Privacy Policy — Liver & Heart
Last updated: 15th May 2026
1. Controller and Contact
The controller responsible for the processing of personal data on Liver & Heart is:
SPOTIC GmbH
Schuppstrasse 31
65191 Wiesbaden
Germany
E-mail: [email protected]
For questions regarding data protection, rights requests or compliance matters, please contact us at [email protected].
2. Scope and Legal Framework
This Privacy Policy applies to all personal data processed by SPOTIC GmbH in connection with the Liver & Heart platform, website, applications and related digital services (“Services”).
We process personal data in accordance with the European General Data Protection Regulation (“GDPR”), the German Federal Data Protection Act (“BDSG”) and other applicable data protection laws.
This Privacy Policy applies to all users of the Services, including patients, members, experts, organizations, partners and visitors, whether registered or not.
3. Categories of Personal Data We Process
Account and Registration Data
When you register, we collect your name, e-mail address, password (stored as a hash) and the date and time of registration. For professional accounts, we may also collect professional title, specialty, affiliation and license information.
Profile Data
Information you voluntarily add to your profile, such as a display name, biography, profile photo, location, areas of interest, professional experience or organization membership.
Health-Related Data
Liver & Heart may process health-related information that you voluntarily provide, such as journey progress, self-reported health interests, risk awareness questionnaire results or other information you share when using health-oriented features of the platform. This data is treated as a special category of personal data under Article 9 GDPR and is processed only on the basis of your explicit consent, or where another lawful basis applies under Article 9(2) GDPR.
Content and Contributions
Text, comments, answers, reviews, posts, event submissions, suggestions or other content you publish or submit through the Services.
Usage and Technical Data
IP address, browser type and version, operating system, device identifiers, pages visited, session duration, click paths, feature usage and interaction patterns. IP addresses are used for security, rate limiting and approximate geolocation, and are not permanently linked to user identities where avoidable.
Payment and Billing Data
If you use paid features, we collect billing name, billing address, plan type, payment status and invoice history. Full payment card details are processed exclusively by our payment providers (Stripe or Mollie) and are not stored by Liver & Heart.
Communication Data
E-mail address, communication preferences, messages you send to us via contact forms or support, and newsletter subscription status.
Audio and Voice Data
If you use voice or speech input features, your audio input may be processed by our speech-to-text providers to generate transcripts. Audio data is processed only for the purpose of transcription and is not used for other purposes.
4. Purposes and Legal Bases for Processing
Providing and operating the Services
Legal basis: Contract performance (Art. 6(1)(b) GDPR) or legitimate interests (Art. 6(1)(f) GDPR) for visitors without registration.
Processing health-related data for personalized features
Legal basis: Explicit consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR). You may withdraw consent at any time.
Account management, authentication and security
Legal basis: Contract performance (Art. 6(1)(b) GDPR) and legitimate interests in platform security (Art. 6(1)(f) GDPR).
Payment processing for subscriptions and paid features
Legal basis: Contract performance (Art. 6(1)(b) GDPR) and compliance with legal obligations (Art. 6(1)(c) GDPR).
Sending transactional e-mails (account confirmations, notifications)
Legal basis: Contract performance (Art. 6(1)(b) GDPR).
Sending the Liver & Heart newsletter
Legal basis: Consent (Art. 6(1)(a) GDPR). You may unsubscribe at any time via the link in every newsletter or via your account settings.
Improving the Services, product analytics and research
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Analytics data is processed in aggregated or pseudonymised form where possible. We do not perform profiling for advertising purposes.
Geolocation for place and event discovery
Legal basis: Consent (Art. 6(1)(a) GDPR) for precise geolocation; approximate geolocation from IP address is based on legitimate interests (Art. 6(1)(f) GDPR).
Legal compliance, fraud prevention and enforcement
Legal basis: Legal obligation (Art. 6(1)(c) GDPR) and legitimate interests (Art. 6(1)(f) GDPR).
5. Health Data and Special Categories
Liver & Heart is a health platform. Some features may involve health-related data, such as journey progress, self-reported health interests, screening orientation or risk awareness results. Such data constitutes a special category of personal data under Article 9 GDPR.
We process health-related data only where you have provided explicit consent or where another valid legal basis under Article 9(2) GDPR applies. Health data is stored with access controls, encryption at rest and strict purpose limitation.
Health data is not shared with Partners for commercial purposes. If partner cooperation involves aggregated health-related reporting, this is done only in aggregated, anonymised or otherwise privacy-protective form, with suppression thresholds applied to prevent re-identification. We do not sell or license health data under any circumstances.
Content on Liver & Heart, including journeys, risk tools, Q&A and expert content, is for educational and informational purposes only. It does not constitute a diagnosis or individual medical advice.
6. Your Rights Under GDPR
Subject to applicable law, you have the following rights regarding your personal data:
- Right of access — to request a copy of the personal data we hold about you (Art. 15 GDPR).
- Right to rectification — to request correction of inaccurate or incomplete data (Art. 16 GDPR).
- Right to erasure — to request deletion of your personal data where no overriding legal basis applies (Art. 17 GDPR).
- Right to restriction — to request that we restrict processing in certain circumstances (Art. 18 GDPR).
- Right to data portability — to receive your data in a structured, machine-readable format (Art. 20 GDPR).
- Right to object — to object to processing based on legitimate interests or for direct marketing purposes (Art. 21 GDPR).
- Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.
To exercise any of these rights, please contact [email protected]. We will respond within the timeframes required by applicable law (generally 30 days).
You also have the right to lodge a complaint with the competent supervisory authority. In Germany, the relevant authority is the Hessischer Beauftragter für Datenschutz und Informationsfreiheit (HBDI) or the supervisory authority of your country of residence.
7. Data Retention
We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, or as required by applicable law.
- Account data is retained for the duration of the account and for a limited period thereafter to facilitate account recovery and comply with legal obligations.
- Payment and billing records are retained for as long as required by tax and commercial law (typically 10 years in Germany).
- Newsletter subscription records and consent logs are retained for as long as needed to demonstrate lawful processing and handle unsubscribe requests.
- Server and security logs are retained for a limited period for security and fraud prevention purposes.
- Health-related data tied to journey progress or personalized features is retained until you delete it or request erasure, unless a longer retention period is required by law.
When data is no longer needed, it is securely deleted or anonymised.
8. Third-Party Providers and Processors
We use selected third-party providers to operate, secure, improve and deliver the Services. These providers act as data processors on our behalf and are bound by data processing agreements. The providers listed below are those confirmed as active in the current codebase and deployment configuration. Specific providers used may depend on the enabled features and deployment environment.
Hosting, Infrastructure and Storage
Cloudflare
Purpose: DNS, SSL/TLS, CDN, WAF/security, caching, image optimization, R2 object storage (primary file storage). In production, Cloudflare R2 is used to store user-uploaded media and platform assets. Cloudflare also provides network-level IP geolocation (country-level) via request headers.
Data processed: IP addresses, request metadata, uploaded files. Processing may occur in data centers globally, including outside the EU/EEA, subject to Cloudflare's Standard Contractual Clauses.
Amazon Web Services (AWS)
Purpose: AWS S3 may be used as an alternative object storage backend for certain deployments, in particular for encrypted storage of medical documents and platform files where configured. AWS SES is configured as an optional e-mail delivery option.
Data processed: Uploaded files and documents (depending on configuration). Processing may occur in EU or non-EU AWS regions depending on configuration. Standard Contractual Clauses apply.
Payments and Subscriptions
Stripe
Purpose: Payment processing, subscription management, invoicing and billing workflows for paid plans. Stripe processes payment card details directly; Liver & Heart does not store full card details.
Data processed: Billing name, billing address, payment card data (processed directly by Stripe), transaction metadata, subscription status. Processing may occur outside the EU/EEA, subject to Stripe's Standard Contractual Clauses.
Mollie
Purpose: EU payment processing fallback supporting SEPA Direct Debit, iDEAL, Bancontact and other EU-native payment methods.
Data processed: Billing name, billing address, payment method data (processed directly by Mollie), transaction metadata. Mollie is based in the Netherlands (EU); processing occurs within the EU/EEA.
AI, Language and Embeddings
AI providers process content you submit through AI-supported features (companion, explanation, search, translation, speech-to-text). They are not used to provide medical diagnosis, treatment decisions, emergency care or prescriptions. Health-related data is processed via AI providers only where necessary for the requested feature and where you have consented where required.
Anthropic
Purpose: Primary AI provider for companion features, content assistance, explanation, routing, summarization, fact-checking and automated translation of platform content.
Data processed: Text content submitted through AI-enabled features. Processing occurs in the United States, subject to Standard Contractual Clauses.
OpenAI
Purpose: AI fallback provider for content assistance and translation. OpenAI Whisper is used for speech-to-text transcription where OpenAI is the configured STT provider.
Data processed: Text content and audio submitted through AI-enabled or voice features. Processing occurs in the United States, subject to Standard Contractual Clauses.
Voyage AI
Purpose: Primary embeddings provider. Text content is converted to vector embeddings to power semantic search and content retrieval. Voyage AI is an Anthropic-affiliated embeddings specialist.
Data processed: Text content submitted for embedding and search purposes. Processing may occur in the United States, subject to Standard Contractual Clauses.
Deepgram
Purpose: Optional speech-to-text provider. If configured, Deepgram transcribes voice input. Used only when Deepgram is the active STT provider and only for the purpose of generating transcripts.
Data processed: Audio data submitted through voice features. Processing may occur in the United States, subject to Standard Contractual Clauses.
Search Infrastructure
Meilisearch
Purpose: Full-text and semantic search indexing. Meilisearch is operated as a self-hosted service on our own infrastructure and does not send data to a third party. Search index data (content titles, summaries, metadata) is stored on our servers and managed internally.
As a self-hosted service, no personal data is transferred to a third-party provider for search purposes.
Maps, Geocoding and Location
MapTiler
Purpose: Map tiles for interactive maps displayed on Liver & Heart (places, search, events). Geocoding to convert addresses to coordinates for place and event discovery.
Data processed: Map tile requests (IP address, requested tile coordinates), geocoding queries (address strings). MapTiler is based in Switzerland; processing may occur within and outside the EU/EEA.
Mapbox (not currently active)
Purpose: Mapbox may be used in future for advanced map features, geocoding or geospatial services if enabled. It is not currently active as a data processor. If Mapbox is activated, this Privacy Policy will be updated accordingly. The @mapbox/mapbox-gl-draw drawing library currently used in admin tools operates client-side only and does not transmit data to Mapbox.
If activated: data processed would include IP address, map tile requests and geocoding queries. Processing may occur in the United States, subject to Standard Contractual Clauses.
Nominatim / OpenStreetMap
Purpose: Geocoding fallback. When MapTiler is unavailable or not configured, geocoding queries (address-to-coordinates conversion) are sent to the public Nominatim service based on OpenStreetMap data.
Data processed: Address strings submitted for geocoding. Nominatim is operated by the OpenStreetMap Foundation; requests may be processed outside the EU/EEA.
MaxMind GeoLite2
Purpose: Approximate IP-based geolocation for locale detection, content localization and feature availability. We use the GeoLite2 City database, which is downloaded to our servers and queried locally. IP lookups are performed against a local copy of the database; IP addresses are not transmitted to MaxMind at query time.
The GeoLite2 database is obtained from MaxMind under the Creative Commons Attribution-ShareAlike 4.0 International License. Database updates are downloaded periodically from MaxMind servers; only the server's IP address is transmitted to MaxMind for this purpose.
E-Mail and Notifications
Mailgun
Purpose: Primary transactional e-mail delivery (account confirmations, password resets, notifications and other system e-mails).
Data processed: Recipient e-mail address, e-mail content, delivery metadata. EU customers can use the EU Mailgun endpoint (api.eu.mailgun.net) for EU-region processing. Standard Contractual Clauses apply where applicable.
Resend
Purpose: Transactional e-mail delivery fallback when Mailgun is unavailable.
Data processed: Recipient e-mail address, e-mail content, delivery metadata. Processing may occur outside the EU/EEA, subject to Standard Contractual Clauses.
Mailjet
Purpose: Newsletter delivery and mailing list management exclusively. Mailjet is used to manage newsletter subscriptions, deliver the Liver & Heart newsletter and handle subscription confirmations and unsubscribes. It is not used for transactional e-mail unless explicitly enabled.
Data processed: Subscriber e-mail address, subscription status, locale and consent metadata. Processing may occur in EU and non-EU data centers, subject to Mailjet's Standard Contractual Clauses. Mailjet is a Mailgun company.
Analytics
PostHog
Purpose: Product analytics and usage tracking to understand how the platform is used, identify issues and improve features. Events are recorded by our servers and, once you accept analytics cookies, also in your browser. User identifiers are pseudonymised (hashed) before they reach PostHog. Session recording and automatic click tracking are switched off, and we do not use PostHog for behavioral advertising or profiling for commercial targeting.
Data processed: Pseudonymised user identifiers (hashed), event names, feature interaction metadata, locale, and aggregated usage patterns. Events recorded in your browser additionally include the pages you visit, the website that referred you, campaign parameters, your device and browser type, and an approximate location derived from your IP address. Health-related data is explicitly excluded from analytics events. We use PostHog's EU instance, so this data is processed within the EU.
Customer Support
Customerly
Purpose: In-app live chat and customer support widget. The Customerly widget is loaded only after you have accepted personalization cookies via the cookie consent banner. If you have not consented or have declined personalization cookies, the widget is not loaded.
Data processed: Name, e-mail address (if provided), chat messages, interaction data and browser metadata. Processing may occur outside the EU/EEA, subject to Standard Contractual Clauses.
Advertising
Liver & Heart currently does not use Google AdSense or third-party behavioral advertising networks. If this changes, we will update this Privacy Policy and request consent where required by law before any advertising trackers are activated.
External Partner APIs and MCP Integrations
Where Liver & Heart integrates external partner APIs, MCP providers or trial/search services, such integrations are used only for configured features. Identifiable user data, health-related data or conversation content is not transmitted to such providers unless the user has explicitly requested the feature, has consented where required, or another valid legal basis applies. We apply the principle of data minimization: only the data necessary for the requested service is transmitted.
9. Cookies and Tracking Technologies
Liver & Heart uses cookies and similar technologies for the following purposes:
- Strictly necessary cookies: Session management, authentication tokens, CSRF protection and security. These cannot be disabled as they are required for the platform to function.
- Functional / personalization cookies: Remembering preferences such as locale, display settings and consent choices. The customer support chat (Customerly) is activated only with your consent.
- Analytics cookies: Usage analytics via PostHog, activated only with your consent where required by law.
You can manage your cookie preferences at any time via the cookie settings available on the platform. Withdrawing consent for non-essential cookies does not affect the functionality of core platform features.
Map features (powered by MapTiler and MapLibre) request map tile images from MapTiler servers when maps are displayed. These requests include your IP address and the tile coordinates requested. Interactive maps for authenticated members are loaded automatically; for visitors, maps may require a click to activate depending on platform configuration.
10. International Data Transfers
Some of our third-party providers process personal data outside the European Economic Area (EEA), in particular in the United States. Where personal data is transferred to countries not recognized by the European Commission as providing an adequate level of data protection, we implement appropriate safeguards, including Standard Contractual Clauses (SCCs) as provided for in Article 46(2)(c) GDPR.
Providers subject to potential non-EEA transfers include Cloudflare, AWS, Stripe, Anthropic, OpenAI, Voyage AI, Deepgram, Mailgun, Resend, Mailjet, PostHog and Customerly. Each operates under Standard Contractual Clauses or equivalent safeguards.
Meilisearch (search) is self-hosted on our own infrastructure and does not involve international transfers.
MaxMind geolocation lookups are performed locally on our servers using a downloaded database; no user IP data is transmitted to MaxMind at query time.
11. Data Sharing and Disclosure
We do not sell personal data. We do not share personal data with Partners for commercial targeting or advertising purposes.
We may share personal data in the following circumstances:
- With service providers: Third-party processors described in Section 8, bound by data processing agreements.
- With Partners: Only aggregated, anonymised or suppressed data as described in our Terms of Use. Partner reports do not contain individually identifiable data unless you have explicitly consented.
- Legal requirements: Where required by law, court order, regulatory authority or to protect rights and safety.
- Business transfers: In connection with a merger, acquisition or sale of assets, subject to equivalent data protection obligations being maintained.
- With your consent: In any other case where you have explicitly agreed.
12. Security
We implement appropriate technical and organizational security measures to protect personal data against unauthorized access, loss, alteration or destruction. These include access controls, encryption at rest and in transit, rate limiting, IP-based geolocation for fraud detection, audit logging and server-side security headers.
Password credentials are stored as cryptographic hashes and are not recoverable in plain text. Full payment card details are never stored by Liver & Heart and are processed directly by our payment providers.
If you believe you have found a security vulnerability or that your data may have been compromised, please contact us immediately at [email protected].
13. Children
Liver & Heart is not directed at children under 16 years of age. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected personal data from a child under 16, please contact us at [email protected] and we will take immediate steps to delete it.
14. Reporting Content and Rights Violations
If you believe that Content on Liver & Heart infringes your intellectual property rights, personal rights, privacy rights or other legal rights, please contact us at [email protected].
To report abusive content, unsafe medical claims or other policy violations, please use the reporting tools on the platform or contact [email protected].
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the Services, applicable law or the providers we use. We will notify registered users of material changes in accordance with the notification requirements of applicable law.
The current version of this Privacy Policy is always available at this URL. The date at the top of this page indicates when the policy was last updated.
16. Online Dispute Resolution
The European Commission provides a platform for online dispute resolution at: https://www.ec.europa.eu/consumers/odr
We are not obligated or willing to participate in dispute resolution proceedings before a consumer arbitration board, unless legally required.
For all data protection enquiries, please contact us at: [email protected]