Privacy Policy

Last Updated: June 17, 2026

VITALS (referred to as “VITALS”, “we”, “our,” or “us”) recognizes the importance of data privacy, and this Privacy Policy sets forth the terms and conditions with respect to how we process your personal information. This Privacy Policy describes the types of personal information that we collect, the purposes for which we use it, with whom we share it, and any rights and responsibilities you may have with respect to such personal information.

VITALS is a platform that provides AI-guided insights and interactions based on personality assessment data and other information you provide to the platform. Using such data, VITALS may provide personalized insights across your Values, Interests, Temperament, Action Style, Learning Style, and Social Style, and AI-guided interactions designed to help you better understand yourself and apply that understanding to your work, relationships, and personal growth. VITALS is not a medical practice, healthcare provider, or covered entity under the Health Insurance Portability and Accountability Act (HIPAA). The Services are not designed to process or store protected health information as defined by HIPAA; any personal information you provide is handled in accordance with this Privacy Policy, not HIPAA.

VITALS offers three subscription tiers: Free Tier (basic profile and core assessment features at no cost); Standard Tier (annual subscription providing access to a comprehensive VITALS profile reflecting detailed insights and in-depth interpretation across all six personality dimensions — Values, Interests, Temperament, Action Style, Learning Style, and Social Style — including dimension-level narrative, trait-level descriptors, and personalized guidance derived from your assessment results; an AI-guided interactive feature ("Ask VITALS"); and Premium Tier (annual subscription providing access to all Standard Tier features plus specialized lens-based insights tailored to specific life contexts, including Career (with 360-degree feedback) and Relationship (with profile comparison); integration with third-party AI platforms via Model Context Protocol (MCP), enabling your VITALS profile data to be used as contextual input within supported AI environments). The subscription tier associated with your account determines which Services and features are available to you and may affect the personal information we collect and how we use it.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF SERVICE.

Scope

This Privacy Policy applies to the personal information you provide us when you (i) visit any website, platform, or app that we own, license, or otherwise operate and that links to this Privacy Policy (each, a “Site”), (ii) purchase or receive services through the Site, or (iii) otherwise contact or engage with us. For purposes of this Privacy Policy, the Site and all information and services furnished by VITALS through a Site shall be referred to collectively as the “Services.”

For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. VITALS may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and VITALS may use such data for any purpose permitted by law.

The Types and Categories of Personal Information We Collect

VITALS collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to VITALS, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:

Personal Information

Collection of Technical/Online Data

In addition, when you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, as well as your experience on the Site and other websites, including the following:

Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data; Social Media. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. For more information, see, where available, the Cookie Policy on each Site. From time to time, we may use on our Site certain third-party cookies and pixels provided by our marketing partners, including social media companies. To the extent we use such third-party cookies and pixels, you hereby agree to the terms and conditions set forth by those third parties, which may include Meta, X (formerly Twitter), TikTok, and LinkedIn, among others.

Site Monitoring. Please be aware that we, and our service providers and partners, use cookies and other tracking technologies within the Site to monitor and record any and all activities and communications to, from, and on, the Site. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording by us and our service providers and partners.

Non-Cookie Technologies. We may deploy on our Site certain types of “Non-Cookie Technologies” provided by our service providers to support our digital advertising programs. These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically or with additional data specifically requested from your browser or device.

Sources of Information

We collect personal information from the following sources:

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., completing assessments, signing up for newsletter), when you provide feedback to us, or whenever you directly engage with us, such as when you contact customer service or otherwise contact us.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).

Third-Party Sources. We may also obtain data from third parties. These third-party sources vary over time, but they are sources deemed credible by us and may be publicly available or available on a commercial basis. They may include: data brokers from which we purchase demographic data to supplement the data we collect; partners with whom we offer branded products or engage in joint marketing activities; fraud prevention agencies or credit reporting agencies in connection with credit determinations, if applicable; publicly available sources such as open government databases or other data in the public domain; social networking providers; advertising companies; and, third-party references. If you purchase our products from our distributors and business partners we may receive certain information about your purchase from them.

How We Use Your Information / Purpose of Collection

We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests. Please see below for more information on how we use personal information:

How We Use Personal Information

For the avoidance of doubt, you hereby agree that VITALS may contact you via any means, including via SMS/text message and email (including through the use of autodialing systems and services), to furnish you information regarding a commercial transaction.

Sharing Information / Third-Party Disclosures

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.

Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions, tracking and responding to consumer questions or complaints, and performing analyses to improve the quality of our Services.

Payment Card Transactions. All payments for purchases made through the Site are completed using a third-party vendor’s online payment system. VITALS does not have access to your credit card information and does not store or disclose your full credit card information. Any personal or financial information you provide to our online payment system is subject to the third party’s privacy policy and terms of use, and we recommend you review these policies before providing any personal or financial information.

Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.

Business Restructuring. Circumstances may arise where, for strategic or other business reasons, VITALS decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of VITALS’s assets.

Legal; Compliance; Legitimate Interests. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, VITALS may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.

Consent. In addition to the reasons for disclosure set forth herein, we may also disclose your personal information upon your consent.

In the event that you facilitate a transaction with VITALS, or request information from or otherwise engage with us, and such activities require VITALS to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct VITALS to intentionally disclose your personal information to the service provider or third party.

Artificial Intelligence (AI); Chatbots

Artificial Intelligence and Large Language Modules. We use Artificial Intelligence (AI) technologies on the Site to deliver our Services, enhance user experience, and improve our Services. By interacting with our Services, you acknowledge that AI systems may process and analyze your personal data as part of this experience. Our AI systems process various types of data, which can be used to: provide personalized guidance, enable features such as chatbots or virtual assistants; improve content and product offerings; and, analyze trends and performance. Our Services do not involve any automated decision-making processes that have a significant legal impact on individuals, including profiling.

Chat Features. When you use any chat or messaging feature on the Site, we (and our service providers and partners) will collect and record all text and other information and content that you may provide or input using those features. If you use a chat or messaging feature while signed into your account, we (and our service providers and partners) may link that information to your account. All of our chat communications are recorded by us and our third-party service providers and partners.

Social Media/ Platform Data Rights

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site may include social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“SMP Data”) be deleted or modified. If you would like SMP Data related to you deleted or modified, please contact us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the SMP Data that you would like deleted and/or modified, and if modified, the modification to said SMP Data. We may also delete SMP Data if requested by the social media platform.

Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

Video Links. We may, from time to time, include or display live or prerecorded videos or similar audio visual materials (“Videos”) on the Site. By clicking on such Videos on our Sites, (i) you may be redirected to a third party’s website to play the Video, or (2) it may play the Video on our Site, although this functionality may be supported by a third party’s website or technology (e.g., YouTube, YouTube API, Vimeo). In any such case, by accessing the Video, you shall become subject to the third party’s terms and conditions, including, but not limited to, its terms of service and personal information privacy policies and practices, including the terms governing YouTube and Vimeo. For the avoidance of doubt, we may collect personal information with respect to you requesting access to, and/or accessing, such Videos, and we may disclose such personal information to third parties, including to our third-party service providers through the use of cookies. By requesting access to, or accessing, such Videos, you hereby agree to the collection and disclosure of your personal information in such circumstances. The provision of Videos on our Website is not an admission by us, and it shall not otherwise be interpreted, in any form or manner, to mean that we are a “video tape service provider” for purposes of the Video Privacy Protection Act (codified as amended at 18 U.S. Code § 2710) (the “VPPA”) or that we are otherwise subject to the VPPA.

Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information for as long as needed to provide you with our Services, to facilitate transactions you have requested, to comply with our legal obligations, to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

VITALS is based in the United States, and the personal information that we collect and process is retained and stored in the United States. VITALS uses service providers that store personal information on our behalf in the United States and in other countries where you may not be a resident. Please be aware that the United States, and these other countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in the countries where our service providers are located.

Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

No Data Collected from Children

The Site is not directed at, nor intended for use by, children. As a result, if you are under the age of sixteen (16), you are prohibited from accessing or using the Services (including the Site) or with providing us with your personal information.

Publicly Posted Information; Feedback and User Submissions

You may, from time to time, have the ability to submit via the Site a comment on, or provide an opinion about, rate, or otherwise discuss our Services, and/or directly provide us feedback on our business, our business sector, or the Services (collectively referred to as “Feedback”). You may also be able to post content in our communities and discussion forums (collectively “User Submissions”) Any information or content you post in your Feedback or User Submissions may be available to other users of the Site (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Feedback or User Submissions to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Feedback or User Submissions that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. In order for VITALS to utilize such Feedback and User Submissions, you grant to VITALS a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Feedback and/or User Submissions in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of VITALS’s and our sub-licensees’ products or services embodying such Feedback and/or User Submissions in any manner and via any media we choose, without reference to the source. VITALS shall be entitled to use Feedback and User Submission for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.

Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to VITALS if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO VITALS, YOU EXPRESSLY REPRESENT AND WARRANT TO VITALS THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE VITALS WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT VITALS’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY VITALS FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO VITALS.

Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, address), and you must do so when such changes are warranted. If our Site does not provide these capabilities, then you must write to us in accordance with the Contact Us section below so we can update our records.

Communications and Marketing Preferences

For the avoidance of doubt, you hereby agree that we may contact you via any means, including via telephone call, SMS/text message, and email (including through the use of artificial or prerecorded voice and autodialing systems and services), to furnish you information regarding your use of the Services. You have choices to how we communicate with you which is described below.

Email Communication. You may, at any time, opt-out from receiving marketing emails from us. To opt-out from such marketing, please use the “unsubscribe” or “preference” features within our email communications or contact us in accordance with the “Contact Us” section below. You will not be opted out of transactional email messages; therefore, you may still receive transactional email messages regarding your subscription (i.e., appointment reminders, renewal notifications, etc.).

SMS/MMS Communication. By opting into or participating in any of our mobile messaging programs (each a “Program”), you accept and agree to the following terms and conditions:

User Opt In. By providing us your mobile phone number and consenting to participate in the Program, you (i) agree to receive from us (or our service providers acting on our behalf) autodialed or prerecorded marketing SMS/MMS mobile messages at the phone number you provided when you opted into the Program, and (ii) understand that consent is not required to make any purchase from us. While you consent to receive SMS/MMS mobile messages that we (or our service providers) send or transmit using an autodialer, an automatic telephone dialing system, or any similar automated system, the foregoing shall not be interpreted to suggest or imply that any or all of our SMS/MMS mobile messages are in fact sent or transmitted via an autodialer, an automatic telephone dialing system, or any similar automated system.

User Opt Out. If you do not wish to continue participating in the Program or no longer agree to this Agreement, you agree to reply STOP, END, CANCEL, UNSUBSCRIBE, OPT-OUT, REVOKE, or QUIT to any SMS/MMS mobile messages from us in order to opt out of the Program. You may receive an additional mobile message confirming your decision to opt out. You understand and agree that the foregoing options are the only reasonable methods of opting out of the Program.

Duty to Notify. If at any time you stop using, whether voluntarily or involuntarily, the mobile telephone number that has been used to subscribe to the Program (e.g., canceling your mobile/wireless service plan, having your mobile/wireless service plan terminated, or selling or transferring the mobile phone number to another party), you agree (i) that you will complete the User Opt Out process set forth above prior to the ending or termination of your use of the mobile telephone number, and (ii) that failure to undertake the foregoing User Opt Out process set forth above is a material breach of this Agreement.

Cost and Frequency. Message and data rates may apply. The Program involves recurring SMS/MMS mobile messages, and additional SMS/MMS mobile messages may be sent periodically based on your interaction with us.

Our Disclaimer of Warranty. The Program is offered on an “as-is” basis and may not be available in all areas at all times and may cease to work in the event of product, software, coverage or other changes made by your wireless carrier. We will not be liable for any delays or failures in the receipt of any SMS/MMS mobile messages connected with a Program. The delivery of SMS/MMS mobile messages is subject to effective transmission from your wireless service provider/network operator and is outside of our control. We are not liable for delayed or undelivered SMS/MMS mobile messages.

Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

Persons with Disabilities

VITALS strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.

Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a resume, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs.

We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law.

We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.

Please see above for any privacy rights you may have with respect to this personal information.

Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

Contact Us

If you have questions regarding this Privacy Policy or our handling of your personal information, please contact us (email) legal@vitals.me.