Consumer Health Data Policy

MONITORED Health UAB, a company registered in Lithuania, company code 303648350, is the controller of your health information.

Contact us about anything in this policy at vitamins@monitored.health.

Because we are established in the European Union, the General Data Protection Regulation (GDPR) applies to everything we do with your information — whichever country you use Vitamins from.

MONITORED Health is a suite of apps that share one account. You sign in once, and your profile — your name, date of birth, sex, country — belongs to the account rather than to any single app.

Your core health record is shared in the same way. The conditions, allergies and medications you enter are held once, for the account, and every app in the suite can read them. That is deliberate: you should not have to tell us about a medication twice, and an app that did not know about it could give you worse advice.

Today the suite is one app: Vitamins, for planning and tracking supplements. Where something is true only of a particular app, this policy says so — look for the app’s name in bold. Everything else applies to the account, and therefore to all of them.

Your consent covers the suite, not one app. It is given once and it applies to the shared health record described above.

When we add an app that uses your health information for a new purpose, that is a change to what you agreed to — so we will update this policy and ask for your consent again before that app processes anything of yours. You will never find that a new app has quietly started using information you gave us for something else.

Under the GDPR this is “special category” data, and under US state health-privacy laws it is “consumer health data”. Either way we treat it as the most sensitive information we hold.

In Vitamins, that means:

• Conditions, allergies and medications you enter or tell Aria about
• What you say during an assessment conversation, in your own words
• The supplement plan generated for you, and any earlier plans
• Your dose records — which doses you marked taken, skipped, or missed, and when
• Your check-in answers about how you are feeling
• Your Pill Box — what you hold, quantities and expiry dates
• Photographs of supplement packaging you scan, and what we read from them
• Your date of birth, sex, height and weight, which affect dosage guidance

We do not ask for, and you should not enter, information about anyone other than yourself.

For most things a company does with your data, the law lets it rely on necessity — the information is needed to provide the service you asked for. Health information is different. We need your explicit consent before we may process it at all, and we must ask for it separately rather than bundling it into accepting our Terms.

That is why the app asks you two questions rather than one, and why neither switch is pre-set:

They are separate because they are genuinely different things, and you may reasonably agree to one and not the other. If you decline either, we cannot provide Vitamins, because the app has nothing to work with. We would rather say that plainly than offer a choice that leads nowhere.

In Vitamins:

• Build your supplement plan — an AI service reads your conditions, medications, allergies, goals and the assessment conversation, and produces a schedule of supplements and doses.
• Track adherence — your dose records drive your calendar, reminders and adherence figures.
• Check in on how you are doing — your answers are stored and shown back to you over time.
• Read supplement packaging — a photograph you scan is sent to an AI vision service which identifies the product and dosage.
• Keep your Pill Box current — quantities fall as you record doses.

Everything is stored in the European Union, in Amazon Web Services’ Frankfurt region. We do not copy it to any other region.

Two of our processors are in the United States — Anthropic and xAI, which generate your plan and read your packaging photographs. Your health information is sent to them each time it is needed, and not held by us anywhere else.

Those transfers rely on Standard Contractual Clauses incorporated in each provider’s agreement with us, and on three further measures:

Your identity is not sent with your health information. Your name, email address and account identifier are never included in what we send to an AI provider. What travels is the health information itself, plus your country and city (which affect climate and local availability advice).

xAI holds nothing. Zero Data Retention has been active on our xAI account since 28 July 2026. Inputs and outputs are not retained after a response is returned.

Anthropic holds inputs for up to 30 days under their commercial terms, longer only where content is flagged under their usage policy.

In Vitamins: your supplement plan is produced by AI without a person reviewing it first.

We have assessed this as not producing legal or similarly significant effects: the plan is information, it does not restrict your access to anything, and it is presented with a clear instruction to consult a healthcare professional.

Vitamins is not a medical device and does not provide medical advice. If you would like a human to review a plan, ask us at vitamins@monitored.health and we will.

Your health information is kept for as long as your account exists.

You can delete an app’s data at any time, from that app’s Settings or by asking us. What happens next depends on whether you use any of our other apps.

If you use other MONITORED Health apps, deleting one removes that app’s data and schedules your account for deletion — but your account, your sign-in and your shared health record stay, so the other apps keep working. Deleting Vitamins does not take your medication list away from an app that still needs it.

When you have deleted the last app, everything goes: your profile, your shared health record, every app’s data, your photographs, and your sign-in itself. Within 30 days there is nothing left and you cannot sign in again.

Deletion is all-or-nothing by design: if any part of the purge fails, the whole thing is rolled back and your sign-in is left intact so you can try again. We never destroy your identity until we have confirmed the data is actually gone — the alternative is an account you cannot reach holding data we cannot show you.

One exception, and we want to be direct about it. The record of your consent — that you gave it, when, under which version of this policy, and the exact wording you were shown — is kept for six years even after your account is deleted. The law requires us to be able to demonstrate that we had your permission, and that obligation outlives the data it authorised. That record contains no health information: only your account identifier, timestamps, and the text you agreed to.

You can ask us to:

• See the health information we hold about you
• Correct anything that is wrong
• Delete it
• Restrict or object to what we do with it
• Export it in a portable form
• Have a person review an automatically generated plan

And you can withdraw your consent at any time. Withdrawing is as easy as giving it. It does not affect anything done while your consent was valid, but from that moment we stop — and since we cannot run Vitamins without it, that means your account stops too. We will tell you clearly before anything is deleted.

Email vitamins@monitored.health. We answer within one month, or 45 days where US state law sets that period.

If you are unhappy with how we have handled your information, you can complain to your local data protection authority. Ours is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija) in Vilnius, Lithuania.

Your information is encrypted in transit and at rest.

Access is limited to what each part of the system needs, and administrative access is restricted to MONITORED Health UAB personnel.

Signing in requires a password of at least eight characters including upper and lower case, a number and a symbol.

If we change this policy in a way that affects what you agreed to — a new purpose, a new recipient, a new category of information, or a longer retention period — we will ask for your consent again rather than assume the old one still covers it. You will see the consent screen once more with the updated wording.

Corrections that do not change what we do, such as fixing a typo, will not trigger that.

Every version is numbered and dated at the top of this page, and the version you agreed to is recorded with your consent. When this policy is revised, the version you agreed to will remain available — a record pointing at a document nobody can read would prove nothing. Ask us at any time and we will send you the exact text you accepted.

Because this policy covers more than one app, it may be updated for a reason that has nothing to do with the app you use. When that happens you are not asked to consent again: we re-ask only when the change affects what you agreed to.