Privacy Policy

VitalNexa Wellness Platform — Your health data, protected by design

Version 1.1 Last Updated: April 7, 2026 Effective Date: April 7, 2026

1. Data Controller

The data controller responsible for your personal data is:

Star's End Ventures, LLC dba VitalNexa
Operating from California, United States
Contact: privacy@vitalnexa.health

For all privacy-related inquiries, data subject requests, or complaints, please contact our Privacy Officer at privacy@vitalnexa.health.

2. Our Commitment to Privacy

Privacy by design, not by afterthought. Every architectural decision in VitalNexa is made with your data privacy as the primary constraint. We built encryption, isolation, and data minimization into the foundation of our platform — not bolted on later.

VitalNexa is built on three core privacy principles:

Data Minimization — We collect only what is necessary to provide personalized wellness insights. We do not collect browsing behavior, advertising identifiers, or social network data.
User Ownership — Your health data belongs to you. You can export all of your data, correct inaccuracies, or permanently delete your account and all associated data at any time.
Zero-Knowledge AI — Our AI wellness assistant never sees your name, email, or any personally identifying information. All data is stripped of PII before it reaches any AI model.

3. Information We Collect

Category	Data Collected	Purpose
Account Information	Email address, full name, hashed password	Authentication, account management
Health Records	Uploaded files (.txt, .pdf)	Health data extraction and analysis
Lab/Bloodwork Results	Biomarker names, values, units, test dates, fasting status	Trend tracking and wellness insights
Chat Conversations	Messages between you and the VitalNexa AI assistant	Personalized wellness guidance
Health Summaries	AI-generated summaries of your health status	Continuity of care across sessions
Audit Logs	IP address, user agent, API actions, timestamps	HIPAA-required security monitoring

What we do NOT collect: We do not collect location data, device fingerprints, advertising identifiers, social media profiles, browsing history, cookies for tracking, or any data from third parties without your explicit consent.

4. How We Use Your Information

Wellness Insights — Analyzing your lab results to identify trends, flag values outside reference ranges, and provide educational information about vitamins, supplements, peptides, and nutrition.
AI Chat — Powering personalized conversations about your health data. All personally identifying information is stripped before any data is sent to the AI model.
Trend Analysis — Visualizing biomarker changes over time with color-coded status indicators.
Security & Compliance — Audit logging for HIPAA compliance, fraud prevention, and unauthorized access detection.

We do not sell, rent, or trade your personal information or health data to any third party, for any purpose, ever.

5. Legal Basis for Processing

Under GDPR and similar data protection regulations, we process your personal data based on the following legal grounds:

Legal Basis	Processing Activities
Consent (Article 6(1)(a) / Article 9(2)(a))	Given at registration. Explicit consent for processing health data. You may withdraw consent at any time via account settings or by contacting us.
Legitimate Interest (Article 6(1)(f))	Service improvement, security monitoring, fraud prevention, and maintaining the integrity of our platform.
Contract (Article 6(1)(b))	Providing the service you signed up for — including account management, lab result analysis, AI wellness chat, and trend tracking.
Legal Obligation (Article 6(1)(c))	Maintaining audit logs and breach notification as required by HIPAA, HITECH, and other applicable regulations.

6. How We Protect Your Information

VitalNexa employs multiple layers of security, each addressing different threat vectors:

Encryption at Rest

All sensitive data fields (chat messages, health record text, health summaries) are encrypted using AES-256-GCM with per-field unique salt and nonce values. This means even if the database were compromised, encrypted fields are computationally infeasible to decrypt without the encryption key.

Measure	Implementation	Standard
Field-level encryption	AES-256-GCM, unique salt + 96-bit nonce per field	NIST SP 800-38D
Key rotation	Versioned keys (v1, v2...) with admin rotation endpoint	NIST SP 800-57
Password hashing	bcrypt with automatic salting, cost factor 12	OWASP recommendation
Key derivation	PBKDF2-HMAC-SHA256, 600,000 iterations	NIST SP 800-132

Multi-Tenant Data Isolation

PostgreSQL Row-Level Security (RLS) policies enforce that each user can only access their own data. This is enforced at the database level, not the application level, preventing any application-layer bug from leaking data between users.

Authentication & Access Control

JWT tokens with 60-minute expiry and HS256 signing
Email verification required before account activation
Account lockout after 5 failed login attempts (15-minute cooldown)
UUID validation on all database parameters to prevent SQL injection

HIPAA Audit Trail

Every API request is logged with user ID, action, IP address, user agent, and timestamp. Audit logs are immutable and retained for the legally required period.

7. AI and Third-Party Data Processing

No personally identifying information ever reaches the AI model. This is enforced by an automated PII filter that runs on every outbound request.

VitalNexa uses Anthropic's Claude AI for wellness chat. Before any data is sent to the AI:

What Gets Stripped (Automatically)

PII Type	Detection Method	Replacement
User's full name	Exact match + individual name parts	[NAME_REDACTED]
Email addresses	Regex pattern matching	[EMAIL_REDACTED]
Phone numbers	Multiple format patterns	[PHONE_REDACTED]
Social Security Numbers	XXX-XX-XXXX pattern	[SSN_REDACTED]
Street addresses	Number + street type pattern	[ADDRESS_REDACTED]
Dates of birth	DOB/birthday context matching	[DOB_REDACTED]
Medical record numbers	MRN/Patient ID patterns	[MRN_REDACTED]
Insurance/policy numbers	Policy/Member/Group ID patterns	[ID_REDACTED]

What the AI Receives

Anonymized lab values with test dates (no user identity attached)
PII-scrubbed chat history for conversation context
System instructions about being a wellness assistant

What the AI Does NOT Receive

Your name, email, user ID, or any account information
Your uploaded health record files
Any data from other users

Anthropic's data use policy prohibits using API inputs for model training. Your conversations are not used to train AI models.

8. HIPAA Compliance

VitalNexa is designed to comply with the Health Insurance Portability and Accountability Act (HIPAA), including the Privacy Rule (45 CFR Part 164, Subparts A and E) and the Security Rule (45 CFR Part 164, Subparts A and C).

Administrative Safeguards

Requirement	Implementation	Status
Security Management Process	Risk analysis, security policies, audit logging	Implemented
Workforce Security	Role-based access, principle of least privilege	Implemented
Information Access Management	Row-Level Security, JWT authentication	Implemented
Security Awareness Training	Developer security training program	Implemented
Security Incident Procedures	Incident response plan with severity classification	Implemented
Contingency Plan	Database backups, disaster recovery procedures	Implemented

Technical Safeguards

Requirement	Implementation	Status
Access Control	Unique user IDs, JWT tokens, email verification	Implemented
Audit Controls	Complete API request logging with user, action, IP, timestamp	Implemented
Integrity Controls	AES-256-GCM authenticated encryption (tamper detection)	Implemented
Transmission Security	TLS/HTTPS for all data in transit	Implemented
Encryption at Rest	AES-256-GCM field-level encryption with key rotation	Implemented

Physical Safeguards

Requirement	Implementation	Status
Facility Access Controls	Cloud infrastructure with provider-managed physical security	Implemented
Workstation Security	Containerized deployment, no direct database access	Implemented
Device and Media Controls	Encrypted volumes, secure file storage	Implemented

Breach Notification Rule

In the event of a breach of unsecured protected health information, VitalNexa will notify affected individuals within 60 days, the HHS Secretary as required, and prominent media outlets if the breach affects more than 500 individuals in a state or jurisdiction.

9. HITECH Act Compliance

VitalNexa complies with the Health Information Technology for Economic and Clinical Health (HITECH) Act, which strengthens HIPAA enforcement:

Enhanced Penalties — We maintain compliance to avoid tiered civil monetary penalties ranging from $100 to $50,000 per violation.
Breach Notification — We follow HITECH's expanded breach notification requirements, including the presumption that any impermissible use or disclosure is a breach unless a risk assessment demonstrates low probability of compromise.
Business Associates — All third-party service providers that may access PHI (including cloud infrastructure and AI providers) are bound by Business Associate Agreements (BAAs) with equivalent security requirements.
Minimum Necessary Standard — We apply the minimum necessary standard to all uses, disclosures, and requests for PHI. Our PII filter enforces this automatically for AI interactions.

10. SOC 2 Alignment

VitalNexa's architecture is designed to meet the AICPA's SOC 2 Trust Service Criteria. While we have not yet undergone a formal SOC 2 Type II audit, our controls are aligned with these standards:

Trust Service Criterion	Our Controls	Status
Security (Common Criteria)	JWT authentication, bcrypt passwords, AES-256-GCM encryption, RLS isolation, account lockout, CORS restrictions, audit logging	Aligned
Availability	Docker containerization, health check endpoints, database connection pooling, graceful error handling	Aligned
Processing Integrity	Input validation (Pydantic schemas), UUID parameter validation, authenticated encryption (GCM tamper detection), database constraints	Aligned
Confidentiality	Field-level encryption, PII scrubbing before AI calls, Row-Level Security, encrypted file storage, key rotation capability	Aligned
Privacy	Data minimization, user consent for collection, right to delete, transparent data use policy, no third-party data sales	Aligned

We plan to pursue formal SOC 2 Type II certification as we scale to production.

11. Additional Regulatory Compliance

CCPA / CPRA (California)

California residents have the right to:

Know what personal information we collect and how it's used
Request deletion of their personal information
Opt out of the sale of personal information (we do not sell personal information)
Non-discrimination for exercising their privacy rights
Correct inaccurate personal information (CPRA addition)
Limit use of sensitive personal information

GDPR Considerations

For users in the European Economic Area, we process health data under the legal basis of explicit consent (Article 9(2)(a)). Users have rights to access, rectification, erasure, data portability, and the right to withdraw consent at any time.

FTC Health Breach Notification Rule

As a health-related technology provider, we comply with the FTC's Health Breach Notification Rule, which requires notification to consumers, the FTC, and in some cases the media, following a breach of unsecured health information.

21st Century Cures Act

VitalNexa supports health data interoperability through FHIR-based import connectors, allowing users to bring their health records from Epic, Cerner, Quest Diagnostics, Labcorp, and other certified health IT systems.

12. Data Retention & Deletion

Data Type	Retention Period	Deletion Method
Account information	While account is active + 30 days after deletion	Permanent erasure from database
Health records & lab results	While account is active	File deletion + database record removal
Chat conversations	Until user deletes them, or account deletion	Encrypted records permanently deleted
Health summaries	Until account deletion	Permanent erasure from database
Audit logs	6 years (HIPAA requirement)	Automatic purge after retention period

When you delete your account, all personal data, health records, lab results, chat history, and health summaries are permanently and irreversibly deleted within 30 days. Audit logs are retained for the legally required period with user identity anonymized.

13. Your Rights (EU/EEA Residents)

If you are located in the European Union or European Economic Area, you have the following rights under the General Data Protection Regulation (GDPR):

Right	Description	How to Exercise
Right to Access	Obtain a copy of all personal data we hold about you	Use the data export feature in Settings, or contact us
Right to Rectification	Correct inaccurate or incomplete personal data	Edit directly in the app (profile, biometrics)
Right to Erasure	Request deletion of your personal data	Delete your account in Settings
Right to Restrict Processing	Limit how we process your data	Contact us at privacy@vitalnexa.health
Right to Data Portability	Receive your data in a structured, machine-readable format (JSON)	Use the JSON export feature in Settings
Right to Object	Object to processing based on legitimate interest	Contact us at privacy@vitalnexa.health
Right to Withdraw Consent	Withdraw your consent at any time without affecting the lawfulness of prior processing	Contact us or delete your account

You also have the right to lodge a complaint with your local Data Protection Authority (DPA). We will respond to all data subject requests within 30 days.

14. Your Rights (California Residents)

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have the following rights:

Right to Know — You have the right to know what personal information we collect, use, disclose, and sell.
Right to Delete — You may request that we delete the personal information we have collected about you.
Right to Opt-Out of Sale — We do not sell your personal information, and we never will. See our Do Not Sell page for details.
Right to Non-Discrimination — We will not discriminate against you for exercising any of your CCPA/CPRA rights.
Right to Correct — You may request correction of inaccurate personal information.
Right to Limit Use of Sensitive Information — You may limit the use of sensitive personal information to what is necessary to provide the service.

To exercise your California privacy rights, contact us at privacy@vitalnexa.health with subject line "CCPA Request".

15. Your General Rights

Access — View all data we hold about you through the My Health Data dashboard
Correction — Request correction of any inaccurate health data
Deletion — Delete your account and all associated data at any time
Export — Download your complete health data in a portable format
Opt Out of AI — Request that your data not be processed by AI systems (this will disable the chat feature)
Restrict Processing — Limit how we use your data
Complaint — File a complaint with the HHS Office for Civil Rights or your local data protection authority

To exercise any of these rights, contact us at privacy@vitalnexa.health. We will respond within 30 days.

16. International Data Transfers

VitalNexa stores and processes data on servers located in the United States and the European Union. If you are located outside the US, your data may be transferred to and processed in the US.

For transfers of personal data from the EU/EEA to the US, we rely on the following transfer mechanisms:

Standard Contractual Clauses (SCCs) — EU-approved contractual terms that require data to be protected to the EU standard
Explicit Consent — Where applicable, your explicit consent to the transfer as part of registration

We ensure that any third-party service providers who process data on our behalf provide equivalent safeguards through Business Associate Agreements and data processing agreements.

17. Cookies

VitalNexa uses essential cookies only. Specifically:

Cookie	Purpose	Type	Duration
`access_token`	Session authentication (HttpOnly, Secure)	Essential	60 minutes
`cookie_consent`	Records your cookie consent preference	Essential	Persistent (localStorage)

No tracking cookies. No analytics cookies. No advertising cookies. We do not use any third-party tracking scripts, pixels, or cookie-based profiling.

18. Children

VitalNexa is not intended for users under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have inadvertently collected personal data from a child under 16, we will take steps to delete that information as quickly as possible. If you believe a child under 16 has provided us with personal data, please contact us at privacy@vitalnexa.health.

19. Contact Information

Contact	Details
Privacy Officer	privacy@vitalnexa.health
General Support	support@vitalnexa.health
Data Protection Requests	privacy@vitalnexa.health (subject: "Data Request")
Security Concerns	security@vitalnexa.health

20. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

Post the updated policy on this page with a new "Last Updated" date
Send an email notification to all registered users
Display a prominent notice within the application for 30 days
Provide a summary of what changed and why

Continued use of VitalNexa after the effective date of changes constitutes acceptance of the updated policy. If you disagree with any changes, you may delete your account at any time.