Privacy Statement emmii

Last updated: 1 November 2026

The emmii platform (hereinafter: "emmii") is an online tool developed by Bettr Health B.V. (hereinafter: "Bettr Health Technology"), with knowledge of the Mayo Foundation for Medical Education and Research (hereinafter: "Mayo"), to support women in the area of health, with a particular focus on women's health. Use of emmii requires the processing of your personal data. Personal data means: data that can be traced back to you as a person, directly or indirectly. "Processing" includes any action that can be performed with this data, such as registering, viewing, storing, supplementing, and providing to third parties.

Bettr Health Technology attaches great importance to your privacy and handles your data with care. This privacy statement explains how we do this.

1. To whom does this Privacy Statement apply?

This Privacy Statement applies to you if you use emmii.

2. Who is the (processing) controller for the processing of your personal data?

Bettr Health Technology is the controller for the processing of your personal data. Bettr Health Technology has appointed a Data Protection Officer (DPO), who oversees compliance with applicable data protection laws and regulations.

3. What personal data is processed in the emmii?

When using emmii, the following personal data about you may be processed:

  • your personal data (such as name, date of birth, email address, phone number, gender);
  • your agreement to the full terms of use as included in emmii;
  • your consent for the processing of your health data;
  • access and identification data;
  • health data requested in emmii's assessment, such as basic health information (such as date of birth, height, weight), medical history (such as conditions, medical procedures, medication use, menstrual data, and smoking behavior), complaints, and the nature and severity of symptoms;
  • information you record in emmii via additional modules, such as tasks and 'Ask emmii';
  • data about the mobile device you use to use emmii (such as IP address, MAC address, or other unique identification code, as well as information about your device, such as browser type and operating system);
  • data about your session (such as login time, navigation within emmii, and duration of the session).

4. For what purposes is your personal data processed?

Your personal data is registered to give you access to emmii and to make your (medical) data digitally accessible at your request. Notifications may also be sent to you. Furthermore, health data entered by you is recorded so that you can be given insight within emmii into your personal situation and to generate, on that basis, personalised, evidence-based information and recommendations. emmii is thereby intended as an information tool and not as a medical device. In this, we may (partly) make use of automated systems, including technologies based on artificial intelligence (AI) and automatically generated content, such as videos. These systems analyse data entered by you in order to generate relevant insights and recommendations. The information is then supportive in nature, is tailored to the data provided by you and is not intended as medical advice, diagnosis or treatment advice. emmii does not take fully automated decisions to which legal consequences are attached for you or which otherwise affect you to a significant degree. Where AI is used or content is automatically generated, we make this recognisable within emmii.

In addition, your data is processed for identification, logging (support), analysis, statistical purposes and for the improvement of emmii. Data about the device and your session is used for analysis, statistical purposes, to improve emmii, to detect errors and to safeguard security.

5. What is the legal basis for the processing of your personal data?

Bettr Health Technology processes your personal data on the basis of the following legal grounds:

  1. performance of the agreement (Article 6(1)(b) GDPR): for offering and operating emmii;
  2. consent (Article 6(1)(a) GDPR and Article 9(2)(a) GDPR): for the processing of health data and other special categories of personal data. This consent is explicitly requested via emmii. If you wish to withdraw your consent, you must delete your account in emmii, after which you will no longer be able to use emmii. Your personal data will then no longer be processed via emmii;
  3. legitimate interest (Article 6(1)(f) GDPR): for the processing of ordinary personal data such as technical data, log data, and usage data for the purpose of improving emmii, conducting analyses, and ensuring security, provided your interests do not outweigh this.

6. How long does Bettr Health Technology keep your personal data?

Bettr Health Technology does not retain your personal data longer than necessary for the purposes described in this statement. Your data will be retained for a maximum of three years following your last use of emmii, unless further investigation is necessary (for example, in case of unauthorized access). This three-year period has been chosen to provide you with reasonable access to your data and progress, to be able to provide the service safely and reliably, and to be able to handle any questions, complaints, or technical issues carefully. After this period, your data will be deleted.

7. With whom is your personal data shared?

One or more processors, such as developers, licensees, and hosting providers, are used to offer emmii. Data processing agreements have been concluded with these parties, setting out arrangements regarding the scope and security of the data processing. These processors have taken appropriate security measures to limit misuse and unauthorized access.

In addition, these processors may make use of other third parties for development, hosting, and management. Arrangements regarding access and security have also been made with these parties.

After data has been fully and irreversibly anonymized, where possible, we may use and/or share this (aggregated) data with third parties for statistical, research, and analysis purposes. This data can no longer be traced back to an individual and therefore does not fall under applicable privacy legislation.

Only if a processor is legally obligated to do so will your data be provided to supervisory or other competent authorities, for example in the event of an investigation into security incidents.

8. Where your data is stored?

The location where your personal data is stored depends on the country in which you use emmii.

Users of organizations within the European Union (EU)
For users who use emmii through an organization in the EU, all personal data are in principle stored and processed exclusively on servers within the European Union. In limited cases, however, identifying data, such as an email address, may be technically processed or verified outside the EU for authentication, security, and account-related purposes. Such a transfer takes place only on the basis of an appropriate transfer mechanism, such as an adequacy decision, the EU-US Data Privacy Framework for certified US parties, or the Standard Contractual Clauses (SCCs) of the European Commission, and where necessary supplementary safeguards. Appropriate technical and organizational measures are taken in this regard.

Users of organizations in the United States and Canada
For users who use emmii through an organization in the United States or Canada, personal data are stored and processed on servers in the United States. Insofar as the GDPR applies to this processing, such transfer takes place via our hosting provider Amazon Web Services (AWS) on the basis of the EU-US Data Privacy Framework, under which AWS is certified.

We ensure that the personal data of EU users and personal data of users in the United States and Canada are processed strictly separately from each other. Personal data of EU users are not stored on servers in the United States. However, when logging in, the email address may be temporarily processed technically in the available backend environments, including the US environment, solely to determine which environment the account belongs to and to be able to send the login code.

In all cases, we take appropriate technical and organizational measures to protect personal data, such as secured infrastructure, contractual arrangements (including data processing agreements), strict access restrictions, logging, monitoring, and procedures for assessing and handling security incidents. In doing so, we take into account applicable security standards and legal obligations that apply to the use of emmii within the healthcare sector where relevant.

9. What are your rights?

You have the right at all times to request access, at reasonable intervals, to the personal data that Bettr Health Technology processes about you. You may request that Bettr Health Technology correct or delete your data. Bettr Health Technology will carefully assess this request in accordance with legal requirements. If your data have been processed on the basis of consent and are in digital form, you may request to receive them in digital form (right to data portability). You may withdraw consent that you have given for the processing of health data at any time. Without consent, you cannot use emmii. In certain cases, you have the right to object to the processing. If your privacy interest outweighs other interests, Bettr Health Technology will honor your request. You may also request that the processing of your data be restricted.

To exercise your rights, you may contact Bettr Health Technology. Your request will be handled within a reasonable timeframe. You may be asked to confirm your identity.

Furthermore, anyone whose personal data is processed has the right to file a complaint with Bettr Health Technology or the competent authority, in this case the Dutch Data Protection Authority, in the event of (possible) violations of the applicable law with regard to the protection of personal data. More information can be found on the website www.autoriteitpersoonsgegevens.nl

10. Modifications

This privacy statement may be amended from time to time. Changes will be made available via emmii. At the top of this statement, you can see when it was last updated. We advise you to check regularly for changes. In the event of material changes to the processing of personal data, users will be actively informed.

11. Contact

If you have questions or comments about the way your personal data is processed in emmii, if you have privacy-related questions for our Data Protection Officer, or if you have a (technical) question about the use of emmii, you can contact:

Bettr Health Technology B.V.
Zonneoordlaan 17
6718 TK Ede
The Netherlands
Email: info@bettr-health.com