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US state privacy laws · GDPR (EU) 2016/679 · UK GDPR · KVKK 6698

Privacy Policy

Version
v3.5
Effective
4 November 2026
Binding language
English (with Turkish counterpart for KVKK)

1Introduction

This Privacy Policy (the “Policy”) explains how VitaMedas, Inc., a Delaware corporation with its registered office at 2261 Market Street STE 69554, San Francisco, CA 94114, United States (“VitaMedas”, “we”, “us”), collects, uses, shares and protects personal data when you use:

  • the Vita app on iPhone, Apple Watch and Android;
  • vitamedas.com, including the Health records vault, doctor links and intake links;
  • any other service of ours that links to this Policy.

Together we call these the “Service”. One account works across all of them. You sign in with Apple, Google or your email address.

This Policy is binding. The English text governs, with one exception: for data subjects in Türkiye, the Turkish notice at /legal/kvkk governs the disclosures that Article 10 KVKK requires.

We use plain words. Where a law defines a term, the law's definition applies. Capitalised terms not defined here have the meaning given in our Terms of Service.

2Who we are (the controller)

Under US state privacy laws, the EU GDPR, the UK GDPR and Türkiye's KVKK, the controller of your personal data (the “business”, in California's terms) is:

Legal name
VitaMedas, Inc.
Commercial name
VitaMedas
Registered office
2261 Market Street STE 69554, San Francisco, CA 94114, United States
Employer Identification Number
Available on request via legal@vitamedas.com
Registry
Delaware Division of Corporations
State of incorporation
Delaware, United States
Data-protection contact
privacy@vitamedas.com · post may be sent to the registered office, marked “Data Protection”
EU representative (GDPR Art. 27)
Where Article 27 GDPR requires us to name a representative in the European Union, we will appoint one and publish their details here. To ask about our current status, write to privacy@vitamedas.com.
UK representative (UK GDPR Art. 27)
Where Article 27 UK GDPR requires us to name a representative in the United Kingdom, we will appoint one and publish their details here. Current status available on request.
KVKK VERBİS registration
Where the KVKK requires us to register in the Turkish data controllers' registry (VERBİS), we register. Current status is available on written request to privacy@vitamedas.com.

3What this policy covers

This Policy covers personal data we process when you, or someone acting for you:

  • create or use an account, in the app or on the website;
  • ask Vita questions by text or voice, attach documents, or keep records about yourself or other people (people, children, medicines, periods);
  • connect Apple Health or Health Connect, or Medicare once it is available;
  • use the Health records vault, create a doctor link or an intake link, or link with a family member;
  • open a doctor link, or upload through an intake link, that someone gave you;
  • contact us, or visit our website.

It does not cover other companies' services that you use alongside ours — for example Apple Health, Medicare's website, or an app you open a downloaded file in. Their own privacy notices apply.

4What we collect

We collect what we need to run the Service and what you choose to give us. We do not buy data from data brokers. We use no advertising networks and no advertising SDKs.

4.1Your account, device and subscription

  • Sign-in details — your email address, how you sign in (Apple, Google or email) and the identifier that service gives us. If you use Sign in with Apple and hide your email, we receive Apple's relay address instead.
  • Profile basics — your display name and the language you use.
  • Country and time — the country you set as home, the country your connection appears to come from, and your time-zone offset. We use them so that answers, doctor pages, units, dates and emergency numbers fit where you are.
  • Subscription — your plan, its status and renewal dates, and purchase identifiers from Apple or Google.
  • Notifications — a push token for your device and your notification settings. On an iPhone that has never been asked, the app from version 3.6.3 turns on Apple's quiet notifications with no permission screen: they go to Notification Center only, until you choose. You can turn each kind off in Settings or by asking Vita in a chat. Notifications are written so they do not name a health topic, a medicine or a result.
  • Website sessions — session and security cookies; see our Cookie Policy.

4.2Questions, answers and voice

  • What you ask and what Vita answers, and each conversation's title. We keep them so you can come back to them and so Vita can follow the conversation.
  • Voice — when you speak to Vita, your recording is sent to Google to be turned into text. We keep the text (the transcript) in the conversation.
  • Safety signals — whether a message was flagged as a possible emergency or a risk of self-harm. When that happens, Vita shows emergency or crisis numbers instead of a normal answer (see the Crisis Protocol).
  • Ratings — in the iPhone app, version 3.6.3 and later, you can give an answer one to five stars and add a short note if you want. We keep the stars, the note and which answer they belong to, as a signal about the quality of answers. They do not change your account or your answers.

4.3Documents and photos you attach in a chat

Lab reports, letters, prescriptions and pictures you attach to a question are stored on our server in Finland. They are encrypted at rest with a key that our server holds, so our systems can open them to answer you. They stay until you delete the conversation or the filed item, or your account. On a paid plan, Vita also files a copy under the person it is about, with a written summary of it.

In the iPhone app, version 3.6.3 and later, Vita can read one of these documents again: when you tap to read it again after giving a new detail, when you change your country, or when you ask for it to be read for another country. The document then goes to Google again (section 9), and the new answer is saved like any other. Sealed vault files are never read this way.

4.4What Vita remembers

Vita keeps short facts from your conversations — about you and about each person you add — so that later answers fit. For example: an allergy, a medicine or a condition you mentioned. We call this “Vita's memory”. You can see these facts and remove them in the app.

Details you state go to the profile. In the iPhone app, version 3.6.3 and later, when you tell Vita a detail about yourself, or about the person a chat is about, a small AI call reads your words and saves the detail straight to that person's profile: weight, height, birth date or age, sex, blood type, allergies, long-term conditions and medicines. The same happens with words you type into a Vita card. The call reads only your own words, never Vita's answers. Code works out every height and weight from the number and unit you gave, and a number with no unit is not saved. If you give an age, we keep that number and the day you said it, and we never make a birth date from it.

Vita normally shows what it saved, with an Undo that works for 24 hours. You can change or remove any detail on the person's page at any time. Details saved this way, such as allergies and conditions, can appear wherever that profile is used, for example on a doctor link or a family link that covers them. Nothing is saved this way from an emergency or crisis message or from a “Someone else” chat, or onto a card someone shared with you. A pregnancy is saved only when you confirm it with a tap, and the call is built to leave out private topics such as sexual health and mental health.

4.5People, children, medicines and periods

  • People you add — name or nickname, age or birth date, sex, height, weight, blood type, relationship to you, conditions, allergies, medicines, family history, smoking, alcohol, exercise and diet, notes, pregnancy details, and their care team with any guidance notes.
  • Children's records — growth, feeding, sleep and daily logs, fever episodes, milestones and vaccines.
  • Medicines cabinet — medicines, schedules, doses you mark as taken, and how much is left. If you scan a medicine box or a prescription to add it, we receive the photo.
  • Period tracker — the days you log, flow, symptoms and your settings, including what Apple Health or Health Connect sends in if you turn on period sync. Fertility signals stay on your phone and are not stored on our server.

4.6Family links, visit pages and doctor links

  • Family links (Vita Family plan) — what you choose to share with a family member, and their access to it.
  • Visit pages and doctor summaries you create, so you can use them at an appointment.
  • Doctor links — when you create one, we store its details (an opaque token, its expiry and what it covers) and a log of each time it is opened (time, IP address, device). A doctor link that covers your whole vault opens on a patient brief built from your app records, for the people the link covers: profile details (such as date of birth, sex, allergies and conditions), current medicines and doses marked in the last 30 days, the care team, and questions from your latest visit page. It never includes Vita's memory.
  • Intake links — when you create one so a clinic can send you records, we store its token, expiry and destination. Files uploaded through it are stored encrypted, like the rest of your vault.

4.7The Health records vault

Files you put in the vault — on vitamedas.com or in the app — are encrypted on your device before they are uploaded, with a key made from a passphrase or a device key that only you hold. We store the encrypted file and the little we need to deliver it: its size, its file type, the upload time, your account ID, an encrypted file name, and the encrypted key that unlocks it. We never receive your passphrase or your key. Section 7 explains what this means, and the few cases where you choose to make a vault file readable.

4.8Apple Health and Health Connect

If you connect Apple Health (iPhone) or Health Connect (Android), Vita reads your health data on your phone. On iPhone this can include records from your hospitals and clinics — lab results, medications, immunizations, allergies, conditions, vital signs and procedures — and metrics such as sleep and steps. On Android, Vita reads metrics only.

This data stays on your phone, in a sealed file. When you ask a question, a short summary goes with it so the AI can answer: up to 12 medicines, your allergies and conditions, 6 lab results, 90 days of vital signs, sleep and steps. We do not store that summary as a record. But note:

  • an answer that quotes a reading is saved as part of that answer;
  • “Explain my results” sends the readings as your question, and the question is saved;
  • a medicine you pick from Apple Health becomes an entry in your medicines cabinet on our server only when you tick it;
  • period data comes into the period tracker only if you turn on period sync.

From iPhone app version 3.6.3, a connection to Apple Health belongs to one Vita account, not to the phone. Only that account's own tap connects it. When you sign out, or another account signs in on the phone, Vita stops reading Apple Health for you and deletes its copy and its summary from the phone. If you sign back in on that phone, Vita builds its copy again from Apple Health without asking, because the phone keeps a coded note that you said yes. Disconnecting takes that yes back. Apple's own permission belongs to the phone, so another account may see no Apple screen when it taps Connect, but nothing connects without that tap.

We never use Apple Health or Health Connect data for advertising or marketing, and we never sell it.

4.9Security events, logs and app analytics

  • Your next step in Vita — in the iPhone app, version 3.6.3 and later, Vita shows one suggested next step at a time, such as a detail to add or a report to bring, and a ring showing how much of your profile is filled in. For this we keep a log of which steps were offered, shown, answered or turned down, with the time and where in the app, and of when an answer read a document (its ID, not its content). A step's name can show what kind of detail it asked about, so we treat this log as health data.
  • What your phone reports — with the same app, your phone tells our server whether Apple Health and a hospital are connected, whether notifications are allowed, and whether Apple Health already holds your height and weight. The report holds no health values and no hospital name, and we keep only the latest one.
  • Server logs — time, IP address, request path, response code, response time and device type (user agent). Kept up to 30 days, for security and reliability only.
  • Security events — IP address, device, refused sign-ins and similar signs of misuse. Kept 30 days.
  • Audit log — a pseudonymous record of actions, such as a file uploaded, a link opened or an account deleted. It holds no content. Kept 5 years.
  • App analytics and crash reports — only if you allow analytics in the app. Google's Firebase then receives app usage events, device type, app version and crash reports. You can turn this off in Settings.

4.10Payments

You pay for Vita through Apple's App Store or Google Play. We never see your card. We receive your plan, the purchase and renewal dates, the subscription status and the store's transaction identifiers. Apple's and Google's own privacy policies cover the payment itself.

4.11Support

If you write to us, we receive what you send — your email address, name, message and any attachments. We use it to answer you and to keep a record of the case.

4.12Changes you make from a chat

In the iPhone app, version 3.6.3 and later, you can ask Vita in a chat to change your language, country, notifications, marketing emails, appearance or any profile detail, or to read a report for another country without changing yours. The AI reads your request, our server makes the change inside your own account, and the chat shows what really happened, with an Undo that works for 24 hours.

So that Undo can work, we keep a log of each change: what was asked, the value before it, and when. The log can hold health details, such as an earlier allergy entry or a fact you asked Vita to forget. Removing Apple Health or a hospital, deleting files, signing out, deleting your account and turning Personalize Vita for me on or off (section 6.1) always need your own tap. Other requests, such as adding a medicine, open the right screen.

4.13Your numbers over time

From iPhone app version 3.6.3, if you said yes on the consent card (section 6.1), Vita keeps each value an answer read from a report: the test's name as printed, the value and its unit, the printed range, any high or low mark, and the date printed on the report if there is one. Each value is linked to the person, the document and the answer. If the report gives no date, the date stays unknown; Vita never uses the upload date in its place.

These values come only from answers Vita wrote. Vita never reads sealed vault files for this. Hospital results stay on your phone and are not uploaded for this.

The values are kept on every plan, a free account included, so they are there if you choose a plan later. Comparing them over time is part of a paid plan: Vita shows whether a value went up, went down or stayed about the same, beside the printed range. Code works this out from the saved values, and two values are compared only if their units can be converted. On a paid plan, your earlier values for the same tests go to Google with a new report, so the answer can compare them. Vita does not call a value improving or worsening, and it predicts nothing.

Deleting a conversation, a document or a person deletes its values, and reading a report again replaces them. They go with your account. If you take back your yes, no new values are saved; those already saved stay until you delete them or ask us to.

5Why we use your data, and our legal basis

Every use of personal data needs a legal basis under Article 6 of the GDPR and UK GDPR and Article 5 of the KVKK. US state laws set their own conditions, described in the two US documents named above.

PurposeDataLegal basis (GDPR / UK GDPR)Legal basis (KVKK)
Run your account and the Service: sign-in, subscription, sync across devices, notificationsAccount, device and subscription dataArt. 6(1)(b) — performance of our contract with youArt. 5(2)(c) — sözleşmenin kurulması veya ifası
Answer your questions and run the health features you use: the assistant, voice, attachments, memory, details saved from a chat, changes made from a chat, people and children's records, medicines, the period tracker, visit pages, family links, and Apple Health, Health Connect or Medicare contextHealth data, and the account data needed to deliver itArt. 6(1)(b) and Art. 9(2)(a) — your explicit consentArt. 5(2)(c) and Art. 6(3)(a) — açık rıza
Compare your own results over time, if you said yes on the consent card (sections 4.13 and 6.1)Values read from your reportsArt. 6(1)(b) and Art. 9(2)(a) — your explicit consentArt. 5(2)(c) and Art. 6(3)(a) — açık rıza
Show you one suggested next step in the app, and how much of your profile is filled in, if you said yes on the consent card (section 6.1)Profile details, whether a report is on file, how many questions you have asked, the next-step log, what your phone reportsArt. 6(1)(b) and Art. 9(2)(a) — your explicit consentArt. 5(2)(c) and Art. 6(3)(a) — açık rıza
Offer you a Vita plan inside the app, if you said yes on the consent card (section 6.1)How many answers you have had, whether you reached the free limit, how many details Vita holds, whether a report is on file. Never what a question or a report saysArt. 6(1)(a) and Art. 9(2)(a) — your consentArt. 5(1) and Art. 6(3)(a) — açık rıza
Keep answers safe: spot emergency and self-harm wording, show emergency or crisis numbers, and check the safety and quality of answersQuestions, answers, safety signals, ratings and notes on answersArt. 6(1)(b) and (f), with Art. 9(2)(a) — your explicit consentArt. 5(2)(c) and (f), with Art. 6(3)(a) — açık rıza
Store your Health records vault and run doctor links and intake linksEncrypted files and their metadata; link details and access logs; for a vault-wide doctor link, the patient brief from your app recordsArt. 6(1)(b) and Art. 9(2)(a)Art. 5(2)(c) and Art. 6(3)(a) — açık rıza
Security, fraud and abuse prevention, audit logServer logs, security events, IP address, device, audit eventsArt. 6(1)(f) — our legitimate interest in a safe serviceArt. 5(2)(f) — meşru menfaat
Service email and notifications: sign-in links, security alerts, plan changes, reminders and other notifications you have not turned offEmail address, push token, notification settingsArt. 6(1)(b) and (f) — contract and legitimate interestArt. 5(2)(c) and (f)
App analytics and crash reports (only if you allow them)Usage events, device type, app version, crash reportsArt. 6(1)(a) — consentArt. 5(1) — açık rıza
Marketing email (only if you opt in)Email address, nameArt. 6(1)(a) — consentArt. 5(1) — açık rıza · ETK 6563
Meet legal duties: tax, accounting, court ordersAccount and billing records, audit logArt. 6(1)(c) — legal obligationArt. 5(2)(ç) — hukuki yükümlülük
Establish, exercise or defend legal claimsData reasonably needed for the claimArt. 6(1)(f) and Art. 9(2)(f)Art. 5(2)(e) and Art. 6(3) — bir hakkın tesisi, kullanılması veya korunması

Where we rely on consent, you can withdraw it at any time (section 14). That does not make earlier processing unlawful. Without consent to process health data, Vita cannot answer health questions, because answering means reading them.

6Health data

Much of what you give Vita is health data. The GDPR (Article 9), the UK GDPR and the KVKK (Article 6) treat it as a special category with stricter rules. In the United States it is “consumer health data” under laws such as Washington's My Health My Data Act; our Consumer Health Data Privacy Policy explains your rights under those laws.

  • Our basis is your explicit consent (Art. 9(2)(a) GDPR and UK GDPR; Art. 6(3)(a) KVKK; and the consent that US health-data laws require). You give it when you start using Vita's health features, and again each time you choose to send, attach or connect something. You can withdraw it at any time by deleting the data or your account.
  • Sharing with a doctor. When you share records with a doctor, Article 9(2)(h) GDPR (medical purposes) can also apply.
  • We use health data only to provide the features you use, to keep them safe and secure, and to meet the law. We do not sell it, we do not use it for advertising, and we do not use it to train AI. A plan offer inside the app appears only if you said yes on the consent card (section 6.1). It looks at counts and at whether a report is on file, never at what a question or a report says.

If someone else added you. If another person keeps your details in their Vita account and you want them removed, write to privacy@vitamedas.com. We will check who you are, then remove your card, your saved details and the chats pinned to you from that account, without reading them. We cannot reach records kept on that person's phone, words about you in their other chats, anything already shared or exported, or backups until they age out.

7Who can read what, and where it is kept

Vita handles your data in three different ways. We keep them apart on purpose, and you should know which is which:

  1. Readable by our server — what the assistant needs to answer you (7.1).
  2. Readable only by you — the Health records vault (7.2).
  3. Kept on your phone — Apple Health, Health Connect, Medicare and hospital records (7.3).

7.1What our server can read

Our servers are run by Hetzner Online GmbH in Helsinki, Finland (EU). The following is stored there in a form our systems can read:

  • your questions, Vita's answers and voice transcripts;
  • documents and photos attached in a chat (encrypted at rest with a key our server holds);
  • Vita's memory;
  • people, children's records, medicines and period-tracker data;
  • values read from your reports (section 4.13);
  • visit pages, doctor summaries and family links;
  • ratings and notes on answers, the next-step log and the log of changes made from a chat;
  • your account, device and subscription data.

An assistant cannot answer a question it cannot read, so this data is not end-to-end encrypted. Backups of this database are kept on the same server in Finland: one copy a day, kept for 30 days, and, when needed, an extra copy just before a software change, which is removed within 35 days. Something you delete can therefore remain in a backup for up to 35 days. After that it is gone.

7.2What only you can read: the vault

Files in the Health records vault are encrypted on your device, in your browser or the app, with XChaCha20-Poly1305. The key comes from your passphrase (through Argon2id) or from a device key, and only you hold it. Our server stores only the encrypted file. It holds no key. As a result:

  • We cannot recover a lost passphrase for you. You can get back in with a recovery method you set up — your 24-word recovery phrase, a passkey, or recovery shares held by people you trust. Without your passphrase or a recovery method, the files cannot be opened.
  • We cannot hand over the contents. If a court orders us to disclose vault content, we can give only the encrypted file and the details in section 4.7. We will tell you about the request unless the law forbids it.

A vault file becomes readable only when you choose:

  • AI description, summary or translation. Your device opens that one file and sends it through our server to the AI (section 9). We keep only a fingerprint (hash) of it.
  • Letting Vita learn from a document. If you choose to let Vita learn from a vault document, a summary of it — findings, values, medicines and report text — is sent to our server and stored as readable facts (section 7.1).
  • Doctor links. Whoever holds a link and its code can open the records it covers, until the link expires or you revoke it.
  • Documents first attached in a chat. If you attach a document in a chat and then save it to your records, our server already holds a readable copy (section 4.3). The sealed vault copy is added to it; it does not replace it.

7.3What stays on your phone

Records and metrics read from Apple Health or Health Connect, and Medicare and hospital records if you connect them, are kept on your phone, not on our servers. A short summary travels with a question only to get you an answer (sections 4.8 and 8). Your phone also tells our server whether Apple Health and a hospital are connected (section 4.9), with no health values.

7.4Who at VitaMedas can read the readable data

Only authorised staff, and only when needed: to answer a request you make, to investigate a security issue, or to check the safety and quality of Vita's answers. Every such read of another person's health data is logged. No one at VitaMedas can read your vault.

8Medicare and hospital records (when you connect them)

8.1What we collect, and from whom

If you are enrolled in Medicare in the United States and you connect it, Vita receives data from the Centers for Medicare & Medicaid Services (CMS): your Medicare claims — Part A (hospital), Part B (medical) and Part D (prescription drugs) — and your coverage details. Claims show things like dates of care, the providers you saw, the diagnoses and procedures recorded, and prescriptions filled. We do not ask Medicare for your name, date of birth or address, so they are not shared with us.

We do not request substance-use disorder claims.

8.2How the connection works

  • You sign in on Medicare's website, not in Vita. We never ask for, see or store your Medicare.gov username or password.
  • Medicare then gives us access tokens. Our server keeps only these tokens.
  • The connection is ongoing, for up to 13 months. During that time Vita fetches your claims only when you ask for them. After 13 months the access ends, and you must connect again if you want to keep using it.
  • Your claims stay on your phone. When you ask, our server fetches your claims from Medicare, turns them into a summary and passes it to your phone. Your phone keeps it. Our server does not keep a copy.
  • When you ask a question, the summary goes with it so the AI can answer, as with Apple Health (section 9). This happens only for questions you ask, and only with your consent.

8.3Who sees your Medicare data

We share your Medicare data with no one. The only exception is the AI processing described above, which happens only to answer a question you ask, with your consent. We never sell Medicare data, never use it for advertising, and never use it to train AI.

8.4Disconnecting, and dormant or closed accounts

  • You can disconnect at any time in the app. We then revoke Vita's access at Medicare, delete the tokens from our server, and delete the Medicare copy on your phone at the same time.
  • If you stop using Vita, the connection ends by itself when its time runs out — at most 13 months after you connected. We cannot renew it without you.
  • If you delete your Vita account, we revoke Medicare access and delete the tokens as part of the deletion. Removing the app from your phone removes the copy on your phone.

Your rights over this data are in section 14, how we tell you about changes is in section 20, and what we do after a breach is in section 13.

8.5Attribution

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.

8.6Hospital and clinic records (when you connect them)

In the United States, many hospitals and clinics let patients connect an app of their choice to their patient portal. If you connect one, you sign in on the hospital's own sign-in page with your own portal login. We never ask for, see or store that password.

  • What arrives: the records the hospital releases to you through its patient-access service — lab results, vital signs, conditions, medicines, allergies, immunizations, procedures, visit and report summaries, and the identifying details on your record that come with them.
  • Where it goes: straight to your phone. Your phone signs in, downloads the records and seals them with a key only that phone holds. The access tokens are kept in your 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 (section 4.9).
  • When you ask a question while “Use my health data in answers” is on, a short summary goes with that question to the AI service (section 9), as with Apple Health, with the lines of your record the question is about, which your phone finds itself. The summary is not saved as a record. 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; a question you send is saved with your conversation like any other. You can delete all of these.
  • Vita only reads. It never writes to or changes your hospital record.
  • Disconnecting: Vita stops updating, stops using those records in answers and asks the hospital to end its access, and you choose whether the records stay on your phone or are deleted. Signing out of Vita, switching to another account, deleting the person in Vita or deleting your account deletes the records and the tokens from your phone and asks the hospital to end its access. In the app from version 3.6.3 this also holds when another account signs in with no sign-out first. If you delete the person or your account on another device, it happens the next time Vita opens on that phone. Some hospitals do not let an app end the access for you: remove Vita in your patient portal's settings.
  • Apart from what goes with your questions as described above, we share hospital records with no one. We never sell them, never use them for advertising and never use them to train AI.
  • Someone else's records. 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.” Connect them only if that is true, for example as a parent or legal guardian, or through your own proxy access at the hospital.
  • If someone connected your records without your permission. This goes for a parent, or for anyone else, and you do not need a Vita account. Remove Vita in your patient portal's settings: that ends the app's access. Then write to privacy@vitamedas.com, with the email address of the Vita account if you know it. We will check your request. We 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.

9How Vita uses AI

Vita's answers come from an AI model. We use the Gemini API from Google LLC, a paid service, as our processor.

  • What goes to Google with each question: your question and the context needed to answer it — what Vita remembers, the profile of the person you are asking about, earlier turns of the conversation, your Apple Health or Health Connect summary and, if connected, your Medicare and hospital summaries — plus documents and photos you attach, and your voice recording so it can be turned into text. On a paid plan, when Vita reads a later report, your earlier values for the same tests go with it (section 4.13).
  • Files. PDFs, and images over 9 MB, are uploaded to Google's file service to be processed. Google deletes them after about 48 hours.
  • No training. Under the paid API terms we use, Google does not use this data to train its models. We never use your data to train any model, ours or anyone else's.
  • Memory. The AI also picks out facts from your conversations for Vita's memory (section 4.4).
  • Reading your own words. In the iPhone app, version 3.6.3 and later, small AI calls also read each message you send: one to find details to save (section 4.4), one to see whether you are asking the app to change something (section 4.12). They also read words you type into a Vita card. At the free limit a message can still be read this way, even though it gets no full answer. These calls see your words and, for the first one, the person's name and how they relate to you. They do not see your records.
  • Reading a document again. If Vita reads a saved document again (section 4.3), the document goes to Google again.
  • Answers read aloud. If you use voice, the answer text goes to Google to be turned into speech. If that does not answer in time, it goes to Microsoft (Azure AI Speech, in the EU) instead.
  • Vault files. The AI sees a vault file only when you ask for an AI description, summary or translation of it (section 7.2).
  • What the answers are. Vita explains health information. It does not diagnose or prescribe, and it does not replace a doctor. See the Medical Disclaimer.

10Who else receives your data

We share personal data with the processors below, who act on our instructions; with people you choose; and in the few other cases listed after the table. Our processors work under written contracts that require them to protect your data and to use it only to provide their service to us. MXroute, our email provider, offers no separate data-processing terms; it receives no health content. The full list, with addresses and transfer safeguards, is at /legal/subprocessors.

RecipientWhat it receivesWhere
Hetzner Online GmbHHosts both of our servers and our backupsHelsinki, Finland (EU)
Google LLC — Gemini APIEach question with its context, attached documents and photos, voice recordings, the words small AI calls read, the answer text to read it aloud; vault files only when you ask (section 9)United States
Microsoft (Azure AI Speech)The answer text, to read it aloud when Google's voice does not answer in timeEU (West Europe)
Cloudflare, Inc.All traffic, to protect our network. The secure (HTTPS) connection from your device ends at Cloudflare, so Cloudflare can see the traffic it carries — except vault files, which stay encryptedGlobal
Google LLC — FirebaseSign-in, push notifications, and app analytics and crash reports if you allow themUnited States
Apple Inc.Sign in with Apple, push notifications, App Store subscription statusUnited States
Google LLC — Google PlayAndroid subscription statusUnited States
MXroute LLCService email: your address and a templated message, never health contentUnited States (Texas)
Internal alerting serviceAlerts to our team with a masked email address, never health content—

Others who may receive personal data:

  • People you choose — anyone holding a doctor link and its code, and a family member you link with.
  • Authorities — only when the law requires it, for example under a court order. We check each request and tell you unless the law forbids it. From the vault we can give only encrypted files.
  • Professional advisers — lawyers and auditors, under a duty of confidentiality, and only as far as needed.
  • A new owner if the company is sold or merged — see section 19.

No sale, no advertising. We do not sell or rent personal data. We do not share it for targeted advertising. We use no advertising SDKs and do not work with data brokers. We give at least 30 days' notice before adding a processor that materially changes the processing; customers under our Data Processing Agreement may object as it describes.

11International transfers

VitaMedas is a US company. Our servers are in Finland, in the EU. Some processors are in the United States: Google (Gemini, Firebase, Google Play), Apple, Cloudflare and MXroute. Microsoft's speech service runs in the EU. When personal data leaves the EEA, the UK or Türkiye, we use these safeguards:

  • From the EEA: the European Commission's Standard Contractual Clauses (Decision 2021/914) and, where the recipient is certified, the EU-US Data Privacy Framework.
  • From the UK: the UK International Data Transfer Addendum (IDTA) to the EU Standard Contractual Clauses.
  • Email through MXroute: MXroute offers no contractual clauses, so we rely on Article 49(1)(b) GDPR — the transfer is needed to send you an email you asked for. These emails never contain health content.
  • From Türkiye: Article 9 KVKK — your explicit consent and, where applicable, undertakings approved by the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu).

Data travels over encrypted connections. Vault files leave your device only in encrypted form, wherever they are stored.

12How long we keep your data

Full detail is at /legal/data-retention. In short:

DataHow long
Conversations, attached documents, memory, people and their records, medicines, period data, visit pages, family linksUntil you delete them or your account
Health records vault (encrypted files)Until you delete them or your account
Account detailsFor the life of the account, then deleted as below
Ratings and notes on answersUntil you delete the conversation, the person it was about, or your account
Values read from your reportsUntil you delete the conversation, the document, the person or your account
Next-step log400 days (about 13 months), or until you delete your account
The latest report from your phoneUntil you delete your account
Log of changes made from a chat, with earlier valuesWhat you asked and the earlier value: cleared within about 30 hours, once Undo ends. The line that a change happened: 400 days. Deleting the person or the conversation removes it sooner
After you delete your accountGone from our live systems within 30 days of your request; gone from backups within a further 35 days
Files sent to Google's file serviceAbout 48 hours
Medicare access tokens (if you connect Medicare)Until you disconnect or delete your account; they stop working after at most 13 months
Server logsUp to 30 days
Security events30 days
Audit log (no content)5 years
Sign-in links sent by email15 minutes on vitamedas.com, 30 minutes for the app
Password-reset links sent by email1 hour
Doctor link tokensUp to 30 days
Cookie-consent records2 years
Billing and tax recordsAs long as the law requires (US federal tax rules: generally up to 7 years)

When you ask to delete your account in the app, it first gives you 7 days to change your mind. We then delete your account and everything listed in section 7.1, and your vault files with it. After deletion three things can remain: a pseudonymous record that an account existed and was deleted; records the law requires 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.

13Security and breaches

We protect your data with technical and organisational measures that fit the risk (Art. 32 GDPR; Art. 12 KVKK). More at /legal/security. In short:

  • HTTPS everywhere, with Secure and HttpOnly session cookies and protection against cross-site request forgery.
  • Vault files encrypted on your device (XChaCha20-Poly1305 with Argon2id); we hold no key.
  • Documents attached in a chat encrypted at rest with a key our server holds.
  • Staff access to readable data limited and logged (section 7.4).
  • Monitoring of sign-ins and unusual access, with security events kept 30 days.

No system is perfectly secure. We hold ourselves to a standard of care that fits the sensitivity of health data.

13.1If there is a breach

  • We tell you without unreasonable delay, and no later than 60 days after we discover the breach, as the US Federal Trade Commission's Health Breach Notification Rule requires. We tell you what happened, what data was involved, and what you can do.
  • We tell regulators: the FTC (and the media where that rule requires) and US state authorities where state law requires; in the EU and the UK, the data protection authority within 72 hours where Article 33 GDPR or UK GDPR requires; in Türkiye, the Personal Data Protection Board within 72 hours (Article 12(5) KVKK).
  • Where a breach is likely to put you at high risk, we tell you directly and without undue delay (Article 34 GDPR).

14Your rights

You have rights over your personal data. They are not absolute, but we act on every valid request within the legal time limits: one month under the GDPR and UK GDPR (we may extend this by two months for a complex request, and will tell you why), 30 days under the KVKK, and 45 days under US state laws.

RightWhat it meansHow to use it
AccessA copy of your personal data and how we use it.Email privacy@vitamedas.com.
CorrectionFix data that is wrong or incomplete.Edit it in the app or on the website, ask Vita in a chat, or email privacy@vitamedas.com.
DeletionDelete some of your data, or your whole account.Delete conversations, people, medicines and logs in the app. Delete your account in the app (Settings › Help & account › Contact support › Delete account), or email privacy@vitamedas.com. To remove a rating, a note or an entry in the log of changes, email us.
RestrictionPause processing while a dispute is settled.Email privacy@vitamedas.com (Art. 18 GDPR).
PortabilityReceive your data in a machine-readable format.Email privacy@vitamedas.com. You can also download your vault files from the vault.
ObjectionObject to processing based on our legitimate interest.Email privacy@vitamedas.com.
Withdraw consentWithdraw any consent: health data, analytics, marketing, Apple Health or Health Connect, Medicare.Turn the feature off or disconnect it in the app; for marketing email, you can also ask Vita in a chat or use the unsubscribe link in the email; or email us. To take back your yes on the consent card, use the Personalize Vita for me switch in Settings › Health-data consent, or email us; a chat cannot change it (section 6.1). Withdrawing consent to health data means deleting that data.
No solely automated decisionsNot to be subject to decisions made by automation alone with legal or similar effects.We make none — see section 15.
ComplaintComplain to a regulator.See section 21.
Türkiye (Art. 11 KVKK)Further rights, including to learn whether your data was transferred abroad and to compensation for damage.privacy@vitamedas.com.
United StatesRights under the CCPA/CPRA, Washington's My Health My Data Act and other state laws, including appeals.See US State Privacy Rights and the Consumer Health Data Privacy Policy. We answer within 45 days (up to 45 more, with notice).

We may need to check that a request really comes from you, usually by confirming you control the account email. Requests are free. If a request is clearly unfounded or excessive, we may charge a reasonable fee or refuse it, as Article 12(5) GDPR allows, and we will tell you why.

15Automated decisions and profiling

We make no decisions about you by automated means alone that have legal or similarly significant effects (Article 22 GDPR). These automated things do happen, and you should know about them:

  • Safety check. Each message is checked automatically for signs of an emergency or self-harm, so Vita can show emergency or crisis numbers straight away. It changes the reply you see. It does not change your account.
  • Vita's memory. Vita builds a picture of your health from what you tell it, so its answers fit you. This is a form of profiling. It is used only to answer you, never to decide anything about you, and you can remove it at any time (section 4.4).
  • Details saved from a chat. A small AI call reads your words and saves details to a profile (section 4.4). You can undo or change them.
  • Changes you ask for. The AI reads your request and our server applies it, with Undo (section 4.12).
  • Your next step. If you said yes on the consent card (section 6.1), code, not AI, picks one suggested step and decides when to show a plan offer (section 5). It changes nothing on your account, and you can ignore it.

16Children

You must be 18 or older to have an account. Vita is not for children to use, and we do not knowingly collect personal data directly from children. Parents and guardians can keep a child's health record inside their own account (section 4.5). We collect it from the parent, never from the child, and the parent can see, change or delete it at any time. We never sell children's data or use it for advertising. Where Turkish law applies, the parental-consent rules of Article 6 KVKK and the Turkish Civil Code apply.

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.

17Cookies and similar technologies

On the website we use a small number of cookies and browser storage entries — for sessions, security (CSRF), language and an encrypted cache of your vault key. The full list is in our Cookie Policy. We use no advertising pixels, no third-party tracking cookies and no fingerprinting. In the app, analytics run only if you allow them (section 4.9).

18Doctors and clinics

  • If you open a doctor link that a patient gave you, we record each time it is opened (time, IP address, device), and the patient can see that record. You do not need an account to open a link.
  • If you create the optional, free doctor account, we keep the email address, display name, and the hospital or clinic and specialty you give us, so patients can tell which notes are yours.
  • If you upload records through an intake link, the files are stored encrypted for the patient who created the link.
  • Clinics and other organisations that use VitaMedas for their patients under a contract with us are the controller of that patient data, and we are their processor under our Data Processing Agreement.

19If VitaMedas is sold or merged

If VitaMedas merges with another company, is bought, or sells all or part of its business, your personal data may pass to the new owner as part of that deal. Before your data moves to a new owner that would handle it under a different privacy policy, we will tell you, and you will be able to delete your account and your data first. The vault stays sealed: a new owner receives the same encrypted files we hold, and no key.

20Changes to this policy

We may update this Policy. The version and the date it takes effect are at the top of the page.

  • Material changes — we tell you by email and with a notice in the app at least 30 days before the change takes effect.
  • New uses of health data — we will not use your health data in a new way without first asking for your consent.
  • Small changes — typos, clearer wording or new contact details — we may publish without separate notice.

Previous versions are available on request.

21Complaints and regulators

If you think we have handled your data wrongly, please tell us first at privacy@vitamedas.com. We treat it as a formal complaint. You can also complain to a regulator:

  • United States — your state Attorney General, or the Federal Trade Commission at reportfraud.ftc.gov. California residents can also contact the California Privacy Protection Agency at cppa.ca.gov. How to appeal a decision of ours is in US State Privacy Rights.
  • European Union — the supervisory authority of the EU Member State where you live or work, listed at edpb.europa.eu.
  • United Kingdom — Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF — ico.org.uk
  • Türkiye — Kişisel Verileri Koruma Kurumu (KVKK Authority), Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4 Balgat, Çankaya / Ankara — kvkk.gov.tr

22How to contact us

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

Email:

Statutory references

  • CCPA / CPRA · California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended by the CPRA
  • MHMD · Washington My Health My Data Act, RCW 19.373
  • FTC HBNR · 16 C.F.R. Part 318 — Health Breach Notification Rule
  • GDPR · Regulation (EU) 2016/679 (General Data Protection Regulation)
  • UK GDPR · UK GDPR; Data Protection Act 2018
  • SCCs · Commission Implementing Decision (EU) 2021/914
  • ePrivacy Directive · Directive 2002/58/EC, Art. 5(3)
  • KVKK · Kişisel Verilerin Korunması Kanunu No. 6698 — applies to our users in Türkiye
  • Health Data Reg. · Kişisel Sağlık Verileri Hakkında Yönetmelik, 21.06.2019

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 v3.5 · Previous versions available on request.