US State Privacy Rights

This document explains the privacy rights of US residents and makes the disclosures that the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the CCPA), requires.

Roughly twenty US states now have comprehensive privacy laws, and they differ in detail more than in substance. Rather than publish a state-by-state maze, we grant every right in this document to every user in the United States, whichever state you live in — including states with no privacy law at all. Section 9.1 shows where each right is a legal entitlement rather than our policy, because that difference matters if you ever need to enforce it.

Health data has its own document: Consumer Health Data Privacy Policy. If you live in Washington, Nevada, Connecticut or Virginia, read that one too — it gives you rights this one does not. Users in the EEA, the UK and Türkiye should read the Privacy Policy, which is where GDPR and KVKK rights live.

In the twelve months preceding the effective date of this document, and at every point before it, VitaMedas, Inc. has:

• not sold personal information, as “sale” is defined by any US state privacy law — including the broad definitions that cover exchange for anything of value rather than only for money;
• not shared personal information for cross-context behavioural advertising;
• not sold or shared the personal information of any consumer we knew to be under 16;
• not used personal information for targeted advertising or for profiling in furtherance of decisions producing legal or similarly significant effects.

There is therefore no “Do Not Sell or Share My Personal Information” link on this site, because there is nothing for it to do. We are not a data broker and are not registered as one in California or Vermont, because we do not meet the definition.

Our revenue is subscriptions paid by users. That is the whole business model, and it is the reason the rest of this document is short.

The CCPA defines eleven categories of personal information plus sensitive personal information. This is every one of them, and our answer for each.

The CCPA treats health information as sensitive personal information (SPI), and so do we. The SPI we collect is:

• Health information — your questions and our answers; documents and photos you attach; the records in your vault; profiles of you and the people you add, children included; remembered health facts; your medicines; period and pregnancy data; children’s records; care team notes; visit pages; what a family member shares with you; health readings from Apple Health or Health Connect sent with a question; Medicare claims, if you connect Medicare; values read from your reports; ratings and notes on answers, the next-step log and the log of changes made from a chat; and anything inferred from them.
• Account log-in credentials — the authentication material for your account. Passwords are never stored in a readable form, and your vault passphrase is never transmitted to us at all.

We use SPI for exactly one thing: performing the service you asked for — answering your question, storing your record, keeping the account secure. We do not use or disclose it to infer characteristics about you, and we do not use it for any purpose outside those permitted by Cal. Civ. Code 1798.121(a) and the corresponding regulations. A plan offer inside the app appears only if you said yes on the consent card (section 11 of the Consumer Health Data Privacy Policy). It looks at counts and at whether a report is on file, never at what a question or a report says.

• You — directly, through the app: what you type, say, attach, scan, and enter in a profile or a Vita card.
• 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 and is not kept as a record.
• Apple’s Medications list — medicines you pick “From Apple Health” become entries in your medicines cabinet.
• Period sync — period data from Apple Health or Health Connect, when you turn it on.
• Health Connect on Android, if you connect it — health metrics, read on your phone in the same way.
• Your vault, when you choose — a summary of a vault document you let Vita learn from.
• Other users — a family member who chooses to share with you through a family link.
• Medicare, if you connect it — your claims, fetched when you ask and kept only on your phone. See section 4.1 of the Consumer Health Data Privacy Policy.
• Your device — app language, OS version, push token, time zone, the country your network connection comes from, and the short report in section 3 (category F); diagnostics only if you allowed analytics.
• Identity providers — Apple or Google, if you sign in that way.
• App stores — the App Store and Google Play, for subscription status only.

We do not buy personal information, obtain it from data brokers, or scrape it from anywhere.

1. Providing the service: answering questions, storing and showing records, medicine schedules and reminders, doctor links and visit pages.
2. Running the safety pipeline that keeps the assistant on the right side of the explain/diagnose line.
3. Account management, authentication, and subscription billing.
4. Notifications you have not turned off.
5. Showing you one suggested next step in the app, if you said yes on the consent card.
6. Offering you a Vita plan inside the app, if you said yes on the consent card.
7. Support, and diagnosing faults you report.
8. Security, abuse prevention, rate limiting, and fraud detection.
9. Product analytics and crash reports, only if you allowed analytics in the app.
10. Complying with law, and establishing or defending legal claims.

We do not use personal information for any purpose materially different from these without telling you first.

We disclose personal information for business purposes only, to service providers and contractors bound by contracts that forbid them from retaining, using or disclosing it for anything other than performing the service for us.

Our own servers are in Helsinki, Finland. We do not run servers in the United States. Records you read from Apple Health stay on your phone, and so do Medicare records if you connect Medicare. Vault files are stored only as ciphertext.

When you create a doctor link or a family link, you choose what the other person can see. That is a disclosure you make, and you can stop it.

The authoritative list, with addresses and transfer safeguards, is at Sub-processors. We may also disclose information to comply with law or to protect rights and safety, as described in the Acceptable Use Policy.

The CCPA requires a retention period, or the criteria for one, for each category. The full schedule is in the Data Retention Policy. In summary:

We keep one backup copy of the Vita app database a day for 30 days, and any extra copy, of it or of the vault server, is removed within 35 days, which is why a deleted item can remain in a backup for up to 35 days.

1. Know and access — what we collect, the sources, the purposes, the recipients, and a copy of the specific pieces of information we hold about you.
2. Delete — subject only to the narrow exceptions the statutes allow, such as a specific legal retention duty.
3. Correct — inaccurate personal information.
4. Portability — a copy in a portable, machine-readable format.
5. Opt out of sale, sharing, targeted advertising and profiling — we do none of these, so there is nothing to opt out of. The right is listed so you know it is not being withheld.
6. Limit the use of sensitive personal information — see section 4.
7. Appeal a refusal, and then complain to your Attorney General.
8. Non-discrimination for exercising any of them.

There are three ways, and you do not need a reason for any of them:

1. In the app — you can delete conversations, people, medicines and log entries, and delete your account and its contents (Settings › Help & account › Contact support › Delete account), without contacting anyone. To remove a rating, a note or an entry in the log of changes, email us.
2. By email — privacy@vitamedas.com, including for a copy of your data.
3. By post — the address in section 16.

Several states require us to honour a browser or device signal that opts you out of sale and targeted advertising. We recognise the Global Privacy Control signal on our website and treat it as a valid opt-out.

In practice it changes nothing about what happens to your data, because we never sell or share it and run no advertising. It does switch off non-essential analytics cookies on the website — see Cookies. We would rather honour a signal that costs us nothing than argue that it does not apply.

We will not deny you the service, charge you a different price, give you a lower quality of service, or suggest that we might, because you exercised a privacy right. Deleting your data will end your ability to use features that depend on that data — that is a consequence of deletion, not a penalty for asking.

We operate no financial-incentive or loyalty programme, and we do not offer anything of value in exchange for personal information. There is therefore no notice of financial incentive to give.

You must be 18 or older to hold an account. We do not knowingly collect personal information from anyone under 13, and we never sell or share the personal information of anyone — so the opt-in consent that several states require before selling the data of a consumer under 16 never arises.

California residents under 18 who are registered users have the right to request removal of content they posted. Tell us at privacy@vitamedas.com and we will remove it, though we note that our minimum age means such an account should not exist and we will close it.

California’s “Shine the Light” law lets you ask, once a year and free of charge, what personal information a business disclosed to third parties for their own direct-marketing purposes.

Our answer is fixed and we will give it to you in writing on request: none. We disclose nothing to anyone for their own direct-marketing purposes.

This document, together with the Privacy Policy, the Consumer Health Data Privacy Policy and the Data Retention Policy, constitutes our notice at collection. It is linked from the point of sign-up, from the app’s settings, and from every page of this site. We collect nothing before you have had the chance to read it.

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

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