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

3. Data we collect

3.1 Account data

3.2 Identity data

3.3 Health data (special category / sensitive data)

3.4 Insurance data

3.5 Sharing and access data

3.6 AI interaction data

3.7 Technical and security data

3.8 What we do not collect

4. Where your data comes from

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

Purpose Data used Legal basis
Create and run your account; sign-in, verification, password reset Account, identity, technical Performance of our contract with you (the Terms)
Store and display your health record Health, identity, insurance Your explicit consent (health data) and contract
Import records from institutions you connect Health, identity Your explicit consent, given when you authorise each connection
Share data with institutions/clinicians you choose; log access Health, identity, sharing/access data Your explicit consent (each grant)
AI features (Aya, Document AI) Health data relevant to your request; uploaded documents; AI interactions Your explicit consent
Insurance wallet Insurance, identity Contract and your consent
Send verification/reset codes and service messages Email, account Contract
Push notifications (if enabled) Push token, notification content Your consent (you can turn them off)
Record acceptance of Terms/Policy versions Account, acceptance records Legal obligation and legitimate interests (proof of consent)
Security, fraud and abuse prevention, rate limiting, audit logs Technical, access logs Legitimate interests (protecting you and the Service) and legal obligation
Comply with law and respond to lawful requests As required Legal obligation

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.

Provider Purpose Data location
Amazon Web Services (AWS) Servers, PostgreSQL database, file storage, key management (AWS KMS) EU — Ireland (eu-west-1)
Vercel Hosting of the web applications (front ends) Global edge network, including the United States
Resend Sending transactional emails (verification and password reset codes) United States
Google Firebase Cloud Messaging Push notifications, if you enable them Global, including the United States
Anthropic AI features (Aya assistant, Document AI) via the Claude API United States

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

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).