Privacy Policy

1. Who we are

PULSE by Veyronix ("PULSE") is provided by Veyronix Limited, a company registered in England and Wales (company number 16821530), registered office 64B Borthwick Road, London E15 1UE, United Kingdom. Veyronix Limited is the data controller for personal data processed through PULSE.

Privacy contact: privacy@veyronix.co.uk. Customer support: support@veyronix.co.uk.

2. About this policy and PULSE's current status

This policy explains what personal data PULSE collects, why, how long it is kept, who it is shared with, and your rights. It covers the PULSE mobile apps (iOS and Android) and the PULSE web app.

PULSE is not yet publicly available. It is "Coming Soon" and is being prepared for a private beta, launching in the United Kingdom first. PULSE is currently free to use. Optional Premium features are planned but have not been built, and no payment data is collected.

PULSE is for adults aged 18 and over. When you sign up you must declare that you are 18 or over. This is a self-declaration; we do not check identity documents. If you declare that you are under 18, the new account is deleted straight away. If you believe a person under 18 is using PULSE, please contact privacy@veyronix.co.uk.

This policy describes PULSE as it will work when this policy takes effect. Some features described here, including account deletion, data download, the 18+ declaration, optional analytics choices and photo metadata removal, are being prepared for release and may not yet be available in the version of PULSE you are using.

3. Information we collect

The table below lists the personal data PULSE processes. PULSE does not collect your date of birth, GPS location, contacts or microphone input, does not send push notifications, and does not sync with Apple Health, Apple Watch or Google Fit. PULSE does not sell personal data or use it for advertising.

Retention periods marked "proposed" are not yet applied. Until they are, that data is kept with no automatic expiry (it is still deleted when you delete your account, where stated).

4. Fitness and health-related information

Some of the information you choose to enter, such as your weight, height, age and sex, your food and calorie diary, water intake, workouts and calories burned, may count as health data. Health data is "special category" data under UK data protection law and needs extra protection.

This information is optional, apart from the default daily goals set when you sign up. It is used only to provide PULSE's tracking features to you. It is excluded from our usage analytics and is not shared with advertisers.

Accepting the Terms of Service, or acknowledging this policy, is not treated as consent to process health data. A separate health-data consent step has been built into PULSE but is switched off. It will be described here only once it has been legally approved and switched on.

5. Sign-in, including Sign in with Google

You can create a PULSE account with an email address and password, or sign in with your Google account.

If you use Google sign-in, PULSE receives your email address, name and profile picture URL. Sign-in is currently handled through our hosting provider Emergent's managed authentication service, which passes this information to PULSE after you sign in with Google. New Google accounts must complete the 18+ declaration and accept the Terms before they can use PULSE.

• We use this information only to create your PULSE account or sign you in, and to show your name and picture in the app.
• If a PULSE account already exists with the same email address, Google sign-in signs you into that account.
• PULSE does not store Google access or refresh tokens, and does not access Gmail, Google Drive, Google Fit, Google Calendar or any other Google service.
• We do not sell Google user data, use it for advertising, or share it except as described in this policy.

After you sign in, PULSE issues its own session token. It is stored securely on your device (in the secure keystore on iOS and Android, or in browser storage on the web) and expires after 30 days. You can sign out of all devices from the app.

6. AI food-photo processing

When you choose to scan food, the photo you take or choose is sent from the app to the PULSE server, then through Emergent's AI gateway to OpenAI, which uses an AI model to identify the food and estimate its nutrition. The scan screen tells you this before you scan.

• Before the photo is sent, the PULSE server re-encodes it to remove embedded metadata, such as location (GPS), camera and other EXIF/XMP information.
• Only the photo, a fixed instruction and a random session label are sent. Your name, email address, user ID and health profile are not sent.
• PULSE does not save your food photos. A photo is held in server memory only while the request is processed. Only the nutrition result is saved, and only if you choose to log it.
• AI estimates can be wrong. Results cannot be edited directly: if a result looks wrong, retake the photo or add the food manually. PULSE does not provide medical or dietary advice.

Although PULSE does not save your food photos, our AI providers may keep them under their own arrangements. We have not yet confirmed how long Emergent or OpenAI keep images or prompts, whether they may be used to train AI models, or where they are processed. We will not make statements about these points until the providers have confirmed them.

7. First-party analytics and device information

PULSE uses its own optional analytics, stored only on PULSE's servers, to understand how the app is used and to improve it. PULSE does not use Google Analytics, Firebase, Mixpanel, Sentry, Crashlytics, advertising SDKs or the Facebook SDK.

Off until you allow them. No optional analytics are collected or stored until you tap "Allow" on the in-app card or switch analytics on in Profile. New accounts start with analytics off. You can change your choice at any time in Profile, and each choice is recorded with its version and time. If you are signed in, events are stored only when both your device and your account have a recorded "Allow". This applies to events sent by the app and to events recorded by the server (for example sign-up, sign-in and scan results).

Pseudonymous, not anonymous. When you are signed in, analytics events are linked to your internal PULSE user ID. They are never linked to your name, email address or health data.

• What may be recorded, if you allow it: sessions, screens viewed, sign-up and sign-in, workouts started or completed, meals and water logged, weight logged, food scans, web-app install prompts and errors.
• Identifiers: a random session ID, a random event ID and, when you are signed in, your internal PULSE user ID. No advertising ID or device fingerprint is used.
• Device information: platform, operating system, browser, device type and model, app version, display mode, release channel, and an approximate country estimated from your device's time zone and language (no IP address lookup).
• An automatic filter removes fields relating to your email, name, phone, weight, height, age, calories, macros, gender, location, address, IP address or passwords before anything is stored. Your nutrition and workout values are never sent to analytics.
• Raw analytics events are deleted automatically after 395 days. They are not included in the in-app data download, but you can request them from the privacy contact.

Records that run regardless of your analytics choice: daily-active markers (your user ID and the date, recorded once per day on any signed-in request, used to operate the service and count active users), server performance metrics and uptime checks (no user ID or IP address), and failed sign-in security records.

Accounts used for beta testing are flagged so that they can be excluded from our usage figures. Their events follow the same consent rules.

8. Cookies and on-device storage

PULSE does not use third-party cookies or tracking pixels. On the web, PULSE uses your browser's storage to keep you signed in and to hold your analytics choice, any analytics events waiting to be sent (only after you allow analytics), session timing and whether you have seen the privacy notice. On iOS and Android, your sign-in token is kept in the device's secure keystore.

9. Who we share data with

PULSE uses the following service providers. Apart from these providers, PULSE does not send personal data to third parties, unless the law requires us to.

Support emails sent to support@veyronix.co.uk or privacy@veyronix.co.uk are handled through Veyronix's email provider. The same provider sends PULSE launch-update emails. When someone signs up for launch updates, Veyronix's support team is notified. Launch-update sign-ups are stored on the Veyronix website's own systems, separately from customer and sales records.

10. International transfers

PULSE uses service providers that are based outside the United Kingdom: Emergent (Emergent Labs, Inc.), OpenAI and Google. Personal data may therefore be stored or processed outside the UK.

11. How long we keep data

Retention periods applied today: app usage analytics and error reports, 395 days; server performance metrics, 90 days; uptime checks, 180 days; failed sign-in records, 90 days; sessions, 30 days; deletion codes, 30 minutes. Account, profile and diary data are kept for the life of your account, or until you delete an individual entry.

Proposed retention periods (not yet applied):

• Daily-active markers: 400 days.
• Beta feedback: 730 days.
• Feedback screenshots: 365 days.
• Administrator audit logs: 730 days.
• Account deletion receipts: 6 years, as proof that deletion was carried out.
• Support correspondence: 24 months after the request is resolved.

Until these proposed periods are put in place, that data is kept with no automatic expiry. Sign-in and deletion-code rate-limit counters are kept only for a short time, to prevent abuse.

12. Deleting your account and getting a copy of your data

Deleting your account: you can delete your account in the app (Profile → Account & data → Delete account), or without the app through PULSE's web deletion page, using a one-time code sent to your account email. Full steps are on the PULSE account deletion page.

When an account is deleted, all sessions are ended and we delete your profile, goals, body measurements, food, activity, weight and water records, favourites, feedback, choice and consent records, daily-active markers and pending deletion requests, and then your user record. If deletion is interrupted, it resumes automatically.

What may remain:

• Analytics events, with your user ID removed.
• A deletion receipt (a reference number, date, method and record counts), which contains no email address or user ID.
• Administrator audit-log entries, which may still refer to your former internal ID. That ID can no longer be linked to you.
• Failed sign-in records, which contain no identifiers.
• Feedback screenshots: our storage provider does not currently allow files to be deleted, so PULSE overwrites each screenshot file with an empty file. We cannot yet confirm that earlier versions, cached copies or backups held by the provider are removed.
• Copies in our hosting provider's backups, for as long as the provider keeps them.

Getting a copy of your data: in the app, Profile → Download my data gives you a file (JSON format) with your profile, goals, age and Terms records, consent history, nutrition, activity, weight and water records, favourites, feedback reports and active days. Analytics events are not included; you can request them from privacy@veyronix.co.uk.

13. Your rights

Under UK data protection law (the UK GDPR and the Data Protection Act 2018), you have the right to:

• be told how your personal data is used (this policy);
• access the personal data we hold about you and receive a copy;
• have inaccurate or incomplete data corrected;
• have your data erased, in certain circumstances;
• restrict how we use your data, in certain circumstances;
• object to processing based on our legitimate interests;
• receive data you have given us in a portable format, where processing is based on consent or contract and is automated;
• withdraw consent at any time, where we rely on consent. This does not affect processing that happened before you withdrew it.

PULSE does not make decisions about you based solely on automated processing that have legal or similarly significant effects.

You can correct your profile, delete entries, download your data, change your analytics choice and delete your account in the app (see section 12). For any other request, email privacy@veyronix.co.uk. The law generally requires us to respond without undue delay and within one month of receiving your request. That period can be extended by up to two further months if a request is complex or you make several requests, in which case we must tell you within the first month. We may need to confirm your identity before acting on a request, and the time limit starts once we have done so. Requests are usually free of charge.

14. Our legal reasons for using your data

We use your data to provide the PULSE service you sign up for, to keep it secure, to improve it, and to meet our legal obligations. We send PULSE launch-update emails only with your consent. You can withdraw it at any time using the unsubscribe link in any launch email, or by emailing privacy@veyronix.co.uk. Withdrawing consent stops future launch emails.

15. Security

Passwords are stored only as salted one-way hashes. Sessions expire and can be revoked from all devices. Deleting an account in the app requires your password (or, for Google accounts, a sign-in within the last 15 minutes), and deleting it without the app requires a one-time code sent to your account email. Feedback screenshots are kept in private storage that is reachable only with PULSE's server-side key; they are shown only to super-administrators through the authenticated admin system, and every view is logged. Administrator access is protected by two-factor authentication and audit logging. No method of transmitting or storing data is completely secure, but we work to protect your information.

16. Changes to this policy

This policy will be updated when PULSE's features or data practices change. The version and "Last updated" date at the top show the current version.

17. Contact and complaints

Questions or requests: privacy@veyronix.co.uk, or write to Veyronix Limited, 64B Borthwick Road, London E15 1UE, United Kingdom.

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