Privacy Policy for the Optimize Health App

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PRIVACY POLICY

Last Updated: Aug 22, 2025

This Privacy Statement relates to the processing of your personal data as part of the services that Optimize B.V. ("we" or "us") provides to you through the Optimize app (hereinafter the "App"). Optimize has its registered office at Keizersgracht 285, 1016 ED Amsterdam, the Netherlands, and is registered in the register of the Dutch Chamber of Commerce under number 93488866.

Optimize values your privacy highly. Therefore, we use this statement to inform you properly about the personal data we collect about 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:

a. Administrative data, name and address details and payment details, so that we can provide you with our services in the App and so that you can buy credits.

b. Data about your lifestyle and goals, so that we can give you personalised lifestyle advice that ensures you can achieve your selected goals. This personal data is provided by you yourself and at your request through third parties such as Apple Health and Whoop. You have complete freedom of choice of which external data sources, such as Apple Health and Whoop, you want to link to.

c. Health data, so that we can give you personalised lifestyle advice that ensures you can achieve your selected goals.

If you have consented to the processing of your personal data, you may withdraw your consent at any time. As it is not possible for us to provide the services to you in that case, you can only withdraw your consent by terminating the service. For individual components, such as notifications or links to external sources, you may withdraw your consent separately. This preserves the lawfulness of the processing of your personal data prior to the withdrawal of consent.

Bases

We process your personal data for the following purposes:

a. your administrative data and payment details. Without this information, we cannot perform our agreement with you to provide the services;

b. data about your lifestyle and your health data (blood values). We need this information to provide the services to you. We process this data on the basis of your consent, which you may withdraw at any time by terminating the service.

With whom will your personal data be shared?

Through our App, we share your contact details with ZorgDomein Nederland B.V. to request laboratory tests from our lab partner Unilabs Diagnostics B.V. Once your blood is shared with Unilabs through your selected collection site and Unilabs has performed the test, we will receive the results of your blood test. Those results are shared with us securely through our collaboration partner Enovation B.V.

In the context of the services, your data will also be processed by the following processors:

a. DigitalOcean (for cloud hosting and data storage); and

b. Mollie (payment services).

We do not transfer your personal data to natural persons or legal entities outside the European Economic Area ("EEA").

What do we do with your data?

How does your lifestyle advice come about? We provide our services by combining your health data and lifestyle preferences. We analyse this information to show test results, build your health profiles and provide you with targeted notifications, recommendations and advice through the App.

We anonymise the information we hold about you for scientific research and for improving our App. Where this involves special personal data, we do so with your explicit consent. The anonymisation process is irreversible. Once your personal data is anonymised, it is no longer possible for us to delete it if you request deletion.

Retention periods

We will not keep your personal data for 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 terminate the agreement. We will then delete your personal data from our systems one year after your account is deleted. Data already processed in anonymised or aggregated form will be retained. In certain cases, we are required by law to keep specific data for longer. For example, we keep your payment details in our records for seven years for tax reasons.

Since you may want to see your blood results again because you need them for medical reasons, we store the results of blood diagnostics through Unilabs for one year after you delete your account. You may request those details by sending an e-mail to privacy@optimizelifestyle.io`.`

Security of your personal data

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

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

Access to the App is fully protected. Your identity is first verified using OAuth 2.0 with proof key for code exchange ("PKCE"), after which your data can only be accessed using biometric authentication (such as Face ID or Touch ID) or a personal access code.

We also apply data minimisation, data repair and pseudonymisation. Sensitive medical data is stored in separate, highly secure databases and can only be linked to users indirectly, without directly traceable personal data being used.

We apply the principles of privacy by design and privacy by default when developing and maintaining the App. 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.

Amendments

We may amend this Privacy Statement from time to time. If we do, we will notify you. You may always – i.e. including after such an amendment – decide to stop using the App.

Your rights?

You have the right to ask us to:

a. provide access to your personal data (such as your contact details);

b. have your personal data (such as your contact details) supplemented, corrected or deleted;

c. stop processing your personal data;

d. restrict the processing of your personal data; and/or

e. transfer your personal data to you or a third party.

These rights are not absolute. We will assess your request in accordance with the GDPR. This means that we will first have to verify your identity on the basis of your proof of identity. As soon as possible and in any case within one month of your access request (unless we have been unable to verify your identity), we will then provide you with information on the actions we have taken in response to your request. We may extend this deadline by two months due to the complexity of your request or the number of requests we receive. In that case, we will notify you.

You have the right to file a complaint with the Dutch Data Protection Authority at any time.

To exercise your rights, you may send an e-mail to privacy@optimizelifestyle.io`.`

Cookies or similar technologies we use

We use functional and analytical cookies. A cookie is a small text file that is stored on your computer, tablet or smartphone the first time you visit the Optimize App. Functional cookies perform a purely technical function. These ensure that the App works properly and that, for example, your preferred settings are remembered. These cookies are also used to make our App work properly and optimise it. If we are required by law to seek consent to place analytical cookies, we will do so through the App.

Contact

If you have any questions about this Privacy Statement, please contact us by sending an e-mail to privacy@optimizelifestyle.io`.`

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PRIVACY POLICY

PRIVACY POLICY

PRIVACY POLICY

Last Updated: Aug 22, 2025

Optimize values your privacy highly. Therefore, we use this statement to inform you properly about the personal data we collect about 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

Personal data and purposes

Personal data and purposes

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

a. Administrative data, name and address details and payment details, so that we can provide you with our services in the App and so that you can buy credits.

c. Health data, so that we can give you personalised lifestyle advice that ensures you can achieve your selected goals.

Bases

Bases

Bases

We process your personal data for the following purposes:

a. your administrative data and payment details. Without this information, we cannot perform our agreement with you to provide the services;

b. data about your lifestyle and your health data (blood values). We need this information to provide the services to you. We process this data on the basis of your consent, which you may withdraw at any time by terminating the service.

With whom will your personal data be shared?

With whom will your personal data be shared?

With whom will your personal data be shared?

In the context of the services, your data will also be processed by the following processors:

a. DigitalOcean (for cloud hosting and data storage); and

b. Mollie (payment services).

We do not transfer your personal data to natural persons or legal entities outside the European Economic Area ("EEA").

What do we do with your data?

What do we do with your data?

What do we do with your data?

How does your lifestyle advice come about? We provide our services by combining your health data and lifestyle preferences. We analyse this information to show test results, build your health profiles and provide you with targeted notifications, recommendations and advice through the App.

Retention periods

Retention periods

Retention periods

Since you may want to see your blood results again because you need them for medical reasons, we store the results of blood diagnostics through Unilabs for one year after you delete your account. You may request those details by sending an e-mail to privacy@optimizelifestyle.io.

Security of your personal data

Security of your personal data

Security of your personal data

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

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

Access to the App is fully protected. Your identity is first verified using OAuth 2.0 with proof key for code exchange ("PKCE"), after which your data can only be accessed using biometric authentication (such as Face ID or Touch ID) or a personal access code.

We also apply data minimisation, data repair and pseudonymisation. Sensitive medical data is stored in separate, highly secure databases and can only be linked to users indirectly, without directly traceable personal data being used.

Amendments

Amendments

Amendments

We may amend this Privacy Statement from time to time. If we do, we will notify you. You may always – i.e. including after such an amendment – decide to stop using the App.

Your rights?

Your rights?

Your rights?

You have the right to ask us to:

a. provide access to your personal data (such as your contact details);

b. have your personal data (such as your contact details) supplemented, corrected or deleted;

c. stop processing your personal data;

d. restrict the processing of your personal data; and/or

e. transfer your personal data to you or a third party.

You have the right to file a complaint with the Dutch Data Protection Authority at any time.

To exercise your rights, you may send an e-mail to privacy@optimizelifestyle.io.

Cookies or similar technologies we use

Cookies or similar technologies we use

Cookies or similar technologies we use

Contact

Contact

Contact

If you have any questions about this Privacy Statement, please contact us by sending an e-mail to privacy@optimizelifestyle.io.

Since you may want to see your blood results again because you need them for medical reasons, we store the results of blood diagnostics through Unilabs for one year after you delete your account. You may request those details by sending an e-mail to privacy@optimizelifestyle.io`.`

To exercise your rights, you may send an e-mail to privacy@optimizelifestyle.io`.`

If you have any questions about this Privacy Statement, please contact us by sending an e-mail to privacy@optimizelifestyle.io`.`