Privacy Policy

This Privacy Policy explains how Lepo Labs (“Lepo,” “we,” “us,” or “our”) handles personal data when you use the Lepo Android application, visit lepo.health, or join our launch waitlist. Lepo helps you understand recovery, sleep, activity, stress, and related health signals using information available through Android Health Connect.

Who we are

Lepo Labs is the provider of the Lepo application and website. We are building Lepo in the European Union and are committed to handling personal data in accordance with applicable EU data protection principles, including lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, and security. Questions or privacy requests may be sent to privacy@lepo.health.

Data the app accesses

With your permission, Lepo may read health and fitness information made available through Health Connect. Depending on the data you and your connected apps provide, this can include sleep sessions, resting heart rate, heart-rate variability (HRV), steps, workouts, activity, and related timestamps. Lepo uses this information to calculate personal baselines, recovery and activity scores, trends, and explanations requested from the coach.

You control Health Connect permissions in Android settings and can revoke them at any time. Lepo requests read access only to the data categories you enable, and only the categories needed for the features you use. Core scoring stays on your phone. If you enable automatic daily summaries or send a chat question to Lepo AI, the app sends the daily aggregate values and derived facts described below for AI processing.

Lepo AI

Lepo AI is an optional premium feature that generates automatic daily summaries and answers questions you send in chat about your recovery, sleep, and activity. These are two separate processing paths:

Automatic daily summaries: after you opt in, the app sends the last seven days of daily aggregate values: sleep duration, sleep stages, wakeups and sleep scores, resting heart rate, heart-rate variability (HRV), steps, active calories, VO2 max, and computed recovery and strain scores, where available. It also sends summary facts computed on your phone, including personal baselines, confidence levels, seven-day averages, changes from those averages (deltas), your exertion target, and gaps in the available data. Dates and local timing information help put the summary in context. Stored coach memory facts are not sent for automatic daily summaries.

User-initiated chat questions: when you send a question, the app sends the same seven-day daily aggregate values, derived summary facts, and timing information described above, together with your question and chat conversation. Chat may also include your locally stored coach memory facts to help personalise the response. Stored coach memory is used only in this chat path.

Lepo does not automatically collect or send your name, email address, or other identifying details, and raw sensor data is never sent, including continuous sensor readings. If you include such details in a chat question, that text is sent to the AI provider as you typed it. Core scoring stays on your phone; only the information described above is sent for Lepo AI processing.

To generate automatic daily summaries and chat answers, we use two service providers: Supabase operates our backend, with processing and data storage in the European Union (EU North region), and OpenAI operates the language model, with processing in the United States. We process Lepo AI data under OpenAI's Data Processing Agreement, which includes Standard Contractual Clauses (SCCs) adopted for transfers of personal data from the EEA, and where applicable the EU–US Data Privacy Framework. Data sent to Lepo AI is used to provide these summaries and chat responses and is not used to train AI models.

Before you first enable Lepo AI, we show a one-time notice describing this processing and obtain your explicit consent under Article 9 GDPR before the first automatic summary. You can withdraw consent for automatic summaries at any time by turning off “Auto-summaries” in Settings. Chat questions remain user-initiated: sending a question starts the chat processing described above. You can also revoke the underlying Health Connect permissions in Android settings at any time.

The app creates a local session for your installation to associate requests with your install for rate limiting and abuse prevention. This session is not linked to your name or email address. Uninstalling the app removes the local session.

Waitlist and website data

If you join the launch waitlist, we collect the email address you submit. You may also tell us what wearable you use, opt in to occasional build updates and beta invitations, or arrive with an optional referral label of up to 200 characters. We use this data to send the messages you choose and to record how the signup was referred. We do not require health information to join. We store the normalised address with the submission date and the source “landing” so we can operate the list, prevent duplicate entries, and demonstrate when consent was provided.

We do not use analytics, advertising trackers, or external font services on this website. Our hosting provider may process limited technical information, such as IP addresses and request logs, as necessary to deliver and secure the site.

Legal bases and retention

We process Health Connect data to provide app features you request and, where required, on the basis of your explicit consent. We process your waitlist choices based on your consent to receive the launch notification and, if selected, build updates and beta invitations. You may withdraw that consent at any time by contacting us. Withdrawal does not affect processing that was lawful before withdrawal.

Waitlist records may be retained for up to ten years unless you ask us to remove your address sooner, though we intend to delete or repurpose the list after the launch notification only with fresh permission. On-device app data remains subject to your device controls, app deletion, and Health Connect settings. We retain operational records only as long as reasonably necessary for the purpose described or to meet legal obligations.

Sharing, sales, and international handling

We do not sell personal data or health data. We do not share it for cross-context behavioural advertising. The service providers that process your app data are named in this policy: Supabase (backend, EU North) and OpenAI (Lepo AI automatic daily summaries and chat). Our website hosting provider may process limited technical information, such as IP addresses and request logs, as described in the waitlist section. All of these may process data only on our instructions, for the stated purpose, and subject to appropriate confidentiality and security obligations.

We aim to keep personal data within the European Economic Area where practical. Our backend infrastructure is located in the EU. OpenAI processes data for your opted-in automatic daily summaries and user-initiated chat questions in the United States; this transfer relies on the Standard Contractual Clauses in OpenAI's Data Processing Agreement and, where applicable, the EU–US Data Privacy Framework.

Your rights and security

Depending on where you live, you may have rights to access, correct, erase, restrict, or receive a copy of your personal data; object to certain processing; withdraw consent; and complain to your local supervisory authority. To exercise a right, email us at privacy@lepo.health. We may need to verify your request and will respond within the period required by applicable law.

We use technical and organisational safeguards designed to protect personal data, including minimising collection, limiting access, and named, contractually bound processors (Supabase and OpenAI). No method of storage or transmission is completely secure, but we review safeguards as the service develops.

Changes

We may update this policy as Lepo develops, including when app functionality or service providers change. We will post the updated version here and revise the date above. Material changes will be communicated where required.

Contact

Contact Lepo Labs at privacy@lepo.health with questions or requests.