Legal Document 03 of 03

Privacy Policy & Data Consent

Version 1.0 · Effective Date: June 2026 · Governing Law: Commonwealth of Kentucky

Vytal Future LLC · Kentucky, USA

1. Introduction

Vytal Future LLC ("Vytal Future," "we," "us," or "our") is committed to protecting the privacy of our members. This Privacy Policy and Data Consent ("Privacy Policy") explains what data we collect, how we use it, who we share it with, how we protect it, and what rights you have regarding your data.

By creating an account or using Vytal Future's Services, you consent to the data practices described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Member Agreement and Terms of Service. Capitalized terms not defined here have the meanings given in that agreement.

2. Data We Collect

2.1 Account and Identity Data

When you create an account, we collect: your name, email address, date of birth, and payment information. Payment information is processed by our third-party payment processor and is not stored by Vytal Future directly.

2.2 Onboarding and Assessment Data

During onboarding and through your ongoing weekly SMS assessments, we collect: your responses to health and wellness assessment questions covering nutrition habits, physical activity, sleep quality, stress management, energy levels, and mood. This data is used to calculate your Vytal Score and pillar scores and to deliver coaching protocols appropriate to your profile.

2.3 Wearable Device Data

If you connect a compatible wearable device to the Vytal Future platform, we collect health and activity data via wearable data integration technology. This data may include: resting heart rate, average heart rate, maximum heart rate, heart rate variability (HRV), sleep duration and sleep stage data (total sleep, deep sleep, REM sleep, time awake), daily step count, active time, active calories, total calories, distance, and stress score (where reported by your device).

This data is collected continuously while your device is connected. You may disconnect your wearable device at any time through your account settings. Disconnecting your device will stop future data collection but will not delete historical wearable data already collected.

2.4 Bloodwork Data

If you purchase the bloodwork panel add-on, your biomarker results from our laboratory partner will be delivered to your Vytal Future dashboard. We store your panel results and use them to calculate your Biomarker pillar score (where applicable) and to provide educational context through the dashboard. Bloodwork data is treated as sensitive health data and is subject to the enhanced protections described in Section 7.

2.5 Communications Data

We collect data from your interactions with our SMS assessment system, including your responses to weekly questions, re-engagement messages, and any replies you send to automated or coach-initiated messages. We also collect data from email communications related to your account.

2.6 Coaching Session Data

If you purchase coaching sessions, we may collect notes from those sessions as documented by your coach. These notes are stored in our internal coaching platform and are not shared with third parties except as required by law.

2.7 Usage and Technical Data

We collect standard technical data about your use of our platform, including: IP address, device type, browser type, pages visited, and session duration. This data is used for platform security, performance monitoring, and service improvement.

2.8 SMS Opt-In Data

When you provide your mobile phone number and consent to receive SMS messages from Vytal Future, we collect and store your SMS opt-in data, including: your mobile phone number, the date and time of your consent, the method by which consent was obtained (account creation / onboarding form), and the consent language presented to you at the time of opt-in.

This data is used solely to deliver the Vytal Future SMS program and to maintain records of your consent. We do not sell, share, lease, or rent your mobile phone number or SMS opt-in data to third parties or affiliates for marketing purposes or any other purpose. Your SMS opt-in information is never shared with third parties for their own marketing use.

3. How We Use Your Data

To create and manage your account and membership
To calculate and update your Vytal Score, pillar scores, and sub-scores
To assign and deliver your personalized health and nutrition protocols
To deliver your weekly SMS assessment and process your responses
To generate coaching flags and deliver automated and human coaching communications
To generate your 3-month Baseline Report and any other milestone reports
To process payments and manage billing
To communicate with you about your account, membership, and Services
To deliver add-on products including supplement recommendations and bloodwork result review
To identify upgrade opportunities and deliver relevant product recommendations
To improve and develop our Services, scoring algorithms, and coaching protocols
To ensure the security and integrity of our platform
To comply with applicable laws and legal obligations
To create anonymized and aggregated datasets for research, analytics, and commercial purposes as described in Section 5

We do not sell your personal identified health data — meaning data that can be used to identify you as an individual — to third parties for advertising or marketing purposes. We may share or sell anonymized and aggregated data as described in Section 5.

4. Third-Party Service Providers

Vytal Future works with third-party service providers to deliver the Services. We share data with these providers only to the extent necessary for them to perform their functions.

The categories of third-party providers we currently use include:

Wearable device data integration providers — to connect and retrieve health and activity data from member wearable devices
Customer relationship management and communication platforms — to manage member records and deliver program communications
SMS delivery and automation platforms — to deliver weekly assessments and automated coaching messages
Laboratory ordering services — to facilitate bloodwork panel ordering and result delivery for members who purchase the bloodwork add-on
Payment processors — to process membership fees and add-on purchases. Payment card data is handled directly by our payment processor and is not stored by Vytal Future
Platform hosting and infrastructure providers — to host and deliver the Vytal Future web and mobile platform
Data storage and database providers — to store and manage member account and health data

We do not share your personal identified data with any third party outside of the above categories except: (a) as required by applicable law or legal process; (b) to protect the rights, property, or safety of Vytal Future, our members, or others; (c) in anonymized and aggregated form as described in Section 5; or (d) in connection with a Business Transfer as described in Section 6.

5. Anonymized and Aggregated Data

Vytal Future may create, use, share, license, or sell anonymized and aggregated datasets derived from member data. These datasets are processed in a manner designed to prevent the identification of any individual member.

Anonymized and aggregated data may be used or shared for purposes including: health and wellness research and analytics, development of population-level health insights and benchmarks, commercial licensing to third parties in industries including healthcare, insurance, wellness, technology, and pharmaceutical research, product development and improvement, and academic or institutional research partnerships.

Anonymized data has been stripped of all directly identifying information — your name, email, phone number, date of birth, address, and any other information that could be used to identify you as an individual. Vytal Future will never sell a dataset that contains your name, contact information, account credentials, or any other directly identifying information to a third party for commercial purposes outside of a Business Transfer as described in Section 6.

5.1 Your Right to Opt Out

You have the right to opt out of having your data included in anonymized and aggregated datasets shared or sold to third parties. Opting out does not affect your membership or access to the Services. To exercise this right, contact Vytal Future at the address in Section 13 or update your preferences in your account settings.

6. Business Sale, Merger, or Asset Transfer

You acknowledge and agree that if Vytal Future LLC is involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, or sale of all or substantially all of its assets or business (collectively, a "Business Transfer"), your personal data — including all health and wellness data, assessment responses, wearable data, scoring history, bloodwork results, and account information — may be transferred to the acquiring entity or successor organization as part of that transaction.

By creating an account and using the Services, you expressly consent to the transfer of your personal data in connection with any Business Transfer. Vytal Future will provide notice to members via email or dashboard notification as soon as reasonably practicable before or upon completion of a Business Transfer that involves transfer of member personal data. If you do not wish your data to be transferred, you may request deletion of your personal data by contacting Vytal Future prior to the completion of the Business Transfer.

7. Sensitive Health Data

Vytal Future collects certain categories of sensitive health data, including wearable biometrics, self-reported health and wellness assessment responses, and bloodwork results. We take the protection of this data seriously and implement reasonable and appropriate technical and organizational measures designed to protect it against unauthorized access, disclosure, alteration, and destruction.

Access to sensitive health data is limited to authorized Vytal Future personnel and coaches who need it to deliver the Services
Sensitive health data is not shared with third parties for advertising, marketing, or any purpose other than delivering the Services or as part of anonymized and aggregated datasets as described in Section 5
Bloodwork results are treated as the most sensitive category of data we hold and are subject to stricter access limitations
Coaches are bound by confidentiality obligations with respect to all member health data

8. Data Retention

Account data is retained for a minimum of 3 years following account closure to comply with applicable legal and business record requirements
Health assessment and scoring data is retained for the life of the account and for 3 years following account closure
Wearable device data is retained for the life of the account and for 3 years following account closure
Bloodwork results are retained indefinitely in your account unless you request deletion
Payment records are retained for 7 years as required by applicable tax and financial regulations
You may request deletion of your health and personal data at any time subject to applicable legal retention obligations

9. Your Data Rights

Subject to applicable law, you have the following rights with respect to your personal data:

Access: You may request a copy of the personal data we hold about you
Correction: You may request correction of inaccurate or incomplete personal data
Deletion: You may request deletion of your personal data, subject to legal retention obligations
Portability: You may request an export of your personal data in a commonly used format prior to or within 30 days of account closure
Objection: You may object to certain uses of your data, including use for service improvement and algorithm development
Opt-Out of Anonymized Data Sale: You may opt out of having your data included in anonymized and aggregated datasets shared or sold to third parties

To exercise any of these rights, contact Vytal Future at the address in Section 13. We will respond to all verifiable requests within 30 days.

10. Cookies and Tracking

The Vytal Future web platform uses cookies and similar tracking technologies for: maintaining your login session, remembering your preferences, and analyzing platform usage. You may disable cookies through your browser settings, though doing so may affect platform functionality. We do not use third-party advertising cookies.

11. Children's Privacy

Vytal Future's Services are intended for adults aged 18 and older. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected data from a person under 18, we will delete that data promptly.

12. Security

Vytal Future implements reasonable and appropriate technical and organizational measures designed to protect your data against unauthorized access, disclosure, alteration, and destruction. No security system is impenetrable and we cannot guarantee that your data will never be accessed, disclosed, altered, or destroyed despite our efforts. You are responsible for maintaining the security of your account credentials.

13. Changes to This Privacy Policy

Vytal Future may update this Privacy Policy from time to time. Material changes will be communicated to members via email or dashboard notification at least thirty (30) days before the effective date. Continued use of the Services after the effective date of any update constitutes your acceptance of the updated Privacy Policy.

14. Contact Information

For questions about this Privacy Policy, to exercise your data rights, or to report a privacy concern:

Vytal Future LLC info@vytalfuture.com vytalfuture.com

Member Agreement & Terms of Service →SMS Consent & Terms →