Privacy Policy

Last updated: June 12, 2026

Contents

  1. Data Controller
  2. Personal Data We Collect
  3. Optional Biology and Wearable Data
  4. Legal Bases for Processing
  5. AI Processing
  6. Wallet, Referral, Gift, Family and TLC Plus Data
  7. Sub-processors
  8. Data Retention
  9. Your GDPR Rights
  10. Children and Family Plan
  11. International Transfers
  12. Cookies and Tracking
  13. Changes to This Policy
  14. Contact

1. Data Controller

The data controller is The Longevity Camp Ltd, Suite 4.01 Ormond Building, 31-36 Ormond Quay Upper, Dublin, Ireland. Company Registration: June 12, 2026. Privacy contact: privacy@thelongevitycamp.com.

2. Personal Data We Collect

We collect account and identity data, optional biology and wearable data, usage and activity data, payment data, wallet and transaction ledger data, referral and gift data, family plan data, and TLC Plus voucher data. Biology data is optional and used to personalise the Lifeshift Path and AI Biology Insight.

3. Optional Biology and Wearable Data

If you connect Apple Health, Oura or Whoop, we process numerical metrics such as HRV, resting heart rate, sleep, activity and recovery signals. These are special-category data under Article 9 GDPR and are processed only on the basis of your explicit consent (Article 9(2)(a)), requested separately before any health data is read. Wearable connection is optional and can be disconnected at any time in Account → Connections. Biology data is encrypted in transit and at rest and retained on a rolling 90-day basis unless a shorter period is required by law or configured by the user. We never use health data for advertising and never sell it.

4. Legal Bases for Processing

We process personal data under contract, consent, legitimate interest and legal obligation. Optional biology/wearable data relies on explicit consent (Article 9(2)(a) GDPR); marketing emails rely on consent. Financial records, wallet ledger, referrals and gift records may be retained to comply with Irish accounting and tax obligations.

5. AI Processing

AI Biology Insight uses selected numerical biology values, selected pillars and path day to generate educational wellbeing insights. We do not send your name, email, raw wearable API responses or direct identifiers to OpenAI. AI-generated insights are educational only and are not medical advice.

6. Wallet, Referral, Gift, Family and TLC Plus Data

Wallet ledger, referral status, gift redemption status, family membership records and TLC Plus voucher counters are processed to deliver the relevant service features, prevent fraud, manage billing and comply with accounting obligations. Wallet credits have no cash value and cannot be redeemed for cash or transferred outside TLC.

7. Sub-processors

We use Supabase, OpenAI, Stripe, Sentry, Mixpanel, Mux, Hetzner/BTCPay Server and Apple to deliver the Services. Sub-processors are EU-based or covered by appropriate safeguards such as Standard Contractual Clauses and Data Processing Agreements where required.

8. Data Retention

Account data is retained while the account is active plus 30 days after a deletion request. Biology data is retained on a 90-day rolling basis. Payment records, wallet ledger, referral and gift records are retained for 7 years where required for tax/accounting obligations. Sentry crash reports are retained for 90 days and Mixpanel analytics events for 12 months before anonymisation.

9. Your GDPR Rights

You may request access, rectification, erasure, restriction, portability, objection and withdrawal of consent by emailing privacy@thelongevitycamp.com. We will respond within 30 days. You may lodge a complaint with the Irish Data Protection Commission or your local supervisory authority.

10. Children and Family Plan

The App is not directed at children under 16. For Family Plan members aged 16-18, the host must confirm parental or guardian authority. Biology sync is disabled by default for accounts associated with minors and requires explicit re-confirmation where legally permitted.

11. International Transfers

Personal data is stored primarily within the EEA using EU-region infrastructure. Where data is transferred outside the EEA — including health data imported from US-based wearable providers — we use appropriate safeguards under GDPR Chapter V, including the EU-US Data Privacy Framework and/or Standard Contractual Clauses where applicable.

12. Cookies and Tracking

The mobile App does not use cookies. The website uses essential cookies only unless future optional analytics or marketing cookies are introduced with appropriate consent.

13. Changes to This Policy

Material changes will be notified by in-app banner and email at least 30 days before taking effect where required.

14. Contact

Email: privacy@thelongevitycamp.com. Post: The Longevity Camp Ltd, Suite 4.01 Ormond Building, 31-36 Ormond Quay Upper, Dublin, Ireland.

Terms of Service

Version 2.1 · draft for legal review · Effective: June 12, 2026

Changelog

v2.1 — Added explicit consent (Art. 9 GDPR) for health/wearable data; Apple Health / Oura / Whoop sources; updated sub-processor list.