Privacy Notice

Last Updated: August 14, 2026

1. Who We Are

Verso Health Ltd (CRN: 17394519) is the data controller for VITALIS. We are registered with the NHS Organisation Data Service (ODS Code: E2E6A) and the Information Commissioner's Office (ICO: ZC222110).

Data Protection Officer: Paul Rogers
Email: ceo@versohealth.co.uk

2. What Personal Data We Collect

Category	Data Collected	Purpose
Account Data	Name, email address	Account management
Wellbeing Data	Mood, energy, sleep, stress, cognitive clarity, physical patterns	Personal pattern tracking
Health Background	Pre-existing conditions, medications, hospital/GP visits	Contextualise wellbeing patterns
Environmental Data	Air quality, weather, pollution (via postcode)	Environmental insights
Wearable Data	Heart rate, sleep stages, HRV	Device integration
Care Circle	Names and phone numbers of trusted contacts	Pattern change notifications
Device Data	Device type, operating system, app version	App performance

3. Legal Basis for Processing

Processing Activity	Legal Basis
Account creation and management	Contract (Article 6(1)(b))
Wellbeing tracking and insights	Consent (Article 6(1)(a))
Health background data	Explicit consent for special category data (Article 9(2)(a))
Care Circle notifications	Legitimate interest (Article 6(1)(f))
Anonymised analytics	Legitimate interest (Article 6(1)(f))

4. How We Share Your Data

Third Party	Data Shared	Purpose	Identifiable?
Supabase	Account, wellbeing, health data	Database hosting	Yes
Vercel	Device data, usage	Hosting	No (anonymised)
OpenWeather API	Postcode	Weather data	No (anonymised)
AirVisual API	Postcode	Air quality data	No (anonymised)
Wearable APIs	Wearable device data	Device integration	No (anonymised)

Your name, email, and Care Circle contacts are never shared with third parties.

5. Your Data Subject Rights

Under UK GDPR, you have the following rights:

Right to access — Request a copy of the data we hold about you
Right to rectification — Correct inaccurate or incomplete data
Right to erasure — Request deletion of your data ("right to be forgotten")
Right to restrict processing — Limit how we use your data
Right to data portability — Receive your data in a portable format
Right to object — Object to processing based on legitimate interests
Right to withdraw consent — Withdraw consent at any time

To exercise any of these rights, contact us at: ceo@versohealth.co.uk

6. How Long We Keep Your Data

Data Type	Retention Period
Account data	Until account is deleted
Wellbeing and health data	5 years after last activity
Anonymised analytics	Indefinitely
Care Circle contacts	Until removed by user

7. Your Consent

By using VITALIS, you consent to our collection and processing of your personal data as described in this Privacy Notice. You can withdraw your consent at any time by:

Deleting your account
Contacting us at ceo@versohealth.co.uk

8. How to Complain

If you have concerns about how we handle your data, you have the right to complain to the Information Commissioner's Office (ICO):

Website: www.ico.org.uk
Helpline: 0303 123 1113
ICO Registration Number: ZC222110

9. Updates to This Notice

We may update this Privacy Notice from time to time. We will notify you of significant changes via email or in-app notification.

Verso Health Ltd | CRN: 17394519 | ODS: E2E6A | ICO: ZC222110
Data Protection Officer: Paul Rogers — ceo@versohealth.co.uk