Privacy Policy
Version 2.1 · 2026-07-17
1. Controller
Avelia Health GbR (Anton Anders, Annett Anders, Viktoria Hoffmann), Wittenberger Str. 91b, 04849 Bad Düben, Germany. Contact: privacy@avelia-health.com.
2. What We Collect
2.1 Website
- Waitlist & contact forms: Name, email address, phone number, and any information you voluntarily provide (e.g. profession, practice name, organisation name and type, country, registration number). Stored in Listmonk, self-hosted in Germany. Phone numbers are collected for verification purposes only and are not used for marketing.
- Avelia Fund & partner applications: If you apply through the midwife fastlane or partner application forms, we additionally collect professional details (practice name, profession, registration number) or organisational details (organisation name, type, expected monthly code volume, description). This data is used solely to assess eligibility and is stored in Listmonk.
- Region cookie: A single functional cookie (
jurisdiction) to display the correct legal information for your country. No consent required under GDPR Art. 6(1)(f) as it serves a legitimate interest. - Analytics (with consent): If you accept analytics in our cookie banner, we collect anonymous usage statistics via self-hosted, cookie-less analytics software. We currently run two such tools in parallel — Matomo and OpenPanel — while we evaluate which one to keep; both are self-hosted on servers in Germany. Neither sets tracking cookies, stores persistent identifiers in your browser, or performs cross-site tracking; IP addresses are processed only transiently or in truncated (anonymised) form. All analytics requests are served through our own domain — no data is transmitted to third parties. You can withdraw consent at any time by clearing your browser’s localStorage.
- Server logs: Our web server records IP addresses, request paths, timestamps, and user agents for security and operational purposes. Logs are retained for 30 days and processed under legitimate interest (GDPR Art. 6(1)(f)). IP addresses are anonymised before any analytics processing.
2.2 Mobile App
- On-device data: Journal entries, tracking data, checklists, and personal notes are stored locally on your device. In the Free tier, this data never leaves your device.
- Cloud sync (Personal & Together tiers): If you enable cloud sync, your data is end-to-end encrypted on your device before transmission. We receive and store only ciphertext. We are technically unable to read, analyse, or access your content. The encryption keys never leave your device.
- Partner linking: When you link with a partner, a shared encryption key is exchanged directly between your devices. We facilitate the connection but cannot read shared content.
- Account data: Email address and hashed password for authentication. Stored in our backend database, hosted in Germany.
3. Legal Basis
| Processing | Legal basis |
|---|---|
| Account creation & service delivery | Contract performance (Art. 6(1)(b)) |
| Region cookie | Legitimate interest (Art. 6(1)(f)) |
| Analytics | Consent (Art. 6(1)(a)) |
| Server logs | Legitimate interest (Art. 6(1)(f)) |
| Newsletter / waitlist | Consent (Art. 6(1)(a)), double opt-in |
| Partner / fund application forms | Consent (Art. 6(1)(a)) |
4. Data Sharing
We do not sell, trade, or share your personal data with third parties. We do not use any third-party analytics, advertising, or tracking services. All infrastructure is self-hosted in Germany.
Sub-processors: Our server infrastructure is hosted by netcup GmbH and Hetzner Online GmbH, located in Germany. No data is transferred outside the European Economic Area.
5. Data Retention
- Account data: Retained until you delete your account.
- Encrypted sync data: Deleted immediately and permanently when you delete your account.
- Server logs: Anonymised or deleted after 30 days.
- Newsletter subscribers: Until you unsubscribe.
- Form submissions (interest, partner, fund applications): Name, email, phone number, and professional/organisational details are retained until the inquiry is resolved or you request deletion.
- Expired accounts (Avelia Fund / code-based): After licence expiry, a grace period of 2–4 weeks applies during which sync data remains available. After the grace period, all encrypted sync data is permanently deleted from our servers. Local data on your device is unaffected.
6. Your Rights
Under the GDPR, you have the right to:
- Access your personal data (Art. 15)
- Rectification of inaccurate data (Art. 16)
- Erasure (“right to be forgotten”) (Art. 17)
- Restriction of processing (Art. 18)
- Data portability (Art. 20) — export is available in the app
- Object to processing based on legitimate interest (Art. 21)
- Withdraw consent at any time without affecting prior processing (Art. 7(3))
- Lodge a complaint with a supervisory authority
To exercise these rights, contact privacy@avelia-health.com.
7. Security
We employ end-to-end encryption (AES-256-GCM with X25519 key exchange), zero-knowledge architecture, TLS 1.3 for data in transit, and encrypted storage at rest. Our infrastructure is regularly audited. We follow the principle of data minimisation — we only process what is strictly necessary.
8. Children’s Data
Avelia is operated by adults (parents and prospective parents). Children do not create accounts or interact with the service directly. However, parents may enter data about their children — such as names, birth dates, developmental milestones, feeding and sleep logs, and health notes — as a core feature of the app.
This data is protected by the same end-to-end encryption as all other content. We cannot read or access it. It is stored exclusively on your device (Free tier) or as encrypted ciphertext on our servers (paid tiers). When you delete your account, all data about your children is permanently erased.
Children under 16 may not create their own Avelia account. If you believe a child has independently created an account, please contact us and we will delete it immediately.
9. Changes
We may update this policy to reflect changes in our practices or legal requirements. Material changes will be communicated via email or in-app notification. The version number and date at the top of this page indicate the current revision.