VitaCoach AI Privacy Policy

Effective Date: 13 October 2025
Last Updated: 13 October 2025

1. Introduction

VitaCoach AI Limited ("VitaCoach AI", "we", "us", "our") is committed to protecting your personal information in accordance with the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

This Privacy Policy explains how we collect, use, and protect your data when you use our mobile app or website.

By using VitaCoach AI, you consent to the practices described in this policy.

2. Information We Collect

Personal Information: Name, email address, age, gender (optional).
Health and Wellness Data: Health conditions, history, weight, height, BMI, hydration levels, dietary goals, activity levels, sleep hours, calorie intake, and other manually logged wellness metrics.
Wearable Data: Steps, heart rate, workouts, sleep quality imported from Apple Health (HealthKit) or Google Fit with your consent.
AI Chat History: Interactions with the AI coach and related insights.
Usage Data: App interactions, session length, feature usage.
Device Information: Device type, OS version, unique identifiers, crash logs.
Payment and Subscription Data: Managed by Apple or Google. VitaCoach AI receives only transaction identifiers and subscription status.
Support and Communication Data: Emails, feedback, and support requests.

3. How We Collect Information

Directly from users during account creation or profile updates.
Automatically through usage analytics such as Firebase Analytics.
From connected wearables including HealthKit or Google Fit.
From AI chat interactions processed through the OpenAI API.
Via cookies and tracking technologies on our website, including Google Analytics, Meta Pixel, and TikTok Pixel.

4. Purpose of Data Collection

Provide personalised AI health and wellness coaching.
Enhance wellness features and recommendations.
Track nutrition, hydration, activity, and progress over time.
Generate insights and reports for users.
Improve AI accuracy and app performance.
Send updates, reminders, and support notifications.
Manage subscriptions and payments.
Ensure legal compliance and maintain security.

5. Legal Basis for Processing (GDPR)

Data Type	Legal Basis
Account and Profile Data	Contract performance
Health and Wellness Data	Explicit consent (Article 9(2)(a))
AI Chat Data	Legitimate interest or consent
Payment Data	Contract performance
Analytics Data	Legitimate interest
Marketing Communication	Consent (opt in)

You may withdraw consent at any time through the app settings.

6. Data Sharing and Disclosure

We may share your data with the following parties:

Service Providers: Firebase for hosting, OpenAI for AI processing, Passio SDK for food recognition, Open Food Facts for nutrition data.
Analytics Partners: Google Analytics, Meta, TikTok (website analytics only).
Payment Platforms: Apple and Google for subscription management.
Legal Authorities: When required by law or to enforce our Terms.
Business Transfers: If VitaCoach AI is acquired or merged.

We do not sell personal or health data.

7. Data Security

We implement the following security measures:

TLS 1.2 or higher encryption for data in transit.
AES 256 encryption for data at rest.
Access controls and audit logging.
Secure data centres within the UK.
Pseudonymisation where appropriate.
Network monitoring and regular security audits.
Independent penetration testing.

Staff with access to sensitive data receive appropriate training and are bound by confidentiality obligations.

If a data breach occurs, we will notify the Information Commissioner’s Office within 72 hours and communicate relevant details to affected users when necessary.

8. Data Retention

Data Type	Retention Period
Account Data	For as long as the account is active plus 90 days after closure
Health and Wellness Data	Until the user deletes their account or withdraws consent
AI Chat Data	Up to 12 months
Payment Data	Stored according to Apple or Google policies
Analytics Data	24 months and anonymised thereafter

9. Your Rights Under GDPR

Users have the right to:

Access their personal data.
Request corrections to inaccurate information.
Request deletion of their data.
Restrict or object to processing.
Withdraw consent at any time.
Request data portability.
Lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk.

Contact: privacy@vitacoachai.com

10. Children’s Privacy

VitaCoach AI is not intended for users under 16 unless parental consent is provided. If we learn that a child has registered without consent, we will delete their information promptly.

11. International Data Transfers

Data may be processed in countries outside the UK, including the United States. All transfers comply with UK GDPR adequacy decisions or standard contractual clauses to ensure equivalent protection.

12. Cookies and Tracking

We use cookies for:

Analytics and usage measurement.
Marketing attribution on our website.

You can manage cookie preferences through your browser or device settings.

13. Third Party Links

Our app and website may contain links to third party sites. We are not responsible for their privacy practices or content.

14. AI Specific Privacy Considerations

AI chat interactions are pseudonymised before processing.
OpenAI processes chat data only to generate responses and does not use it to train public models.
No human reviews private chat data unless required for debugging or preventing misuse.

15. Wearable Device Integration

If you connect Apple Health or Google Fit, VitaCoach AI may import metrics such as steps, heart rate, sleep, workouts, and weight.

You can revoke access in your device settings or within the app. Wearable data is used solely to enhance coaching and is not used for advertising.

16. Changes to This Policy

We may update this Privacy Policy periodically. If material changes occur, we will notify users by email or in app notification before the changes take effect.

17. Contact Information

VitaCoach AI Limited
5 Jardine House, Bessborough Road
Harrow, HA1 3EX
United Kingdom
Email: privacy@vitacoachai.com