01
Who is responsible for your data?
It is important to distinguish two roles.
Your healthcare provider is responsible for your health data
Lofte is used by healthcare providers (such as physiotherapists, psychologists and speech therapists) to assign exercises and homework tasks to their clients. For the health-related data this creates — such as your assigned tasks and your progress — your healthcare provider or their practice is the data controller. Lofte processes this data solely on the instructions of and on behalf of your healthcare provider, acting as a processor. For questions about this data, your rights or objections, please contact your healthcare provider.
Pixelgilde is responsible for the technical operation of the app
For a limited set of data needed to make the app work technically — such as your device identifier, your push token and the link between your account and a practice — Pixelgilde acts as data controller.
Pixelgilde (sole proprietorship)
Maastricht, The Netherlands
Chamber of Commerce (KvK) number: 42070198
Email: info@lofte.app
02
What data do we process?
We process as little data as possible. Specifically:
Data you provide yourself
- Your name, which you provide when setting up the app.
- Your email address, which is optional and used only to transfer your account to another device (see section 4).
Health-related data (on behalf of your healthcare provider)
- The exercises and homework tasks your healthcare provider assigns to you.
- Whether and when you have completed a task (your progress).
- Personal tasks you may create yourself.
Technical data required for operation
- A device-bound token linking your app to your account, stored in your device's secure storage (iOS Keychain or Android Keystore).
- A push token so we can send you notifications.
- The link between your account and the practice or supporter you are connected to.
We do not collect analytics or crash data, and we do not track you for advertising purposes.
03
Why and on what legal basis?
| Data | Purpose | Legal basis |
|---|---|---|
| Name, tasks, progress | Assigning and tracking your exercises and homework | Processed on behalf of your healthcare provider; the legal basis is determined by your healthcare provider |
| Device and push token | Making the app work technically and sending you notifications | Performance of the service (legitimate interest) |
| Email address | Transferring your account to another device | Your consent (you provide it yourself) |
| Link with a supporter | Giving a supporter access to your progress | Your consent (see section 5) |
04
Your email address and account transfer
You provide your email address voluntarily. It is stored unencrypted only on your own device.
When you want to transfer your account to a new device, the app sends your email address via our server to our email provider (Proton), solely to send you a transfer email. In this process:
- Your email address is not stored unencrypted and not logged on our server.
- On our server we keep only an encrypted (hashed) version of your email address, which we use during account recovery to check whether an entered address matches.
While the email is being sent, your email address passes through our server and our email provider's servers. This is technically necessary to send the message.
05
Supporters
You can link a supporter (for example a parent, carer or family member) to your account. A linked supporter can view and edit your tasks and progress.
This link is established by entering a 6-digit code. The link always takes place with your agreement. You can end a link with a supporter via the app's settings.
06
Who do we share data with?
We never sell your data. We use the following service providers (sub-processors) to operate the app:
- Fly.io — hosting of our servers (with a SOC 2 Type 2 and GDPR data processing agreement).
- Apple (APNs) and Google (FCM) — delivering push notifications to your device.
- Proton — sending the transfer email (see section 4).
We also share data with your healthcare provider and, if you have set this up, with your supporter.
07
How long do we keep your data?
- Your account and the associated technical data are kept for as long as you use the app. After 365 days of inactivity, your device link is cleaned up.
- Your healthcare provider is responsible for the retention period of your health-related data; statutory retention periods for medical records apply.
08
Your rights
You have the right to access, correct and delete your data, and to object to its processing.
- For your health-related data, please contact your healthcare provider, who is responsible for it.
- For the technical data for which Pixelgilde is responsible, you can contact us at info@lofte.app.
You also have the right to lodge a complaint with the Dutch Data Protection Authority or your local supervisory authority.
09
Security
We take appropriate technical and organizational measures to protect your data, including encrypted storage of sensitive identifying data and secure storage of access tokens on your device.
10
Changes
We may update this privacy policy from time to time. The date at the top indicates when it was last updated.
11
Contact
Questions about this privacy policy? Email info@lofte.app.