How Amiko handles your personal data.

Scope

This policy explains how Amiko Srl handles personal data for the Respiro app and compatible connected inhaler sensors, including accounts managed by an authorised family caregiver. Amiko is responsible for this processing as the controller.

It also covers a provider’s or caregiver’s own Respiro Hub account: their name, email, login details and access records. Patient data handled for a healthcare organisation or study is governed by that organisation’s privacy notice and its agreement with Amiko. Where Amiko acts on its instructions, Amiko is a processor.

Please do not send health information through the website contact form.

Who we are

Amiko Srl, Via Ruggiero Settimo 4, 20146 Milan, Italy, VAT/P.IVA IT08963920965, is the controller described above. Privacy requests and our Data Protection Officer can be reached at privacy@amiko.io.

A healthcare organisation you choose to share data with is an independent controller of the data it receives. Its privacy notice explains its use of that data.

Data we handle

Depending on how you use Respiro, we handle:

• Account and profile: name, email, date of birth, country, sex assigned at birth and device time zone.
• Health profile and treatment: respiratory conditions, medicines and inhalers, strengths and device formats, schedules, reminders and notes.
• Medication and technique records: scheduled, manual and sensor-recorded doses, taken or missed times, and supported sensor measurements and technique results. Measurements may include peak inspiratory flow, inhalation duration, inhaled volume, orientation, actuation coordination and shaking, depending on the setup.
• Symptoms and check-ins: symptoms, severity, mood and notes; optional reliever-use context such as triggers or preventive use.
• Location and environmental information: the location used for your outlook and, with location permission, the approximate or precise location of relief events, including indoor/outdoor information; weather, air quality and pollen for the relevant place.
• Devices and service use: sensor identifiers, pairing and sync status, signal, battery and firmware; app-usage and diagnostic information.
• Consent records: the terms and consents you accept.

Health information receives additional protection under data-protection law. We do not use it for advertising, and we do not sell your personal data.

Where data comes from

Data comes from information you enter, connected sensors and, for accounts managed on someone’s behalf, the authorised caregiver or provider. Respiro also calculates summaries, technique information and the breathing outlook.

External services provide environmental information, maps, notifications, analytics and diagnostics as listed below. We do not send inhaler-use, symptom or other health-record content to app-usage analytics, diagnostic, map or forecast services. Those services receive the limited request or technical data needed for their functions.

Bluetooth, location and permissions

Respiro asks for device permissions when needed. Bluetooth, and related nearby-device permissions on some phones, are needed to find and sync a sensor. Declining a permission prevents the related feature from working.

With location access, Respiro can attach a location to a relief event and provide local environmental information. You can change the outlook location in Settings or choose a city manually, and turn device location access off. Location attached to relief events and environmental records is kept with those records, as explained under Retention and deletion.

Care providers can see shared relief events but not their location.

Health-data consent

At sign-up, we ask for your explicit consent to process health data, alongside acceptance of the Terms and this policy. We rely on Article 9(2)(a) GDPR for this processing. The consent covers the uses described here, including de-identified or pseudonymised data used to improve and develop Respiro. Pseudonymised data remains personal data.

You can withdraw consent through the request option in Settings or at privacy@amiko.io. Because the service depends on health data, withdrawing this consent closes your account. You can request a copy of your data first. Withdrawal does not affect the lawfulness of earlier processing; Retention and deletion explains what happens next.

Purposes and legal bases

• Providing Respiro: operating accounts, syncing sensors, recording medication use and check-ins, showing technique information and records. Basis: our contract with you; explicit consent for health data.
• Breathing outlook and reminders: the features you enable, as described below. Basis: consent, including explicit consent for health data.
• Improvement and development: using de-identified or pseudonymised activity data to improve Respiro, develop features, evaluate device performance and support R&D, with appropriate safeguards. Basis: legitimate interests in improving the service; explicit consent for health data as described above.
• Aggregate analytics: creating fully anonymised, aggregated statistics and reports that we may share, license or sell to healthcare organisations, researchers and life-sciences companies. Basis: consent, including explicit consent for health data used to create them.
• Product information: limited in-app prompts and links. Basis: legitimate interests. Any future marketing emails require your consent and will include an opt-out.
• Security and obligations: troubleshooting, security, legal and medical-device duties, and legal claims. Basis: legitimate interests and applicable legal obligations.

Breathing outlook

The outlook describes local conditions for breathing over approximately the next 12 hours, shown as Calm, Mixed or Rough. Without a compatible sensor, it uses local weather, air quality and pollen information, together with your pollen preferences. With a compatible sensor, it can also use your respiratory condition and sensor-recorded reliever use to adjust environmental factors using fixed rules. Manual dose entries, including reliever use, and symptom check-ins do not feed the calculation.

The calculation runs on our servers using those inputs and your forecast location. A change in level does not trigger an alert; an optional routine morning note is separate.

This analysis is profiling, but it makes no decision with legal or similarly significant effects: it does not automatically change your care or account. It does not assess condition control or predict an attack. Symptoms can occur at any level. Do not use it to adjust treatment or delay seeking medical help.

Sharing and service providers

Healthcare programmes and clinicians

You choose whether to connect to a programme or clinician. Before connection, we show the sharing scope: up to the last 12 months of your Respiro history, plus ongoing data. This can include profile details, medication use, adherence, symptoms and mood. The history window is fixed.

You can stop future sharing at any time. The organisation may retain data already received in its own records under its privacy notice and applicable law. The sharing window is separate from how long Amiko keeps your account data.

Service providers

We use the following services. Processors act on our instructions under contract; map and environmental services also operate under their own service terms.

Other sharing

Clinical studies have their own privacy information, participation documents and applicable legal bases. Programme sponsors receive only anonymised, aggregated reporting; identifiable study data follows the separate study arrangements.

We may disclose data to meet legal requirements or medical-device safety duties. If Amiko is involved in a merger, acquisition or asset sale, any transfer must protect your data under applicable law. We will require the recipient to honour this policy, or tell you what will change and explain your choices.

International transfers

Account and health data are stored in AWS’s Ireland region. Some service providers process limited technical, location or contact data outside the EU, including push tokens, diagnostics, forecast or map requests, and email details.

Where required, transfers use recognised safeguards, such as the European Commission’s Standard Contractual Clauses or the EU–US Data Privacy Framework where applicable. You can request details and copies of the safeguards at privacy@amiko.io.

Retention and deletion

We keep account data while your account is active. You can request account deletion or withdraw health-data consent using Settings or privacy@amiko.io. The Settings option opens a pre-filled request; we handle it without undue delay.

After the request is actioned, we keep the data for around 30 days to allow recovery from a mistaken request, then erase the personal data. The same process applies when a provider- or caregiver-managed record is removed through Hub.

Limited records may remain longer:

• Medical-device records: relevant complaints, malfunctions and safety incidents, including necessary technical details, may be kept for 10 years following the end of the device lifecycle, or another period required by law, solely for that purpose.
• Backups: daily backups are retained for around 30–35 days, then overwritten on the normal cycle.
• Diagnostics and logs: Bugfender and backend operational logs for up to 12 months; Firebase analytics for 14 months and crash reports for 90 days.

Children and minors

Respiro asks for date of birth and country during account setup. Minors cannot register independently: an authorised parent or caregiver sets up and manages the account through Hub and provides the required consent. Additional local requirements must be met where applicable.

Your rights

Under applicable data-protection law, you can request access, correction, deletion, restriction or a portable, machine-readable copy of your data, and withdraw consent. You can object to processing based on legitimate interests and to direct marketing. Some rights have legal conditions or exceptions.

Use Settings or privacy@amiko.io. We may need to verify your identity. We respond without undue delay, normally within one month; if the law allows extra time, we will explain why within that month. You can edit much of your profile in the app.

For data held by a healthcare organisation, contact that organisation. You can complain directly to the Italian Garante per la protezione dei dati personali, or another competent supervisory authority; you do not need to contact us first.

Security

We protect data with encryption in transit and at rest, role-based access, staff and administrator multi-factor authentication, code review and security checks. An optional app passcode or biometric lock protects access on your device. Authorised support staff access data only when needed to help you or investigate a problem.

If a personal-data breach occurs, we assess it and notify the relevant authority and affected people where required by law.

Changes and contact

We will inform you of material changes to how we handle your data and request renewed consent where required. If you decline renewed consent needed to continue providing Respiro, your account closes and the retention and deletion rules above apply.

For privacy questions or rights requests: privacy@amiko.io, or Amiko Srl, Via Ruggiero Settimo 4, 20146 Milan, Italy.