Health Data Privacy Policy

Last updated: August 6, 2026

This Consumer Health Data Privacy Policy explains how AGENCY BRAUN EOOD collects, uses, stores, shares and protects consumer health data through LifeDesk.

It supplements the general LifeDesk Privacy Policy and applies where consumer health privacy laws, including the Washington My Health My Data Act and similar laws, apply.

1. Company Responsible for Consumer Health Data

AGENCY BRAUN EOOD
Bulgarian company name: АГЕНЦИЯ БРАУН ЕООД

78 Angel Dimitrov Street
8016 Burgas
Bulgaria

UIC/EIK: 206587414
VAT ID: BG206587414

Managing Director: Artur Braun

Privacy enquiries: privacy@lifedesk.me

In this policy, “LifeDesk”, “we”, “us” and “our” refer to AGENCY BRAUN EOOD.

2. Scope of This Policy

This policy applies to consumer health data processed through:

the LifeDesk Health area;
medical document storage;
health-related goals, notes and records;
user-initiated AI processing of selected Health-area data;
communications and privacy requests relating to Health features.

This policy does not replace the general LifeDesk Privacy Policy.

3. Categories of Consumer Health Data We Collect

Depending on which LifeDesk Health features you choose to use, we may collect or process:

symptoms and health conditions;
medication and supplement information;
medical events and appointments;
physical or mental health information;
body measurements;
health-related goals and notes;
fitness and activity information entered in the Health area;
medical documents, photographs and attachments;
information about treatments, diagnoses or healthcare services entered by you;
health-related information contained in selected data submitted by you to the LifeDesk AI Assistant;
technical information associated with your use of the Health features.

We do not collect consumer health data through the Health area before you have enabled the feature and provided the required Health Data Consent.

4. Sources of Consumer Health Data

We obtain consumer health data from:

information you enter directly into LifeDesk;
medical documents, photographs or files you upload;
Health-area information you select for use with the AI Assistant;
information you voluntarily submit in communications with us;
other LifeDesk users where they are authorized to store information concerning you.

LifeDesk does not automatically obtain medical records from healthcare providers unless such a connection is expressly introduced in the future and disclosed to you before use.

5. Why We Collect and Use Consumer Health Data

We collect and use consumer health data to:

provide the LifeDesk Health features requested by you;
store, organize and display your health information;
allow you to track symptoms, medication, appointments, measurements and health-related goals;
store and display medical documents;
synchronize Health data across your authorized devices;
provide AI-assisted processing where you actively ask the AI Assistant to use selected Health data;
secure the Health area and prevent unauthorized access;
respond to privacy, support and deletion requests;
comply with applicable legal obligations;
establish, exercise or defend legal claims where necessary.

We do not use consumer health data for targeted advertising or advertising profiles.

We do not sell consumer health data.

We do not use consumer health data to determine eligibility for employment, insurance, credit, housing or other similarly significant decisions.

Before using the LifeDesk Health area, you must provide explicit Health Data Consent.

The consent request explains:

the categories of Health data processed;
the purposes of the processing;
the use of contracted technical service providers;
possible user-initiated AI processing;
how consent may be withdrawn;
the consequences of withdrawal.

You may decline consent and continue using the non-Health areas of LifeDesk.

You may withdraw your Health Data Consent at any time under:

Settings → Legal & Privacy → Health Data Consent

Withdrawal disables the Health area and initiates deletion of data stored in that area.

We may disclose or make consumer health data available only where necessary to provide the service requested by you.

The categories may include:

Health information selected for a user-initiated AI request;
medical documents stored on our server infrastructure;
technical and account information necessary to operate, secure and maintain the Health features;
information required to comply with a lawful request or defend legal claims.

We do not share consumer health data with advertisers, data brokers or social-media advertising platforms.

8. Categories of Recipients

Consumer health data may be processed by the following categories of recipients:

hosting and server infrastructure providers;
secure file-storage and backup infrastructure;
AI infrastructure providers where you actively initiate an AI-assisted Health request;
employees, developers or contractors who require access for security, maintenance or support and are subject to confidentiality obligations;
legal advisers or public authorities where legally required.

Current relevant providers include:

Hetzner Online GmbH

Hetzner provides server, infrastructure, database, file-storage and backup services for the LifeDesk application.

Health data stored within LifeDesk may therefore be hosted on Hetzner infrastructure.

Anthropic, PBC

Where you actively request the LifeDesk AI Assistant to process selected Health data, the information required to answer your request is transmitted through Anthropic’s commercial API.

Health data stored in the Health area is not automatically transmitted to Anthropic.

Anthropic states that commercial API inputs and outputs are not used to train its models by default. Under its standard API retention policy, submitted information may generally be retained in its backend systems for up to 30 days, subject to limited exceptions.

Professional and legal recipients

Health data may be disclosed to legal advisers or competent authorities only where necessary to comply with law or establish, exercise or defend legal claims.

9. No Sale of Consumer Health Data

LifeDesk does not sell consumer health data.

LifeDesk does not receive money or other valuable consideration in exchange for consumer health data.

LifeDesk does not permit its service providers to use consumer health data for their own advertising, data-brokerage or general model-training purposes.

10. International Processing

The LifeDesk application is hosted through server infrastructure operated by Hetzner.

Some consumer health data may be processed outside the European Economic Area when you actively use an AI-assisted Health function.

In particular, information transmitted to Anthropic may be processed in the United States and other countries.

Where required, international transfers are protected through mechanisms such as:

an adequacy decision;
the EU–US Data Privacy Framework where applicable;
European Commission Standard Contractual Clauses;
data-processing agreements;
additional technical and organizational safeguards.

11. Retention and Deletion

Health data is retained while:

your LifeDesk account remains active;
the Health area remains enabled;
you have not deleted the relevant content;
retention is necessary for the provision of the service or compliance with law.

You may delete individual Health entries and medical documents through LifeDesk.

When you withdraw Health Data Consent:

access to the Health area is disabled immediately;
further processing of Health-area data is stopped;
Health entries and medical documents are scheduled for permanent deletion from active systems without undue delay and no later than 30 days;
remaining backup copies are overwritten according to our backup-retention schedule and no later than 90 days;
deleted Health data will not be restored if you later enable Health again;
only a minimal record of consent and withdrawal may be retained.

Withdrawal does not automatically delete information independently entered into the general LifeDesk AI conversation because the general AI conversation is not assigned to individual LifeDesk areas.

You may delete the general AI conversation separately where that function is available or request its deletion by contacting us.

12. Your Consumer Health Data Rights

Depending on applicable law, you may have the right to:

confirm whether we collect, use or share consumer health data concerning you;
access your consumer health data;
obtain information about the categories of recipients;
request correction of inaccurate data;
withdraw consent to future collection or sharing;
request deletion of consumer health data;
receive certain data in a portable format;
appeal a refusal to act on a request;
lodge a complaint with the relevant authority.

Under Washington law, authenticated requests generally must be handled within 45 days, subject to a permitted extension in appropriate circumstances. Deletion requests must also address relevant processors and backup systems.

13. How to Exercise Your Rights

You may exercise your rights through:

the LifeDesk settings;
the Health Data Consent withdrawal function;
the account-deletion function;
an email to privacy@lifedesk.me.

Please send requests from the email address associated with your LifeDesk account where possible.

We may request additional information reasonably necessary to verify your identity and protect your account from unauthorized access or deletion.

You do not need to create a new account to submit a privacy request.

14. Appeals

If we refuse to take action on a consumer health data request, you may appeal the decision by emailing:

privacy@lifedesk.me

Use the subject:

Consumer Health Data Privacy Appeal

Please explain why you believe the decision should be reconsidered.

We will review the appeal and provide a written response within the period required by applicable law.

15. Security

We use technical and organizational safeguards designed to protect consumer health data, including:

authenticated access;
server-side authorization controls;
private file storage;
encryption in transit and at rest;
access restrictions based on necessity;
security monitoring;
protected backups;
deletion procedures;
confidentiality obligations for authorized personnel.

No online service can guarantee absolute security.

16. Changes to This Policy

We may update this policy to reflect changes in LifeDesk, applicable law or our service providers.

We will not collect or use additional categories of consumer health data for materially different purposes without updating this policy and obtaining consent where required.

The current version and update date will be published on the LifeDesk website.