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Washington My Health My Data Act · Nevada SB 370 · Connecticut CTDPA · Virginia SB 754

Consumer Health Data Privacy Policy

Version
v1.4
Effective
4 November 2026
Binding language
English

1Who this applies to

This policy applies to consumer health data as that term is defined by the Washington My Health My Data Act (MHMD), the Nevada consumer health data law (SB 370) and the health-data provisions of the Connecticut Data Privacy Act. It also covers Virginia’s protection for reproductive and sexual health information.

It applies to you if you are a resident of Washington, Nevada, Connecticut or Virginia, and — because we would rather run one honest process than four — we extend the rights described in section 10 to every user in the United States, whichever state you live in.

Virginia. Virginia law protects reproductive and sexual health information. In Vita, that means your period record and your pregnancy details. We collect them only when you enter them or turn on period sync. Apart from the service providers in section 6.1, which process them for us only to answer you, we never disclose them to anyone without your consent.

This document sits alongside our Privacy Policy and does not replace it. It is published separately because MHMD requires a distinct link, and because health data deserves to be described in its own document rather than buried in section 14 of another one. Where this policy and the Privacy Policy differ on consumer health data, this policy governs.

2What counts as consumer health data

MHMD defines consumer health data extremely broadly: personal information that is linked or reasonably linkable to a consumer and that identifies their past, present or future physical or mental health status. That includes inferences. In practice, for a service like ours, it means:

What you ask
The text or speech of a health question is itself health data. Asking about a symptom reveals that you have it, or fear you do.
What you store
Documents and photos you attach in a chat or keep in the vault — test results, letters, prescriptions, medicine boxes — and the labels you give them.
Who you ask about
The people you add, children included, and their ages, conditions and relationships to you. A parent's data is health data about the parent, not only about you.
What your phone sends
Readings and records from Apple Health or Health Connect that go with a question, Medicare claims if you connect Medicare, and, if you connect a hospital's patient portal, a short summary of those records with the lines a question is about.
What we infer
Anything the assistant derives from the above, including remembered facts, life-stage cohort, the topics you return to, and which details are missing from a profile.
Bodily functions and measurements
Anything you record about sleep, diet, exercise, pain, medicines, periods, pregnancy, or reproductive and sexual health.

We treat all of it as consumer health data. We do not run the exercise of arguing that a given field falls outside the definition.

3Categories we collect, and why

CategoryExamplesWhy we collect it
Health questions and answersYour questions, our answers, conversation titlesTo answer you, and to let you re-read the conversation later
VoiceThe audio of what you say in voice mode, and its transcriptTo turn speech into a question we can answer, and to read the answer back
Documents and photos you attachLab reports, letters, prescriptions and pictures you attach in a chat. They are stored on our server, encrypted with a key our server holds, so the assistant can read them. On paid plans, a copy is filed to the person it is about, with a written summaryTo answer questions about them, and to keep them with the conversation or the person's record
Health records vaultFiles you put in the vault, with their names and labels. The files are stored only as ciphertext (section 12)To store them for you and to show them back to you or to a doctor you choose
People and profilesName or nickname, age or birth date, sex, height, weight, blood type, relationship, conditions, allergies, medicines, family history, smoking, alcohol, exercise and diet, notes, pregnancySo answers are about the right person — an answer for a 2-year-old is not an answer for a 70-year-old
Remembered factsFacts the assistant keeps between conversations, about you and each person you addSo you do not have to repeat your history every time you open the app
Details you state in a chatFrom iPhone app version 3.6.3: weight, height, birth date or age, sex, blood type, allergies, long-term conditions and medicines you state about yourself or the person a chat is about, or type into a Vita card, saved straight to that profile. A small AI call reads your own words to find them. Vita normally shows what it saved, with an Undo that works for 24 hours. A pregnancy is saved only when you confirm it with a tapSo answers fit you without you having to say it twice
Ratings of answersFrom iPhone app version 3.6.3: one to five stars on an answer, and any note you writeAs a signal about the quality of answers. They do not change your account or your answers
Next-step logFrom iPhone app version 3.6.3: which suggested steps were offered, shown, answered or turned down, the time, where in the app, and when an answer read a document (its ID, not its content). A step's name can show what kind of detail it asked aboutTo show you one next step, and not to ask the same thing twice
Changes made from a chatFrom iPhone app version 3.6.3: a log of each change you ask for in a chat, with what was asked, the value before it and when. It can hold health details, such as an earlier allergy entry or a fact you asked Vita to forgetSo you can undo a change for 24 hours
What your phone reportsFrom iPhone app version 3.6.3: whether Apple Health and a hospital are connected, whether notifications are allowed, and whether Apple Health already holds your height and weight. No health values and no hospital name. We keep only the latest reportSo Vita does not ask you to connect what is connected, or ask for what it already has
MedicinesYour medicines cabinet: medicines, schedules, doses you tick, supply left, and photos of medicine boxes or prescriptions you scan to add themTo show your schedule, remind you, and answer questions about your medicines
Periods and pregnancyPeriod days you log, flow, symptoms and settings, plus what Apple Health or Health Connect sends when you turn on period sync. Pregnancy details you enter. Fertility signals stay on your phoneTo keep your period record and answer with your own history in view
Children's recordsGrowth, feeding, sleep and the daily log, fever episodes, milestones and vaccinesTo keep a child's record and answer with it in view
Care team and guidance notesThe care team you list for a person, and guidance notes: what to do, how often, and when it was doneTo keep care instructions in one place
Doctor visit pagesVisit pages and doctor summaries you createTo help you prepare for an appointment and show it to a clinician
Family linksWhat you choose to share with a family member, and what they choose to share with youSo family members can help each other, with each person in control of what is shared
Readings sent with a questionA short digest from Apple Health or Health Connect — medicines, allergies, conditions, recent lab results, vital signs, sleep, steps — sent with a question. It is not saved as a record. An answer that quotes it is saved as part of the answer, and “Explain my results” sends the readings as your question, which is savedTo answer with your own readings in view
Your numbers over timeFrom iPhone app version 3.6.3, if you said yes on the consent card (section 11): each value an answer read from a report, with the test's name as printed, its unit, the printed range, any high or low mark and the date printed on the report if there is one. Never from sealed vault files. Hospital results stay on your phoneTo show you your own results side by side, and say whether one went up, went down or stayed about the same
Plans (not offered now)Diet and movement plans made before we switched plans offWe do not create plans now. Any plan data from before is kept only until you delete your account or ask us to delete it
Safety signalsWhether a message triggered our crisis or emergency classifierTo show emergency information, and to audit that the safety system works
Account and deviceEmail, sign-in method and identifier, display name, language, home country and the country your connection comes from, time zone, plan and subscription status, push token, notification settingsTo run the account, send notifications you have not turned off, and bill correctly
Security recordsIP address, device, and refused sign-ins, kept for 30 daysTo protect your account and the service

We do not collect precise geolocation, contacts, advertising identifiers, or biometric identifiers. We do not read your photo library: we receive only the photos you choose to attach or scan. Face ID and Touch ID unlock the vault on your device; the biometric never leaves your phone and we never receive it.

4Where it comes from

  • You, directly — everything you type, say, attach, scan or enter into a profile or a Vita card. This is most of it.
  • Documents and photos you attach — lab reports, letters, prescriptions, and photos of medicine boxes.
  • Apple Health, if you connect it — health metrics, and, if you also allow Health Records, the records your hospitals and clinics send to Apple Health: lab results, medications, immunizations, allergies, conditions, vital signs and procedures. They are read on your iPhone and kept there. A short digest goes with a question; we do not keep it as a record. From app version 3.6.3 a connection belongs to one Vita account: only that account’s own tap connects it, and Vita deletes its copy from the phone when you sign out or another account signs in. If you sign back in on that phone, Vita builds its copy again without asking; disconnecting takes that yes back.
  • Apple’s Medications list — when you pick medicines “From Apple Health”, the ones you tick become entries in your medicines cabinet on our server.
  • Period sync — when you turn it on, your period data from Apple Health or Health Connect.
  • Health Connect on Android, if you connect it — health metrics, read on your phone in the same way. Android has no hospital records.
  • Your vault, when you choose — if you let Vita learn from a vault document, a summary of it (findings, values, medicines, report text) becomes remembered facts (section 12).
  • A family member — through a family link, we receive what they choose to share with you, under their control and revocable by them.
  • Medicare, if you connect it — see section 4.1.
  • A hospital or clinic, if you connect its patient portal — see section 4.2.
  • Your device — app language, operating-system version, push token, time zone, and the short report described in section 3. We work out a country from your network connection, never from GPS.
  • Your identity provider — if you sign in with Apple or Google, the email address and identifier they assert. If you use Apple Private Relay, we receive only the relay address.
  • Your app store — the App Store or Google Play tells us that a subscription is active. They do not tell us your payment details and we never see them.

We do not buy consumer health data, we do not obtain it from data brokers, and we do not scrape it.

4.1If you connect Medicare

Connecting Medicare is optional. If you connect it, you sign in on Medicare’s own website. We never ask for your Medicare.gov password, and we never see it. Our server keeps only the access tokens Medicare issues. When you ask, your claims are fetched through our server, summarised, and stored only on your phone. A short summary goes with a question you ask, to the AI service in section 6.1, so it can answer. We do not request claims about substance-use disorder treatment. Access lasts up to 13 months; then you reconnect. Disconnecting revokes access at Medicare, deletes the tokens, and deletes the copy on your phone. Beyond that, we never share Medicare data with anyone without your explicit consent. The Privacy Policy describes the Medicare connection in full.

This product uses the Blue Button APIs but is not endorsed or certified by the Centers for Medicare & Medicaid Services or the U.S. Department of Health and Human Services.

4.2If you connect a hospital

For accounts in the United States. Connecting a hospital or clinic is optional. You sign in on the hospital’s own sign-in page with your own patient-portal login; we never see that password. Your phone downloads the records the hospital releases to you — lab results, vital signs, conditions, medicines, allergies, immunizations, procedures, social history and visit summaries — and keeps them sealed on the phone, with the access tokens in the phone’s secure storage. Our servers never receive the records or the tokens; your phone tells our server only that a hospital is connected, not which one. While “Use my health data in answers” is on, a short summary, with the lines of your record a question is about, goes with a question you ask to the AI service in section 6.1, so it can answer. An answer that quotes it is saved with your conversation on our servers, and Vita can remember a short fact from that answer. If you tap Ask on a record, its name and value are written into your question for you to send or change. You can delete all of these. Vita only reads and never changes your hospital record. When you disconnect, you choose whether the records stay on your phone or are deleted. Signing out, switching account, deleting the person or deleting your account deletes them from the phone and asks the hospital to end its access. The Privacy Policy describes the connection in full.

From app version 3.6.3, before you sign in to anyone else’s portal you confirm with one tap: “I have permission to view this person’s records.” If someone connected your records without your permission, whether you are a parent or anyone else, you do not need a Vita account to act. Remove Vita in your patient portal’s settings, then write to privacy@vitamedas.com, with the email address of the Vita account if you know it. We will check your request and can delete you as a person on that account, with what our servers hold about you there. If the records were connected for you as that person, this also deletes them from the phone the next time Vita opens there. We hold no copy of the records, and we cannot reach a phone in any other way.

5How we use it

  1. To answer the question you asked, in the language you asked it.
  2. To store, index and show back the records you chose to keep, and to render a share you created for a clinician.
  3. To keep answers consistent with what you have already told us, so you are not starting from zero every time.
  4. To run the safety pipeline that stops the assistant diagnosing, prescribing, or missing a crisis signal.
  5. To operate the account: sign-in, subscription status, reminders and notifications you have not turned off, and support you contacted us about. On an iPhone that has never been asked, the app from version 3.6.3 turns on Apple’s quiet notifications until you choose.
  6. To keep the service secure and working — rate limits, abuse detection, error diagnosis.
  7. To comply with a law that obliges us, or to establish or defend a legal claim.
  8. If you said yes on the consent card (section 11), to show you one suggested next step in the app, such as a detail to add or a report to bring. Code picks it, from your profile, what you have done in the app and what your phone reports.
  9. If you said yes on the consent card (section 11), to offer you a Vita plan inside the app. This looks at how many answers you have had, whether you reached the free limit, how many details Vita holds and whether a report is on file. It never looks at what a question or a report says.
  10. If you said yes on the consent card (section 11), to keep the values an answer read from a report, and on a paid plan to compare them over time. On a paid plan your earlier values for the same tests go to our AI provider with a new report. Vita calls a value neither better nor worse, and it predicts nothing.

6What we share, and with whom

“Share” here means disclosure to another company, whether or not money changes hands. We share consumer health data only with service providers who process it on our written instructions, under a contract that forbids them using it for their own purposes, and only the minimum each one needs.

6.1The complete recipient list

MHMD requires a list of the specific affiliates and the categories of third parties we share with. VitaMedas, Inc. has no affiliates and no parent or subsidiary companies. The complete list of third parties is:

RecipientWhat it receivesWhere it processes
Hetzner Online GmbHHosts both of our servers and our backups. Everything we hold on our servers is stored there. Vault files are stored only as ciphertext.Helsinki, Finland (EU)
Google LLC (Gemini)Each question with its context — remembered facts, profiles, the Apple Health or Health Connect digest, earlier turns of the conversation — plus documents and photos you attach, voice audio to transcribe, and the answer text to read it aloud. From iPhone app version 3.6.3, small calls also read your own words to find details to save and to see whether you are asking the app to change something, including words typed into a Vita card and messages at the free limit, and a saved document goes again when Vita reads it again. A vault file only when you ask for an AI description of it. PDFs, and images over 9 MB, go to Google's file service, which deletes them after about 48 hours. Google does not train its models on this data.United States
Microsoft Corporation (Azure AI Speech)Only the assistant's reply text, to be read aloud when Google's voice does not answer in time. No question text, no records.European Union
Cloudflare, Inc.Network transit and protection. Secure connections end at Cloudflare, so our traffic, questions included, passes through its network on the way to our servers. Vault files pass through only as ciphertext.Global edge
Google LLC (Firebase)Sign-in identifiers and push delivery tokens. App usage events and crash reports, only if you allowed analytics in the app.United States
Apple Inc.Sign-in, push delivery, and App Store subscription status. No health content.United States
Google LLC (Google Play)Purchase information, to confirm an Android subscription. No health content.United States
MXroute LLC (email)Email address and templated message text. No health content.United States
Telegram (internal alerts)Operations alerts to our own team, with the email address masked. No health content.Global

The current, authoritative version of this list, with each company’s transfer safeguards, is at Sub-processors. We give 30 days’ notice before adding one.

Separately, and only when you do it: a doctor link makes the records you selected readable to whoever holds the link and its code, until it expires or you revoke it. A family link shows a family member what you chose to share with them. Those are disclosures you make, not ones we make, and you can stop them.

6.2Where your data is stored

Our own servers — the one behind the Vita app and the one behind vitamedas.com — and our backups run at Hetzner in Helsinki, Finland, in the EU. We do not run servers in the United States. Some companies in section 6.1 process data in the United States, as the table shows.

Records you read from Apple Health stay on your phone; only a short digest travels with a question. If you connect a hospital or Medicare, those records stay on your phone too. Vault files are stored only as ciphertext.

7We do not sell consumer health data

We have never sold consumer health data and we do not sell it now. “Sale” under MHMD is broad — it covers exchange for anything of value, not only money — and our answer covers that breadth.

MHMD requires a signed, specific valid authorization before any sale, separate from consent to collect. We have never sought one, we have no mechanism to collect one, and no revenue in our business depends on it. Our revenue is subscriptions, paid by users, and nothing else.

8No advertising, no profiling, no inference sale

There is no advertising in VitaMedas. We run no advertising SDK, set no advertising cookie, and share no identifier with an ad network or measurement partner. We do not participate in cross-context behavioural advertising, and there is consequently nothing for you to opt out of.

We do not sell inferences drawn from your health data, and we do not disclose them to data brokers. We honour the Global Privacy Control signal as an opt-out where any state law gives it effect — see US State Privacy Rights.

9Geofencing

MHMD makes it unlawful to operate a geofence around a facility that provides in-person health-care services in order to identify, track or advertise to people near it. Nevada prohibits the same.

VitaMedas operates no geofence of any kind. The app does not request precise location. Where we show a country-appropriate emergency number, we work it out on our server from the country on your account and the country your network connection comes from — never from device GPS. We store a country, not a location. Security records keep IP addresses for 30 days, to protect accounts.

10Your rights

You have the right to:

  1. Confirm whether we are collecting, sharing or selling your consumer health data.
  2. Access it, together with a list of every third party with which we have shared it and an active contact address for each. Section 6.1 is that list, published in advance.
  3. Withdraw your consent to our collection and sharing of it.
  4. Delete it, including from backups and from every processor that holds it for us.
  5. Appeal if we refuse any of the above.
  6. Not be discriminated against for exercising any of them. We will not degrade the service, change your price, or close your account because you asked.

10.1How to exercise them

Email privacy@vitamedas.com from the address on your account, or write to us at the postal address in section 15. You can also delete your account and its data from inside the app — Settings › Help & account › Contact support › Delete account — without contacting anyone.

We respond within 45 days. Where a request is genuinely complex we may take one further 45 days, and we will tell you why within the first 45. There is no fee. We will verify that the request is really yours — normally by confirming control of the account email — and we will not ask you for more identifying information than that verification needs.

An authorized agent may act for you if you give them written permission and we can verify both their authority and your identity.

10.2What deletion actually does

MHMD sets a higher deletion standard than most privacy laws. This is what actually happens:

  • You can delete a single conversation (with its messages and attached files), a person, a medicine or a log entry in the app at any time. Deleting a conversation or a person also removes its ratings and its log of changes from a chat, takes its values read from reports, and takes the answer and document IDs out of the next-step log. Deleting a document takes its values too. Deleting a person leaves the chats about them until you delete those too.
  • When you delete your account, the app first gives you 7 days to change your mind. We then delete the account and everything in section 3 that we hold — conversations, messages, attached documents and their filed copies, remembered facts, people and their records, medicines, period data, visit pages and links, values read from your reports, ratings, the next-step log and the log of changes — together with your vault ciphertext. This is done in the live database within 30 days of your request.
  • Backups are included. We keep one backup copy of the Vita app database a day for 30 days, and we can make an extra copy just before a software change. A deleted item can stay in a copy until that copy is removed, so your data is gone from every backup within a further 35 days. We do not treat “it is only in a backup” as an exemption.
  • We tell every processor in section 6.1 that still holds anything of yours to delete it. Google’s file service deletes uploaded documents after about 48 hours on its own.
  • Doctor links and family links you created stop working.
  • What survives is a pseudonymous record that an account existed and was deleted on a date, which is how we prove to you that we did it, any record a specific law obliges us to keep, such as billing and tax records, and, if you used an unsubscribe link, that email address on our unsubscribe list, so that we do not email it again — see Data Retention.

10.3If we say no: appeals

If we refuse a request we will tell you in writing, explain why, and give you instructions for appealing. An appeal goes to legal@vitamedas.com and is decided by someone other than the person who made the first decision. We answer an appeal within 45 days.

If we deny the appeal, we will give you a way to contact your state’s Attorney General. For Washington residents that is the Washington State Office of the Attorney General consumer complaint service; for Nevada, Connecticut and Virginia, the equivalent office of your state Attorney General. You do not need our permission to complain, and you may do so instead of appealing rather than after.

12The vault: data we cannot read

Files you put in the vault are encrypted on your device — in your browser or in the app — with a key only you hold, derived from your passphrase or kept on your device. We store ciphertext. We do not hold the key, and no employee, contractor, court order or subpoena can make us produce plaintext we do not have.

This is a mathematical property of the system, not a promise about our conduct. It also has a consequence you should understand: if you lose your passphrase and your recovery material, we cannot recover your files. For your rights above, unreadable data is still your data — we will confirm it exists, tell you what we hold, and delete it on request.

A vault file becomes readable in four cases, and each one starts with you:

  • An AI description. If you ask for an AI description, summary or translation of a vault file, your device decrypts that one file and sends it through our server to the AI service in section 6.1. We keep only a fingerprint (a hash) of it.
  • Letting Vita learn from a document. If you choose this, a summary of the document — findings, values, medicines, report text — is sent to the app server and stored there as readable remembered facts, like anything else you tell Vita.
  • A doctor link. The records you choose become readable to whoever holds the link and its code, until it expires or you revoke it.
  • Saving a chat attachment to your records. A document you first attached in a chat is already held by the app server in readable form (section 3). The sealed vault copy is an extra copy; it does not replace the readable one.

The conversational assistant is different and we will not blur the two: the questions you ask it are processed in plaintext, because a model cannot answer text it cannot read. Section 3 says exactly what that involves and section 6.1 says exactly who sees it.

13Minors

VitaMedas is for adults. You must be 18 or older to hold an account. We do not knowingly collect consumer health data from anyone under 13, and the federal Children’s Online Privacy Protection Act rules for under-13s therefore do not arise in normal operation.

Adults do ask us about children in their care, and those answers are the point of the product. Data about a child — a profile, growth, vaccines, the daily log — is entered by the adult account holder, belongs to that account, and is deleted with it. If you believe a person under 18 has created an account, tell us at privacy@vitamedas.com and we will close it and delete the data. If you give Vita an age or birth date under 18 for yourself, in a chat or on your profile, Vita does not save it. We note only that it happened and how many times, with none of your words. Someone at VitaMedas reviews that note, and if the account belongs to a person under 18 we close it and delete its data.

We never sell the personal information of anyone, and so we never sell the personal information of a consumer under 16 — the case in which several state laws require opt-in consent.

14Changes to this policy

If we change the categories of consumer health data we collect, the purposes we use it for, or the parties we share it with, we will update this page, change the version and effective date, and — because MHMD does not let us apply a new purpose to data already collected — obtain your consent before the new use begins. For material changes we email account holders at least 30 days beforehand.

15Contact

VitaMedas, Inc.
2261 Market Street STE 69554
San Francisco, CA 94114
United States

Privacy requests: privacy@vitamedas.com
Appeals: legal@vitamedas.com

Statutory references

  • MHMD · Washington My Health My Data Act, RCW 19.373 — consumer health data privacy policy (.020), consumer rights (.030), consent (.040), authorization to sell (.050), geofencing (.100).
  • Washington CPA · RCW 19.86 — MHMD violations are unfair or deceptive acts, enforceable by the Attorney General and by private action.
  • Nevada SB 370 · NRS 603A.400 et seq. — consumer health data; Attorney General enforcement.
  • CTDPA · Conn. Gen. Stat. 42-515 et seq., as amended by SB 3 (2023) — consumer health data and geofencing.
  • Virginia SB 754 · Virginia SB 754 (2025), amending the Virginia Consumer Protection Act, Va. Code 59.1-200 — reproductive or sexual health information may not be obtained, disclosed, sold or disseminated without the consumer's consent.
  • FTC HBNR · 16 C.F.R. Part 318 — Health Breach Notification Rule, as amended 2024; applies to vendors of personal health records not covered by HIPAA.
  • COPPA · 15 U.S.C. 6501-6506; 16 C.F.R. Part 312 — children under 13.

Questions, requests, or complaints?

VitaMedas is operated by VitaMedas, Inc. (commercial name VitaMedas), 2261 Market Street STE 69554, San Francisco, CA 94114, United States.

Document last updated 4 November 2026 · Version v1.4 · Previous versions available on request.