Consumer Health Data Privacy Policy.

1. What counts as consumer health data

“Consumer health data” means personal information linked to you that identifies your past, present, or future physical or mental health status. It is read broadly: it covers your diet, nutrition, body measurements and health goals, from your first use, and not only clinical records. Values we work out from what you enter (such as BMI, your steps-to-goal activity ratio, and your non-clinical “momentum” consistency score) count too. We treat everything in §2 as consumer health data, and call it “health data” for short below.

2. Health data we collect

We collect only what the features you use need.

Collected for every user, because the core of Vyra is food and nutrition tracking:

• Food and diet logs: meals you describe or photograph, the recognized food items, portions, and their nutrition values (calories, protein, carbs, fat, fiber, sugar, sodium).
• Meal photos: the image, when you log a meal by photo or scan a barcode (§3 covers how we keep and use it).
• Body and profile: weight and weigh-in history, height, sex, activity level, unit preference, and time zone. If you connect Apple Health or Health Connect and allow it, a body-weight reading imported from there becomes an entry in that same weigh-in history and is saved to your account, exactly like a weight you type in yourself (see §3).
• Goals: your calorie, macro, water and step targets, target weight, goal direction, and pacing preference.
• Hydration: each drink you log: when, which drink (such as water, coffee, tea, milk, juice, or an alcoholic drink if you log one), which cup, how much, and how much counts toward your water goal. Your daily total comes from these.
• Dietary preferences you enter: diet style, eating pattern, intermittent-fasting window, and any allergies (allergy matching happens on your device, and your allergies are not sent along when we recognize your food).
• Activity: a daily summary of your steps against your step goal and, if you count your movement from a fitness tracker, that choice and a calorie target your phone works out (§3 says exactly what).
• Progress signals: a non-clinical “momentum” consistency score and saved insight summaries, both based on your logging.
• Reminders you set.

Optional. Medications: each medication you add, with its dose and schedule; the doses you log, including where you injected; and the side effects you note, with how strong they felt. Nothing about medications is collected unless you add one.

Not collected in the released app. These parts of Vyra are built but turned off, and collect nothing unless we turn them on, update this policy, and (where required) ask for your consent:

• Conditions (a condition label and an optional standard code).
• Uploading lab and blood-test documents and reading results from them.
• Insights that combine your food with medications or labs.
• Personalized clinical guidance (“caution”-tier) behaviors.

3. Where the data comes from

• You: everything you type, log, photograph, or set in the app.
• Apple HealthKit / Android Health Connect: only if you connect it, and only for the types you allow. Vyra asks to read three things: your steps, your active energy burned, and your body weight. In the same permission screen it asks to write, as set out under “What Vyra writes back” below. The three reading types are handled differently:
  • Steps and active energy. Your raw step and active-energy readings stay on your device, where Vyra uses them to show your step trend and a “burned” figure beside what you have eaten. What reaches us is one number per day: how much of your own daily step goal you reached, capped at 100%. If you choose to count your movement from a fitness tracker, we also receive that choice and a daily food calorie target that your phone works out from your tracker’s usual day. Together with your calorie goal, that target shows how much your tracker usually records you moving in a day, and your nutrition targets reflect that usual day too. Which tracker you use stays on your device.
  • Body weight: this one does reach us. If you allow it, Vyra imports your most recent weight reading (for example one recorded by a smart scale) into your Vyra weight log, at most one entry per calendar day. It is saved to your account just like a weight you type in yourself, which is what lets your weight history survive reinstalling the app or moving to a new phone. You can see it, correct it, and delete it in the app (§7).
• RevenueCat (subscription processor): your subscription status (trial, active or lapsed) and plan, tied to an account ID, so we know what you have access to. This carries no health information.
• Meta Muse (a service you connect): only if you connect Vyra to Meta’s Muse agent, and only what you ask it to send: your words and, when it has one, a photo of the food. We answer with an estimate, and we save a meal to your account only when you ask. Muse acts for you under Meta’s own privacy terms and is not a processor of ours (§5). What it sends is collected on the same necessity basis as an entry you type in the app (§6), and §8 says how long we keep it. You can disconnect it at any time in Muse. Details: Vyra for Muse.

What Vyra writes back to Apple Health / Health Connect. The connection runs in both directions: Vyra also writes entries you logged in Vyra into the Apple Health / Health Connect store on your phone, so the other apps you trust can read them. You can refuse that half and keep the reading half, or allow only part of it: Vyra writes only the types you granted, and if you grant none it writes nothing. It copies only:

• Your weigh-ins: the weight and when you recorded it, for weigh-ins that started in Vyra (typed on the weigh-in screen, entered in chat, or the starting weight you gave during onboarding). A weight Vyra imported from your health app is normally held back, since it is already there. The exception: if you log a weight in chat for a day your health app had already covered, that day’s entry can be written back carrying the imported reading.
• Your meals: for each food item you logged, its name in your Vyra log, when you logged it, which meal it belonged to (breakfast, lunch, dinner or snack), its calories, and its protein, carbohydrates, fat, fiber, sugar and sodium.
• Your water: each drink you log, as its own entry, with the volume and when you drank it.

Three limits apply. It is forward-only: Vyra copies what you log or edit after you turn writing on, and does not copy your earlier history. Deletions follow: remove a meal, weigh-in or drink in Vyra and the copy Vyra wrote is removed too, although Vyra can only remove records it wrote itself. And it happens on your own phone: nothing about this step reaches our servers, any processor in §5, or our analytics. Once an entry is in your health app, Apple’s or Google’s terms and your own settings there apply, including any backup or sharing you have turned on.

Meal photos. A meal photo you take is sent to our AI processor for food recognition (§5) and is stored with your account, encrypted and kept apart from other accounts. We keep it while your account is active and use it to run food logging and to check and improve the accuracy of our food recognition, which can include a member of our team reviewing a photo when you report a wrong result or ask for help. A photo sent through Meta Muse is kept for 30 days instead (§8). We do not use your photos to train AI models, and we never run facial recognition on them or extract biometric identifiers from them. No setting changes either. Photos are permanently purged when you delete your account (§8). A copy also stays in an encrypted store on your device, and that copy is what your in-app history shows.

4. How we use it

We use your health data only to provide and improve the features you use:

• Recognize and log your meals and work out their nutrition values.
• Check and improve the accuracy of that food recognition, including a member of our team reviewing a stored meal photo when you report a result as wrong or ask us for help (§3).
• Track your intake against your goals and show your progress and trends.
• Deliver the reminders you set.
• Keep your account, sync your data across your own devices, and restore it if you reinstall.
• Keep the service secure, fix crashes (without health content, §5), and understand and improve how features are used, which can include health data such as which features you use.

We do not use your health data for advertising or to train AI models, and no setting in Vyra turns either on (§6). The accuracy work above means reading a result you told us was wrong and fixing how the feature handles it, never learning from your data.

5. Who processes your data

We share data only with processors that act on our instructions under contract. We do not share health data with advertisers, data brokers, or any third party for its own purposes, and we have no affiliates we share it with. Vyra ships with no advertising SDKs and does no cross-context behavioral advertising.

Meta’s Muse agent is not a processor. If you connect it (§3), Muse carries your requests to us and our answers back to you, at your direction and under Meta’s own terms. We send it nothing you did not ask for, and disconnecting it in Muse stops new requests at once.

We may also disclose data if the law requires it (for example, a valid legal request), or in a merger or acquisition, in which case this policy, including its no-sale commitment, continues to apply.

6. Consent, sale and sharing

Necessity. We collect health data because the feature you are using needs it to work, and the law does not require separate consent for that. So unless Vyra asks for your consent (below), there is no consent to give. That includes medications, if you add one, and meal photos, which your food entry is based on and which let us check and correct it. You can edit or delete any entry, or delete your account (§7, §8).

Where we ask for your consent. In some countries Vyra asks for your consent to use your health data, on a Your health data screen. Vyra can’t count your numbers without that data, so you can withdraw your consent at any time by deleting your account (§8). In some countries Vyra also asks before you save your first medication. You can withdraw that by deleting your medications, which erases each one with its logged doses and side effects. Withdrawing doesn’t undo what we did with your data before you withdrew.

No other use. Everything we do with your health data is listed in §4, and each item is part of running a feature you use. There is no secondary use, optional program, or setting that widens it. If that ever changed, we would ask for your separate, affirmative opt-in before the new use began.

No sale, and no sharing for others’ purposes. We do not sell your health data or disclose it for money or anything else of value, and we have no arrangement to. If that ever changed, we would first get the signed written authorization the law requires. We do not share health data with anyone for their own purposes, including advertisers and data brokers. Only the processors in §5 handle it, on our instructions. A service you connect yourself, such as Meta’s Muse agent, sees only the request you ask it to carry and our answer.

No training. We do not train AI models on your data, including your meal photos and corrections, and no setting turns it on. Our AI processor is also set up for zero retention and no training.

No location tracking. Vyra does not collect precise location, asks for no location permission, and does not track your movements. We do not use a geofence around any health-care facility, pharmacy or other place to infer or collect health data about you.

Two countries. We keep the latest country of your App Store or Google Play account and of the internet address your device connects from, with no history. We use them to pick local can and bottle sizes when estimating your food and to count users by country, and both go with our analytics events and scrubbed error reports (§5). Our subscription and notification processors also see that internet address and keep the country it resolves to. A country is an approximate location, and we declare it as one in Google Play’s Data safety section. We never use either country to infer anything about your health.

7. Your rights and how to use them

Wherever you live, you have these rights over your health data. Washington, California (including for sensitive personal information), Connecticut, Nevada and other states with similar laws give them by statute; we give them to everyone.

• Access: confirm whether we collect, share or sell your health data, and get a copy plus a list of all third parties and affiliates it has been shared with or sold to. We have no affiliates we share it with and we do not sell it, so that list is the processors in §5.
• Portability: get a copy in a portable, structured, commonly used, machine-readable format. Today we put the export together by hand and send it within the legal deadline.
• Delete: have your health data deleted (§8).
• Stop collection: stop using a feature and we collect nothing further from it; delete its entries, or your account (§8), and we hold nothing from it. If Vyra asked for your consent to use your health data, you withdraw it by deleting your account; if it did not, there is no separate consent to withdraw (§6).
• Correct: fix inaccurate information. Most profile and log data can be edited in the app.
• No discrimination: we will not deny you service or charge you differently for using these rights.
• Appeal: if we deny a request, reply to our decision or write to [email protected]. We will send our decision and reasons within the time the law requires.

How: in the app, edit or delete single entries, or delete your whole account under Settings (§8). Or email [email protected]. We check the request against your account and answer within the time your local law sets, and as quickly as we can: 15 days in Taiwan, 20 working days in New Zealand, 30 days in Singapore, Canada and Australia, and 45 days in the United States (extendable once where allowed). For Connecticut residents, we will tell you what we did on an appeal within 60 days of receiving it.

Authorized agents. Someone you authorize may make a request for you. We will ask the agent for proof of your written authorization and separately verify your identity (and, where the law allows, may contact you to confirm) before acting.

California. California treats health data as sensitive personal information. We use it only for the purposes in §4, never to infer characteristics about you or for advertising. We do not sell or share your personal information, so there is nothing to opt out of and no “Do Not Sell or Share” control. If that changed, we would add one.

Global Privacy Control (GPC). On our website we honor browser opt-out signals, including GPC. Because we do not sell or share consumer health data, a GPC signal has nothing to opt out of, but we still treat any GPC signal we receive as a valid opt-out request.

If you are unsatisfied after appealing:

• Washington residents may contact the Washington State Attorney General at https://www.atg.wa.gov/file-complaint.
• California residents may contact the California Privacy Protection Agency or the California Attorney General.
• Nevada residents may contact the Nevada Attorney General at https://ag.nv.gov/ under Nevada’s Consumer Health Data Privacy Law (SB370).
• Residents of other states may contact their state Attorney General.
• Canadian residents may complain to the Office of the Privacy Commissioner of Canada. Quebec residents may complain to the Commission d’accès à l’information du Québec.

8. Keeping and deleting your data

We keep your health data only while your account is active and for as long as we need it to provide the service. After your account is deleted we keep only the health-free records described below. We delete or de-identify health data when it is no longer needed for the purpose we collected it for.

When you delete your account:

1. Your account is soft-deleted at once and a 30-day grace period begins. Signing back in during that window cancels the deletion.
2. After the grace period, a hard purge permanently removes your data from every store that holds it, including your food logs, meal photos (every stored version of each image), weights, goals, any medications and conditions, reminders, and any stored documents, plus your sign-in records.
3. We keep only a health-free deletion record confirming that the deletion happened, and any minimal records the law requires us to keep.

What Meta Muse sends us. If you connect Muse (§3), we keep the photo it sends and our record of how we matched the food for 30 days, so we can check a result that looks wrong, and then delete them. We delete them straight away if you delete your account in the app, without waiting for the grace period above, or if Muse ends its connection with us. We only learn that you disconnected Muse when it ends that connection, and if it does not, the 30 days apply. A meal you save through Muse is an ordinary entry, kept like any other.

At our processors. Our AI processor keeps nothing, so there is nothing to delete there, and after the purge we ask our analytics processor to delete your analytics data. Some other processors keep limited, health-free records after that, such as crash reports for up to 90 days and your subscription history for as long as we use our subscription processor.

How to ask. Delete your account in the app under Settings, email [email protected], or use getvyra.ai/delete-account on the web, without installing or opening the app.

9. How we protect your data

• Encryption in transit and at rest (our storage uses a key we control, and stored documents are encrypted too).
• Per-user isolation in the database, so one account cannot read another’s data.
• Least-privilege access for our systems and staff; production access is limited and monitored.
• Health data is kept out of our error reports and server logs.
• Health-platform minimization: your raw step and active-energy readings stay on your device, and what we receive from them is a single capped daily activity ratio and, if you count your movement from a fitness tracker, that choice and a daily food calorie target worked out on your phone from your tracker’s usual day (with your calorie goal, it shows your usual daily movement). Body weight is the exception: an imported reading is saved to your account as a weigh-in, and only if you allow it (§3).
• No precise location and no geofencing (§6).

No system is perfectly secure, but we work to protect your data in line with its sensitivity.

Breach notification. As a non-HIPAA health-app vendor, if a breach affects your identifiable health information, we will notify you and the appropriate authorities as the FTC Health Breach Notification Rule and applicable state law require.

10. Cookies and tracking

The app contains no advertising SDKs and no cross-site trackers; Google’s analytics SDK in the iOS app receives no health data (§5).

Our website (getvyra.ai) uses cookieless, EU-hosted analytics (PostHog) for page-visit counts only, with no cookies, no cross-site tracking and no personal data, so there is nothing to consent to and no cookie banner. We do not use advertising or cross-site tracking cookies, we do not sell or share data collected on the website, and we honor Global Privacy Control signals (§7).

11. Children

Vyra is intended for adults 18 and older. We do not knowingly collect data from anyone under 18. If we learn we have, we will delete it.

12. How this connects to our general Privacy Policy

This policy covers your health-related data and has its own link (https://getvyra.ai/consumer-health-privacy), separate from our general Privacy Policy. Where the two overlap, this policy controls for consumer health data. The general policy covers other information, such as account and device basics, in more detail.

13. Changes to this policy

If we materially change how we handle your health data (including turning on any of the features listed as off in §2, or using your data for anything beyond running a feature you use), we will update this policy and its effective date. A new use beyond necessity would need your separate, affirmative opt-in first. There is no such use today (§4, §6).

14. Contact

Questions or requests: [email protected]

Vyra Health Inc., 2810 N Church St, STE 88042, Wilmington, DE 19802