LONGSAL APP PRIVACY POLICY
1. General Information
SIA “Longsal”, registration No. 40203510883 (hereinafter – LONGSAL, we, us, or our), acts as the data controller in relation to the personal data processing activities described in this App Privacy Policy, in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation – GDPR) and other applicable data protection laws.
This App Privacy Policy explains how LONGSAL collects, uses, stores, shares, and otherwise processes personal data when you use the LONGSAL mobile application, web application, and related digital services (collectively, the LONGSAL App).
This App Privacy Policy supplements the general LONGSAL Privacy Policy. Where a matter relating specifically to the LONGSAL App is addressed in this App Privacy Policy, this App Privacy Policy applies. For matters not specifically addressed here, the general LONGSAL Privacy Policy applies.
Certain services accessible through the LONGSAL App, including testing services, may also be subject to additional service-specific privacy terms. For example, the LONGSAL Gut Microbiome Test may be subject to a separate Gut Microbiome Test Privacy Policy.
The LONGSAL App is intended to provide digital tools supporting personalised health, nutrition, lifestyle, testing, supplementation, consultation, and longevity-related services. The exact functionality available to a user may depend on the version of the App, country, subscription, services purchased, and features selected by the user.
2. Personal Data We May Process
Depending on how you use the LONGSAL App and which features you choose to use, LONGSAL may process the following categories of personal data.
2.1. Account and Profile Information
This may include:
first name and last name;
email address;
telephone number;
date of birth;
sex or other profile information where relevant to a selected service;
account identifiers;
authentication and account security information;
language and communication preferences;
country or region;
profile settings and preferences.
We process information necessary to create, maintain, secure, and manage your LONGSAL account.
2.2. Health and Wellness Information
Certain LONGSAL App functions may involve the processing of health-related information, including:
information concerning health status;
symptoms and wellbeing information;
medical history information voluntarily provided by the user;
lifestyle information;
physical activity and exercise information;
sleep-related information;
nutrition and dietary information;
body measurements and other health-related measurements;
information concerning medications;
information concerning dietary supplements;
allergies, intolerances, or dietary restrictions;
information relevant to personalised health, nutrition, supplementation, or lifestyle recommendations.
Health data constitute a special category of personal data under the GDPR and are subject to enhanced protection.
Where required by applicable law, LONGSAL processes health data on the basis of the user's explicit consent or another applicable condition under Article 9 of the GDPR.
2.3. Test and Laboratory Data
Where relevant to services used through the LONGSAL App, we may process:
laboratory test results;
LONGSAL test results;
genetic or nutrigenetic test information where the relevant service is used;
gut microbiome test information where the relevant service is used;
blood test results;
other laboratory examination results;
test metadata;
interpretations of test results;
previous and repeat test results;
recommendations generated or prepared in connection with such results.
Specific testing services may be subject to additional privacy terms.
2.4. Questionnaires and Information Provided by You
The LONGSAL App may allow you to complete questionnaires or provide additional information concerning your health, lifestyle, nutrition, goals, preferences, or other matters relevant to the services you use.
We process information that you choose to submit through these forms in order to provide and personalise the relevant services.
2.5. Documents and Files
The LONGSAL App may allow you to upload documents and files, including:
laboratory reports;
medical documents;
test reports;
health-related documents;
dietary or supplementation information;
other documents that you choose to provide.
Such documents may contain personal data and health data.
You should only upload information that is relevant to the services you wish to receive and that you are entitled to provide to LONGSAL.
2.6. Photographs, Camera and Image Data
Certain LONGSAL App functions may allow you to use your device camera or upload photographs.
Depending on the functionality used, this may include photographs of:
food and meals;
dietary supplements;
supplement labels and packaging;
nutrition labels;
documents;
other objects or information intentionally submitted for analysis.
Images may be processed using automated image-recognition, optical character recognition, artificial intelligence, or other technological tools in order to identify or extract relevant information.
LONGSAL does not access your camera or photo library unless permitted by your device settings and required for a feature you choose to use.
Where device permissions allow you to select specific photographs rather than providing general access to your photo library, LONGSAL will process only the photographs selected or otherwise intentionally submitted by you.
2.7. Nutrition and Supplement Information
Where relevant functionality is used, LONGSAL may process information concerning:
foods and meals;
estimated nutritional composition;
calories;
macronutrients and micronutrients;
dietary patterns;
dietary supplements;
supplement ingredients;
dosage information;
supplement usage;
product information extracted from photographs or entered manually.
This information may be combined with other information in your profile to provide personalised insights or recommendations.
2.8. Consultation and Service Information
Where consultations or other professional services are arranged or provided through the LONGSAL App, we may process:
consultation bookings;
consultation dates and times;
information provided before, during, or following consultations;
consultation-related communications;
recommendations and follow-up information;
information necessary to coordinate participation by healthcare professionals or other persons authorised by you.
2.9. Technical and Usage Data
When you use the LONGSAL App, certain technical information may be processed automatically, such as:
device type;
operating system and App version;
IP address;
language settings;
login and authentication information;
security logs;
timestamps;
crash and diagnostic information;
interactions with App features;
technical identifiers necessary for operation and security.
Such information may be used to operate, secure, troubleshoot, and improve the LONGSAL App.
Where analytics or similar technologies require consent under applicable law, they will be used only after the required consent has been obtained.
3. How We Use Personal Data
Depending on the services and features you use, LONGSAL may process personal data for purposes including:
creating and managing your account;
authenticating users and maintaining account security;
providing LONGSAL App functionality;
maintaining your personalised profile;
providing testing and related services;
receiving and displaying laboratory and test results;
processing questionnaires;
storing and organising information submitted by you;
analysing health, nutrition, lifestyle, test, and supplementation information;
providing personalised insights and recommendations;
comparing data and results over time;
helping users monitor relevant health, nutrition, lifestyle, or supplementation information;
processing photographs and extracting information from images;
analysing food, meals, or dietary supplements where such functionality is available;
arranging and providing consultations;
sending service-related notifications and reminders;
providing customer support;
preventing fraud, misuse, and security incidents;
maintaining, troubleshooting, and improving the App;
complying with legal obligations;
establishing, exercising, or defending legal claims;
other purposes specifically communicated to you and supported by an appropriate legal basis.
LONGSAL will not process personal data for purposes incompatible with the purposes for which the data were collected unless such processing is permitted by applicable law.
4. Artificial Intelligence and Automated Processing
Certain LONGSAL App functions may use artificial intelligence, machine learning, automated analysis, image recognition, document processing, or other computational tools.
These technologies may, depending on the functionality selected by the user, be used to:
extract structured information from documents;
recognise information contained in photographs;
analyse food or supplement information;
organise laboratory or test results;
identify patterns in information provided by the user;
assist in generating explanations, summaries, or personalised insights;
support the preparation of recommendations;
improve the efficiency and functionality of LONGSAL services.
Where external technology providers are used for such processing, LONGSAL takes appropriate measures to ensure that personal data are processed in accordance with applicable data protection requirements.
LONGSAL seeks to limit information provided to external service providers to what is reasonably necessary for the relevant function.
Health or other sensitive personal data will not be used for unrelated advertising purposes.
Where required by applicable law, LONGSAL will obtain appropriate consent before processing health data through AI or other automated tools.
The use of artificial intelligence or automated tools does not necessarily constitute automated individual decision-making within the meaning of Article 22 GDPR.
If LONGSAL introduces automated decision-making that produces legal effects concerning a user or similarly significantly affects the user within the meaning of Article 22 GDPR, LONGSAL will provide the information and safeguards required by applicable law.
5. Personalised Information and Health Disclaimer
Information, analyses, insights, scores, estimates, or recommendations presented through the LONGSAL App may be based on information provided by the user, test results, scientific information, computational analysis, professional review, or combinations of these sources.
Unless explicitly stated otherwise for a particular regulated service, information provided through the LONGSAL App is intended for informational, wellness, lifestyle, nutrition, or decision-support purposes and is not intended to replace diagnosis, medical treatment, or advice from a qualified healthcare professional.
Automated analyses, including analyses of photographs, food, supplements, documents, or health-related information, may contain inaccuracies and should not be treated as independently verified medical conclusions.
6. Legal Bases for Processing
Depending on the particular processing activity, LONGSAL may process personal data on one or more of the following legal bases:
Performance of a Contract
Where processing is necessary to provide the LONGSAL App or another service requested by you or to take steps at your request before entering into a contract.
Consent
Where you have consented to a specific processing activity.
Where required, consent may be withdrawn at any time.
Explicit Consent for Health Data
Where health data or other special categories of personal data are processed and explicit consent is the applicable condition under Article 9 GDPR.
Legal Obligation
Where processing is necessary for LONGSAL to comply with applicable legal obligations.
Legitimate Interests
Where processing is necessary for legitimate interests pursued by LONGSAL or a third party, provided those interests are not overridden by your rights and freedoms.
Such interests may include ensuring system security, preventing misuse, maintaining service functionality, protecting legal rights, and improving internal operations where permitted by law.
7. Device Permissions
Certain App features may require access to device functionality.
Depending on the features available, the LONGSAL App may request permission to access:
the camera;
photographs or selected images;
files or documents;
notifications;
other device functionality necessary for a feature requested by the user.
LONGSAL requests device permissions only where necessary for the relevant functionality.
You may manage permissions through your device settings.
Disabling a permission may prevent the relevant App feature from functioning but should not affect unrelated functionality.
LONGSAL will update this App Privacy Policy if additional categories of sensitive device permissions are introduced.
8. Sharing of Personal Data and Service Providers
LONGSAL does not sell personal data.
LONGSAL does not disclose personal data to third parties without an appropriate legal basis.
Depending on the services and functionality used, personal data may be processed by or disclosed to:
cloud infrastructure and hosting providers;
database and data-storage providers;
authentication and security providers;
technology and software service providers;
artificial intelligence and machine-learning service providers;
image, document, or data-processing providers;
analytics and diagnostic providers, where applicable;
laboratories and testing partners;
healthcare professionals, consultants, or specialists involved in providing a service where applicable;
communication and notification service providers;
payment service providers;
professional advisers;
public authorities where disclosure is required by law;
other recipients authorised by the user or otherwise supported by an appropriate legal basis.
Service providers receive access only to personal data reasonably necessary to provide the relevant service.
Where a service provider acts as a data processor on behalf of LONGSAL, appropriate contractual and organisational safeguards are implemented in accordance with applicable data protection law.
We may also disclose personal data where necessary to protect the rights, property, security, or legal interests of LONGSAL, our users, or others, subject to applicable law.
9. International Transfers of Personal Data
Some technology or service providers may process personal data outside Latvia, the European Union, or the European Economic Area.
Where personal data are transferred outside the European Economic Area, LONGSAL takes measures to ensure that the transfer complies with Chapter V of the GDPR.
Depending on the circumstances, safeguards may include:
a European Commission adequacy decision;
European Commission-approved Standard Contractual Clauses;
other legally recognised transfer mechanisms.
Where appropriate, supplementary safeguards may also be implemented.
10. Data Security
LONGSAL implements technical and organisational measures appropriate to the nature, sensitivity, context, and risks of the personal data processed.
Such measures may include, where appropriate:
access controls;
authentication mechanisms;
role-based access restrictions;
encryption during transmission;
secure data storage;
logging and monitoring;
backup and recovery procedures;
security updates;
measures designed to prevent unauthorised access, disclosure, alteration, loss, or destruction.
Access to personal data is limited to persons and service providers who require access for legitimate purposes.
No electronic system can guarantee absolute security, and LONGSAL periodically reviews and improves its safeguards where appropriate.
11. Data Retention
LONGSAL retains personal data only for as long as reasonably necessary for the purposes for which the information was collected or as required or permitted by applicable law.
Retention periods may depend on:
the type of data;
the service provided;
whether the user maintains an active account;
the sensitivity of the information;
contractual requirements;
legal retention obligations;
security and fraud-prevention requirements;
the establishment, exercise, or defence of legal claims.
Health-related information is retained only for as long as necessary for the relevant service or another lawful purpose.
Where specific LONGSAL services require different retention periods, those periods may be described in the applicable service-specific privacy terms.
Where information is irreversibly anonymised so that it can no longer identify an individual, it is no longer personal data under the GDPR and may be retained for statistical, analytical, scientific, service-improvement, or other lawful purposes.
12. Account and Data Deletion
Users may request deletion of their LONGSAL App account and personal data associated with that account.
Where account deletion functionality is available directly within the LONGSAL App, users may initiate deletion through the relevant account or privacy settings.
LONGSAL will also provide an external web-based method through which users can request deletion of their LONGSAL App account and associated personal data.
Account deletion is different from temporary account deactivation. Where a valid account deletion request is completed, LONGSAL will delete or anonymise personal data associated with the account unless continued retention of particular information is required or permitted by applicable law.
Where personal data have been provided to service providers acting on LONGSAL's behalf, LONGSAL will take appropriate steps to ensure deletion or other appropriate handling of such information in accordance with applicable data protection requirements.
Certain information may be retained where necessary, including for:
compliance with legal obligations;
accounting or transaction record requirements;
fraud prevention or security;
establishment, exercise, or defence of legal claims;
another lawful basis recognised under applicable law.
Where information must be retained after account deletion, access to such information will be limited to the purposes for which retention is required.
Deleting the LONGSAL App from a device does not automatically delete the user's LONGSAL account or personal data.
13. Withdrawal of Consent
Where processing is based on consent, you may withdraw your consent at any time.
Withdrawal does not affect the lawfulness of processing performed before the withdrawal.
If you withdraw consent necessary for processing health data or providing a particular personalised service, LONGSAL may be unable to continue providing the affected functionality or service.
Withdrawal of one consent does not necessarily require deletion of the entire LONGSAL account where other services can continue lawfully without the affected processing.
14. Your Data Protection Rights
Subject to the GDPR and other applicable laws, you may have the right to:
receive information about the processing of your personal data;
request access to your personal data;
obtain a copy of your personal data;
request correction of inaccurate or incomplete data;
request deletion of personal data;
request restriction of processing;
object to certain processing;
receive personal data in a portable format where applicable;
withdraw consent at any time where processing is based on consent;
exercise rights relating to automated decision-making where applicable;
lodge a complaint with a competent supervisory authority.
In Latvia, the competent data protection supervisory authority is the Data State Inspectorate (Datu valsts inspekcija).
These rights are subject to the conditions and limitations provided by applicable law.
15. Children and Minors
The LONGSAL App is not intended to allow minors to independently provide health data or use services requiring parental or guardian involvement where such involvement is required by applicable law.
Where LONGSAL provides a service relating to a minor, LONGSAL processes the minor's personal data in accordance with applicable legal requirements.
Where required, LONGSAL will obtain consent or authorisation from a parent, guardian, or other legal representative.
Specific functionality available to minors may be restricted.
16. Marketing and Advertising
LONGSAL may send marketing communications only where an appropriate legal basis exists.
Where marketing is based on consent, users may withdraw that consent at any time.
Withdrawing from marketing communications does not prevent LONGSAL from sending communications necessary for account operation, security, consultations, tests, purchases, or other services requested by the user.
LONGSAL does not use health data or other sensitive personal data for third-party targeted advertising.
If advertising or additional tracking technologies are introduced into the LONGSAL App in the future, this App Privacy Policy and applicable consent mechanisms will be updated before such processing is implemented where required by law.
17. Notifications
The LONGSAL App may send notifications relating to:
account security;
consultations;
test status or availability;
reminders;
recommendations;
service updates;
other functionality requested by the user.
Where device permission is required, notifications will be enabled only after the appropriate permission has been granted.
Users may manage notification permissions through their device settings and, where available, within the LONGSAL App.
18. Changes to This App Privacy Policy
LONGSAL may update this App Privacy Policy from time to time, including where:
App functionality changes;
new services or technologies are introduced;
service providers change;
personal data processing activities change;
applicable legal or platform requirements change.
The current version will be made publicly available through the LONGSAL website and accessible from the LONGSAL App.
The date of the latest update will be displayed at the beginning of this policy.
Where changes materially affect the processing of personal data or users' rights, LONGSAL will provide additional notice or obtain consent where required by applicable law.
19. Relationship With Other LONGSAL Privacy Policies
This App Privacy Policy applies specifically to personal data processing connected with the LONGSAL App.
It should be read together with the general LONGSAL Privacy Policy.
Where a user accesses a specific LONGSAL service through the App that is subject to additional privacy terms, those additional terms also apply to the processing associated with that service.
For example, personal data processing specifically associated with the Gut Microbiome Test may additionally be governed by the LONGSAL Gut Microbiome Test Privacy Policy.
In the event of a difference between this App Privacy Policy and service-specific privacy terms concerning a particular service, the more specific terms apply to the processing associated with that service.
20. Contact and Privacy Requests
For questions concerning this App Privacy Policy, personal data processing, withdrawal of consent, account deletion, or the exercise of data protection rights, please contact:
SIA “Longsal”
Registration No. 40203510883
Latvia
Email: [email protected]
LONGSAL may take reasonable steps to verify the identity of a person submitting a privacy or deletion request before fulfilling the request.
Requests concerning personal data will be handled without undue delay and within the time limits established by applicable data protection law.
21. Data Controller
The controller responsible for the processing described in this App Privacy Policy is:
SIA “Longsal”
Registration No. 40203510883
Latvia
Email: [email protected]