Lyvra Privacy Policy

Version: 2026-10
Canonical URL: https://lyvra.health/legal/privacy
Effective: 10 October 2026

1. Who is responsible for your data

1.1 This Privacy Policy explains how Lyvra handles your personal data when you use Lyvra, a patient-controlled personal health record or "health passport" (the "Service").

1.2 The data controller is Lyvra ("Lyvra", "we", "us").

1.3 CNDP reference: our declaration to the CNDP has not yet been filed. We will publish its reference here once it is issued.

1.4 Contact for privacy questions: privacy@lyvra.health.

1.5 Applicable law. The Service is launching first in Morocco, and this Policy is written for Moroccan Law 09-08 on the protection of individuals with regard to the processing of personal data. We plan to launch later in France, Spain and Switzerland; we will update this Policy before doing so to meet the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (nFADP).

2. Our approach in short

• You control your health record. Institutions see your data only through grants you create, and every access is logged for you to see.
• We do not sell your data and we do not use it for advertising.
• Health data is encrypted with a key specific to you.
• You can delete your account in the app, and we erase your personal and health data, keeping only minimal legal evidence.

3. Data we collect

3.1 Account data

• Email address
• Password (stored only in a protected, hashed form — we cannot read it)
• Email verification and password reset codes (short-lived)
• Records of which Terms and Privacy Policy versions you accepted, and when
• Session information needed to keep you signed in

3.2 Identity data

• Name, date of birth, sex, country
• Phone number (optional)

3.3 Health data (special category / sensitive data)

• Health profile: allergies, conditions, medications, blood type
• Emergency contacts (names and contact details of people you choose — please tell them you have added them)
• Emergency card information
• Uploaded documents: PDFs and images such as lab results, prescriptions and imaging reports, and data extracted from them
• Imported records: information from hospitals and clinics you connect through SMART-on-FHIR, such as results, observations, orders, visits, and care-team notes or responses
• Care-team responses added by clinicians you share with

3.4 Insurance data

• Coverage cards and details you add to your insurance wallet

3.5 Sharing and access data

• Grants you create (recipient, scope, duration, revocation)
• Access log: who viewed what under a grant, and when

3.6 AI interaction data

• Questions you ask Aya and its answers, if you use Aya

3.7 Technical and security data

• Data needed to run and protect the Service, such as IP address, device/browser information, timestamps, and security and audit logs (for example sign-in attempts and rate-limit events)
• Push notification token, if you enable notifications

3.8 What we do not collect

• We do not use advertising trackers or third-party analytics trackers.
• We do not collect payment card data (the Service is currently free).
• We do not buy data about you from data brokers.
• We do not collect your precise location.

4. Where your data comes from

• From you: what you enter or upload.
• From hospitals and clinics you connect: records imported through SMART-on-FHIR connections that you authorise.
• From clinicians you share with: care-team responses or notes they add.
• Generated by the Service: access logs, security logs, and data extracted from your documents by Document AI.

5. Why we use your data, and our legal basis

We do not use your data for advertising, we do not sell it, and we do not use automated decision-making that produces legal or similarly significant effects on you.

6. How we handle health data

6.1 Health data is sensitive. We handle it with extra care: - it is processed only to provide the Service you asked for; - it is encrypted with a data key specific to you, which is itself protected using a cloud key management service (AWS KMS); - access by our staff is restricted to what is strictly necessary to operate, support and secure the Service; - it is never used for advertising or sold.

6.2 You can withdraw consent at any time (see section 12). Because storing health data is the core of the Service, withdrawing consent to that processing means you will need to delete your account.

7. Sharing with institutions and clinicians — directed by you

7.1 We share your health data with a hospital, clinic or clinician only when you create a grant. A grant: - is limited in scope (for example summary, records, or orders); - is limited in time; - can be revoked by you at any time.

7.2 Every access under a grant is logged and shown to you.

7.3 Once an institution has accessed your data, it may keep copies under its own legal obligations, and it is responsible for that data as its own controller. Revoking a grant stops further access through Lyvra but cannot recall data already accessed.

7.4 We do not otherwise share your data, except: - with the service providers listed in section 8, who act on our instructions; - where required by law or by a competent authority; - to a successor entity if the Service is transferred, under the same protections and after notifying you.

8. Service providers (sub-processors)

We use the following providers to run the Service. They process data on our behalf and under contract.

9. International transfers

9.1 Your data is stored mainly in the European Union (Ireland). Some providers process data in the United States or on global networks (see section 8). This means your data is transferred outside Morocco.

9.2 Under Law 09-08, transfers of personal data outside Morocco require that the destination country provides adequate protection or that the CNDP authorises the transfer. These authorisations have not yet been obtained.

9.3 For later EU/Swiss launch, transfers to the United States will need an appropriate mechanism (for example EU–US Data Privacy Framework certification or Standard Contractual Clauses).

10. How long we keep data

10.1 We keep your data while your account is open.

10.2 When you delete your account in the app, we erase your personal and health data: uploaded documents are deleted from storage and the contents of your records are scrubbed. Active sharing grants stop.

10.3 We keep only minimal evidence needed to meet legal obligations and defend legal claims, such as: - records of the Terms and Privacy Policy versions you accepted, and when; - audit evidence of access to your data (who accessed, when) without the health content.

These are kept for as long as needed to meet our legal obligations and to establish, exercise or defend legal claims.

10.4 Other periods: - verification and reset codes: until used or expired (short-lived); - security and technical logs: for the limited period needed for security, audit and abuse-prevention purposes; - backups: deleted data may remain in encrypted backups until they are overwritten in the normal backup cycle.

11. Security

11.1 We use technical and organisational measures appropriate to health data, including: - encryption in transit (TLS); - encryption at rest; - per-patient data keys, protected by AWS KMS; - audit logs of access to data; - rate limiting and protections against abuse of sign-in and code entry; - verification codes with expiry and attempt limits.

11.2 No system is completely secure. If we become aware of a personal data breach affecting you, we will notify you and the authorities as required by law.

12. Your rights

12.1 You have the right to: - Access — see the data we hold about you. Most of it is visible directly in the app, including your access log. - Correction — correct your data. You can edit your profile in the app. Records imported from an institution should be corrected at that institution. - Copy of your data — you can request a copy of your data. - Deletion — delete your account in the app (see section 10). - Objection — object to processing based on legitimate interests, for legitimate reasons. - Withdraw consent — at any time, for example by revoking grants, disconnecting institutions, disabling notifications, not using AI features, or deleting your account. Withdrawal does not affect processing already carried out.

12.2 How to exercise your rights: use the in-app features, or email privacy@lyvra.health. We may need to verify your identity. We will reply within the time limits set by applicable law.

13. Minors

You must be at least 16 to create an account. We do not knowingly collect data from children under 16; if we learn that we have, we will delete it. Family or dependant accounts are not currently offered.

14. AI processing

14.1 Aya, our assistant, can answer questions about your own records. It is powered by Anthropic's Claude API and is currently in limited availability (offered only to selected accounts).

14.2 Document AI can extract structured data from documents you upload.

14.3 When you use these features, we send the relevant parts of your data (for example your question, relevant records, or the document) to Anthropic in the United States, only to provide the feature to you.

14.4 Under Anthropic's commercial API terms, we understand that data sent through the API is not used to train its models by default.

14.5 AI outputs can be wrong and are not medical advice or a diagnosis. AI is not used to make decisions about you with legal or similarly significant effects.

15. Emails and notifications

15.1 We send service emails that are needed to run your account, such as verification and password reset codes, and important notices (for example a new version of the Terms or this Policy). You cannot opt out of these while you have an account.

15.2 Push notifications are optional. If you enable them, we use Google Firebase Cloud Messaging to deliver them. Keep in mind notifications can appear on your lock screen. You can turn them off in your device or browser settings.

15.3 We do not send marketing emails.

16. Cookies and local storage

16.1 The app uses your browser's local storage to keep you signed in and to remember app state. This is strictly necessary for the Service to work.

16.2 By current design, we do not use advertising or analytics trackers or cookies.

16.3 Signing out clears session data from your browser. On a shared device, always sign out.

17. Changes to this Policy

17.1 We may update this Policy. Each version has a version number and an effective date.

17.2 When we publish a new version, we will tell you in the app (and may email you), and you will be asked to accept the new version. We record which version you accepted and when.

17.3 Until you accept, your account may be limited (for example, read-only). If you do not agree, you can request a copy of your data and delete your account.

18. Contact

• Privacy: privacy@lyvra.health

19. Complaints

19.1 If you have a concern, please contact us first so we can try to help.

19.2 You have the right to complain to Morocco's data protection authority, the CNDP (Commission Nationale de contrôle de la protection des Données à caractère Personnel), www.cndp.ma.

19.3 When we launch in the EU or Switzerland, this section will list the relevant authorities (for example the CNIL in France, the AEPD in Spain, and the FDPIC in Switzerland).