Legal

Privacy Policy

Your privacy matters to us. This policy explains how Optoceutics ApS ("we", "us", "our") collects, uses, and protects your personal data when you use the EVY Platform.

Last updated: December 25, 2025

Summary

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Your data is yours

You can export or delete your data at any time.

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We never sell data

Your personal information is never sold to third parties.

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Encryption by default

All data is encrypted in transit and at rest.

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GDPR & CCPA compliant

We follow EU and California privacy regulations.

1. Who We Are

Optoceutics ApS is a Danish company developing wellness technology. The EVY Platform includes EVY Sound, EVY Light, EVY Insights, EVY Games, and Julia (AI assistant).

Contact:
Optoceutics ApS
Copenhagen, Denmark
Email: privacy@optoceutics.com

Data Controller: Optoceutics ApS is the data controller for personal data processed through the EVY Platform.

2. Data We Collect

Account Information

Email address (for authentication)
Name (optional, for personalization)
Account preferences and settings

Usage Data

Session data (start time, duration, product used)
Feature interactions (for improving user experience)
Device information (browser type, operating system)

Wellness Data (Optional)

Self-reported mood or wellness notes
Session feedback and ratings
Progress tracking data you choose to record

Note: EVY is a general wellness product. We do not collect medical data or health information as defined by HIPAA.

3. How We Use Your Data

We use your data for the following purposes:

Provide the service: Authenticate your account, save your preferences, and enable platform features.
Improve the experience: Analyze usage patterns to improve product design and fix bugs.
Communicate with you: Send account-related emails (OTP codes, important updates). Marketing emails require explicit opt-in.
Research (with consent): If you opt into our research program, anonymized data may be used to study wellness outcomes.

Legal basis (GDPR): We process data based on (a) your consent, (b) contract performance, (c) legitimate interests, or (d) legal obligations.

4. Data Sharing

We do not sell your personal data.

We may share data with:

Service providers: Cloud hosting (Hetzner, Germany), email delivery, payment processing. All providers are GDPR-compliant and bound by data processing agreements.
Care team (with consent): If you use EVY with a caregiver, clinician, or coach, you can choose to share your progress data with them.
Legal requirements: We may disclose data if required by law or to protect our legal rights.
Aggregated research: Anonymized, aggregated data may be used for research publications. Individual users cannot be identified.

5. Data Storage & Security

Location: Data is stored on servers in the European Union (Germany).
Encryption: All data is encrypted in transit (TLS 1.3) and at rest (AES-256).
Access controls: Only authorized personnel can access personal data, and access is logged.
Retention: We retain your data while your account is active. After account deletion, data is purged within 30 days (except where legal retention is required).

6. Your Rights

Under GDPR (EU) and CCPA (California), you have the right to:

Access

Request a copy of your personal data

Rectification

Correct inaccurate data

Erasure

Delete your account and data

Portability

Export your data in a standard format

Restriction

Limit how we process your data

Objection

Object to certain processing activities

Withdraw consent

Revoke consent at any time

Non-discrimination

Exercise rights without penalty (CCPA)

To exercise these rights, email privacy@optoceutics.com or use the data export/delete features in your account settings.

7. Cookies & Tracking

We use cookies for:

Essential cookies: Required for login and core functionality. Cannot be disabled.
Analytics cookies: Help us understand how users interact with the platform. You can opt out in settings.

We do not use third-party advertising cookies or sell cookie data.

8. Children's Privacy

The EVY Platform is not intended for children under 16. We do not knowingly collect data from children. If you believe a child has provided us with personal data, please contact us immediately.

9. International Transfers

Your data is primarily stored in the EU. If data is transferred outside the EU/EEA, we ensure adequate protection through:

EU Standard Contractual Clauses (SCCs)
Adequacy decisions by the European Commission
Binding Corporate Rules where applicable

10. Changes to This Policy

We may update this policy from time to time. Significant changes will be communicated via email or in-app notification. Continued use of the platform after changes constitutes acceptance.

11. Contact & Complaints

For privacy questions or to exercise your rights:

Email: privacy@optoceutics.com
Response time: Within 30 days

If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority:

Denmark: Datatilsynet (datatilsynet.dk)
EU: Your local Data Protection Authority
California: California Attorney General

Wellness Product Disclaimer

EVY is intended as a general wellness product and is not intended to diagnose, treat, cure, or prevent any disease or medical condition. Claims regarding the effectiveness of EVY are based on ongoing research and have not been conclusively proven. If you have a medical condition, consult a healthcare professional before using EVY.