Privacy Policy

Introduction

VOR Eye Rehab ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and web services (collectively, the "Service").

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the Service.

Information We Collect

Personal Information

When you create an account, we collect:

• Name and email address
• Account credentials (securely hashed passwords)
• Profile information you choose to provide

Health and Exercise Data

To provide rehabilitation services, we collect:

• Exercise session data (type, duration, difficulty level)
• Symptom scores (dizziness, brain fog, headache, eye strain, nausea)
• Progression metrics and difficulty adjustments
• Exercise performance data
• Session dates and times

Patient-Reported Episodes and Optional Health Context

If Episode Context is available and you choose to use it, Eye Rehab stores the symptom-checker answers you save, episodes you record, visibility choices, factual report content, and receipts showing which revision a clinician reviewed. Episode entries may include dates and times, reported severity, symptoms, functional impact, surrounding circumstances, and an optional note. These observations do not diagnose a condition, establish a cause, or predict a future episode.

You may separately connect Apple Health on iOS or Health Connect on Android. With your permission, Eye Rehab reads sleep-session intervals to summarize daily duration, daily step totals, resting heart rate in beats per minute, and heart-rate variability in milliseconds. Android uses RMSSD; Apple Health uses SDNN. These methods are labeled separately and are not treated as equivalent. Eye Rehab does not read steps cadence for this feature.

Each import reads at most 14 local calendar days while the app is in the foreground or when you request a refresh. Eye Rehab requests no write, background-read, or extended-history access. Daily summaries are prepared on your device and sent to your Eye Rehab account over HTTPS, together with measurement times, method, and limited source information such as the source app and device name. Health payloads are encrypted in server storage. These summaries support viewing and exporting your recorded health context around episodes. They do not establish an episode trigger, diagnose a condition, or control exercise progression. We do not sell these data or use them for advertising or model training.

Connecting health data is optional and does not change access to exercises or episode logging. Disconnecting stops new reads by Eye Rehab but does not delete records already imported to Eye Rehab or change records held by Apple Health or Health Connect. The app provides a separate action to delete imported daily summaries. Android users can manage imports at Settings → Data Sharing → Connected health data, and can revoke system access in Android’s Health Connect settings. You may grant all, some, or none of the requested categories. If you delete imported summaries while still connected, a later refresh may import them again. Source records in Health Connect or Apple Health are not deleted by Eye Rehab.

Imported summaries remain in your account until you delete them or delete your account/data, subject to the legal and backup retention provisions below. Export Data includes your imported summaries. Importing does not automatically share them with a clinician: episode sharing and imported-health sharing require separate choices for each active clinician link. Revoking a grant stops future access through that link; it does not recall copies you or your clinician already exported.

Face Data and Head Tracking (Front-Camera Face Detection)

On supported devices (iPhone X and later with Face ID), our app uses Apple's TrueDepth camera via ARKit to measure head rotation during vestibular-ocular reflex (VOR) exercises. This feature requires your explicit camera permission and can be disabled in the app settings.

What we collect: The TrueDepth camera detects your face position and orientation in real time. From this, we calculate head rotation angular velocity (speed in degrees per second), movement smoothness, left-right symmetry, and endurance metrics. These are the only values derived from face tracking.

What we do NOT collect: We do not capture, store, or transmit any facial images, video frames, facial feature maps, blend shape coefficients, biometric identifiers, or any data that could be used to identify you by your face. No facial recognition is performed.

On-device processing: All face tracking data (anchor transforms and euler angles) is processed entirely on your device in real time and is immediately discarded after computing the exercise metrics. Raw face data never leaves your device and is never stored on disk.

What is stored and transmitted: Only the computed numeric exercise metrics (head rotation speed, smoothness score, symmetry ratio, endurance score) are saved to your exercise session record and transmitted to our servers over HTTPS. These metrics are stored with HIPAA-compliant AES-256-GCM encryption. If you have linked your account with a healthcare professional, these exercise metrics (not face data) may be shared with them to monitor your rehabilitation progress.

No third-party sharing: Face data and derived head tracking metrics are never shared with third-party advertisers, data brokers, or analytics providers. Derived exercise metrics are only shared with your linked healthcare professional if you have opted into data sharing.

Retention: Raw face tracking data is not retained — it exists only in device memory during an active exercise session. Derived exercise metrics are retained as part of your exercise session history and are subject to the same data retention and deletion policies described in this privacy policy.

On Android devices, the app uses Google ML Kit Face Detection via the standard front camera to measure head rotation during VOR exercises. No face mesh or depth data is collected — only head pose angles used in real time for exercise feedback. All processing happens on-device. This feature requires your explicit camera permission and can be disabled in Settings at any time.

Technical Information

We automatically collect:

• Device information (device type, operating system, app version)
• Usage statistics and analytics
• Log data and error reports
• IP address and general location (country/region)

How We Use Your Information

We use your information to:

• Provide and maintain the Service
• Track your rehabilitation progress and adjust exercise difficulty
• Send exercise reminders and notifications (if enabled)
• Analyze usage patterns to improve the Service
• Respond to your support requests and inquiries
• Detect and prevent technical issues and fraud
• Comply with legal obligations
• Send you updates about the Service (you may opt-out of non-essential communications)

Consent and Legal Basis (GDPR)

We process your personal data based on the following legal grounds under GDPR:

Consent-Based Processing

When you create an account, we ask for your explicit consent for:

• Terms of Service: Agreement to our service terms (required)
• Privacy Policy: Acknowledgment of this privacy policy (required)
• Health Data Processing: Explicit consent to process your health-related rehabilitation data (required for service functionality)
• Marketing Communications: Optional consent to receive product updates, tips, and promotional content

Consent Records

We maintain records of your consent including:

• Type of consent given
• Date and time of consent
• Version of terms/policy agreed to
• Method of consent (app registration, quiz submission)

Withdrawing Consent

You can withdraw consent at any time:

• Marketing emails: Toggle off in Settings → Marketing Emails, or click "Unsubscribe" in any marketing email
• Health data processing: Delete your account through Settings → Clear All Data
• Data sharing with professionals: Pause or disconnect in Settings → Data Sharing

Note: Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

Data Storage and Security

Your data is stored securely using industry-standard practices:

• All data is encrypted in transit using HTTPS/TLS
• Passwords are securely hashed using modern cryptographic algorithms
• Database access is restricted and monitored
• We use secure cloud infrastructure with regular security updates
• Backup, restoration, and deletion-propagation controls are reviewed against the active hosting provider

While we implement reasonable security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

Data Sharing and Disclosure

We do not sell your personal information. We may share your data in the following circumstances:

• With Healthcare Providers: If you choose to export your progress data to share with your therapist or healthcare provider
• Service Providers: With third-party vendors who assist in providing the Service (authentication, hosting, analytics) under strict confidentiality agreements
• Legal Compliance: When required by law, court order, or governmental regulation
• Business Transfers: In connection with a merger, acquisition, or sale of assets (users will be notified)
• Safety and Protection: To protect the rights, property, or safety of VOR Eye Rehab, our users, or others

Patient-reported episode context is not made visible merely because you connect with a clinician. You make a separate choice for each clinician link to share episode/intake information and, independently, optional imported health context. The newest choice for that exact link controls future access. Making an episode private or revoking a scope blocks the clinician's next request, but cannot retract information they already exported or are lawfully required to retain.

All third-party service providers are carefully vetted and contractually obligated to protect your data in accordance with this Privacy Policy.

Your Privacy Rights (GDPR & CCPA)

Under GDPR (for EU/EEA residents) and other privacy laws, you have the following rights:

GDPR Rights (Articles 15-22)

• Right of Access (Art. 15): Request a copy of all personal data we hold about you
• Right to Rectification (Art. 16): Update or correct inaccurate information through your account settings
• Right to Erasure (Art. 17): Request deletion of your account and all associated data via Settings → Clear All Data
• Right to Data Portability (Art. 20): Export your complete data in JSON format via Settings → Export Data
• Right to Restrict Processing (Art. 18): Request limitation of how we process your data
• Right to Object (Art. 21): Object to processing based on legitimate interests, including direct marketing
• Right to Withdraw Consent (Art. 7): Withdraw consent at any time via app settings or by contacting us

How to Exercise Your Rights

We will respond to your request within 30 days as required by GDPR. We may request verification of your identity before processing certain requests.

Note: Some data may be retained as required by law or contract, including under a valid legal hold. The applicable rule depends on the service relationship and jurisdiction.

Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Service. Specific retention periods:

• Active Accounts: Data retained while account is active
• Episode Context: No age-based deletion job is enabled; records remain until an available patient deletion or account-deletion action is completed
• Legal Holds: A legal hold may temporarily block deletion, but does not force continued clinician visibility after sharing is revoked
• Deleted Accounts: Personal data permanently deleted within 30 days of account deletion
• Backup Systems: Deleted records may remain in protected backups until the applicable provider rotation completes; production rotation and restoration evidence is verified before this feature is enabled
• Legal Requirements: Some data may be retained longer to comply with legal obligations

Children's Privacy

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

For users between 13-18 years old, we recommend parental guidance and supervision when using the Service.

Third-Party Services (Data Processors)

We use the following third-party services to provide our Service. Each operates under a Data Processing Agreement (DPA) as required by GDPR Article 28:

• Clerk (Authentication)
  Processes: Email, name, password (hashed), session data
  Privacy: clerk.com/legal/privacy
• Stripe (Payment Processing)
  Processes: Email, billing information, payment method details
  Note: We do not store credit card numbers; Stripe handles all payment data
  Privacy: stripe.com/privacy
• Resend (Email Delivery)
  Processes: Email address, email content, delivery status
  Used for: Quiz results, account notifications, marketing emails (with consent)
  Privacy: resend.com/legal/privacy-policy
• Cloud Infrastructure (Data Hosting)
  Processes: All application data (encrypted in transit and at rest)
  Location: European Union data centers

We maintain Data Processing Agreements with all processors and regularly review their security practices. You may request details about our sub-processors by contacting [email protected].

International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

When we transfer data internationally, we ensure appropriate safeguards are in place, such as standard contractual clauses or Privacy Shield certification (where applicable).

California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected
• Right to know whether personal information is sold or disclosed
• Right to opt-out of the sale of personal information
• Right to request deletion of personal information
• Right to non-discrimination for exercising CCPA rights

Note: We do not sell personal information.

Data Breach Notification

In accordance with GDPR Article 33 and 34, in the event of a personal data breach:

• We will notify the relevant supervisory authority within 72 hours of becoming aware of a breach (unless the breach is unlikely to result in a risk to your rights and freedoms)
• If the breach is likely to result in a high risk to your rights and freedoms, we will notify you directly without undue delay
• Notification will include: nature of the breach, categories of data affected, likely consequences, and measures taken to address the breach

We maintain documented procedures for detecting, reporting, and investigating personal data breaches.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will notify you of significant changes by:

• Posting the new Privacy Policy with an updated date
• Sending an email notification (for material changes affecting your rights)
• In-app notification

Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Medical Disclaimer

VOR Eye Rehab is a rehabilitation tool and not a substitute for professional medical advice, diagnosis, or treatment. Always consult with your healthcare provider before starting any rehabilitation program. The privacy and security of your health information is important to us, but the app should be used in conjunction with professional medical care.