Privacy

Privacy Policy

Last updated: [EFFECTIVE DATE — TBD]

Draft — pending legal review. This document is not yet in force and is not the authoritative lawful-basis document until it has been reviewed and signed off. Bracketed items are placeholders to be completed before publish.

Who we are

vitls is a personal health-tracking app. This policy explains what personal data vitls collects, why, how long we keep it, who processes it, and the rights you have over it.

The data controller is [CONTROLLER LEGAL ENTITY / TRADING NAME — TBD] ("vitls", "we", "us"). Reach us about anything in this policy at help@vitls.app.

Because vitls processes health data — a special category under the GDPR (Article 9) — we hold it to a higher standard and rely on your explicit consent as the lawful basis.

The data we collect

1. Health and wellbeing data you enter (special category — GDPR Art. 9)

Food and nutrition, training and sets, body weight, sleep, resting heart rate and HRV, and subjective check-ins including alcohol, mood, drive, and free-text notes. This is the core of the service and the most sensitive data we hold.

2. Account and security data

Your account and contact details, authentication sessions, password-reset records, and — if you enable it — two-factor authentication (TOTP) data. We also keep the email-based verification records our authentication system uses to confirm your address.

3. Security and abuse-prevention metadata

To protect accounts, our sign-in and sign-up endpoints record a short-lived rate-limit entry keyed on the requesting IP address. This is personal data derived from your network connection; its retention is described under How long we keep data.

4. A pseudonymised erasure record

When an account is deleted, we keep a pseudonymised security record — held outside our main database — noting that an erasure happened, so that if a security incident is discovered later we can still report the categories and number of people affected, as the law requires. This record contains no email address and no free text — only a salted, one-way digest and event counts.

What we do not collect on this website. This website sets no cookies, runs no analytics, and loads no third-party scripts, fonts, or tracking pixels. Visiting these pages does not profile you and does not require a cookie banner.

Lawful basis

We rely on your explicit consent (GDPR Art. 9(2)(a)) to process your special-category health data, captured when you sign up. You can withdraw consent at any time by deleting your account; withdrawal does not affect processing carried out before you withdrew.

How your data is used

  • To provide the app: storing and showing your logs, trends, and check-ins.
  • To secure your account: authentication, optional 2FA, and abuse/rate-limit protection.
  • AI analysis you initiate: if you ask vitls's assistant to analyse your data, the results for that request are sent to Anthropic (our AI sub-processor) to generate the response. This happens only when you invoke it — never automatic, never in bulk, and scoped to your own data.

We do not sell your data, and we do not use it for advertising.

Who processes your data (sub-processors)

  • DigitalOcean — hosting and encrypted backups. Your data is stored and backed up in DigitalOcean's SYD1 region (Sydney, Australia).
  • Anthropic — only when you invoke AI analysis, and only for that request.

Data residency. Your data is currently stored solely in Sydney, Australia (DigitalOcean SYD1). If we ever store data in additional regions, we will update this policy first.

How long we keep data

  • While your account is active, we keep your data so the app works.
  • When you delete your account, we hard-delete your records from the live database immediately.
  • Residual copies in our encrypted backups are removed on our backup schedule: erasure completes within 30 days.
  • Security / rate-limit metadata has its own short lifecycle: cleared from the live database typically within about a minute of your last request, with a periodic sweep guaranteeing removal within roughly a day, and any backup copy following the same 30-day backup lifecycle.

Your rights

Subject to applicable law, you can ask us to:

  • Access the data we hold about you.
  • Delete your account and data. Account deletion is available today — from within the app (Apple also requires an in-app deletion path). Deletion triggers the erasure schedule above.
  • Correct (rectify) inaccurate data, and export a machine-readable copy. At this stage these are handled by request — email help@vitls.app and we will action them. (A self-service export is planned but not yet available; we will not pretend otherwise.)
  • Withdraw consent (by deleting your account).

You also have the right to complain to a data-protection supervisory authority [RELEVANT SUPERVISORY AUTHORITY — TBD by jurisdiction]. To exercise any right, contact help@vitls.app.

Security

We protect your data with encryption in transit (TLS) and encrypted backups, per-user data isolation, least-privilege access, and optional two-factor authentication. No system is perfectly secure, but security is a first-order concern for us. If a personal-data breach ever occurs, we will notify the relevant authority and affected users as required by law (within 72 hours where the GDPR applies).

Children

vitls is not directed to children. [MINIMUM AGE — TBD, e.g. 16/18 per jurisdiction] — a human must confirm the age threshold and any parental-consent handling before publish.

Changes to this policy

We will post any changes here and update the "Last updated" date. Material changes affecting how we use your health data will be brought to your attention.

Contact

Questions or requests: help@vitls.app.