Privacy Policy

Aurelia Vitals, Inc. (“we,” “us,” or “our”) is a Delaware corporation with its principal place of business in Houston, Texas. This Privacy Policy explains how we collect, use, disclose, and protect information when you use our website (phirahealth.com) (the “Website”), our Phira mobile application (the “App”), and the Phira wearable device (the “Device”) (collectively, “Phira” or the “Services”). We aim to comply with applicable state and federal privacy laws, including the laws of the states where our users reside. We may update this Policy to reflect changes in our practices or applicable law. We will notify you of material changes by posting the updated Policy with a new “Last Updated” date and, where required by law, through additional notice such as in-app notification or email.

1. Information We Collect

We collect the minimum amount of data necessary to provide the Services.

1.1 Information You Provide

  • General information: When you sign up for our Services, we collect personal data like your name, email, birth month and year, password, location, time zone, and language. Based on how you use the Services, we may also infer your sex or gender.

  • Well-being: When using our Services, you may enter personal data about yourself, such as your weight, height, BMI, body temperature, and menstrual cycle details. You may log symptoms linked to your menstrual cycle, pregnancy, perimenopause, or menopause, as well as general health and well-being. This can include details about your sex life, physical and mental health, food intake, water intake, and sleep duration. 

  • Third-party services (including wearables): With your permission, we can connect to third-party services like Apple HealthKit, Google Health Connect and Oura Health. This allows us to automatically import your health and activity data into the app, so you don’t have to log it yourself. The imported data may include fitness activities, weight, height, BMI, calories burned, heart rate, steps taken, distance traveled, body temperature, sleep patterns, and other activity details.
    This information helps provide insights into your activities and improves our ability to predict your cycle. We process this data to enhance the App’s features and functionality.  Importing data is subject to the privacy policies and terms of Google Health Connect and Apple HealthKit and Oura Health. If you use a wearable device to connect to the App, please review its terms and privacy policies as well. Your device provider may collect usage data for its own purposes, such as improving its services.

  • Communications: Communications you send us, such as support requests or survey responses.

1.2 Information Collected from Our Wearable Device

  • Health-related data collected via the Phira wearable device, along with insights we generate from that data. 

1.3 Personal data we collect automatically

When you use the Services, we may automatically collect certain information:

  • Device information: device model; information about the operating system and its version; unique device identifiers; enabled device accessibility features (e.g., display features, hearing features, and physical and motor features); app diagnostic information (device type, OS version, crash logs), mobile operator and network information; device storage information or version of your device system. 

  • Location information: IP address for an approximate location; browser type, country; time zone or information about your mobile service provider. We do not collect your exact location. We only use location details for the reasons listed below. 

  • Data about your use of the Services, including: frequency of use; areas and features of the Services that you access or use; or engagement with features (website interaction data, features used, screens viewed).

  • To collect this and other information, we may use cookies and other similar technologies.

2. How We Use Your Information

Depending on the features you use, we will process your personal data based on the following reasons:

Your consent: You allow us to process your health data to provide the Services.

Contractual obligations: We process certain personal data to meet our contractual commitments to you, such as managing your Phira account and handling administrative tasks. 

Legitimate interests: We may process your personal data based on our legitimate interests to improve our Services. For example, we might use your personal data to: 

  • identify and fix issues;

  • provide and personalize the Services, including generating the wellness-related insights offered in the App;

  • improve content in the App; 

  • fraud prevention, including ensuring interactions (e.g. app-installs) are from real members, not bots;

  • to respond to your inquiries and provide customer support;

  • to conduct research and improve our algorithms, using de-identified or aggregated data wherever feasible;

  • monitor and analyze App performance; 

  • notify you about your subscriptions;

  • scan for vulnerabilities to ensure security; and 

  • review overall App usage trends and forecast customer retention. 

We carefully balance our interests with your rights to ensure our activities don't negatively impact you or your rights.

Legal obligation: We may be legally required to process your personal data to comply with applicable laws and regulations. 

Principles of processing

Data minimization and purpose limitation: We only process personal data for the specific purposes for which it was collected or authorized by you. 

No sale of personal data: We do not sell or rent your personal data. We will only share your personal data as outlined in this Privacy Policy. This includes sharing your personal data with our service providers who help us operate our Services. We will not use information from Apple HealthKit, Google Health Connect or Oura Health for advertising or sell it to advertising platforms, data brokers or resellers.

 3. Your privacy rights

What are your rights?

You have rights in relation to your personal data. Only you or someone authorized to act on your behalf can make a request about your personal data. If you authorize someone to act on your behalf, we may need to verify their authorization. 

Erasure of your personal data

You can ask us to delete your personal data at any time. Keep in mind that deleting some personal data might affect your experience with certain features that depend on historic information.  

How to exercise your privacy rights

To exercise your privacy rights, you can email us at contact@phirahealth.com.

You can request to delete your account or make certain changes directly in the App's settings. 

We will handle your request within one month of receiving it. In some cases, such as for complete deletion of your personal data stored in our backup systems, it may take up to 90 days. If we need more time to act on your request, we will let you know and explain the reason for the delay. Please be aware that once the deletion process begins, it can’t be undone. This is because your personal identifiers are immediately unlinked from your App information, which means we can no longer identify you, even if some data temporarily remains in our backup systems.

Your consent is required for us to use your health data. You can withdraw this consent at any time by either contacting us or deleting your account through the App.

What else should you know?

If your request is unclear, we might reach out to you for clarification. We reserve the right to refuse or charge a reasonable fee for requests that require use of computing or human resources to fulfill and fall outside the scope of what is covered under regular support for our Services.

To process your request, we’ll need to verify your identity. Usually, this involves confirming that the request is coming from the email you used to register. If you haven’t registered, we may ask you for additional verification to ensure we respond appropriately. 

If you have any concerns about our privacy practices, please let us know by emailing our support team at contact@phirahealth.com.

4. Third party data processing

We will not share your personal data with third parties except as specified within this Privacy Policy.

Processing to make the App run 

Sometimes, we work with other companies to process your personal data on our behalf. We call these companies or service providers "processors." 

  • Service providers who process data on our behalf under contract (e.g., cloud hosting/infrastructure, customer support tools, email service providers, site analytics, payment processors), bound by confidentiality and data-protection obligations.

  • Professional advisors (e.g. legal, accounting) as needed.

  • Regulators or as required by law, subpoena, or valid legal process, subject to Section 2's law-enforcement disclosure practices.

  • A successor entity in the event of a merger, acquisition, or asset sale, subject to this Policy or a substantially similar one.

Aggregated information

We may aggregate, anonymize or de-identify your personal data so that it cannot be used to identify you. This personal data might be shared with third parties, like research institutions or used for statistical purposes. For example, we share general age and demographic information, along with aggregated statistics about activities or symptoms to identify patterns across and support scientific research. This helps us create articles, blog posts and scientific publications that advance research on female health.

If we want to include you in specific research studies, we will ask for your consent. You can withdraw your consent at any time by emailing us at contact@phirahealth.com.

Information posted by you

We may also preserve or share some of your personal data in the following limited circumstances: 

  • in response to subpoenas, court orders, or legal processes, as required by applicable law (including to meet national security or law enforcement needs); 

  • when necessary to maintain the security and integrity of the Services or to protect any member's security, consistent with applicable laws. In such cases, we may also delete some of your personal data (e.g., by resetting your password to prevent unauthorized access);

  • to assert legal rights or defend against legal claims; 

  • when disclosure is authorized or requested by the member who has provided the personal data; 

  • in the event of a business acquisition, transfer or reorganization; and

  • depending on the situation, we may rely on legitimate interest or legal obligations as the basis for these processing activities. 

5. Phira for partners

If you are over 18, you can choose the Phira for Partners Service, allowing certain information from your Phira account to be shared with your partner. As the main member, you have complete control over this sharing and you can stop it at any time. 

What information will be shared with my partner?

Your partner will have read-only access to the information you choose to share. They cannot download or edit your information. Specifically, they cannot see or edit: 

  • calendar information created before you decided to share; 

  • personal notes; 

  • any symptoms or feelings logged in the App; or 

Your partner will see a view-only version of your current cycle day and cycle phase predictions. They will also receive tailored daily educational insights and notifications during key phases of your cycle. 

What personal data is collected from you as a partner? 

If you're a partner receiving information, we will collect your name and email to set up your account with Phira. We'll also ask for your month and year of birth to verify your age. While we don't collect your gender directly, it may be inferred based on your App usage. No health data about you will be collected. 

6. Retention of your personal data

We will keep your personal data for as long as necessary to provide you with the Services or fulfill the purposes for which it was collected (except as noted below). 

Impact of account deactivation/requests to erase personal data: You can deactivate your account at any time. We will process your request within one-month. In some cases, it will take up to 90 days to completely erase your personal data from our backup systems. If you choose to deactivate your account, Phira will delete your personal data, and it will not be recoverable should you later create another account.

Deleting the App or inactivity: If you delete the App from your device or your account becomes inactive, we will retain your personal data for one year in case you decide to reactivate the Services or reinstall the App. After one year of inactivity, your personal data will be deleted. Phira will apply this standard retention policy. However, you can still request earlier deletion by contacting us at any time.

Limitations: Even after your account is deleted, we may need to retain certain personal data and other information. This is required or permitted by applicable law, and may include situations like: 

  • complying with legal obligations; 

  • managing and handling legal claims; and 

  • archiving for public interest, scientific or historical research, or statistical purposes.

How do we delete your data?

We use industry-standard methods to securely and permanently delete your personal data from our systems, making it impossible to recover. This process may include sending automated notifications to our processors who process your personal data on our behalf.

7. Security of your personal data

General security measures

We take various technical and organizational steps to protect your personal data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. These measures are designed based on the nature of the personal data we handle and the risks associated with special categories of personal data we collect. This includes:

  • encryption: your personal data is encrypted both in transit and at rest;

  • vulnerability scanning: we conduct regular scans and penetration testing;

  • data integrity protection: we have measures in place to protect the integrity of your data;

  • organizational and legal measures: for example, our employees have different levels of access to your personal data, limited to what is necessary for operating the Services. We hold our employees strictly accountable for any disclosure, unauthorized access, alteration, destruction or misuse of your personal data; and

  • privacy assessments: we conduct regular data protection impact assessments to ensure that the Services comply with privacy principles.

Please keep your password secure and don’t share it with others. Consider adding a passcode or enabling face ID for an extra layer of protection. 

While we strive to protect your information by instituting the optimal measures, procedures & policies consistent with the industry standards, we cannot guarantee absolute security, nor can we ensure that your personal data won’t be intercepted during transmission to us.

Security breaches

If there is a security breach and where required by law, we will either post a notice or try to contact you by email. We will take reasonable steps to fix the issue according to applicable laws and this Privacy Policy. For potential personal data breaches, we may take additional actions, such as logging you out from all the devices, resetting your password and other necessary steps to address the situation.

If you want to report a security incident related to the Services, please email us at contact@phirahealth.com

8. Children's Privacy

General age limitation: Our Services are not for children, and we do not knowingly collect personal data from anyone under 13. If you know of someone under 13 using the Services, please email us at contact@phirahealth.com.

Age limitation for residents of the European Economic Area (EEA), United Kingdom (UK), Canada and India: For legal reasons, residents of the EEA, the UK, Canada or India must be at least 16. If you know of someone under 16 using the Services, please email us at contact@phirahealth.com

Some features of the App are only available to members who are 18 or older.

9. Communication with you

We might contact you via email, pop-ups or push notifications to share updates with you about Services, offers, promotions, rewards and events. These messages will be based on the Services you have chosen from Phira, (e.g. your selected mode) and the features you interact with.

Opt-out options: You can unsubscribe from marketing emails by clicking the “Unsubscribe” link in the email. Opting out of these marketing emails or notifications will not stop essential Service-related emails. To stop receiving push notifications, adjust your settings on your device. In some cases, we might ask for additional consent for certain communications.

Please note we may contact you through third-party platforms (like social media) with information about our Services, offers, promotions, rewards and events.

Presence on social networks 

We may use social media to promote Phira and interact with our customers. When you engage with us on these platforms, we process information about you, like your username, profile picture and any comments or posts related to Phira. This information is used solely for engagement purposes.

11. Storage and international personal data transfers

Phira is based in the US. The personal data we collect is transferred to and processed in the US, where it is subject to US law and to other countries (where it follows the laws of those countries). These transfers are usually cloud-based and occur when you use our Services. Please note, the laws in these countries may not offer the same protections as those in your country.

For further information, please email us at contact@phirahealth.com.

12. Contact us

If you have any questions or concerns about your privacy, you may contact us by writing to:

Aurelia Vitals, Inc.
4200 San Jacinto St, Houston, TX 77004
Email: contact@phirahealth.com