Privacy Policy

This summary is not a substitute for the full policy, but it highlights important points.

• –Vyla processes sensitive reproductive health and wellness data that you choose to provide, such as cycle logs, symptoms, temperature, LH test information, cervical mucus, intimacy logs, notes, AI messages, and wearable signals.
• –We use your data to provide the Services, including account access, cycle tracking, predictions, insights, reminders, reports, AI features, wearable sync, subscriptions, support, security, and product improvement.
• –Vyla AI chat requires Premium in the current app. If you use Vyla AI, your messages and relevant account or cycle context may be processed to generate responses and support chat history.
• –If you connect a wearable, we process device metadata and synced wellness signals to show readings and support insights.
• –We do not sell your reproductive health data to advertisers or data brokers.
• –We do not currently describe Vyla as an ad-supported app, and the current mobile app codebase does not include third-party advertising SDKs.
• –We share data with service providers only as needed to operate the Services, with payment providers to process subscriptions, with identity providers if you choose social sign-in, and with other people only when you choose to share or use social features.
• –You may have rights to access, correct, delete, export, restrict, or object to certain processing of your data, depending on where you live.
• –Some features are optional. You can choose whether to use Vyla AI, upload LH images, enable notifications, connect a wearable, invite friends, or share reports.

The controller or business responsible for the processing described in this Privacy Policy is:

If we appoint a Data Protection Officer, EU representative, UK representative, or other privacy contact, we will provide the details here.

If you contact us about privacy, please do not include sensitive health information in the subject line of your email. We may need to verify your identity before responding to certain requests.

This Privacy Policy applies to personal data processed through:

• –the Vyla iOS and Android apps
• –Vyla websites and landing pages
• –Vyla backend services and APIs
• –Vyla AI chat and AI-assisted logging features
• –cycle, symptom, fertility, wellness, and health-data tracking features
• –LH image capture, upload, and analysis features
• –wearable, Bluetooth, and connected-device features
• –notifications, reminders, and in-app messages
• –subscriptions, plan selection, checkout, billing, and payment status workflows
• –report generation, exports, secure links, share cards, email drafts, and sharing flows
• –referral, invite, friend, and comparison features
• –support, troubleshooting, security, diagnostics, and operational systems

This Privacy Policy does not apply to third-party services that Vyla does not control, including app stores, operating system providers, third-party identity providers, payment processors, email providers, messaging apps, wearable vendors, AI infrastructure providers, analytics providers, or websites you access through external links.

The data we collect depends on how you use Vyla, your device settings, your subscription, your country, and the features you choose.

Vyla is built around reproductive health and wellness. Many categories of data described in this policy may be considered sensitive personal data, special category data, consumer health data, or health-related personal information under applicable laws. This may include:

• –period and menstrual cycle data
• –fertility, ovulation, and pregnancy-intention information
• –LH test results and images
• –cervical mucus information
• –intimacy logs
• –symptoms and pain entries
• –mood and stress information
• –sleep and wearable signals
• –AI messages about your body, health, cycle, symptoms, sex life, fertility, or wellness
• –reports, summaries, and predictions derived from your logs

We process this information to provide features you request, operate and secure the Services, and carry out other purposes described in this Privacy Policy. We do not use sensitive reproductive health information for third-party targeted advertising.

We collect data:

• –directly from you when you create an account, complete onboarding, log information, use Vyla AI, upload images, connect devices, manage subscriptions, request support, invite friends, generate reports, or change settings
• –automatically from your device and app session when you use the Services
• –from connected devices and wearables you choose to pair
• –from third-party sign-in providers if you use Google, Apple, or another supported identity provider
• –from payment providers, app stores, or checkout providers when you select or purchase a subscription
• –from notification, analytics, hosting, security, support, and infrastructure providers that help operate the Services
• –from other users if they invite you, send you a friend request, share content with you, or participate in comparison features with you

We use personal data for the following purposes.

If you are in the UK, EEA, or another jurisdiction that requires a legal basis, we generally rely on the following bases.

Where we rely on consent, you may withdraw consent at any time. Withdrawal does not affect processing that occurred before withdrawal and may affect your ability to use certain features.

Some data is required to use parts of the Services. For example:

• –an email address or supported sign-in credential may be required for a standard account
• –cycle setup information may be required to generate cycle estimates
• –payment information is required to purchase Premium
• –push notification permission is required to receive push notifications
• –Bluetooth permission is required for certain wearable features
• –relevant logs may be required for useful predictions, reports, or AI answers

If you do not provide required data, the relevant feature may not work. Optional data can be skipped, but skipping it may reduce the accuracy, relevance, or availability of some features.

We may disclose personal data to the following categories of recipients.

• –sell your reproductive health data to advertisers or data brokers
• –use your sensitive reproductive health data for third-party targeted advertising
• –require you to use Vyla AI, upload LH images, enable notifications, connect a wearable, or use friend-comparison features
• –provide medical diagnosis or emergency care
• –knowingly collect personal data from children under 13

If our practices change in a way that requires additional notice or consent, we will provide that notice or request that consent as required by law.

Vyla AI is intended to help you understand your logs, ask general cycle and wellness questions, and organize information. Vyla AI is not a clinician and does not provide medical advice, diagnosis, or treatment.

When you use Vyla AI:

• –your message and relevant app context may be processed to generate a response
• –your chat history may be stored with your account
• –AI outputs may be inaccurate, incomplete, or unsuitable for your situation
• –you are responsible for deciding whether to save any AI-assisted log suggestion
• –sensitive information you type into chat may be processed as described in this policy
• –we may use safety systems, moderation, logging, or review processes to prevent misuse and improve reliability

If you use LH image features, Vyla may request camera or photo permissions and process images you capture or upload. We use LH images to confirm image validity, analyze or help record LH test results, save the result to your log if you choose, troubleshoot image processing failures, and improve reliability where permitted.

You can choose manual LH entry if available. You can manage camera and photo permissions through your device settings.

Vyla may offer notifications for period reminders, fertile window reminders, cycle delay alerts, ovulation-related updates, logging reminders, wearable sync reminders, subscription events, account messages, and similar app-related notices.

Notification content may reveal sensitive cycle or wellness information to anyone who can see your device. You can manage notifications in the app and through your device settings.

Vyla may let you generate cycle reports, health data reports, share cards, summaries, secure links, or email drafts. These outputs may include sensitive data selected by you or generated from your logs.

Use care when sharing reports or links. Recipients may store, forward, screenshot, copy, or misunderstand the information. Vyla cannot control external recipients or external apps once you share information.

If you invite someone, accept a friend request, or use comparison features, Vyla may process information about both users involved. Comparison features should be used only with people you trust.

Depending on the feature, we may show summary-level information rather than raw logs. Even summary information can be sensitive. You can manage friend or comparison permissions where the app provides those controls.

We may create aggregated, anonymized, or de-identified data from personal data so that it no longer reasonably identifies you. We may use such data for analytics, research, product development, benchmarking, reliability, and business purposes.

Where we describe data as de-identified, we intend to maintain it in de-identified form and not attempt to re-identify it except as permitted by law.

The primary Vyla product is a mobile app, but we may also operate websites, landing pages, checkout flows, support pages, secure links, or browser-based features.

We and our service providers may use cookies, local storage, mobile SDKs, device identifiers, pixels or similar technologies, session tokens, analytics events, and crash logs for authentication, session continuity, security, analytics, checkout, fraud prevention, feature delivery, and preference storage. Where required, we provide consent choices for non-essential cookies or similar technologies.

The current Vyla app is not described as ad-supported, and the current mobile codebase does not include third-party advertising SDKs. We do not use sensitive reproductive health data for third-party targeted advertising.

We may send service-related communications, such as account, security, billing, support, or policy notices. We may send marketing communications only where permitted by law and with required choices. You can opt out of marketing emails where offered.

We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain your account, support tracking history, preserve preferences and consents, meet legal obligations, prevent fraud, resolve disputes, and enforce agreements.

• –Account and profile data may be retained while your account is active and for a reasonable period afterward
• –Cycle, wellness, symptom, fertility, and wearable records may be retained until you delete them or request deletion, subject to legal exceptions
• –AI chat history may be retained while associated with your account unless deleted under our retention practices
• –Subscription and payment records may be retained for tax, accounting, dispute, refund, fraud prevention, and compliance purposes
• –Security logs, audit logs, backups, and diagnostic records may be retained for limited periods consistent with security and operational needs
• –De-identified or aggregated data may be retained for longer because it is no longer reasonably associated with you

We use administrative, technical, and organizational safeguards designed to protect personal data, including encryption in transit and at rest where appropriate, secure token storage, authenticated API access, access controls, environment separation, logging and monitoring, rate limiting, secure development practices, vendor review, and incident response processes.

No method of transmission or storage is completely secure. You also play an important role by securing your device, using strong credentials, keeping recovery information safe, updating your app, managing lock-screen notification visibility, and sharing reports only with trusted recipients.

Vyla may process, store, or transfer personal data in countries other than the country where you live. These countries may have privacy laws that differ from those in your jurisdiction.

Where required, we use appropriate safeguards for international transfers, such as adequacy decisions, standard contractual clauses, data processing agreements, transfer risk assessments, or other lawful transfer mechanisms.

Depending on the feature and your jurisdiction, you may be able to:

• –update account and profile information
• –choose what cycle and wellness data to log
• –choose whether to use Vyla AI, upload LH images, or connect a wearable
• –manage Bluetooth, camera, photo, and notification permissions through your device
• –manage in-app notification preferences and quiet hours where available
• –choose whether to use friend, referral, comparison, report, export, or sharing features
• –manage privacy preferences where offered
• –change subscription settings or sign out
• –request access, correction, deletion, or export of your data
• –delete your account where available

Depending on where you live, you may have rights including:

• –the right to know or be informed about how we process personal data
• –the right to access personal data
• –the right to receive a copy of personal data
• –the right to correct inaccurate personal data
• –the right to delete personal data, subject to exceptions
• –the right to data portability
• –the right to object to certain processing
• –the right to restrict certain processing
• –the right to withdraw consent where processing is based on consent
• –the right to limit certain uses or disclosures of sensitive personal data where applicable
• –the right to opt out of certain sales, sharing, targeted advertising, profiling, or automated decision-making where applicable
• –the right not to be discriminated against for exercising privacy rights
• –the right to appeal a decision regarding your request where applicable

To exercise rights, contact us at privacy@vyla.health or support@vyla.health. We may need to verify your identity before acting on a request.

Vyla uses automated processing to provide features such as cycle day calculation, period predictions, fertile window estimates, ovulation estimates, symptom and trend summaries, wearable-based wellness insights, notification timing, AI responses and AI-assisted logging suggestions, and subscription access rules.

These features are informational and are not intended to make legally significant decisions about you. Predictions and AI outputs may be inaccurate or incomplete. You should not rely on them for medical decisions.

If you are in the United Kingdom or European Economic Area, this section supplements the rest of this Privacy Policy.

If you are a resident of a U.S. state with an applicable consumer privacy law, this section supplements the rest of this Privacy Policy.

If you are a California resident, this section supplements the rest of this Privacy Policy and applies to personal information under the California Consumer Privacy Act, as amended.

Some laws define "consumer health data" broadly. Where such laws apply, Vyla may collect consumer health data including menstrual cycle data, fertility and ovulation information, pregnancy-intention information you provide, symptoms, mood, sleep, pain, temperature, LH, cervical mucus, intimacy, and wellness logs, wearable health and wellness signals, AI messages about health or wellness, and inferred cycle, fertility, and wellness insights.

You may have rights to access, delete, withdraw consent, or appeal decisions regarding consumer health data depending on where you live.

Vyla is not intended for children under 13, and we do not knowingly collect personal data from children under 13 without legally valid authorization. If a higher minimum age applies where you live, that higher age applies.

If you believe a child has provided personal data to Vyla in violation of applicable law, contact us so we can investigate and take appropriate action.

Vyla is a consumer wellness app. Unless we expressly state otherwise in a separate written agreement, Vyla is not acting as a HIPAA covered entity or business associate when you use the consumer app.

If you choose to share a Vyla report with a healthcare provider, that provider's handling of the report may be subject to separate health privacy laws and the provider's own policies.

We may update this Privacy Policy from time to time. If we make material changes, we may notify you through the app, by email, through our website, or by other reasonable means. The "Last updated" date shows when this version was last revised.

Your continued use of the Services after an updated Privacy Policy becomes effective means your data will be processed under the updated policy to the extent permitted by law. If we need consent for a new processing activity, we will request it.

For privacy questions, requests, or complaints, contact: