# Privacy Policy

Version 2.0 · Last updated 12 October 2026 · Effective 30 days after publication

Novak Consulting Ltd, a company registered in New Zealand ("we", "us", "our"), provides Vitality Tracker: the website and web app at **vitalitytracker.app** and the **Vitality Tracker mobile app** for iPhone and Android (together, the "Service"). This policy explains what personal information we collect, where it comes from, what we do with it, who else handles it, how long we keep it, and how you can control it.

Vitality Tracker is in **beta**. The Service changes often, and this policy changes with it (see *Changes*).

## 1. The short version

- We collect health and fitness information **only from sources you connect or enter yourself**, and only what you allow.
- We use it to **show you your own health picture** and to **build and improve Vitality Tracker's scores, algorithms and devices**.
- We **never sell** your information, never use it for **advertising**, and never use Apple Health data for marketing or data mining.
- You can **disconnect any source**, **turn off** the weekly report, and **delete your account in the app** at any time.

## 2. What we collect

### 2.1 Your account

Email address (your username); password (stored only as a one-way hash by our authentication provider); first and last name; date of birth; biological sex; country; time zone; height; waist and hip circumference; maximum heart rate; your unit choice; and the goals you set (sleep, steps, training load, target weight).

### 2.2 What you enter yourself

On the web and in the app you can log weight, body fat, energy used and eaten, protein, fat and carbohydrates, meals, sleep and fasting hours, VO₂ max, resting heart rate, heart rate variability, steps, exercise and training sessions, protocols, a daily journal (how you feel), and notes and annotations. In the app you can also log blood glucose, ketones, Lumen readings, blood pressure, sickness episodes, hydration, alcohol, bowel movements, menstrual periods, night-time events, and your morning alarm time.

### 2.3 Apple Health (iPhone) and Health Connect / Samsung Health (Android)

If you allow it, the app **reads** from Apple Health — or, on Android, from Health Connect and Samsung Health — the categories you approve on the system permission screen. You choose each category there and can change your answer at any time in your phone's settings. The app asks to read only what its features use:

- **Sleep:** time in bed and asleep, and sleep stages.
- **Heart:** heart rate, resting heart rate, heart rate variability, and heart rate recovery after exercise.
- **Breathing and blood:** blood oxygen (SpO₂), respiratory rate, blood pressure and blood glucose.
- **Temperature:** wrist temperature during sleep (iPhone) or skin temperature (Android).
- **Activity:** steps, active and resting energy, VO₂ max, walking step length and mindful minutes; on Android also distance, elevation and total energy.
- **Workouts:** type, duration, energy, effort, swimming strokes, and the **workout route**, which is precise location (see 2.6).
- **Body measurements:** weight, body fat and height.
- **Nutrition:** energy, protein, fat and carbohydrates.

The app **writes** to Apple Health / Health Connect only what you log or measure with it, so your other apps can see it too:

- **Meals** you log: energy, protein, fat, carbohydrates, saturated, monounsaturated and polyunsaturated fat, fiber, sugar and sodium.
- **Water** you log in Hydration.
- **Blood pressure** you enter.
- **Blood glucose** readings from a glucose sensor you connected.
- **Weight and body fat** from a VT Longevity Pro Scale.

It does not ask for anything else — no ECG, cycle tracking, hearing, or the date of birth, sex or blood type stored in Apple Health.

### 2.4 Services you connect

When you connect another service, you sign in to **that service** and approve what it shares with us. We receive the data it makes available for the permissions you approved, and keep the access key it issues on your phone. You can disconnect at any time in the app.

| Service | What we receive (as approved by you) |
| --- | --- |
| **Oura** | Sleep, readiness, activity, heart rate, HRV, SpO₂, stress, workouts, tags, sessions, ring settings, your email and basic personal info |
| **Withings** | Weight and body composition (including segmental fat and muscle), blood pressure, activity |
| **Polar** | Training sessions, activity, sleep, nightly recharge, heart rate, your physical info |
| **Google Health (Fitbit)** | Activity and fitness, health metrics and measurements, sleep, nutrition, and location data for workouts |
| **LibreLinkUp (Abbott)** | Glucose readings from your FreeStyle Libre sensor. Your LibreLinkUp email and password are kept **only on your phone** and are never sent to us. |

### 2.5 Vitality Tracker devices and chest straps

The app talks to these devices directly over Bluetooth. Their makers do not receive your information.

- **VT Longevity Pro Ring and VT Longevity Pro Band:** heart rate, heart rate variability, blood oxygen (SpO₂), stress, respiratory rate, skin temperature, sleep and sleep stages, steps and activity, and the workouts the device records, including those you start in the app.
- **VT Longevity Pro Scale:** weight and body composition (including segmental fat and muscle), and the electrical measurements it is calculated from.
- **A heart-rate chest strap** (such as the Polar H10), if you add one: heart rate and the time between heartbeats. The app uses them for your live heart rate and HRV and, if you choose, for your workouts' heart rate. Recordings you make with the strap are kept as files **on your phone only**; they are not in backups or the weekly report, and reach us only if you share them.
- **Device details:** the device's name, Bluetooth identifier, battery level and firmware version.
- **Device logs:** to diagnose connection problems, the app keeps a log of its Bluetooth exchanges with your ring or band on your phone, including the readings the device sends. The log is limited in size, oldest entries removed first. It reaches us only if you send it from the device's card in the app.

### 2.6 Location

We do not track where you are. The app uses your phone's location only while an **outdoor workout you started in the app** is running, and only with your permission, to measure its distance, pace and route. Workout routes — the ones the app records and the ones you recorded with Apple Health or Google Health — **stay on your phone**, where they show your workouts on a map; they are left out of backups and of everything the app sends us. Otherwise location reaches us only as the country and time zone you give us.

### 2.7 Your device and the app

The device name you choose for the app, your phone's operating-system version, the app version, and — in the weekly report (section 4.2) — a description of which apps and devices on your phone record which kinds of health data.

### 2.8 The website

When you use the website we collect technical and usage information through cookies and similar technologies. See our **Cookie Policy**. The mobile app does not use cookies and does not track you across other companies' apps or websites.

## 3. How we use it

We use your information to:

1. **Provide the Service:** show your data; compute your scores and estimates (such as Capacity, sleep scores, Vitality Score, Metabolic Age, Vascular Age, body composition and energy needs); send the reminders and alerts you turn on.
2. **Build and improve Vitality Tracker:** learn which apps and devices our members use and what each of them records, and develop and check our algorithms, scores and devices against it. This is product development for a wellness service, not a research study.
3. **Explain your numbers with AI** when you ask (section 5).
4. **Keep your account working and secure:** sign-in, backups, troubleshooting, preventing misuse.
5. **Support you** when you contact us, and send you service emails (such as sign-up codes and important changes).
6. **Meet legal obligations.**

We do **not** use your information for advertising, we do **not** sell it, and we do **not** use information from Apple Health for marketing, advertising or use-based data mining.

## 4. Where your information goes

### 4.1 Our systems

- **Your account and health data** are stored in our database, hosted by **Supabase in Sydney, Australia**. Access is restricted per account, and data is encrypted in transit and at rest.
- **Daily backup:** once a day, while the app is open, the app uploads a backup of the data it keeps on your phone to private storage in the same place, so it can be restored if your phone is lost or replaced. We keep every backup from the last 7 days, then one a week for the 4 weeks before that, then one a month for the 3 months before that — so no backup is more than about 4 months old. Older ones are deleted automatically.
- **Glucose, ketones and their notes:** your glucose and ketone readings, and the notes and markers you attach to them (meals, exercise and similar), are stored in our glucose service, hosted by **Amazon Web Services in Auckland, New Zealand**.

### 4.2 The weekly report (app, only with your permission)

Once a week, if you allow it, the app checks the sources you connected and sends us a report: which kinds of data each source provides, the underlying readings (mostly from the last 7 days; some from up to 90), and the summaries the app computed (Capacity, sleep scores, activity, and your logs). It does **not** include your whole on-device database. The app asks before the first report, and you can turn it off in **Settings → Send to VT**. Reports are filed under your account, stored privately in Sydney, Australia, and read by the Vitality Tracker team for the purposes in section 3.2. They are not used for a research study.

### 4.3 Service providers

These companies process information for us, under their own security and privacy commitments, and only to provide their service to us:

| Provider | What for | Applies to |
| --- | --- | --- |
| Supabase | Database, sign-in, file storage (Sydney, Australia) | Web and app |
| An AI service provider (United States) | AI explanations ("Ask Eir", section 5) | Web and app |
| Amazon Web Services | Hosting our glucose service (Auckland, New Zealand) | App |
| SendGrid (Twilio) | Sending emails | Web and app |
| Help Scout | Customer support | Web and app |
| Cloudflare | Network delivery and security | Website |
| Google (Tag Manager, Analytics, Firebase) | Website usage analytics — see the Cookie Policy | Website |
| Sentry | Error and crash reports | Website |
| Meta (Facebook) and TikTok | Advertising measurement pixels on the website, only if you accept marketing cookies — see the Cookie Policy. **Never** sent health data. | Website |

### 4.4 Other sharing

We share your information otherwise only:

- **When you choose to:** for example when you share a report or a screenshot, or send a link to a professional.
- **When the law requires it:** for example a court order.
- **If our business changes hands:** a buyer would be bound by this policy.

The Vitality Tracker team can access account information to run the Service and support you, can access health data to investigate a problem you report or keep the Service secure, and reads the weekly reports you agreed to send. We do not let anyone else read your health data.

### 4.5 Google services

The use of information received from Google Health API and/or Developer Tools will adhere to the [Google Health API Developer and User Data Policy](https://developers.google.com/health/policies/health-api-developer-user-data-policy), including the Limited Use requirements. Information received from other Google APIs adheres to the [Google API Services User Data Policy](https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.

In practice, information we receive from Google:

- is used only to provide and improve the features you see in Vitality Tracker;
- is shared with others only with your consent for those features (for example an AI explanation you ask for, section 5), or for security, to comply with the law, or as part of a merger or acquisition with your prior consent;
- is read by people only with your consent (such as the weekly report you agreed to send, section 4.2), for security, to comply with the law, or in aggregated, anonymized form for our internal operations;
- is **never** sold, never used or transferred for advertising, and never used to decide credit-worthiness or for lending;
- is never used for medical diagnosis or treatment, or for research.

## 5. AI explanations ("Ask Eir")

When you tap an "Ask Eir" button, the app sends the numbers behind that screen — for example your HRV, resting heart rate, sleep, stress, training load and recent symptoms, with up to 7 days of history — to our server, which passes them to a **third-party AI service provider in the United States** to write the explanation. With them go your **age, sex and account ID**, so the explanation fits you and the request can be traced if something goes wrong; never your name or email address. The provider is set **not to use your information to train its AI models**. The app asks for your permission before the first explanation, and you can withdraw it at any time in **Settings → AI explanations**. Eir is not offered on screens whose data comes from Oura.

## 6. How long we keep it

- While your account is open, we keep your information so the Service can show your history.
- **When you delete your account** (in the app: *My Profile → Delete account*; or by writing to us), it closes immediately and your information — including backups and weekly reports — is **permanently erased within 60 days**. Until then you can ask us to restore it.
- **If you have ever connected Oura**, your account and all its information are erased **within 72 hours** of your deletion request instead, as Oura's terms require — so it cannot be restored.
- **Inactive accounts:** after 6 months without use, we delete an account and its information, backups and weekly reports included.
- **Disconnecting a service** stops us receiving new data from it. What we already received stays in your account until you delete it or your account.
- Information on your phone is removed when you delete your account in the app.

## 7. How we protect it

Data is encrypted in transit (TLS) and at rest. Each account can reach only its own data. Access keys for connected services are kept in your phone's secure storage (Keychain on iPhone). We limit who on our team can access personal information. No system is perfectly secure; if a breach affects you, we will tell you and the relevant authorities as the law requires.

## 8. International transfers

Your information is stored in Australia (your account, health data, backups and weekly reports) and New Zealand (glucose and ketone readings), and some of our service providers process it in other countries, including the United States. When we send information abroad, we take reasonable steps to make sure it is protected to standards comparable to New Zealand's Privacy Act 2020.

## 9. Your rights and choices

You can:

- **See** most of your information in the Service, and ask us for a copy.
- **Correct** it in the Service or by asking us.
- **Delete your account** in the app (*My Profile → Delete account*) or by writing to us.
- **Export** your data (CSV on the web; reports and the share function in the app).
- **Withdraw permission** at any time: disconnect a service; turn off the weekly report (*Settings → Send to VT*); revoke Apple Health or Health Connect access in your phone's settings; turn off notifications.
- **Object** to processing, or ask us to restrict it.

Write to **hello@vitalitytracker.app**; we answer within 20 working days. If you are not satisfied, you can complain to the New Zealand **Office of the Privacy Commissioner** (privacy.org.nz), or to the data protection authority where you live.

## 10. Children

The Service is for people **18 and over**. We do not knowingly collect information from anyone younger; if we learn we have, we delete it.

## 11. Changes

We will tell you about changes by email or in the Service and update the date at the top. Significant changes take effect at least **30 days** after we tell you.

## 12. Contact

**Novak Consulting Ltd**, Auckland, New Zealand · **hello@vitalitytracker.app**

Contact: hello@vitalitytracker.app

Source: https://vitalitytracker.app/legal/privacy