Data Privacy Policy for Sapiens Wearable Programs

In brief

• This policy covers Sapiens wearable programs, such as the 4-month Energy Management Journey. These programs use a wearable (usually an Oura Ring, or your own Garmin or Whoop), short personal messages and monthly virtual team sessions to help you build healthy habits.
• These programs do not use laboratory tests, biosamples or test kits. Our privacy policy for stress diagnostics covers those services.
• Using a wearable is voluntary. You connect your wearable data only after you give explicit consent, and you can disconnect it at any time.
• Wherever possible, we work with your personal six-letter code instead of your name.
• Your employer never receives your individual wearable data, your habits or your messages.
• For groups of more than 8 participants, Sapiens can show an anonymised team dashboard in the virtual team sessions. You decide whether your data is included.
• Sapiens stores program data on Microsoft Azure in EU regions, with encryption in transit and at rest. Our AI support runs in the EU and never receives personally identifiable data.
• Your data is never sold and never used to train AI models.
• This is a wellness program. It does not diagnose, treat or monitor any medical condition and it is not an emergency service.

Scope and terms

This policy applies to every Sapiens program in which participants use a wearable for habit change, whether your employer booked the program or you booked it yourself.

"Customer" means the employer or organisation that booked the program with Sapiens. If you booked it yourself, the sections about the Customer do not apply to you.

"Participant", "you" means the person taking part in the program.

"Program" means the wearable-based habit-change journey described in the contract between the Customer and Sapiens, including team sessions, wearable tracking and personal habit support.

"Six-letter code" means the random personal code Sapiens gives you, for example "KTRBWE". It carries no information about you.

The program is for adults only. You must be at least 18 years old to take part.

Data controller

Sapiens Health & Performance GmbH ("Sapiens")
Dinxperloer Straße 365
46399 Bocholt
Germany

Email: support@be-sapiens.com
Phone: +49 172 88 66 434

Sapiens is the independent controller of your program data. The Customer is an operational partner. It promotes the program and helps with scheduling. It has no access to Sapiens systems and receives no individual program data.

Data protection officer

We have appointed Martin Bastius of heyData GmbH as our external data protection officer.

Martin Bastius, heyData GmbH
Bertolt-Brecht-Platz 3
10117 Berlin
Germany
Email: datenschutz@heydata.eu
Phone: +49 89 41325320

How the program works, step by step

1. Registration. You fill out a short Sapiens registration form (Typeform, EU data centre). You can register with your name or only with your six-letter code. We ask for the contact details we need to reach you (mobile number or email), your preferred message channel and, if you want a provided ring, a delivery address and ring size. Many participants give their office address. The form also collects your consent.
2. Wearable delivery. Where needed, we send you a ring sizing kit first. Then we send you an Oura Ring, or an equivalent wearable in countries where Oura is not available. The courier needs a name and address on the parcel. You can also use your own Garmin or Whoop instead.
3. Your own wearable account. You download the wearable app (for example Oura) and create your own account. You accept the provider's terms and privacy policy yourself. The provider is the independent controller for your account.
4. Connecting your data. After informed consent, you authorise Sapiens through the provider's secure sign-in (OAuth). The provider shows you which data categories Sapiens may read. Sapiens never sees your password.
5. Personal habit support. Sapiens sends you short personal messages by SMS, iMessage, WhatsApp or email. Your Customer decides which channels are allowed, and you choose among them. Messages include habit check-ins and proactive check-ins based on your wearable trends.
6. Monthly team sessions. In each virtual team session, you scan a QR code that opens a short form. You enter only your six-letter code and the two or three personal habits you commit to for the coming month. The form does not ask for your name.
7. Optional team dashboard. In groups of more than 8 participants, your coach can screen-share an anonymised team dashboard in the session (see below).
8. Support on request. You can reach your Sapiens coach at any time by SMS, iMessage, WhatsApp or email.
9. End of the program. Sapiens ends its access to your wearable data, you return the provided wearable and your program data is deleted as described below.

Which data we process

1. Identity and contact data

• Your six-letter code, and your first and last name only if you choose to give it
• Mobile phone number or email address, depending on your message channel; for WhatsApp, your WhatsApp account identifier
• Delivery name, delivery address and ring size (only if you receive a provided wearable)
• Name of the Customer and the program or team group you belong to
• Your consents and when you gave or withdrew them

Identity and contact data are stored separately from your wearable and habit data, which are stored under your six-letter code only.

2. Wearable data from Oura

Sapiens requests only the following Oura data permissions. Oura shows them to you before you agree, and you can untick permissions you do not want to share.

• Daily summaries (Oura permission "daily"): sleep score, readiness score and their contributors, such as heart rate variability (HRV) balance, resting heart rate, recovery index and body temperature deviation; activity score, steps, active calories, inactive time and activity levels; daytime stress and recovery time; resilience level.
• Sleep periods (part of "daily"): bedtime and wake time, total sleep and time in each sleep stage, sleep efficiency, time to fall asleep, average and lowest heart rate, average HRV and breathing rate during sleep.
• Heart rate (Oura permission "heartrate"): heart rate measurements over the day and night.
• Workouts (Oura permission "workout"): type, start and end time, intensity and calories of workouts Oura detects or you log.
• Sessions (Oura permission "session"): guided or unguided breathing, meditation and relaxation sessions you record in the Oura app, with heart rate and HRV during the session.
• Blood oxygen (Oura permission "spo2"): your average blood oxygen level during sleep and the breathing regularity index, where your ring supports it.
• Basic profile (Oura permission "personal"): age and biological sex, to read your HRV and heart rate against people like you. Oura includes height and weight in the same permission. Sapiens does not use them.

Sapiens does not request your Oura email address, your Oura tags (personal notes you add in the app, such as alcohol, medication or cycle notes) or your ring's hardware data. Sapiens receives summaries and measurements from Oura's cloud, not raw sensor data and not your location.

3. Wearable data from Garmin and Whoop

If you use your own Garmin or Whoop, we read the comparable categories through the provider's official authorisation process: sleep and sleep stages, recovery, heart rate variability, resting heart rate, stress, daily activity and workouts. We do not request your location or GPS routes. For other devices without an integration, you follow your data in your own app and share only what you choose in your check-ins.

4. Habit and program data

• The habits you commit to each month and your answers to habit check-ins (for example "yes" or "no"), stored under your six-letter code
• Messages you exchange with Sapiens and your message settings, such as how often you want to hear from us
• Attendance at team sessions
• Whether you include your data in the team dashboard
• Status of a provided wearable (sent, received, returned)

How we use your wearable data

Habit check-ins. We send short messages that help you follow the habits you chose.

Proactive check-ins. Sapiens software compares your recent data with your own baseline. If your recovery or resilience markers drop, for example several short nights in a row or an HRV well below your usual level, you may receive a short message with practical suggestions. A Sapiens coach can follow up if you want.

These check-ins are wellness messages. They are not medical alerts. They do not mean that anything is wrong with your health, and nobody watches your data around the clock.

Team dashboard (optional). For groups of more than 8 participants, Sapiens can show an aggregated team dashboard by screen share in the virtual team sessions, for example the group's average sleep or recovery trend. To protect each person's anonymity, the dashboard shows group values only, never individual values or names, and it is only shown when more than 8 participants have chosen to include their data. You decide whether your data is included, and you can change your choice at any time. The dashboard is owned by Sapiens and stays with Sapiens at all times. It is not sent to your employer or to anyone else.

AI support. Sapiens uses Claude, a large language model by Anthropic, running in the European Union. It helps us write personal habit messages and answer your messages faster. The program is built so that Claude never receives personally identifiable data: no name, email address, phone number, employer or six-letter code. It only receives what it needs for one message, under a random internal ID, such as your chosen habits and relevant wearable trends. The data is not used to train AI models. If you prefer messages without AI support, tell us and your messages are based on fixed rules and your coach.

No decision with legal or similarly significant effects is made automatically about you. All messages are wellness suggestions that you are free to ignore.

What your employer sees

Your employer does not receive your individual wearable data, your habits, your check-in answers or your messages. Colleagues and team leads who join a team session may see the anonymised team dashboard described above, which never shows individual values.

The Customer also receives administrative information: how many people enrolled and how many provided wearables were sent. If a provided wearable is not returned after several reminders, Sapiens charges the Customer for it and names the participant concerned on that invoice. You can avoid this by returning the wearable, or by paying for it yourself if you want to keep it.

Purpose and legal basis

We process your data only to deliver the program: logistics, wearable integration, habit support, team sessions and your questions.

• Identity, contact and delivery data: to deliver the program you signed up for (Art. 6(1)(b) GDPR). Where your employer booked the program, also our legitimate interest in delivering it (Art. 6(1)(f) GDPR).
• Wearable data, habit data and health-related messages, including AI support: your explicit consent (Art. 9(2)(a) and Art. 6(1)(a) GDPR).
• Inclusion in the team dashboard: your separate consent (Art. 9(2)(a) and Art. 6(1)(a) GDPR).
• Invoices and accounting records: our legal obligations under German tax and commercial law (Art. 6(1)(c) GDPR).
• System security and defence of legal claims: our legitimate interests (Art. 6(1)(f) GDPR), with data minimisation.

Voluntary participation. Taking part, connecting a wearable and being included in the team dashboard are voluntary. If you decline or withdraw, there are no consequences for your employment. You can still join the team sessions without connecting any data. Withdrawal does not affect processing that took place before.

Your choices during the program

• Take part under your six-letter code instead of your name.
• Disconnect your wearable at any time in your wearable account settings, or ask us to do it.
• Include or exclude your data from the team dashboard.
• Change your message channel or how often you hear from us.
• Turn off proactive check-ins or AI support and keep the rest of the program.
• Leave the program at any time and ask us to delete your data.

Who receives your data

Sapiens shares data only with service providers that we need to run the program. Each one is bound by a data processing agreement and receives the minimum it needs.

• Microsoft Ireland Operations Limited (Microsoft 365 and Azure, EU regions West Europe, Germany West Central and North Europe): hosting of all program data, email and internal processing.
• Typeform S.L. (Spain, EU data centre): registration and monthly habit forms. Monthly habit forms carry only your six-letter code. We transfer the answers to our Azure systems and delete them from Typeform afterwards.
• Oura Health Oy (Finland), Garmin and WHOOP: provide your wearable data to Sapiens after your authorisation. For your own wearable account, each provider is an independent controller under its own privacy policy.
• Anthropic (Claude, running in the European Union): AI support for messages, without personally identifiable data.
• WhatsApp Ireland Limited (only where the Customer allows WhatsApp and you choose it): delivery of WhatsApp messages. Meta may process data outside the EU.
• Messaging providers for SMS and iMessage (only if you choose these channels): delivery of your messages. They receive your phone number and the message, never your wearable account.
• DHL and, where it ships directly, the wearable manufacturer: delivery of the sizing kit and wearable. They receive the delivery name, address and phone number only.
• Microsoft Teams by default, or Zoom Video Communications, Inc. (USA) where the Customer requires it: live team sessions. They receive no individual wearable data. Sessions are not recorded.

Within Sapiens, only your assigned coach and Sapiens management can link your six-letter code to your identity. Logistics staff see only delivery details. Engineering staff work with pseudonymised data and access identity data only for technical troubleshooting.

Data security

• Encryption in transit and at rest for all program data on Microsoft Azure in the EU. Sapiens databases are reachable only through a private Azure network.
• Pseudonymisation wherever possible: wearable, habit and form data are stored under your six-letter code, separately from your name and contact details.
• Wearable access tokens are stored encrypted and used only by the integration service. Sapiens never stores your wearable account password.
• Multi-factor authentication, individual logins and role-based access on every system that holds participant data.
• Audit logging of access to sensitive systems, quarterly access reviews and same-day removal of access when someone leaves.
• Encrypted company devices for all staff and coaches.
• A documented incident response process. Customers are notified within 48 hours of any actual or suspected personal data breach. The supervisory authority is notified within 72 hours where the law requires it.
• Cyber insurance with Hiscox, with cover of up to EUR 1,000,000 per claim.

A note on messages. SMS messages are not end-to-end encrypted, and message previews can appear on your lock screen. We keep wearable details in messages short. If you prefer, choose email or another channel your Customer allows, or ask us to keep messages free of any figures.

Retention and deletion

• Sapiens ends its access to your wearable data at the end of the program and revokes the access token. You can also revoke it yourself at any time.
• Delivery addresses and ring sizes are deleted once the provided wearable is returned or settled.
• Wearable data, habit data and message history are deleted 6 months after the end of the program, or earlier on request. In employer programs, all program data is deleted at the latest when the Customer contract ends. Sapiens confirms deletion in writing on request.
• Typeform answers are deleted from Typeform after transfer to our systems.
• Invoices and accounting records are kept for the statutory periods under German tax and commercial law. They contain no wearable or habit data.
• If you want to continue after the program, for example as an individual client, we ask for your consent again.

Transfers outside the EU

Sapiens stores all program data in the EU, and our AI support runs in the EU. If you live outside the EU, your data is transferred to the EU for processing. A few providers listed above may process data in the USA, for example Meta for WhatsApp or Zoom where a Customer requires it. These transfers rely on the EU-U.S. Data Privacy Framework where the provider is certified, or on the European Commission's Standard Contractual Clauses, with the UK Addendum for UK participants. Before a program starts outside the EU, Sapiens checks the local data protection requirements of the participants' country, in addition to GDPR.

Your rights

You have the right to access, correct, delete, restrict and transfer your data, to object to processing based on legitimate interests and to withdraw your consent at any time. To exercise these rights, write to support@be-sapiens.com from the email address you registered with, or send a message to your coach with your six-letter code. We may need to confirm your identity before we act.

You also have the right to complain to a supervisory authority, in particular in the EU country where you live or work. For Sapiens, this is usually the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW), Kavalleriestr. 2-4, 40213 Düsseldorf, Germany, email: poststelle@ldi.nrw.de, phone: +49 211 38424-0. UK participants can also complain to the Information Commissioner's Office (ICO).

Wellness program, not medical care

• The program is a lifestyle and wellness service. It does not diagnose, treat, prevent or monitor any disease, and it does not replace medical advice, diagnostics or treatment.
• The wearables used in the program are consumer wellness devices. Sapiens does not use them to detect or monitor medical conditions. Wearable scores are estimates and can be inaccurate.
• Sapiens coaches work as performance and health coaches. Some of them are licensed medical doctors, but within the program they do not diagnose, prescribe or issue sick notes, and no doctor-patient relationship is formed.
• Messages are not monitored around the clock and are not an emergency service. In an emergency, call your local emergency number (112 in the EU). If you feel unwell or worry about your health, contact a doctor.
• If you are pregnant, have a medical condition or take medication, check with your doctor before you change your exercise, sleep or nutrition habits.
• You decide which suggestions you follow. Sapiens accepts no liability for actions you choose to take based on the program.

Changes to this policy

We update this policy when our services, providers or the law change. The date at the top shows the latest version. If a change affects how we use your wearable data, we inform active participants by message before it applies.