1. Who we are
Josie is a digital health platform designed to support adult women living with or seeking a diagnosis of Polycystic Ovary Syndrome (PCOS). The service is operated by:
Laure Santolini and Manon Vervaeke
doing business as Health Surfers
Antwerp, Belgium
For all privacy-related questions, requests, and concerns, contact us at: privacy@josie.care
This policy is written in English, which is the legally binding version. French and Dutch translations are available; in the event of any conflict between versions, the English text prevails.
2. What this notice covers
This notice explains how Health Surfers collects, uses, stores, and shares your personal data when you use the Josie mobile application and associated services (collectively, “Josie” or “the service”). It also explains your rights under the General Data Protection Regulation (GDPR) and how to exercise them.
Please read this notice carefully before using Josie. By creating an account, you confirm that you have read and understood it.
3. What data we collect
3.1 Account and profile data
When you create an account, we collect:
- Email address
- Password (stored as a cryptographic hash; we never store your password in plain text)
- Name (optional)
- Date of birth or age range
- Country of residence
3.2 Health and symptom data
This is the core data that powers Josie. It includes:
- PCOS diagnosis status and phenotype (if known)
- Symptom logs: which symptoms you report, their severity, and the date and time of logging
- Menstrual cycle data: period start and end dates, flow, and related symptoms
- Medication and supplement records: names, dosages, frequencies, and adherence logs
- Appointment records: date, specialty, and any notes you add
- Laboratory test results and body measurements you choose to enter
- Wellbeing tracker responses (five questions, weekly)
- Goals and health profile information from onboarding
- Wearable health data (if you choose to connect Apple HealthKit or Android Health Connect): derived daily aggregates of sleep duration, daily steps and active minutes, resting heart rate, and workout sessions. Raw wearable samples are never stored; only the computed daily summaries are retained on Josie servers.
This data is Special Category Data under GDPR Article 9 because it concerns health. We apply additional safeguards to this category of data, described in Section 5.
3.3 Usage and analytics data
To improve the service, we collect anonymised and aggregated data about how users interact with Josie. This includes:
- Which features you use and how often
- Screens visited and actions taken within the app
- Session duration and app opens
- Crash reports and error logs
Analytics data is collected only with your explicit consent (optional at onboarding). You can withdraw this consent at any time in Profile > Privacy.
3.4 Device and technical data
We automatically collect certain technical data when you use Josie:
- Device type and operating system version
- App version
- IP address (used for security and fraud prevention; not linked to your health data)
- Crash diagnostics
3.5 Data you do not have to provide
No field in Josie is mandatory beyond email address and password for account creation. You may leave health fields blank, decline to answer onboarding questions, or skip symptom categories. The more you log, the more useful Josie becomes, but providing data is always your choice.
4. How we use your data
4.1 Providing the service
We use your data to operate Josie: to show you your symptom history, generate pattern insights, produce appointment preparation reports, and deliver the features you use.
Lawful basis: Performance of a contract (GDPR Article 6(1)(b)).
4.2 Processing your health data
Your health data is processed to power the core features of Josie: symptom tracking, cycle analysis, pattern recognition, evidence report generation, and wellbeing tracking.
Lawful basis: Your explicit consent under GDPR Article 9(2)(a). You provide this consent during onboarding. You can withdraw it at any time, which will trigger an account deletion flow.
4.3 Processing wearable health data
If you choose to connect Apple HealthKit or Android Health Connect, we read derived daily aggregates (sleep duration, daily steps and active minutes, resting heart rate, workout sessions) from your device. Raw minute-level samples are never stored. This processing is optional, off by default, and requires separate consent both in Josie and through the OS permission dialog on your device. You can disconnect at any time via Profile > Privacy > Wearable data, with the option to retain or delete the data already stored.
Lawful basis: Your explicit consent under GDPR Article 9(2)(a), collected as a separate consent category.
4.4 Improving Josie
With your optional consent, we use anonymised and aggregated usage data to understand how Josie is being used, identify problems, and improve the product.
Lawful basis: Consent (GDPR Article 6(1)(a)), optional and withdrawable.
4.5 Sending you communications
If you have opted in to marketing communications, we may send you product updates, PCOS health content, and information about new features.
Lawful basis: Consent (GDPR Article 6(1)(a)), optional and withdrawable.
4.6 Research participation
If you have separately consented to research participation, anonymised and aggregated data may be included in a future clinical validation study. This processing uses data that cannot be linked back to you individually. It is never a condition of using Josie.
Lawful basis: Consent (GDPR Article 6(1)(a)), optional and withdrawable, collected as a separate consent category.
4.7 Legal obligations and security
We may process data to comply with legal obligations, respond to lawful requests from authorities, or protect the security and integrity of the service.
Lawful basis: Legal obligation (GDPR Article 6(1)(c)) and legitimate interests (GDPR Article 6(1)(f)).
5. Special category data (health data)
Your symptom logs, cycle data, medication records, test results, and wellbeing tracker responses are Special Category Data under GDPR Article 9. We apply the following additional safeguards to this data:
- Explicit consent required. We collect separate, explicit consent for health data processing during onboarding. This consent can be withdrawn at any time.
- Encryption at rest and in transit. All health data is encrypted using AES-256 at rest and TLS 1.3 in transit.
- EU data residency. Your health data is stored on servers located in the European Union (Ireland, eu-west-1 region). It does not leave the EU in the ordinary course of operations.
- Immutable audit trail. Health records older than seven days cannot be altered or deleted except through a formal GDPR erasure request. This protects the integrity of your longitudinal health record.
- Access controls. Your health data is accessible only to you. Health Surfers staff cannot access individual user health records except where strictly required for technical incident resolution, under documented access controls.
- No sale of health data. Your health data is never sold, rented, or traded to any third party.
6. Data processors
We use the following third-party service providers to operate Josie. Each is engaged under a Data Processing Agreement in compliance with GDPR Article 28.
| Processor | Purpose | Data location |
|---|---|---|
| Supabase | Database, authentication, file storage, and backend functions | EU (Ireland, eu-west-1) |
| RevenueCat | In-app purchase and subscription entitlement management (iOS and Android) | US (Standard Contractual Clauses in place); processes purchase tokens and pseudonymous user ID only, no health data |
| PostHog | Product analytics (optional, consent-gated) | EU (EU Cloud) |
| Sentry | Crash reporting and error tracking | EU region |
| Apple Inc. | App Store distribution, in-app purchases, and HealthKit data source (iOS) | Apple’s infrastructure |
| Google LLC | Play Store distribution, in-app purchases, and Health Connect data source (Android) | Google’s infrastructure |
We do not share your health data with any of these processors except as strictly necessary to provide the service. Apple and Google receive only technical and transaction data, not your symptom or health records.
7. Data transfers outside the EU
Your health data is stored in the EU and does not leave the EU in the ordinary course of operations. Where any processor operates infrastructure outside the EU (for example, RevenueCat in the US and some Sentry operations), we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission.
8. How long we keep your data
| Data category | Retention period |
|---|---|
| Account and profile data | For the duration of your account, plus 30 days after deletion |
| Health and symptom data | For the duration of your account, plus 30 days after deletion |
| Wearable derived data (if connected) | For the duration of your account, plus 30 days after deletion; deleted immediately on disconnect if you choose the delete option |
| Consent records | 6 years after account closure (legal obligation) |
| Anonymised research data (if consented) | Retained in aggregate form after account deletion; cannot be linked back to you |
| Billing records | 7 years (Belgian accounting law) |
| Crash and error logs | 90 days rolling |
When you delete your account, all personal data is removed within 30 days. Consent records are retained for 6 years as required by law. Billing records are retained for 7 years as required by Belgian accounting law.
9. Your rights under GDPR
You have the following rights in relation to your personal data. To exercise any of them, contact us at privacy@josie.care. We will respond within 30 days.
Right to access. You can request a copy of all personal data we hold about you. You can also export your data directly in the app via Profile > Privacy > Export my data (JSON and PDF formats).
Right to rectification. You can correct or update any data we hold about you. Most data can be edited directly in the app.
Right to erasure. You can request deletion of your account and all associated personal data. This can be done in Profile > Privacy > Delete account, or by writing to privacy@josie.care. Deletion completes within 30 days. For step-by-step instructions, see how to delete your account and data.
Right to withdraw consent. You can withdraw any consent you have given (health data processing, analytics, marketing, research participation) at any time via Profile > Privacy > Consent settings. Withdrawing health data consent will close your account as the service cannot function without it.
Right to data portability. You can receive your data in a machine-readable format (JSON) via Profile > Privacy > Export my data.
Right to restriction. You can request that we restrict processing of your data while we are responding to a complaint or dispute.
Right to object. You can object to processing based on legitimate interests. This right does not apply to processing based on contract performance or legal obligation.
Right to lodge a complaint. If you believe we have not handled your data correctly, you have the right to lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données): apd-gba.be.
10. Children
Josie is intended for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If you believe a person under 18 has created an account, please contact us at privacy@josie.care and we will delete the account promptly.
11. Cookies and tracking
The Josie mobile application does not use browser cookies. On the web (josie.care), we use only strictly necessary cookies required for the website to function. Analytics on our website are subject to a separate cookie consent notice.
12. Security
We apply technical and organisational measures to protect your data, including:
- AES-256 encryption at rest
- TLS 1.3 encryption in transit
- Certificate pinning in production builds
- Row-level security on all database tables
- Rate limiting on authentication endpoints
- Vulnerability scanning via automated tooling
In the event of a data breach affecting your rights and freedoms, we will notify you and the Belgian Data Protection Authority within 72 hours of becoming aware of the breach, as required by GDPR Article 33.
13. Changes to this notice
We may update this notice from time to time. If we make a material change, we will notify you in-app and by email before the change takes effect. The effective date at the top of this page will always reflect the most recent version. Continued use of Josie after an update constitutes acceptance of the updated notice.
14. Contact
For any questions about this policy or your personal data:
Email:privacy@josie.care
Website:josie.care
Health Surfers
Antwerp, Belgium