Privacy Policy

This version supersedes all prior Privacy Policies published by Communication Band Ltd for the Ottavia service.

This Privacy Policy explains what personal information Ottavia processes about you, how and why, and the choices and rights available to you. It is issued by Communication Band Ltd, a company incorporated in England and Wales ("Ottavia", "we", "us"), and covers the Ottavia mobile application and the ottavia.band website.

This Policy should be read together with our Terms and Conditions. Where applicable law requires express consent for health-data processing or another purpose, we request that consent through a control that is legally distinguishable from acceptance of the Terms, even if both controls appear in the same onboarding flow.

---

1. Who We Are and What This Policy Covers

1.1 Controller

Communication Band Ltd (England & Wales) is the controller of the personal information described in this Policy.

1.2 Scope

This Policy covers the Ottavia app and the ottavia.band website, offered in the United Kingdom, the European Union, the United States, Australia and New Zealand. It does not cover third-party services you access through Ottavia, which have their own privacy terms.

---

2. Our Privacy Model: How We Organize Identity and Health Data

2.1 Primary records and identifiers

Ottavia uses different primary records for account/payment information and for health, wellbeing and lifestyle information. This is an organizational and technical risk-reduction measure, not a promise that the records are anonymous, physically isolated or incapable of being associated.

Your health-side profile holds the health, fitness, nutrition, lifestyle and related information you provide or connect, together with guidance and interaction data generated through the Service. Its primary identifier is a randomly generated internal identifier rather than your name, email or payment details.

If you subscribe to a paid feature, we also hold an identified account containing an account identifier, authentication information, subscription status and payment-related references. Technical and subscription records may enable an identified account and health-side profile to be associated.

2.2 Why we describe this as pseudonymous, not anonymous

We do not describe your health-side profile as anonymous. Our systems may maintain technical records associated with subscriptions, account functionality or device use that can enable a health-side profile to be associated with an identified account. For this reason, we do not treat the health-side profile as anonymous, and we do not promise that it is technically impossible to associate it with your identity.

Because of this, we treat active health-side data as pseudonymous personal data, not anonymous data. We do not state or imply that a health-side profile is technically unlinkable from an identified account.

2.3 Legal basis for health-side data

Where UK/EU data-protection law applies, we rely on your explicit consent for processing health information where Article 9 requires it, given through the acceptance flow described in Section 4. Other processing of your health-side data may rely on another lawful basis, such as what is necessary to provide the Service you request, where applicable and permitted by law. You may withdraw your consent at any time, as described in Section 12, though this will affect our ability to provide the Service to you.

2.4 The Experts Library does not change this

When you use or subscribe to an Expert Lens, Ottavia's AI system uses the lens's expert-informed materials and approach to generate guidance. The expert does not receive your identity or individual health-side data and does not personally review your question or response.

---

3. Data We Process

3.1 In your health-side profile

Health, fitness and reproductive-health data, which may include sleep, heart rate and variability, activity and location data, blood pressure, body composition, respiration, temperature, stress, energy expenditure, training load, pregnancy status, menstrual-cycle information, blood glucose and related metrics, read with your permission from sources such as Apple HealthKit, Android Health Connect, Garmin or Google Health services where enabled.

Nutrition, lifestyle, goals, date of birth, gender, height, weight, profile information, medical conditions and free-text context you provide, plus documents, photographs and voice recordings you choose to submit.

The guidance and interaction history Ottavia generates for you, including your conversations with Expert Lenses.

A randomly generated identifier that is not, by itself, tied to your name, email or payment details (see Section 2 on the limits of this separation).

3.2 In your identified account (if you have one)

An account identifier, such as your email, and authentication data.

Subscription status and entitlements.

Payment and subscription information. Apple or Google processes an in-app purchase made through its store. Stripe processes a direct web purchase when that channel is offered. Ottavia may receive identifiers, subscription status and limited payment details such as card brand and last four digits, but does not store full payment-card numbers.

---

4. How We Use Your Data and Our Legal Basis

4.1 Separate affirmative controls

Acceptance of the Terms and any express consent required for health-data processing are captured through legally distinguishable affirmative controls. Optional marketing consent is separate. You may withdraw consent as described in Section 12, but withdrawing consent needed for core health-data processing may prevent us from providing the affected parts of the Service.

4.2 Providing the Service

We process your health-side profile to generate the guidance you request. Where UK/EU data-protection law applies, our legal basis is your explicit consent (Article 9 UK GDPR/GDPR) where that consent is required; elsewhere, or for processing not requiring Article 9 consent, we may rely on another lawful basis, such as what is necessary to provide the Service, where applicable and permitted by law. We process your identified account to provide and bill paid features. Legal basis: performance of our contract with you.

4.3 Secondary purposes

We may use usage data and, where specifically disclosed and permitted, interactions or conversation samples for quality assurance, safety evaluation, security and service improvement. For ordinary technical and security data, we rely on our legitimate interests where permitted. Where a purpose involves health data or requires consent under applicable law, we rely on explicit or other valid consent for that purpose. We do not treat acceptance of the Terms as consent for these activities.

4.4 Keeping the app working and safe

We process limited technical data (for example crash and error reports) to operate, secure and maintain Ottavia. Legal basis: our legitimate interests, or your consent where required in the UK/EU/EEA.

4.5 Analytics

We process product-usage analytics to understand how Ottavia is used, in aggregate. Legal basis: your consent in the UK/EU/EEA; our legitimate interests elsewhere, where permitted.

4.6 No advertising use

We do not use your data for advertising, and we do not sell it. See Section 8 on marketing.

---

5. AI Providers

5.1 General principle

This Policy's disclosures and the consent you give cover all AI providers we use, rather than treating any one provider as a fixed contractual dependency, except where the law requires provider-specific consent or disclosure. We do not promise a specific AI architecture or provider mix, and it may change over time.

5.2 No training on your data

We use business or API services for production processing. AI providers process data under their applicable service and data-processing terms, including for service delivery, security and abuse monitoring. We do not authorize them to use Ottavia production data to train general-purpose models unless we first provide any notice and obtain any consent required by law.

5.3 Primary guidance provider

Our primary AI provider, currently OpenAI, may receive information needed to answer your request, including profile details, health-related information, conversation history, photographs and voice audio. Depending on the product and configuration used, provider-side conversation or application state may be retained until it is deleted; we do not promise zero data retention.

5.4 Automated quality and safety review

Ottavia may use a separate AI service, currently Anthropic, for limited automated sampled quality or safety evaluation of selected responses. The material evaluated may include your question, relevant health context, generated response and image links. We do not send account identifiers for this purpose, but free text may still identify you. Where this secondary processing involves health data or applicable law requires consent, it is used only after the required notice, legal basis or consent, and withdrawal controls are in place.

---

6. Sub-processors

We use the following service providers to operate Ottavia. The data received depends on the feature and configuration in use.

---

7. The Experts Library and the Expert Firewall

When you use or subscribe to an Expert Lens, Ottavia applies expert-informed materials and methods to your health-side profile through its AI system, as described in our Terms.

Experts do not receive your identity, your individual health-side data, or any other individual user's data. Where we provide experts with information about how their Expert Lens is being used, it is limited to aggregated, de-identified figures.

---

8. Marketing

8.1 Marketing consent

Where the law requires your affirmative opt-in before we send you marketing, we ask for a separate, optional, unticked choice that is distinct from your acceptance of the Terms and your health-data consent. Where opt-in is not required, we may contact you subject to an easy opt-out.

8.2 Health data is not used for marketing

We do not use your health data or conversation content for targeted advertising, marketing profiling, or building advertising audiences, and we do not disclose it to third parties for advertising. This does not prevent personalization that is an integral part of delivering Ottavia itself, such as relevant responses or in-app content.

8.3 No third-party advertising in the app

We do not display third-party advertising or sponsored content inside Ottavia. We may promote our own subscriptions, experts, Expert Lenses and features.

---

9. Analytics, Crash Reporting and Your Choices

We use the analytics and crash-reporting providers described in Section 6. Where consent is required, these tools should remain off until you make the relevant choice, and you may later withdraw that consent through the available app, website or device controls.

---

10. International Transfers

Your data may be processed outside your country, including in the United States. Where applicable law requires a transfer mechanism or safeguard, we require our processors to rely on an appropriate legally recognized mechanism, such as an adequacy arrangement, Standard Contractual Clauses or applicable UK transfer safeguards, and we are in the process of completing and documenting this for each provider we use.

---

11. Data Retention and Deletion

11.1 Deletion

You may request deletion using the available in-app controls and by contacting support@ottavia.band. Account deletion and deletion of a health-side profile may use separate processes, so contact us if you want both addressed. Deletion may not be immediate or complete where information remains in backups, security or legal records, or provider systems; we act on deletion requests as required by applicable law.

11.2 Account data

We retain account, health, interaction and subscription information while needed to provide the Service and for legitimate operational, security, accounting and legal purposes. We do not currently apply one fixed retention period to all health-side data.

11.3 AI provider retention

Conversation and application-state data processed by our primary AI provider may be retained until deletion for the product currently used. We do not promise a 30-day or zero-retention period. We will update this Policy if the provider or configuration materially changes.

11.4 Data we keep after deletion

We may retain and use data that has been genuinely and irreversibly anonymized or aggregated, such that you are no longer reasonably identifiable from it. Removing an account identifier alone does not make data anonymous, and we do not treat it as such.

---

12. Your Rights

12.1 If you hold an identified account

Where we can reliably associate a verified request with your account or health-side profile, we facilitate the rights available under applicable law, which may include access, correction, deletion, restriction, objection and portability, subject to legal limitations.

12.2 Where we cannot reliably associate a request

We may ask for information reasonably needed to verify your identity and locate the relevant records. If we cannot reliably associate a verified request with a health-side profile, we may be unable to act on that profile through administrative processes; available self-service controls may still be used.

12.3 Export

We do not currently offer a self-service export or download feature. You may request a copy or transfer of eligible data by contacting us, and we will respond in accordance with the rights and limitations that apply to you.

12.4 How to exercise your rights

Contact us using the details in Section 17, or use the in-app controls where available. UK/EU users also have the right to complain to their local data protection supervisory authority.

12.5 Complaints

If you believe we have not handled your personal information in accordance with applicable data protection law, you can submit a complaint to us at support@ottavia.band. We will acknowledge your complaint within 30 days of receipt, look into the matter, and aim to provide you with a substantive response within three months, except where exceptional circumstances require more time, in which case we will explain why and give you an updated timeframe. You do not need to complain to us first, and submitting a complaint to us does not affect your right to complain directly to the UK Information Commissioner's Office or your local data protection supervisory authority at any time.

---

13. Security

We use technical and organizational measures appropriate to the data we hold, as required by applicable law. We do not promise absolute security or that a breach can never occur. Where the law requires us to notify you, a regulator or another party of a security incident, we will do so within the manner and timeframe the law requires; we do not make a voluntary blanket promise to notify every incident or within a fixed period beyond that.

---

14. Children

Ottavia is intended only for users aged 18 or over. If we learn that we have processed personal information relating to someone under 18 contrary to this requirement, we will take steps to restrict the account and delete the information, as appropriate and required by law.

---

15. Apple and Google

Where you access Ottavia through the App Store or Google Play, Apple's or Google's own platform terms and privacy rules also apply to that purchase and to certain data (for example health-data permissions and in-app purchases).

Where Ottavia reads data through Apple HealthKit or Health Connect, we handle that data subject to the platform's health-data rules, including not using it for advertising.

---

16. Changes to This Policy

We may update this Policy from time to time. We will give notice of a material change in the manner and within the timeframe required by applicable law and, where circumstances reasonably permit, before it takes effect, and will update the effective date above.

---

17. Contact

Communication Band Ltd, company number 16142823, registered in England and Wales. Registered office: 188 Brent Street, London NW4 1BE, United Kingdom. ICO registration: ZC206854. Contact: support@ottavia.band. UK users may complain to the Information Commissioner's Office, and EU/EEA users may complain to their local supervisory authority. Details of Ottavia's EU representative will be published before the Service is actively offered in the EU/EEA. Washington and Nevada consumer-health notices are available at https://ottavia.band/washington-consumer-health-data-privacy-policy and https://ottavia.band/nevada-consumer-health-data-privacy-notice.