Privacy Policy
This Privacy Notice for Orvella Ltd (doing business as Orvella) ("we", "us", or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
- Download and use our mobile application (Orvella), or any other application of ours that links to this Privacy Notice
- Use Orvella. Orvella is a personal health record app that helps people with endometriosis log symptoms lightly and build a clear history to share with their doctor. It records and reflects - showing patterns and trends over time - but never diagnoses, predicts, or recommends treatment. Orvella is not a period or fertility tracker.
- Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@orvellaapp.com.
The short version
- Orvella is available on the App Store and Google Play.
- Orvella helps you record and reflect on your own health, and build a record you can take to appointments.
- Your health information is sensitive data. We only process it with your explicit consent, and you can withdraw that consent at any time.
- Your data is stored in the United Kingdom, encrypted in transit and at rest.
- We never sell your personal information, to anyone, for any purpose.
- We never share your health information with advertisers, employers, or insurers.
- We do not show you ads or use your health information to advertise to you.
- You can export or permanently delete your data from within the app.
- Orvella records and reflects - it does not diagnose, predict, or give medical advice.
Summary of key points
This summary provides key points from our Privacy Notice. You can find more detail by using the table of contents below.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? Yes. Some of the information may be considered "special" or "sensitive" in certain jurisdictions. We process health information you choose to log, and may process data about a person's sex life or sexual orientation if you choose to record it. We only do this with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.
Do we collect any information from third parties? We may receive limited information from Apple or Google when you sign in, from Apple Health or Health Connect if you connect them, and from RevenueCat about whether a subscription is active. We do not buy marketing lists or collect information from public databases for advertising. Learn more about information collected from other sources.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way is by visiting https://www.orvellaapp.com/support/, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
1. What information do we collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- email addresses
- passwords
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
- health data
- data about a person's sex life or sexual orientation
Orvella exists to let you record health information about yourself. Depending on what you choose to log, this may include: pain levels and locations, the impact symptoms have on your day, bleeding, fatigue, medication taken and whether it helped, bowel and bladder symptoms, pain during or after sex, whether you are experiencing a flare, notes you write, cycle context, your goals, and where you feel you are in your health journey. Under UK data protection law this is special category data concerning health, which receives extra legal protection.
Payment Data. If you buy a premium subscription, the purchase is handled by Apple through the App Store or by Google through Google Play. We use RevenueCat to tell us whether your subscription is active. We do not receive or store your card or payment details. You may find their privacy notices here: RevenueCat, Apple, and Google.
Social Media Login Data. We may provide you with the option to register with us using Sign in with Apple or Google Sign-In. If you choose to register in this way, we will collect certain profile information about you from that provider, as described in How do we handle your social logins?.
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, contacts, storage, Apple Health / Health Connect, photo library, Face ID / biometrics, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
- Mobile Device Data. We automatically collect limited device information needed to run the app securely and fix problems, such as device type, operating system version, and crash reports.
- Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Apple Health / Health Connect data (only if you connect it)
If you choose to connect Apple Health (HealthKit) or Health Connect, Orvella reads only the categories you specifically permit, and only to display and include them in your own records. We never use health data obtained this way for advertising, and we never share it for that purpose.
Device contacts (only if you choose one)
If you tap Choose from contacts when adding someone to your care team, Orvella opens your device address book so you can pick one person. We copy only the fields you confirm (name, phone, email, organisation, and address) into your Orvella care team. We do not sync, upload, or browse your address book, and we do not write anything back to Contacts.
Information automatically collected
In Short: Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Orvella does not request device GPS or precise location permission. Country or similar location information, if collected, is derived from technical signals such as IP address, not from your device's location services.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Crash and diagnostic reports are on by default so we can keep the app stable; they never include your health information, names, or notes, and you can turn them off in Settings. If you opt in to product analytics, we may also collect basic usage information about which screens and features you open, and which published community articles you open (title and topic), with no logs, notes, names, or symptom values attached.
Google API
Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Information collected from other sources
In Short: We may receive limited information from the sign-in, health, and payment providers you choose to use with Orvella.
We do not buy mailing lists, scrape public databases, or collect information from marketing partners for targeted advertising. We may receive:
- a sign-in identifier (and, if you share it, a name or email) from Apple or Google when you use Sign in with Apple or Google Sign-In
- health categories you specifically permit, if you connect Apple Health or Health Connect
- subscription status from RevenueCat, Apple, and Google
- the contact fields you confirm, if you pick someone from your device address book
If you interact with us on a social media platform using your social media account, we may receive personal information about you from that platform, such as your name, depending on that platform's privacy settings. Their own use of your information is not governed by this Privacy Notice. You may have the right to withdraw your consent to processing your personal information. Learn more about withdrawing your consent.
2. How do we process your information?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
- Manage the beta waitlist and reply to support messages. We use the name, email, and message you send on the waitlist or support form so we can run beta access and answer you. (Retention period: only as long as needed to manage beta access or finish the support request, then deleted. Backups cycle out on a rolling basis.)
3. What legal bases do we rely on to process your information?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Diagnose problems and/or prevent fraudulent activities
- Respond to people who contacted us and manage early access, without using this for ads or health profiling.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
| Purpose | Lawful basis (UK GDPR) |
|---|---|
| Creating and securing your account, and providing the core app | Performance of a contract (Art. 6(1)(b)) |
| Recording your health information and generating your own records and reports for you | Your explicit consent (Art. 9(2)(a)), and contract (Art. 6(1)(b)) |
| Managing beta access, waitlist requests and support messages | Legitimate interests (Art. 6(1)(f)), and consent where you contact us |
| Managing your subscription and entitlements | Performance of a contract (Art. 6(1)(b)) |
| Keeping the app secure, preventing abuse, and crash and diagnostic reports | Our legitimate interests (Art. 6(1)(f)) |
| Optional product analytics | Your consent (Art. 6(1)(a)) |
| Copying a contact you pick into your care team | Your consent (Art. 6(1)(a)) |
4. When and with whom do we share your personal information?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. They act only on our instructions.
The third parties we may share personal information with are as follows:
| Provider | What they do | Where |
|---|---|---|
| Supabase | Hosts our database and stores your data | United Kingdom (London region) |
| Sentry | Crash and diagnostic reports (no health content) | European Union |
| PostHog | Optional product analytics if you opt in (no health content) | European Union |
| RevenueCat | Tells us whether your subscription is active | United States |
| Apple | App Store, TestFlight, Sign in with Apple, HealthKit | United States / EU |
| Sign in with Google, Google Play | United States / EU | |
| FormSubmit | Delivers waitlist and support form submissions to us | United States / EU |
| 123 Reg | Website hosting for orvellaapp.com | United Kingdom |
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
We may also disclose data if we are legally required to do so, or to protect the safety of a person. We do not currently share your health data for commercial research. If we introduce optional research participation in future, we will explain it clearly, update this policy, identify the relevant recipients or categories of recipients, and seek separate explicit consent before sharing health data for that purpose.
5. How do we handle your social logins?
In Short: If you choose to register or log in to our Services using Apple or Google, we may have access to certain information about you.
Our Services offer you the ability to register and log in using Sign in with Apple or Google Sign-In. Where you choose to do this, we will receive certain profile information about you from that provider. The profile information we receive may vary depending on the provider, but will often include your name and email address (which may be a private relay address if you choose Apple's option), as well as other information you choose to share.
We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by Apple or Google. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
6. Is your information transferred internationally?
In Short: We may transfer, store, and process your information in countries other than your own.
Your Orvella records are stored in the United Kingdom. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see When and with whom do we share your personal information? above), including facilities in the United States and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request. Where personal data is transferred outside the UK, we rely on appropriate safeguards recognised under UK law - such as UK adequacy regulations or the UK International Data Transfer Agreement / Addendum - so that your data continues to be protected.
7. How long do we keep your information?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Waitlist and support messages are kept only as long as needed to manage beta access and respond to you. Backups are cycled out on a rolling basis.
8. How do we keep your information safe?
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. Access to your data is protected by row-level security, so your records are only ever accessible to your account. Data is encrypted in transit and at rest, and access is restricted.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
9. What are your privacy rights?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in How can you contact us about this notice? below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.
How to contact us:
- Online: https://www.orvellaapp.com/support/
- Email: privacy@orvellaapp.com
- Post: See How can you contact us about this notice?
What happens after you complain:
- We will acknowledge your complaint within 30 days of receiving it.
- We will investigate without unjustifiable or excessive delay.
- We will keep you informed of progress and explain the outcome.
If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office, the UK supervisory authority.
- Website: ico.org.uk/make-a-complaint
- Helpline: 0303 123 1113
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in How can you contact us about this notice? below or updating your preferences in the app.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in How can you contact us about this notice? below. You will then be removed from the marketing lists. However, we may still communicate with you - for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at privacy@orvellaapp.com.
10. Controls for Do-Not-Track features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
11. How Orvella handles your health information
Orvella is a personal endometriosis record. It does not diagnose, predict, or give medical advice, and it is not a medical device. We process health information you choose to log only with your explicit consent. You can withdraw that consent in the app. We never sell your personal information, and we never share your health information with advertisers, employers, or insurers. We do not show advertising, we do not use your health entries to profile or target you, and we do not use them to train AI models. Reports and patterns are calculated from your own log on a deterministic basis. Your encrypted journal is stored with a key bound to your device; if you lose the device or reinstall, those entries cannot be recovered by us. You can export or permanently delete your data in the app. For privacy questions, contact privacy@orvellaapp.com. We are registered with the UK ICO, number ZC226672.
12. Children and young people
Orvella is not available to anyone under 16, and accounts for under-16s are blocked. For young people aged 16 to 17, we apply data-minimising defaults designed to collect and share as little as possible, in line with the ICO's Age Appropriate Design Code. If you believe someone under 16 has created an account, please email privacy@orvellaapp.com and we will delete it.
13. Do we make updates to this notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
14. How can you contact us about this notice?
If you have questions or comments about this notice, you may email us at privacy@orvellaapp.com or support@orvellaapp.com, or contact us by post at:
Orvella Ltd
Suite A
82 James Carter Road
Mildenhall
IP28 7DE
United Kingdom
Registered in England and Wales, company number 17386927
ICO registration number: ZC226672
Privacy: privacy@orvellaapp.com
Support: support@orvellaapp.com · Support form
15. How can you review, update, or delete the data we collect from you?
You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. You can exercise several of these directly in the app (including exporting and permanently deleting your data). If you cannot open the app, request deletion on our Delete account page. To request to review, update, or delete your personal information, please visit https://www.orvellaapp.com/support/.