Privacy Policy

Who we are

This client portal is operated by Vitalife Clinic Ltd, a company registered in England and Wales (company number 16777077), registered office at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom ("we", "us", "our"). We are the data controller for the personal data described in this policy, and we are registered with the Information Commissioner's Office as a data controller under reference ZC220213.

The portal exists to support your wellness journey: programmes, health check-ins, messaging with your coach, appointments, purchases and account management. This policy explains what personal data we collect through it, why, and the rights you have under UK data protection law (UK GDPR and the Data Protection Act 2018).

What we collect

Your health data

Much of what makes this portal useful is health data, which UK GDPR treats as special category data deserving extra protection. We process it for two different reasons, and it is worth being clear which is which, because they give you different control.

To provide your care. Your check-ins, your coach’s notes, your goals, your appointments and your correspondence with us are processed because we are providing you with health care, under Article 9(2)(h) of the UK GDPR. That work is done by, or under the responsibility of, a clinician bound by a duty of confidence. This is not something you consent to and then withdraw: it is the basis on which a clinic keeps a record of the care it gave you, and it is why your clinical record is kept for six years after we last saw you even if you ask us to delete everything else.

For the optional extras. The AI features that work over your own material, and any use of what you have written for marketing or publication, are done on the basis of your explicit consent. You can withdraw that at any time in your settings or by contacting us, and withdrawing it genuinely stops it. Nothing you have written is ever published without your explicit written agreement first.

How we use your data

• To run your programmes: unlocking stages, tracking progress, awarding badges and keeping your streaks.
• To let your coach support you: they see your check-ins, goals, habits, programme progress and the messages you send them.
• To compute progress insights: engagement, learning, consistency and wellbeing indicators derived from your activity, shown to you and, in a privacy-filtered form, to your coach.
• To send you helpful notifications, including gentle reminders if your programme goes quiet. These stop after a few unanswered reminders.
• To process purchases, subscriptions and refunds.
• To keep the service secure, diagnose problems and meet our legal obligations.

We do not sell your data, and we do not use it for third party advertising.

AI assistance

Some portal features are AI assisted: coaches can generate draft progress summaries and message suggestions, programme content can be AI drafted before a coach reviews it, and you can ask for a short AI written "story so far" about your own progress.

All of it is written on our own computers. Every AI assisted feature in the portal runs on hardware Vitalife owns and controls in the United Kingdom: the coach's progress note, your own "story so far", drafted programme content and the illustrations on our articles. Your check-ins, your progress and anything you have written are not sent to any AI company, and nothing about you is used to train any model.

We still minimise what those features are given. Your name is not included, and your private writing is only ever used in your own story, or in a coach summary if you have explicitly switched that on in your privacy choices.

Who we share it with

We use a small number of trusted service providers, each acting under contract as our processor and only for the purpose described:

• Stripe: payment processing. Your card details go directly to Stripe and are never stored by us.
• Zoom: live programme sessions and appointments, where your programme includes them.
• Brevo: email delivery.
• Twilio: coach messaging over WhatsApp, only if you opt in and provide your WhatsApp number.
• Our hosting provider, which stores the portal's data on servers under our control.

Blood tests you order through us are carried out by London Medical Laboratory, who analyse your sample in their own laboratories. They are not one of the processors above. When you buy a test we place the order with them on your behalf, and pass on what they need in order to run it: your name, your email address, your phone number, the delivery address for your kit, and, where we hold them, your date of birth and your sex at birth. The kit is included in the price and comes to you by post.

Usually we register you as the patient at the same time, so there is nothing for you to do but post your sample back. If we do not hold your date of birth or your sex at birth, we cannot do that part for you: those two details decide which reference range your result is read against, and we will not guess them. In that case the test reference code in your kit lets you register the sample yourself on London Medical Laboratory's own patient site, and your results page shows you the code and tells you what to do.

This matters if you ask us to delete your data. We can delete our copy of your results. London Medical Laboratory keep their own records of the sample they analysed, as any laboratory must, and if you registered the sample yourself you also have an account with them. In either case that copy is theirs to hold, so you would need to ask them separately.

Where a provider processes data outside the UK, transfers are protected by appropriate safeguards such as the UK Addendum to the EU Standard Contractual Clauses. Beyond these providers, we only disclose personal data where the law requires it.

Security

Your health data, personal writing, contact details and other sensitive fields are encrypted at rest in our database, and all traffic to the portal is encrypted in transit (HTTPS). Access within the clinic is limited by role: coaches see only their side of the privacy line described above, and administrative access is restricted and logged.

How long we keep it

We keep your data for as long as you hold an account with us, so your history and progress remain available to you.

If you have not signed in for twelve months and hold no active membership, we will email you to ask whether you would like to keep your account. If we do not hear from you within thirty days of that notice, we will close the account and delete or anonymise your personal data. Signing in at any point starts the twelve months again.

If you close your account yourself, or ask us to erase your data, we delete or anonymise your personal data within a reasonable period.

Either way, we keep what the law or professional guidance requires us to keep, for example clinical record keeping, accounting and tax, for as long as those rules say, and no longer.

Your rights

Under UK GDPR you have the right to access a copy of your personal data, to have inaccurate data corrected, to have your data erased, to restrict or object to processing, to data portability, and to withdraw consent at any time without affecting the lawfulness of earlier processing. To exercise any of these rights, contact us using the details below. We will respond within one month.

Cookies

The portal uses strictly necessary cookies only: a session cookie to keep you signed in, a security token that protects forms, and, where two-step sign-in is switched on for an account, a cookie that remembers a trusted device for 30 days so you are not asked for a code every time you sign in. We do not use advertising or third party analytics cookies in the portal.

The trusted-device cookie holds a random value and nothing about you. It only works while the matching record on your account agrees, so it stops working the moment you change your password, re-enrol, or we clear it. None of these three needs your consent, because the portal cannot do what you asked it to do without them.

Visitor measurement

We count visits to our website and to this portal so we know which pages are useful and which are not. We do it ourselves, on our own servers. We do not use Google Analytics or any other third party measurement service, and no information about your visit is sent to anyone outside Vitalife Clinic Ltd.

This measurement sets no cookies and stores nothing at all on your device. For each page view we record the page address, whether it was the first page of your visit, the site and page that linked you to it and any campaign tag carried in the link, your general device type, browser and operating system, the width of your browser window, how long the page was open, how far down it you scrolled, and whether we judged the visit to be automated rather than a person.

To count one person visiting three pages as one visitor rather than three, we need to recognise repeat views within a single day. We do this without identifying you: your IP address and browser description are combined with a secret that changes every day and turned into an anonymous code by a one way process. Your IP address itself is never written to disk, and the daily secret is destroyed after two days, at which point the codes from that day cannot be traced back to any address by anyone, including us. The result is that we can count visitors within a day and cannot follow anyone from one day to the next.

We may also work out roughly where a visit came from: the country, and where our reference table carries that much detail, an approximate town, a coordinate rounded to about eleven kilometres, the type of internet connection and the name of the internet provider. It is approximate by design rather than by accident, and it can be some distance out: a visitor on a mobile network resolves to their provider's gateway, so somebody browsing in Bournemouth can read as London.

All of that is worked out on our own server from a downloaded reference table (IP Geolocation by DB-IP, CC BY 4.0), so no third party is ever asked anything about you. Your IP address is used for that lookup and then discarded along with everything else, and none of this is ever combined with your account.

Detailed records are deleted after 90 days. Only anonymous daily and monthly totals are kept beyond that. Because nothing is stored on your device and nothing identifies you, this does not require your consent, and it continues to work whether or not you accept cookies. We also honour the "Do Not Track" and "Global Privacy Control" settings in your browser: if either is switched on, your visits to the portal are not counted at all.

Our lawful basis is legitimate interests: understanding how our own site is used so we can improve it. Given that no personal data is retained by this process, the impact on your privacy is minimal.

Contact & complaints

For anything about your data, email our data protection contact at privacy@vitalifeclinic.co.uk. You can also use the contact page at vitalifeclinic.co.uk/contact, message your coach in the portal, or write to our registered office above.

If you are unhappy with how we have handled your data, you can complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113. We would appreciate the chance to resolve your concern first.