WellPD — Privacy Notice — European Economic Area
HOW EMPATICA PROCESSES YOUR PERSONAL DATA
Last updated: 20 October 2026
1. Who we are and what this Notice covers
This Privacy Notice (“Notice”) explains how Empatica processes personal data — including health data — of people who purchase and use WellPD: the Embrace Mini wearable, the WellPD mobile application (“App”), the User Portal and the Subscription Service (together, the “Services”).
Empatica is the data controller for all processing described in this Notice: we decide why and how your personal data are processed, and we are responsible for that processing. Your controller is Empatica S.r.l., Via Stendhal 36, 20144 Milan, Italy, the entity you contract with under the WellPD Terms and Conditions (“Empatica”, “we”, “us”). Other companies of the Empatica group process your data on our behalf, as described in section 6.
This Notice should be read together with the WellPD Terms and Conditions and the Instructions for Use. It does not cover data processed by your healthcare professionals: WellPD is a product you buy and use yourself; no healthcare professional receives your data through WellPD unless you export a report and share it yourself (section 6(d)).
Where used in this Notice, “you” means the person who holds a WellPD account and wears the Embrace Mini.
2. Personal data we process
Identity and contact data — name, date of birth (used, together with the Wearable’s serial number, to sign you in to the App, and to verify that you are at least 18), gender, postal and email address, phone number, the e-mail address and password you use for the User Portal, language and country of residence.
Health-related data — physiological signals recorded by your Wearable (for example movement data from its accelerometer; the signals depend on the Wearable model), wearing time, Parkinson’s-related measures computed from them (tremor, bradykinesia and dyskinesia scores), sleep and activity measures (including non-wear or “no data” time), the medication plan you enter in the App (medication names, doses and schedule) and your medication log (taken, skipped, as-needed), the WellMove motor measure and the daily PD insights narrative generated from your recordings, monitoring time, and symptoms and notes you record. Health-related data are “special category” data under the GDPR and receive additional protection.
Insights — summaries, trends and interpretations generated from your Wearable data and App entries, some of them automatically by artificial intelligence (section 5).
Order, payment and subscription data — orders, shipping details, subscription status, payment method reference and transaction records (card details are collected and stored by our payment service provider, Stripe, not by Empatica — section 6(b)).
Device and technical data — Embrace Mini serial number, firmware and App version, phone model and operating system, IP address, identifiers, Bluetooth and connectivity status, battery, crash and diagnostic logs, timestamps, App usage events.
Usage and analytics data — which screens you open and which features you use in the App and the User Portal, and pairing/onboarding events, recorded with a pseudonymous identifier.
Support and communications data — your requests to customer support, adverse-event reports, survey answers, feedback and other User Submissions, and our records of communications with you.
Marketing data — your consent choices, subscription status to newsletters and interaction with our messages.
We do not process data of children: WellPD is intended for adults aged 18 and over (section 9).
3. Where the data come from
Mostly from you and your use of the Services: what you enter at purchase and registration, what the Embrace Mini records while you wear it, and what the App and Portal record while you use them. We also receive data from an authorised representative acting for you, from your payment service provider (payment confirmation), and from the app stores (purchase and installation status). If you contact us on social media, we may receive the data those platforms share with us.
4. Why we process your data and on what legal basis
The table lists each purpose, the data used and the legal basis that applies under the GDPR; section 16 adds what national law provides.
Purpose | Data | Legal basis (GDPR) | What happens if you do not provide the data |
|---|---|---|---|
Providing WellPD — selling and shipping the Embrace Mini, creating and managing your account and subscription, pairing the Wearable, recording and displaying your measurements, sleep, activity, medication log and Insights, sending service messages by e-mail, text message, phone call or push notification (for example the reminder we send at least 7 days before your subscription renews) | Identity and contact, order/payment/subscription, device and technical, health-related data, Insights | Performance of the contract with you (art. 6(1)(b)); for health-related data, your explicit consent (art. 9(2)(a)), requested in the App before the Wearable records data | Without the contract data we cannot sell or deliver WellPD; without your consent to health data the Wearable cannot record and the App cannot display measurements |
Customer support — answering your requests, troubleshooting, warranty and returns | Identity and contact, support, device and technical, and — where needed to help you — health-related data | Performance of the contract (art. 6(1)(b)); health data: your explicit consent (art. 9(2)(a)) when you ask us to look at your recordings | We may be unable to resolve your request |
Safety and vigilance — monitoring the performance and safety of the Embrace Mini and the App, investigating incidents, handling adverse-event reports, corrective actions, reporting to authorities | Health-related, device and technical, support data, adverse-event records | Compliance with medical-device legal obligations (art. 6(1)(c)); health data: art. 9(2)(i) (public interest in the area of public health — safety and quality of medical devices) | Mandatory — we cannot exempt you |
Regulatory and quality management — records required by medical-device law and our quality management system, audits and inspections | Device usage, calibration and validation records, health-related data where the record requires it | Legal obligation (art. 6(1)(c)); art. 9(2)(i) | Mandatory |
Security — protecting our systems, detecting and preventing fraud and security incidents, logging access | Device and technical, account and usage data | Our legitimate interest in keeping the Services and your data secure (art. 6(1)(f)) | Mandatory for the operation of the Services |
Improving WellPD and research — analytics and research on pseudonymised data to evaluate and improve the algorithms, develop new features and digital biomarkers, and support future regulatory and clinical submissions | Health-related, device and usage data in pseudonymised or aggregated form; demographic data | Your consent (art. 6(1)(a)), and for health data your explicit consent (art. 9(2)(a)) — requested separately in the App | Optional — you can refuse or withdraw at any time; WellPD works the same |
Marketing — news about Empatica products and services, surveys, educational content, by email or in-app | Identity and contact, marketing preferences, interaction data | Your consent (art. 6(1)(a)) | Optional |
Legal claims — establishing, exercising or defending legal claims | Whatever data the dispute concerns | Our legitimate interest (art. 6(1)(f)); health data: art. 9(2)(f) | — |
Corporate transactions — assessing and carrying out mergers, acquisitions, financing or sale of assets | Whatever data the transaction concerns | Our legitimate interest (art. 6(1)(f)); health data related to an identified or identifiable individual will not be shared | — |
Accounting and tax — invoices, payments, statutory records | Identity, order and payment data | Legal obligation (art. 6(1)(c)) | Mandatory |
Consent. Where the table says we rely on your consent, we ask for it separately in the App or on the website, with a clear description of what you are agreeing to. Accepting the Terms and Conditions is not consent. You can withdraw consent at any time in the App settings or by writing to privacy@empatica.com; withdrawal does not affect processing carried out before it. If you withdraw consent to the processing of health data for providing WellPD, the Wearable stops recording and the App stops displaying measurements; you may keep your account and export your data (section 7).
Legitimate interests. Where we rely on our legitimate interests, we have assessed that the processing is necessary and that our interest is not overridden by your interests, rights and freedoms. You can ask for a summary of that assessment and you can object (section 7).
5. Insights, artificial intelligence and automated processing
Some Insights are generated automatically, without human review, by algorithms — including artificial-intelligence models — that analyse the data recorded by your Wearable and the entries you make in the App. The App labels AI-generated Insights as such. Insights are for your information: they are not medical advice, and no decision producing legal or similarly significant effects on you is taken by automated means (GDPR art. 22). The PD insights narrative is produced on our servers by a language model from a summary of your recordings for the period; the model runs within our cloud infrastructure (Amazon Web Services), which acts as our processor and does not use your data for its own purposes or to train its models. Generated insights are stored with your account so that they stay the same each time you open them. Empatica does not use your data to train models that could identify you; models are trained on pseudonymised or aggregated data, and only from users who have consented to research and improvement (section 4).
6. Who receives your data
We disclose personal data only to the extent necessary for the purposes in section 4.
(a) Empatica group. Empatica S.r.l. (Italy) operates the WellPD platform; Empatica, Inc. (United States) provides hosting operations, technical support and customer success; Global Kinetics UK Corporation Limited (United Kingdom) provides support and account administration for UK users; Empatica Care, Inc. (United States) sells WellPD in the United States. Your controller is Empatica S.r.l.; the other group entities act as its processors, under the intercompany data-processing agreement that binds them.
(b) Service providers (processors) acting on our documented instructions: cloud hosting and storage; identity and access management; infrastructure monitoring and logging; customer-support ticketing; SMS, email and push-notification delivery; payment processing (Stripe Payments Europe, Limited, Ireland, which processes payment data in the United States under the EU–U.S. Data Privacy Framework, with the European Commission’s Standard Contractual Clauses as a fallback; Stripe also acts as an independent controller, through Stripe Technology Company, Limited, Ireland, for its own legal obligations, such as fraud prevention and anti-money-laundering checks, under its own privacy notice); shipping and logistics; tax calculation; surveys; AI infrastructure (within our cloud provider); audit and certification. Our current list of service providers, with their location, is published at https://www.empatica.com/wellpd/privacy-policy/sub-processors and updated when it changes; you can also ask us for it.
(c) Authorities and regulators — medical-device competent authorities (for example for vigilance reporting), supervisory authorities, courts and law enforcement, where the law requires or permits it, limited to what is necessary.
(d) People you choose to share with. You can export a report from the App or the User Portal and share it with your healthcare professional or anyone else you choose. We do not send it on your behalf; once you have shared it, the recipient is responsible for how it is used.
(e) Professional advisers and successors — auditors, lawyers and, in a corporate transaction, the acquiring or successor entity, under confidentiality and with equivalent safeguards.
We do not sell your personal data and we do not share it with third parties for their own marketing.
7. Your rights and how to exercise them
Depending on the law that applies to you (section 16), you have the right to: access your personal data and obtain a copy; rectify inaccurate data; erase your data (we may have to keep data that medical-device or other law requires us to retain — we will tell you); restrict processing in the cases the law provides; port the data you provided to us, in a machine-readable format, where processing is based on consent or contract and carried out by automated means — the App and the User Portal include an export function; object to processing based on legitimate interests and, at any time, to direct marketing; withdraw consent at any time; not be subject to a solely automated decision with legal or similarly significant effects; obtain information about international transfers and a copy of the safeguards; and lodge a complaint with the supervisory authority identified in section 16.
Write to privacy@empatica.com or use the in-App privacy settings. We may ask you to verify your identity. We respond within the time the applicable law sets (one month, extendable by two further months in complex cases) and free of charge, unless a request is manifestly unfounded or excessive. An authorised representative may exercise rights on your behalf with your written authorisation.
Data Protection Officer. Empatica S.r.l. has appointed a Data Protection Officer (42 Law Firm S.r.l.), who can be contacted at privacy@empatica.com or at the postal address in section 15.
8. How long we keep your data
Data / purpose | Retention |
|---|---|
Account, contract and subscription data; measurements, medication log and Insights | For the duration of the contract and for 10 years thereafter (the limitation period for contractual liability), unless a longer period is required by litigation, requests of competent authorities or applicable law. You may ask for earlier erasure (section 7); we then delete what no legal obligation requires us to keep |
Safety, vigilance and quality-management records (including the pseudonymised device data those records require) | For the period medical-device law prescribes — up to 25 years after pseudonymisation |
Research and improvement (with your consent) | Pseudonymised data up to 25 years after pseudonymisation, unless you withdraw consent earlier; anonymised data indefinitely |
Marketing | Until you withdraw consent or object and, in any event, no longer than 24 months after your last interaction with our communications |
Security logs | 7 days to 1 year depending on the log, unless needed to investigate an incident |
Support records and adverse-event reports | Support: 3 years after closure; adverse-event reports: as vigilance records above |
Legal claims | Until the applicable limitation period expires |
After the retention period we securely delete or irreversibly anonymise the data in accordance with our data-retention procedures.
9. Children
WellPD is intended for adults aged 18 and over and is not intended for children. We do not knowingly process children’s personal data; if we learn that we have, we delete it.
10. International transfers
Empatica S.r.l. is established in Italy; Empatica, Inc. and Empatica Care, Inc. in the United States; Global Kinetics UK Corporation Limited in the United Kingdom. Our service providers operate in the European Economic Area, the United States and other countries. Your data are stored in the EEA (AWS, Ireland).
Where your personal data are transferred outside the EEA, we use the European Commission’s Standard Contractual Clauses (Decision 2021/914) with transfer impact assessments, or an adequacy decision. Empatica maintains executed Standard Contractual Clauses with Empatica, Inc. at all times. You can ask us for a copy of the safeguards (section 7).
11. Security
We apply technical and organisational measures appropriate to the sensitivity of health data, under an information-security management system certified to ISO/IEC 27001: encryption in transit and at rest, pseudonymisation of research data, access control and multi-factor authentication, logging and monitoring, secure development, backups and business continuity, staff training and confidentiality obligations, and contractual security obligations on our service providers. No system is perfectly secure; keep your Wearable, your phone and your User Portal password secure — anyone who holds your Wearable and knows your date of birth can sign in to the App — and tell us at once if your Wearable is lost or stolen or if you suspect misuse of your account.
12. Cookies and tracking
The App and the User Portal use only the technical cookies and identifiers necessary to operate them and, with your consent, analytics. Our websites use cookies, including Google Analytics for marketing, as described in the Empatica Cookie Notice at https://www.empatica.com/legal/cookie_policy.
13. Third-party links
The Services may contain links to third-party websites or apps. Their privacy practices are governed by their own notices; we are not responsible for them.
14. Changes to this Notice
We may update this Notice to reflect changes in the law or in the Services. We post updates in the App and on our website and update the “Last updated” date; for material changes we notify you in advance by email or in the App and, where the law requires it, ask for your consent again.
15. Contact
privacy@empatica.com — Empatica S.r.l., Via Stendhal 36, 20144 Milan, Italy (attention: Data Protection Officer).
16. Information for users in the European Economic Area
Controller: Empatica S.r.l., Via Stendhal 36, 20144 Milan, Italy (VAT IT07462810966). Law: Regulation (EU) 2016/679 (GDPR) and national data protection laws. Supervisory authority: the authority of the Member State of your habitual residence, place of work or place of the alleged infringement (list at edpb.europa.eu/about-edpb/about-edpb/members_en); for Empatica S.r.l., the lead authority is the Italian Garante per la protezione dei dati personali. Transfers: section 10 (SCCs / adequacy). Language: this Notice is available in Danish, Dutch, English, Finnish, French, German, Italian, Norwegian, Spanish and Swedish, on the page for your country listed in the Terms and Conditions (definition of "Privacy Notice"). National provisions. In France, you may give us instructions on what should happen to your data after your death (article 85 of the Loi Informatique et Libertés). In Italy, after a person's death, their rights may be exercised by anyone with an interest of their own, acting on their behalf or for family reasons, unless the person prohibited it (article 2-terdecies of the Codice in materia di protezione dei dati personali). In Spain, heirs and persons linked to the deceased may ask for access to, rectification or erasure of the deceased's data, unless the deceased prohibited it (article 3 of the Ley Orgánica 3/2018).