingly collect personal information from anyone under 16. If you are a parent or guardian and believe a child has given us their information, write to dpo@welleo.com and we will delete it.
C4. Links to other sites
Our store and app may link to sites we do not control. We are not responsible for their content, their privacy practices or their security. Read their policies before giving them your information.
C5. Changes to this policy
We update this policy when our practices change, or for operational, legal or regulatory reasons. The revised version is published here with a new "Last updated" date and version number, and where the change is significant we will tell you before it takes effect. The table below records what changed and when.
| Version | Date | What changed |
|---|---|---|
| 2.7 | 31 October 2026 | Added what the app can now read from Apple Health: walking heart rate, cardio recovery, wrist temperature during sleep, resting energy, exercise minutes, stand hours, floors climbed and time in daylight (B1, B4). Added that, on iPhone, Apple Health can wake the app in the background to send us new data, at most once an hour (B4). B4 now also names blood oxygen and blood glucose, which the app already read from Apple Health and Health Connect. |
| 2.6 | 22 October 2026 | Corrected what welleo_locale_detected is for (A8). It now records the language you pick in the site's language selector, so the site opens in that language when you come back, and it stays until you clear your browser's site data. Before, it marked that the automatic language redirect had already run. |
| 2.5 | 9 October 2026 | Added WhatsApp as a way to contact customer support: what it carries, who provides it, and that Meta may process your messages in the United States (A1, A5, A7, B4, B5, B6). Corrected B5, which said our CRM does not receive your results: it holds whatever you choose to send us when you contact support, such as a photo of a test. Added what the app imports from Apple Health, Health Connect and wearables if you connect them, including your period entries with a separate consent, and that it never writes to them (B1, B4, B7). Named Terra, which connects wearables: what it receives, its own uses, where it processes data and how long it keeps it (B5, B6, B7). |
| 2.4 | 1 October 2026 | Added section B11. The app records which sections and cards it showed on the Home and recommendations screens and which ones you tapped, linked to your account and kept for 13 months, and it sends crash reports to an error-tracking service we run ourselves. Neither was described before. The introduction to Part B now says which of its sections cover health data. Also corrected what happens when you delete your account (B7). The consents you give to professionals and the notifications we sent you are deleted with your account; this policy wrongly said they were kept. Past appointments are kept for now, while we confirm whether the law on clinical records requires it; this policy wrongly said they were deleted. B7 now lists what survives deletion: the record of what you accepted when you signed up, and your past appointments. |
| 2.3 | 16 September 2026 | Named our Data Protection Officer and made dpo@welleo.com the contact for everything to do with personal information, in place of hello@welleo.com. Corrected the Shopify cookie names in A8 to the ones the store sets today. |
| 2.2 | 15 September 2026 | Added section A8, covering cookies and similar technologies: the categories set, who sets them, how long they last, and how to change your choice. Names the advertising and analytics recipients — Meta, Google, TikTok, Klaviyo, Judge.me and Microsoft Clarity — in A5 and A8, together with what each collects and when. Adds that some of those events are sent from our servers rather than your browser, that the marketing tags are also used for retargeting, and that this data goes to the United States under Standard Contractual Clauses. It replaces a single sentence and means the cookie banner's link now reaches a full explanation. Also recorded that completing the wellness check sends your email address and the recommended products to our email provider, and that your answers are not sent with it. |
| 2.1 | 11 September 2026 | Corrections from a verification pass. Uploaded report files are kept for 180 days, not for the life of the account. Consents and notification records are stated as surviving account deletion, which is what happens. Qassay is named as a brand of the controller rather than a separate recipient, and automated reading of uploaded reports is stated as not enabled — it is not. Processing locations are now named: Spain, with email from Ireland. Removed a claim that the minimum age is aligned across both app stores, which has not yet been checked. |
| 2.0 | 11 September 2026 | Split into a store part and an app-and-health-data part. Added legal bases, an inventory of the health data processed, the Article 9 basis, an explicit exclusion of health data from marketing and advertising, named recipients, per-category retention, security practices, a named privacy contact, and the statement that the app is not a medical device. Merged a duplicated rights section. Recipient locations and the retention of commercial records are stated in general terms pending a completed inventory; they will be named in a later version. |
| 1.0 | 5 August 2026 | Initial version. |
C6. Contact
P4Q HEALTH S.L.
Calle Nuestra Señora de la Guía 19, 48810 Alonsotegi, Bizkaia, Spain
Data Protection Officer: dpo@welleo.com · +34 944 98 20 28
For the purposes of data protection law, P4Q HEALTH S.L. is the controller of your personal information.