Livewell Privacy Policy

Last updated: 5 June 2026

This Privacy Policy applies to all services provided by Livewell, including the Livewell Nutrico+ mobile application (nutrition, calorie, and weight tracking) and the Livewell XP mobile application (step challenges and physical activity tracking), collectively referred to as the "Services".

By installing our mobile applications or in any way using or accessing our Services, you accept the terms and conditions of this Privacy Policy and the processing of your personal data.

Personal data controller

Responsible for the processing of your personal data is:

COMPANY NAME
PT. LIVEWELL INDONESIA SEHAT

ADDRESS
GEDUNG MASINDO, JL. MAMPANG PRPT. RAYA NO.73A
KOTA ADM. JAKARTA SELATAN, JAKARTA

E-MAIL
[email protected]

About our Services

Livewell Nutrico+ helps users record what they eat, track calorie intake and macronutrients, set weight loss or weight gain goals, and monitor their health and nutrition progress.

Livewell XP helps users participate in step challenges, track daily physical activity, earn rewards/XP, and engage with other participants through leaderboards and group challenges.

Some sections of this Privacy Policy apply only to one of the Services. Where this is the case, it is clearly indicated.

Information about personal data we collect

When you register for any of Livewell's Services, we collect personal data from you such as: your email address, first and last name, height, weight, date of birth, gender, and country of residence.

As you continue using the Services, you regularly upload additional personal data onto your account. The specific data depends on which Service you use:

Common to all Services:

Device identifier, IP address, and device information used to register and log in
App usage data (screens viewed, buttons pressed, features used)

When using Livewell Nutrico+:

Calorie intake and food/meal logs
Photos of meals or food items captured via your device camera (only if you choose to log meals with photos)
Weight loss/gain goals and weight history
Diet and nutrition routines
Body measurements and BMI

When using Livewell XP:

Daily step count and step history
Distance traveled, pace, and active minutes
Calories burned (estimated)
Location data — foreground and background (see dedicated section below)
Challenge participation, XP points, levels, badges, and achievements
Leaderboard rank and challenge group memberships
Digital voucher/reward codes earned from challenges (where applicable)
Device sensor data (accelerometer, gyroscope, pedometer)

In an ongoing effort to improve our Services, additional personal data may be collected from you. In such cases, we will notify you when the personal data collection takes place.

Location data — foreground and background tracking (Livewell XP only)

This section is important and applies only to users of Livewell XP. Please read it carefully.

Livewell XP requires access to your device's location services in order to deliver the core features of the Service. We collect precise location data in two modes:

Foreground location access — When you have the app open or are actively participating in a tracked walk, run, or challenge session, we collect your precise GPS location to:

Measure the actual distance you have walked or run
Map the route of your activity
Display your activity on maps and route summaries within the app

Background location access — With your explicit permission, Livewell XP also collects your location data when the app is not open or running in the foreground. Background location is used to:

Continuously track step-based challenges that run throughout the day without requiring you to keep the app open
Accurately count steps and distance during walks/runs when your phone screen is locked or you are using another app
Maintain the integrity of multi-hour or all-day step challenges
Provide accurate leaderboard rankings that depend on continuous activity tracking

Your control over location access:

You will be asked to grant location permission the first time you use a feature that requires it. You can grant "While Using the App" permission only, or "Always" permission (which enables background tracking).
You can change or revoke location permission at any time through your device's system settings (Settings → Apps → Livewell XP → Permissions on Android; Settings → Privacy → Location Services on iOS).
If you revoke background location access, you can still use the app, but step challenges that run while the app is closed may produce inaccurate or incomplete results.
If you revoke all location access, certain features (route mapping and distance measurement) will not function.

We do not sell your location data. Location data is processed only for the purposes described in this Privacy Policy and is not transferred to third parties for advertising or any unrelated commercial purpose.

Camera and photo access (Livewell Nutrico+ only)

Livewell Nutrico+ may request access to your device's camera and/or photo library so that you can take photos of meals or food items as part of logging your nutrition. This access is used solely for the following purposes:

Capturing or selecting photos of food/meals that you attach to your meal log entries
Storing those photos in association with the corresponding meal log entry in your account

The camera is only activated when you explicitly choose to take a photo within the app. Livewell does not access your camera or photo library in the background.

Your control:

You will be asked to grant camera and/or photo permission the first time you use a feature that requires it.
You can revoke camera/photo access at any time through your device's system settings.
If you revoke camera/photo access, you can still use Livewell Nutrico+ to log meals using text entries, but photo-based meal logging will not be available.

You can delete individual meal photos at any time through the app. Deleting a meal photo removes it from our servers.

Rewards and digital vouchers (Livewell XP)

Livewell XP may offer rewards for completing challenges in the form of digital voucher codes. When you earn a reward:

The voucher code is delivered to you within the app and/or sent to the email address registered to your Livewell account.
We may store a record of which rewards you have earned and redeemed in order to operate the rewards program, prevent duplicate claims, and respond to support requests.
No additional personal data (such as physical shipping address or phone number) is collected to deliver digital vouchers.
Where a voucher is redeemed with a third-party merchant, your interaction with that merchant is governed by the merchant's own terms and privacy policy. Livewell does not share your account information with merchants beyond what is necessary to issue and validate the voucher code.

Our use of your personal data

Your privacy is important to us and we will only process your personal data in accordance with this Privacy Policy and relevant personal data regulation.

Use of Third-Party Services

In providing our Services, we may use third-party services to enhance your experience, including Google APIs. We handle all data received from Google APIs in full compliance with Google's API Services User Data Policy. Livewell's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

For Livewell Nutrico+: If you connect to the Service using a Third-Party Application (e.g., Apple HealthKit, Facebook), Livewell will collect and use your personal information from such Third-Party Applications such as your username, name, profile picture, country, hometown, email address, date of birth, gender, as well as such health data that you choose to synchronize with Livewell's Services.

For Livewell XP: Livewell XP does not currently integrate with external health platforms. If such integrations are added in the future, this Privacy Policy will be updated and you will be notified accordingly.

We also use third-party services for map tile rendering (Livewell XP), analytics, and crash reporting.

By using our Services, you consent to the terms of service and privacy policies of these third parties where applicable.

Data processing necessary to provide the Services

As part of offering the Services to you, we process the personal data you provide at the time of registration:

First and last name
E-mail
Date of birth
Country of residence
Weight
Height
Device identifier, i.e. information on what device, IP address etc. you use to register and log in to the Services

As you continue to use the Services, you will regularly provide Livewell with further personal data. It follows from the nature of the Services that we must process such data to enable the Services — for example, we will process your weight and calorie intake to enable monitoring and presentation of your personal goals in Livewell Nutrico+, and we will process your step count, location, and activity data to enable challenge participation, leaderboards, and XP/reward calculations in Livewell XP. This processing is a prerequisite for us being able to offer the Services to you.

Some of the data mentioned above can be deleted and we can cease processing it for the future if you so require, without you having to terminate your use of the entire Services. If you want us to cease processing certain data about you, we will inform you about the consequences of such cessation, i.e., how it will affect your use of the features of the Services.

Social features and leaderboards (Livewell XP only)

Livewell XP includes social and competitive features such as public leaderboards, group challenges, and friend connections. When you participate in these features:

Your display name and challenge-related stats (e.g., total steps in a challenge, current rank) may be visible to other participants in the same challenge.
Your precise location is never shared with other users.
You can adjust visibility settings in the app to limit what other users see.

No sharing with employers, sponsors, or third-party organizations. Even where a challenge is associated with a sponsor, partner, or group, Livewell does not share your individual personal data (including your identity, step counts, location, or activity history) with that sponsor or organization. Any reports provided to sponsors or partners are limited to aggregated, anonymized statistics that cannot be used to identify individual participants.

Customer relationship as a legal ground

Marketing sent by Livewell to you on the basis of a customer relationship as a legal ground for processing personal data does not require consent. Such data will be processed and used in compliance with relevant personal data regulation.

Profiling

Livewell's Services are based on profound knowledge of best practices with regard to health and fitness. Livewell cooperates with nutritionists, behavioral psychologists, personal trainers, sports scientists, and stress experts to stay on top of the latest research and science. In addition, Livewell analyzes the usage of the Services in order to provide you with the most relevant features possible with regard to your personal goals.

In analyzing the usage of the Services, Livewell will process certain data for so-called profiling. Profiling means processing of your and other users' personal data to analyze or predict aspects of your use of the Services, behavior, activity patterns, and progress in reaching your health or fitness goals. The data processed will include user habits — actions you take such as moving between screens, pressing buttons, logging meals, joining challenges, and your activity patterns over time.

The purposes of the profiling are to monitor how engaged users are in different features of our Services, find ways to make the Service more effective, and vary the features or content to better match your individual usage patterns and preferences.

The profiling of your data may also be used as the basis for marketing toward new potential customers on other platforms than the Livewell Services, such as other social media platforms. Please note that this so-called look-alike process of recruiting new customers does not mean that you will receive any marketing, nor that any third parties will gain access to your data for any other purpose than for Livewell to reach new customers — third-party providers (for example social media) will only process your data on behalf of Livewell as processors.

Livewell's processing of your personal data for profiling purposes as described above does not require consent as a legal ground. If consent is required under relevant personal data regulation, you hereby give your consent to Livewell using your personal data as defined above for profiling, for the purpose of improving the Services and providing customer support.

Marketing — legitimate interest

Livewell may use your personal data for profiling and marketing purposes via emails, notifications, or other messages, by Livewell or Livewell's selected business partners. Profiling will be used for marketing purposes to enable personalized and relevant offers to you, based on your preferences (see Profiling above).

The use of personal data for marketing purposes will only concern offers that have a close relation to your use of the Services, and offers will be sent to you by Livewell; no personal data will be transferred to third parties for marketing purposes. This processing is based on a legitimate interest.

Opt-out from marketing

In case you do not want Livewell to use your personal data for marketing purposes, you may at any time unsubscribe from any further messages by clicking the "unsubscribe" link at the bottom of such a message, or by using the opt-out features available in the app settings.

Cookies

Livewell uses cookies on its websites in order to function properly. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them).

If your internet browser is set and configured to accept cookies, you consent to the use of cookies.

A cookie is a small text file which is created by the websites you visit and may contain information about you as a visitor. Information from cookies may be used to improve the user experience and/or the Services and to target marketing campaigns and offers to our customers.

If you do not accept cookies, you can prevent cookies from being saved on your computer by changing the settings of your web browser. If you choose not to accept cookies, you can still use our Services, but their functionality may be somewhat limited.

Access, rectification and erasure of personal data

You have the right to request access to and rectification or erasure of your personal data processed by Livewell. If you wish to exercise these rights, please contact us at https://livewellindo.com/hubungi-kami. Alternatively, you can also erase your personal data by deleting your account via the Services.

If a request for erasure concerns data that is necessary for Livewell to offer the Services, such requests will have the effect that your account will be terminated.

Retention and storage of your personal data

Except where you delete your account, request rectification or erasure for the relevant personal data, or opt out from processing relating to marketing, we generally store and process your personal data for as long as you are a registered user of our Services and have a user account. We will cease storing and processing your personal data if your user account/registration is terminated, if you request rectification or erasure, or opt out from marketing, unless it is necessary for us under the applicable purposes to store or process the relevant personal data for a longer time (e.g. for book-keeping purposes).

Location data collected through Livewell XP is retained for the duration of active challenges and your account's activity history. You may delete individual activity sessions (including their location/route data) at any time through the app.

Additionally, we periodically review the need to store or delete your personal data if your account has been inactive, which usually occurs after a period of five (5) years of persistent inactivity on the Services.

Transfer of data

Personal data collected from you may be shared with third-party providers of Livewell that process personal data on behalf of Livewell, such as server hosting providers, data storage providers, companies carrying out system and sales performance monitoring, customer support systems, map providers, and payment service providers. These service providers will be considered processors of your personal data.

At times, some of your personal data may be transferred and processed by processors established in the United States or other countries (some of which will be outside the EEA). We may also transfer your personal data in the event that our business (or part of it) is sold, for instance as part of a merger or acquisition. Livewell will always apply safeguards to protect your personal data from unauthorized disclosure. In case of transfer of data to third parties that are outside of the EU or EEA and that do not offer an adequate level of data protection, Livewell will apply the EU Commission's model clauses and/or binding corporate rules, or similar instruments/mechanisms.

In no event does Livewell transfer personal data to third parties with the right for such parties to use the data other than on behalf of Livewell.

Livewell may further disclose your personal data in order to comply with a legal or regulatory obligation, if we reasonably believe that this is required by law, regulation, or other legislation, or in order to protect and defend Livewell, our business partners, or users' rights and interests, subject always to relevant applicable personal data regulation.

Portability

You have the right to receive your personal data which you have provided to Livewell, in accordance with relevant personal data regulation, provided that such request does not adversely affect the rights and freedoms of others.

Complaints

If you have any questions or complaints about our processing of your personal data, you are welcome to contact us at https://livewellindo.com/hubungi-kami. You also have the right to lodge a complaint with a supervisory authority.

Security of the personal data we process

The security and integrity of your personal data are important to us. In addition to complying with applicable relevant personal data regulation, we use accepted industry standards, technologies, and procedures, such as firewalls, security software, and encryption in transit, in order to protect the integrity of your personal data and to prevent any unauthorized access. However, no system can be 100% secure, and despite our efforts, there is always a risk of unauthorized access to your personal data. By using our Services, you assume this risk. We urge you to use a unique and strong password for your Livewell user account and to protect such password. You should further limit access to your computer and browser and log out after having used the Services.

Children

If you are under age 13, you are not allowed to submit any personal data through our Services. We encourage parents and legal guardians to monitor their children's Internet use and to help us enforce our Privacy Policy by instructing their children to never provide any personal data through our Services without their permission. If you become aware that a child under the age of 13 has submitted personal data to us, please contact us at https://livewellindo.com/hubungi-kami.

Changes to our Privacy Policy

From time to time, it may become necessary to make changes to this Privacy Policy. Therefore, we reserve the right to update and/or modify this Privacy Policy at any time by giving notice to you. Please review this Privacy Policy frequently, and especially before you register an account with us. The date of the last modification is listed at the top of this Privacy Policy.

Contact

We will communicate with you by email and notices posted on your mobile device. If you do not wish to receive notices on your mobile device, you can always turn off this service. If you unsubscribe from our mailing list, you will still receive answers to your questions sent to our support but you will not receive promotional emails.

We welcome your feedback regarding our Services. If you have any questions or suggestions regarding our Privacy Policy, please contact us at https://livewellindo.com/hubungi-kami.