Privacy Policy

This privacy policy covers the processing of your personal data in connection with the services that Optimize B.V. ("we", "us" or "our") provides to you through the Optimize app (the "App"). Optimize is located at Keizersgracht 285, 1016 ED Amsterdam, the Netherlands, and is registered with the Dutch Chamber of Commerce under number 93488866.

This privacy policy explains how we collect, use, share and protect personal data in the course of our business. It is intended for all external persons whose personal data we process ("you", "your").

Optimize values your privacy. That is why we use this policy to inform you about the personal data we collect about you as part of the services we offer you through the App, the purposes for which we do so, the parties with whom we share your personal data, how we handle your personal data and what rights you have.

Personal data and purposes

We process the following categories of personal data about you for the following purposes:

1. Administrative data, such as name, (email) address, date of birth, phone number, payment details (the references of your payments and mandates with our payment service provider; we do not store your IBAN or card number ourselves), user ID, preferred language, push notification token, credit balance and account status:
   • To offer you our services in the app, including creating and managing user accounts for the Optimize app, authentication, management of profile, address and notification settings, and management of business customer accounts; and to enable you to purchase laboratory tests and app credit.
   • To facilitate the scheduling of laboratory tests and blood draw appointments at partner locations; to track the status of appointments; and to collect your feedback (ratings) on completed appointments.
   • To send service-related emails to end users (such as appointment confirmations, laboratory result notifications and invoice confirmations).
   • To process payments for tests, memberships and top-ups of business balances; to generate and store invoices; to manage vouchers and credits; and to pay out participants in our partner programme, for which we keep their IBAN and account name.
2. Health data (some of which is sensitive personal data), such as the results of your blood tests, biomarker values, your fitness and exercise habits, diet, sleep patterns, data from wearable devices and any medical or health-related information you choose to provide (for example current medication or conditions), documents you upload, such as earlier lab results, and your questions to and conversations with the coach in the app:
   • To give you personalised lifestyle advice that helps you reach your chosen lifestyle goals.
   • To generate understandable interpretations of your blood values and make them available to you by translating them into personalised insights and recommendations in an accessible format.
   • To run your personal 12-week lifestyle programme by assigning you actions, following your progress and adjusting the programme weekly based on the input you report yourself.
   • To alert you if your results give reason to: notable values are flagged automatically. A physician affiliated with Optimize reviews the flag and may ask you additional questions anonymously through the app; the physician does not see your name and you do not see theirs. You then receive advice to contact your GP, or a message that this is not necessary. This is a safety measure within the lifestyle service; Optimize does not provide medical care and does not make diagnoses. This review and your answers are deleted together with your account.
   • This personal data may be provided to us by you and (at your request) through third parties such as Apple Health, Health Connect, Oura, WHOOP and Fitbit (see our sub-processors page).
   • We process this data only with your explicit consent, to give you personalised lifestyle advice as part of the service. You can withdraw this consent at any time in the app under Privacy & consent. Because we cannot provide the service without this data, we will then close your account and delete your data in line with the retention periods below.
3. Cycle data (sensitive personal data) that you record yourself when you use the cycle feature, such as the start and end date of your period, symptoms, mood and other notes, whether you are pregnant or in menopause, and the predictions we base on this:
   • To track your cycle, give you predictions and reminders, and align your lifestyle advice and the timing of a blood test with your cycle.
   • The cycle feature is optional. We process this data only with your separate, explicit consent, which we ask for when you switch the feature on. This consent is independent of the consent for your other health data.
   • The data needed for predictions and advice, such as the dates of your period, your cycle phase and whether you are pregnant or in menopause, goes to our servers. Scores per symptom and your own symptoms are stored only on your device; free-text notes in your daily log go to our servers.
   • You can withdraw this consent at any time in the app via Stop tracking. We then delete your cycle data, including what is stored only on your device. Your account and your blood results remain.
4. Anonymised data for improvement and research (only with your consent):
   • To improve the app, our analyses and our advice using data that we first anonymise, so that it can no longer be traced back to you.
   • To share anonymised data with universities, academic hospitals and non-profit research institutions for scientific or statistical research. Never with advertisers or insurers.
   • Both purposes are optional and each requires your own consent. Without this consent you can use the app in full. We never use or share data that directly identifies you, such as your name or email address, for these purposes. Cycle data is always excluded: we do not use or share it for improvement or research, not even anonymised. The same applies to data from wearables and health platforms, such as Apple Health and Health Connect.
   • If you withdraw one of these consents, we stop anonymising and sharing for that purpose from that moment. Data that has already been anonymised or shared cannot be recalled.
   • If you gave consent for research before October 2026, that choice applies to Scientific research and to Improving the app. You can withdraw either at any time under Privacy & consent.
5. Marketing data (only with your consent), such as your name, email address, preferred language and, for app attribution, a device and advertising identifier:
   • To send you news and offers from Optimize, and to measure through which advertisement or link you installed the app (app attribution). We do not use your health data for this, nor to decide who receives which message. You can withdraw this consent at any time in the app under Privacy & consent or via the link in every email.
6. Technical and usage data (such as application error logs, audit logs of interactions in the app, and device and usage information, including cookie identifiers):
   • To operate our marketing website and mobile app, including by placing necessary cookies on your device.
   • To see how the app is used (product analytics), linked to your user ID and without your IP address: our analytics service derives only your approximate location (city and postcode) from your IP address and does not store the address itself. Health data is not included; anything concerning the cycle feature is counted without any link to you. We do this on the basis of our legitimate interest. You can object to this in the app under Privacy & consent.
   • We process this data to maintain and improve the security, stability and performance of our app and website. Where we use non-essential tracking or analytical cookies on our website, we do so only with your consent, which you can withdraw at any time.

If you have given consent for the processing of your personal data, you can withdraw that consent at any time. You withdraw each consent in the app under Privacy & consent, and the consent for the cycle feature via Stop tracking. If you withdraw the consent for the processing of your health data, we will close your account, because we cannot provide the service without that data. If you withdraw another consent (cycle feature, improvement or research with anonymised data, marketing), the rest of the service keeps working as normal. For individual components, such as notifications or links to external sources, you can also withdraw your consent separately. This does not affect the lawfulness of the processing of your personal data before the withdrawal.

Our services are intended exclusively for persons aged 18 or over. We do not knowingly process personal data of minors, including special categories of personal data. If we find that personal data of a minor has been processed, we will delete that data without delay.

Legal bases for processing your personal data

Who do we share your personal data with?

Your privacy is a priority for us. We take your privacy very seriously and treat your personal data with the greatest possible care and confidentiality.

We engage external service providers to support the delivery and operation of our services. Depending on the circumstances, these parties may act as processors or sub-processors, processing personal data on our behalf and in accordance with our instructions. These service providers may operate within one or more of the following categories:

• Laboratory and healthcare partners (including laboratories and sample collection services);
• Health data integration services (for example the integration of data from wearables or third parties);
• AI-based analysis and personalisation services;
• Payment service providers; and
• Analytics and monitoring services.

An up-to-date overview of the third parties we engage, including further details on their role and the nature of the processing activities, is available on our sub-processors page.

If you use Optimize through your employer or another business customer, they only see whether and when a credit was used. Optimize never shares your health data, results or advice with your employer.

In addition, only if you give separate consent, we share anonymised data with universities, academic hospitals and non-profit research institutions for scientific or statistical research; never with advertisers or insurers. This data cannot be traced back to you. We do not share data from wearables and health platforms for this purpose. We never provide cycle data to third parties for their own purposes, not even anonymised or for research.

We ensure that all processors and sub-processors are subject to appropriate contractual safeguards, including data processing agreements where required, and that they take adequate technical and organisational measures to protect personal data in accordance with applicable data protection law.

International data transfers

Most of your personal data is processed and stored within the European Economic Area (EEA). In some cases, however, we share personal data with third parties established outside the EEA, for example in the United States or the United Kingdom, where this is necessary to provide our services.

Where personal data is transferred to a country outside the EEA, a so-called "third country", we ensure that the transfer takes place in accordance with the GDPR and that an appropriate and lawful transfer mechanism is in place to protect your data and guarantee an adequate level of protection. Depending on the circumstances, this may mean that we rely on lawful transfer mechanisms such as an adequacy decision adopted by the European Commission or the use of Standard Contractual Clauses (SCCs) approved by the European Commission.

You can contact us at any time if you would like more information about international data transfers or the safeguards that apply in a specific case.

What do we do with your data?

How is your lifestyle advice created? We provide our services by combining your health data and lifestyle preferences. We analyse this information to show you your test results, build your health profile and give you targeted notifications, recommendations and advice through the app. In providing these personalised insights, we use automated analysis, including artificial intelligence ("AI"), to interpret your biomarker results and other input. The AI model generates tailored explanations and lifestyle recommendations for you. This automated analysis may highlight areas for improvement in your health and habits, but it does not constitute a medical diagnosis or medical advice and does not involve decisions that have legal or similarly significant effects on you. For the avoidance of doubt: the app and the lifestyle advice are not intended to diagnose, treat, cure or prevent any disease or medical condition. The flagging of notable results is a referral function to your GP, not treatment.

We apply data minimisation, data separation and pseudonymisation while providing our services to you. To protect your personal data, we keep separate databases: one with personal identification data (such as your name, email address, date of birth and contact details) and one with your health data. These datasets are linked through a unique user ID and a private key that is accessible only to Optimize.

As a result, your health data is pseudonymised for as long as your account is active: only Optimize can link it to you using this key, and it is not directly identifiable to third parties. Pseudonymised data is still personal data. We therefore do not share it for improvement or research.

If you give consent, we anonymise your health data to improve the app and our advice or to share it for research. For this we use only data that is anonymised according to the standard below. We never use cycle data or data from wearables and health platforms for this.

When assessing whether data is anonymised, we take into account all means reasonably likely to be used to identify a person, including the available technology, the cost and time required, and any legal restrictions. Where such means are not reasonably available, the data is treated as anonymous.

In practice, we anonymise as follows. Your name, email address, user ID and any other detail that points to you directly are never included, and we do not give you a fixed number that returns in a later dataset. We include dates by month only, and your age only in a five-year band. We include conditions and medication only by group, as you choose them in the app; anything you type yourself is not included. If a group occurs in fewer than five people in a dataset, we leave it out for them. Once your personal data has been anonymised, it is no longer possible for us to delete it at your request.

Retention periods

We do not keep your personal data longer than necessary for the purposes for which it was collected. In most cases this means that we keep the data until you delete your account or end the agreement.

If you delete your account, we delete your personal identification data and your health data, including your blood results, uploaded documents, conversations with the coach and wearable data, within 30 days. Our backups are overwritten after seven days; no later than seven days after deletion, your data is gone from them as well. Data that was previously anonymised with your consent remains; it can no longer be traced back to you. If your consent for improvement or research is on when you delete your account, we first anonymise your blood values and medical history according to the standard above and then delete the rest. What remains can no longer be traced back to you. We always delete cycle data and data from wearables and health platforms in full.

There are two exceptions. We keep payment and invoice data in our records for seven years to meet tax obligations. We keep data needed for an ongoing complaint or dispute until it is resolved.

We keep technical data for a short time: error logs and server and access logs (containing IP addresses) for a maximum of 90 days, audit logs (who viewed or changed your record, with IP address) for a maximum of 24 months and login records (login attempts and login links, with IP address) for a maximum of 12 months. We use product analytics data for a maximum of 12 months; after that we delete it from our own systems and our analytics service no longer uses it.

Data you enter for an order you do not complete is deleted after 30 days. We keep support conversations, including those via WhatsApp, for two years after they are closed, so that we can respond to later questions or complaints. We keep a log of sent emails for 90 days; after that we remove the email address and subject from that log. Our email service does not store the content of emails and keeps delivery information for a maximum of 30 days; addresses that turn out to be unreachable or that generate a complaint remain on a suppression list so that we do not email them again. If you unsubscribe from marketing, we keep only an encrypted (hashed) version of your email address so that we can permanently honour your unsubscribe.

We keep cycle data for as long as you use the cycle feature. If you stop tracking or delete your account, we delete it within 30 days, together with what we derive from it, such as predictions. No later than seven days after that, it is gone from our backups as well. It is not kept in anonymised form.

If you want to keep your blood results, for example for medical reasons, download them before you delete your account; the app offers this before the final confirmation.

Security of your personal data

We have taken technical and organisational measures to adequately protect your personal data against loss or any other form of unlawful processing.

Your personal data is stored encrypted. Reports and other static files are separately secured according to current encryption standards (AES-256).

Access to the app is fully secured. Your identity is first verified using OAuth 2.0 with Proof Key for Code Exchange ("PKCE"), after which your data is accessible only through biometric authentication (such as Face ID or Touch ID) or a personal passcode.

We also apply data minimisation, data separation and pseudonymisation. For optimal data protection we maintain two separate databases: one with personal identification data (e.g. your name, email address, phone number, date of birth and address) and one with your health data. These two datasets can only be combined using a unique user ID in combination with a private key held only by Optimize. Without this key, no third party (including service providers or malicious actors in the event of a security breach) can directly identify you from the health data alone.

In developing and maintaining the App we apply the principles of privacy by design and privacy by default. Our technical and organisational security measures are aligned with current best practices and recognised standards, including ISO/IEC 27001 (information security), the OWASP Mobile Security Guidelines and the principles and recommendations of the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Changes

We may change this privacy policy from time to time. If we do, we will notify you. If your consent is required for a new purpose, we will ask for it first in the app. Without your consent, nothing changes for you. You can always decide to stop using the app, including after such a change.

Your rights

Under the GDPR and relevant data protection legislation you have a number of rights regarding your personal data. We respect these rights and have put processes in place to enable you to exercise them. These rights include:

1. Right of access: you have the right to ask whether we process your personal data and, if so, to request a copy of the personal data we hold about you.
2. Right to rectification: you have the right to request that we correct inaccurate or incomplete personal data we hold about you.
3. Right to erasure: you have the right, in certain circumstances, to request the deletion of your personal data (the "right to be forgotten"). This right is not absolute; sometimes we must retain certain data to comply with legal obligations or to establish or defend legal claims.
4. Right to restriction of processing: you have the right to request that we suspend or restrict the processing of your personal data in certain scenarios.
5. Right to data portability: for data you have provided to us and that we process by automated means on the basis of your consent or a contract with you, you have the right to request a copy in a structured, commonly used and machine-readable format (and you have the right to transmit that data to another controller, or to ask us to transfer it, where technically feasible). You can download your blood results as a PDF in the app at any time.
6. Right to object: you have the right to object to our processing of your personal data where we rely on legitimate interests, and an absolute right to object to processing for direct marketing purposes. You can object to product analytics in the app under Privacy & consent.
7. Right to withdraw consent: where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of the earlier processing. You do this in the app under Privacy & consent, and for the cycle feature via Stop tracking. Withdrawing is as easy as giving consent. If you withdraw the consent for the processing of your health data, we will close your account, because we cannot provide the service without that data.

These rights are not absolute. For example, we cannot erase data we are legally required to retain, or grant access to information that contains the personal data of others. We will assess your request in accordance with the GDPR. This means that we first verify your identity in an appropriate way, preferably through your account in the app; only in case of reasonable doubt will we ask for additional proof. As soon as possible and in any event within one month of your request, we will inform you of the measures we have taken. We may extend this period by two months due to the complexity or number of requests; in that case we will inform you.

You have the right at any time to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). To exercise your rights, you can email privacy@optimizelifestyle.io.

Cookies and similar technologies

We use functional and analytical cookies and, only with your consent, marketing cookies. A cookie is a small file that is stored on your computer, tablet or smartphone when you first visit or use our app or website.

Functional cookies serve a purely technical function. These cookies are needed to make sure the app and the website work properly and that, for example, your preferences are remembered. Your consent is not required for these cookies.

We may also use analytical cookies to gain insight into the use of our app and website and to improve our services. Where these analytical cookies have a limited impact on your privacy (for example where data is aggregated or anonymised), they may be used without consent where permitted by applicable law. In all other cases, including where analytical or tracking technologies involve the processing of personal data that is not strictly necessary, we will ask for your prior consent via the app or website. Where we use cookies or similar technologies for marketing or tracking purposes, we will always ask for your prior consent.

In the app we use similar technologies. With your consent for marketing, we measure through which advertisement or link you installed the app (app attribution), using a device and advertising identifier for this. On iOS, Apple will additionally ask you for this itself. Without that consent, we do not start this measurement. If you place an order on the website and have consented to marketing cookies, we pass the purchase, together with your IP address, to Meta and AppsFlyer to link it to an advertisement; we keep that IP address ourselves for a maximum of seven days.

Contact

If you have questions about this privacy policy, please contact us by emailing privacy@optimizelifestyle.io.

Optimize has appointed a Data Protection Officer ("DPO"). The DPO is available for all questions, requests or concerns regarding the processing of your personal data, including the exercise of data subject rights, via the contact details above.

Version history

October 2026: separate consent for the cycle feature; two optional purposes for improvement and research with anonymised data; withdrawal per consent in the app; marketing and app attribution as a purpose of their own; product analytics with objection in the app; all data deleted on account deletion, with time limits; download of results before deletion; anonymisation by a fixed standard, also before an account is deleted.

July 2026: previous version.