Privacy Policy

Translation of the German version. In case of discrepancies, the German version prevails.

1. Controller

The controller responsible for data processing within the meaning of the GDPR is:

This privacy policy applies both to your visit to this website and to your use of our app Orgando. Sections 2 and 3 concern the website and contacting us; sections 4 onwards concern the app.

2. Provision of the website and server log files

Each time our website is accessed, our hosting provider processes technically necessary data in server log files. This may include, in particular, the IP address, date and time of access, the page accessed, the referrer URL, browser type, operating system and status codes.

Processing is carried out for the technical provision, stability and security of the website and to prevent misuse, on the basis of Art. 6(1)(f) GDPR. Log data is stored only for as long as necessary for the stated purposes, as a rule no longer than 60 to 90 days, unless a security incident or a statutory retention obligation requires longer storage.

Hosting provider: IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany.

Cookies and reach measurement

This website does not use any analytics, marketing or tracking cookies. Where technically necessary information is processed in the browser, it serves solely the provision and security of the website.

3. Contacting us by e-mail

If you contact us by e-mail (e.g. at kontakt@lakesidesoftware.app), we process the data you send us in order to handle your request.

• Categories: name, e-mail address and content of the request.
• Purpose: handling and responding to your support and contact requests.
• Legal basis: Art. 6(1)(b) GDPR where your request relates to the initiation or performance of a contract, otherwise Art. 6(1)(f) GDPR (legitimate interest in responding to enquiries).
• Mail hosting / processor: IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany.
• Deletion: contact requests are stored until the matter has been fully dealt with. Any storage beyond that takes place only where statutory retention obligations exist or the data is required for the performance of a contract or for the defence of legal claims.

Please note: unencrypted e-mail does not offer complete protection. Please do not send us any health data, findings, doctor's letters or login credentials by e-mail. Should we nevertheless receive such data, we will process it only to the extent necessary to handle your request and where an appropriate legal basis exists (for health data, Art. 9(2)(a) GDPR), and delete it afterwards unless statutory retention obligations apply.

4. Core principle: your data stays on your device

Orgando is designed as a data-minimising app for iPhone and Android smartphones. All health data you record – such as medications, blood pressure readings, blood glucose, symptom and pain diary, vaccinations, lab values, diagnoses, allergies, appointments, contacts and documents – is stored exclusively locally on your device. This data is not transmitted to us and is not stored on our servers. We have no access to it.

The only exceptions are actions you trigger or switch on yourself: the optional backup to your own cloud (Section 6), the optional AI features (Section 7), location-based features such as the doctor search and the UV index (Section 8), the referral programme (Section 9) and purchases via the App Store or Google Play (Section 11). If you share, print or e-mail reports or documents from the app, you decide who receives them.

5. Apple Health (iPhone) and Health Connect (Android)

If you allow it, the app reads selected health values from Apple Health (HealthKit) or, on Android, from Health Connect – mainly for display. At your request it also imports blood pressure and blood glucose values locally into the respective diary, either manually or automatically in the background (e.g. from Bluetooth blood pressure monitors or CGM sensors such as FreeStyle Libre, provided their app shares the values with Apple Health or Health Connect). The app does not write any data to Apple Health or Health Connect. All values remain on the device and are neither stored nor shared by us; they are not part of the backup described in Section 6 (except for the blood pressure and blood glucose values imported into the diaries).

You can revoke access at any time: on the iPhone under Settings → Privacy & Security → Health, on Android in the Health Connect settings. The use of information received via Health Connect adheres to Google's Health Connect Permissions policy, including the Limited Use requirements.

Legal basis: your consent (Art. 6(1)(a) in conjunction with Art. 9(2)(a) GDPR).

6. Backup: export file and optional backup to your own cloud

a) Export file: You can export your data at any time as a backup file (.orgando) – optionally encrypted with a password – and save or share it via the share menu, e.g. for a new device or when switching between iPhone and Android. You decide where the file goes.

b) Automatic backup (optional): In the settings you can switch on an automatic backup to your own cloud account. It is disabled by default.

• iPhone: The backup files are stored in your iCloud Drive (folder “Orgando”). Provider: Apple Distribution International Ltd., Hollyhill Industrial Estate, Cork, Ireland; Apple's iCloud terms and privacy policy apply.
• Android: The backup files are stored in a hidden app folder of your Google Drive. To do so, you sign in with your Google account and grant the app access to this app folder only (drive.appdata) – the app has no access to your other files. Provider: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland; Google's terms of service and privacy policy apply. The app's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
• Scope: all entries recorded in the app including documents, scans and lab images, your personal details (“My Data”) and preferences, and the AI consent log. Data from Apple Health or Health Connect (Section 5) and device-bound settings such as the app lock are not included.
• Encryption: If you set a backup password (recommended), backups are encrypted with AES-256 before they leave the device. The password stays in the protected key storage of your device and is never transmitted.
• No access by us: Backups are stored exclusively on your device or in your own cloud account. We operate no servers for this and have no access to them.
• Deletion: The app keeps only the most recent backups (adjustable) and deletes older ones automatically. After switching the backup off, no further backups are made; you can delete existing files in the Files app (iCloud Drive) or in Google Drive in a web browser (Settings → Manage apps → Orgando → Delete hidden app data).

c) Operating system device backup: Independently of the app, iOS (iCloud or computer backup) and Android (backup to your Google account, device transfer) may include app data in the device backup if you have enabled this in the system settings. This backup is managed by the operating system provider in your account; we have no access to it.

d) Transfer from the previous iPhone version: On the first launch after the update, the data of the previous app version is transferred once, locally on the device. No data is transmitted in the process.

Legal basis for the automatic backup: your consent by switching the feature on (Art. 6(1)(a) in conjunction with Art. 9(2)(a) GDPR), which you can withdraw at any time by switching it off.

7. Optional AI features

For certain convenience features (e.g. recognising medications or vaccination labels from a photo, importing a medication plan, summarising documents, reading lab results) you can use optional AI features. These are triggered only with your explicit consent and only for the respective task. No content is transmitted without your consent.

• Recognising the document type (central scan button): when you capture a document using the scan button in the middle of the tab bar, the app can – with your consent – transmit a heavily reduced image of the first page, solely to recognise the type of document (e.g. lab report, vaccination record, medication plan) and assign it to the right section. The actual analysis only takes place afterwards in the respective section, if applicable after redaction and with renewed consent. If you decline, you choose the section yourself and nothing is transmitted.
• Data minimisation before sending: for photo/document scans, the app detects sensitive text locally and lets you redact it; location/metadata (EXIF) is removed. Only the content you release, redacted where applicable, is processed.
• What data is transmitted: depending on the feature, the image or PDF you release (redacted where applicable) or the text extracted from it. Technical connection data (in particular the IP address) is routed through our EU proxy so that the AI provider does not directly receive your IP address. No persistent device identifier is transmitted for this purpose.
• Processing in the EU: AI processing is carried out via the processor DeutschlandGPT GmbH, Gabriele-Münter-Straße 3, 82110 Germering, Germany (Munich Local Court, HRB 282400). A data processing agreement under Art. 28 GDPR is in place with the provider. Statements about server location (Germany/EU) and certifications (e.g. BSI C5, ISO 27001) are based on information provided by the provider.
• Sub-processors and AI model providers: for hosting, operation and AI features, DeutschlandGPT uses the following service providers, among others:
  • T-Systems International GmbH, Hahnstraße 43d, 60528 Frankfurt am Main, Germany – hosting and operation of the AI infrastructure
  • Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany – cloud infrastructure and hosting
  • IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Germany – hosting services
  • Microsoft Ireland Operations Limited (Azure), One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland – cloud infrastructure
  • Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg – cloud infrastructure
  • Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland – cloud infrastructure
  • Mistral AI SAS, 15 rue des Halles, 75001 Paris, France – AI model provider (processing of text, documents and voice/image content)
  • OpenAI Ireland Ltd, The Liffey Trust Centre, 117–126 Sheriff Street Upper, Dublin 1, Ireland – AI model provider (text, documents, voice/image content, e.g. chat, OCR, voice input)
  • Linkup Technologies SAS, 28 avenue des Pépinières, 94260 Fresnes, France – web search within the service; the search query is transmitted, deleted immediately after the response and not used for training (zero data retention)
  • Functional Software, Inc. (Sentry), 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA – error and crash reporting; processing in Sentry's EU region, with EU Standard Contractual Clauses (Art. 46 GDPR) for the transfer to the US headquarters
  According to the provider, DeutschlandGPT has concluded data processing agreements under Art. 28 GDPR with these service providers. Processing takes place predominantly within the EU; where a transfer to third countries occurs, an adequate level of data protection is ensured through EU Standard Contractual Clauses or adequacy decisions.
• Storage and deletion at the AI service: inputs and responses are stored at the AI service for the duration of use and can be deleted; they are not used to train AI models. For the web search feature, zero data retention applies explicitly (see Linkup above).
• EU proxy: all server requests are routed through an EU proxy service operated by us (processor Scaleway, France), so the upstream provider does not directly receive your IP address.

Consent per operation: because health data may be processed here, we obtain your explicit consent before each individual transmission – informed, freely given and specific to the operation concerned (no blanket bundled consent). Each consent is logged within the app (record of proof under Art. 7 GDPR) and can be withdrawn at any time with effect for the future.
Legal basis: Art. 6(1)(a) in conjunction with Art. 9(2)(a) GDPR.

8. Location-based features (doctor search, UV index, emergency numbers)

Some optional features use your location. Access is requested via the operating system's location permission and used only while you use the respective feature; you can revoke it at any time in the iOS or Android settings. We do not store your location.

a) Doctor search: The doctor search is optional and only runs when you actively start it. It uses the Places API (New) of the Google Maps Platform provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. Google is not our processor here but processes the requests as an independent controller (Google Maps Platform EEA terms with the “Google Controller-Controller Data Protection Terms”). The request is made server-side via our EU proxy (Scaleway, France) as an HTTPS call – no Google SDK and no Google map embedded in the app are used.

• Data transmitted: your search term (the selected specialty), the app's language and region, and your location coordinates (rounded to about 100 m) as the centre of the search radius. No other health data, no IP address, no device or user identifiers and no account data are transmitted.
• IP address: Because the request is routed through our EU proxy, Google does not receive your IP address, only that of our server. In our assessment, Google therefore cannot attribute a search request to a particular person.
• Display & storage: Results are shown as a list in the app. We do not store search queries or results permanently. Processing by Google is governed by the Google Maps Platform terms and Google's privacy policy, which also describes your rights towards Google. If you open a result in a maps app, that app's terms apply.
• Note: A search term such as “cardiologist” or “psychotherapist” may allow conclusions about a health interest. The feature is therefore optional and designed to minimise data.

The legal basis for the transfer to Google is your consent (Art. 6(1)(a) GDPR; where the search term relates to health, also Art. 9(2)(a) GDPR). The recipient is Google Ireland Ltd. in the EU. If Google also processes the data in the US, it does so under its own responsibility; Google LLC is certified under the EU-U.S. Data Privacy Framework.

b) UV index: To display the UV index, your coordinate, rounded to about 1 km, is sent to the weather service Open-Meteo (servers in the EU, without an account or identifier). The display can be switched off in the app settings.

c) Emergency numbers: To show the emergency numbers of the country you are in, the app determines the country from a coarse location (approx. 3 km). For this it uses the location and geocoding service of the operating system (Apple or Google); the numbers themselves are built into the app.

Legal basis for b) and c): your consent by granting location access (Art. 6(1)(a) GDPR).

9. Referral programme “Invite friends”

The app offers a referral programme: if a new user redeems your personal invitation code or link, you and the invited person receive a bonus (free Premium months). So that invitations and bonuses can be assigned, the app generates a random, pseudonymous identifier (UUID) on your device and stores it in the device's protected key storage. It contains no information about you or your device.

• Data transmitted and stored: the pseudonymous identifier, your invitation code, a code you may have redeemed, the number of successful invitations and the expiry date of a bonus. Names, e-mail addresses, contacts or health data are not transmitted.
• When: when the app is started or brought back to the foreground (querying the status and any bonus) and when you redeem a code.
• Where: a database on servers of Scaleway (France/EU) as our processor, accessed via our EU proxy.
• Sharing: You send your invitation link yourself via the share menu; we receive no information about the recipients.

Legal basis: Art. 6(1)(b) GDPR (participation in the programme and granting of the bonus) or Art. 6(1)(f) GDPR (legitimate interest in an abuse-resistant referral programme). The data is deleted when it is no longer required for the programme, at the latest when the programme ends; we delete it earlier on request.

10. Error and stability analysis

The app contains no crash or usage analytics service (no analytics, no crash-reporting SDK, no advertising, no tracking). Apple and Google only provide us with aggregated crash and performance statistics via App Store Connect or the Google Play Console – and only from users who have allowed sharing analytics data with app developers in their device settings. This data contains no content from the app. If you report an error to us by e-mail, Section 3 applies.

11. Purchases and subscriptions

Purchases and subscriptions are processed exclusively via the Apple App Store (iPhone) or Google Play (Android). Payment processing and management are handled by Apple or Google; we do not receive any payment data. The app checks the status of your subscription on the device. The privacy policies of Apple or Google apply.

12. Recipients / processors at a glance

Recipient	Purpose	Location / legal basis of transfer
IONOS SE	Provision of the website (server log files)	Germany · DPA (Art. 28)
IONOS SE	Handling of contact/support requests (e-mail hosting)	Germany · DPA (Art. 28)
DeutschlandGPT GmbH	Optional AI processing (sub-processors/model providers see Section 7)	Germany/EU · DPA (Art. 28)
Scaleway	EU proxy for server requests, referral programme database	France/EU · DPA (Art. 28)
Google Ireland Ltd.	Optional doctor search (Places API) – independent controller, not a processor	EU · consent; Controller-Controller Data Protection Terms; further processing in the US by Google (EU-U.S. Data Privacy Framework)
Open-Meteo	UV index (rounded coordinate, no identifier)	EU
Apple	App Store purchases / subscriptions; optional backup to your iCloud Drive	per Apple's privacy policy · user's own account
Google	Google Play purchases / subscriptions; optional backup to your Google Drive	per Google's privacy policy · user's own account

13. Storage period

The data you record in the app remains on your device until you delete it or uninstall the app. You can delete individual entries or, via the settings, all data at any time. Backups in your own cloud account remain until you or the app (automatic deletion of older backups) remove them. At the AI service, inputs and responses are stored for the duration of use and can be deleted; they are not used to train AI models (zero data retention applies to the web search feature). For the storage period in the referral programme, see Section 9.

14. Your rights

Under the GDPR you have, in particular, the following rights:

• Access to the data processed about you (Art. 15)
• Rectification of inaccurate data (Art. 16)
• Erasure (Art. 17)
• Restriction of processing (Art. 18)
• Data portability (Art. 20)
• Objection to processing (Art. 21)
• Withdrawal of consent with effect for the future (Art. 7(3))

As we do not store your health data ourselves, many of these rights can be exercised directly in the app (e.g. viewing, editing, deleting). For anything beyond that, contact us at kontakt@lakesidesoftware.app.

15. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority. The competent authority includes the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg.

16. Changes to this privacy policy

We update this privacy policy when the legal situation or the app's features change. The current version is always available on this page.