Saluso - One Health, One Place

Introduction

At salusO, which is operated by Your Health One Place, Lda., a company registered in Portugal under registration number 518839702 ("Company", "we", "us", or "our"), your privacy and the protection of your personal and health information are extremely important to us. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you access or use our platform, website, mobile applications (including our iOS app distributed through the Apple App Store), and related services (collectively, the "Services").

This Privacy Policy is intended to comply with Apple's App Store Review Guidelines (including Guidelines 5.1.1, 5.1.2, and, where applicable, 5.1.3), the General Data Protection Regulation (GDPR), and, where applicable, the Health Insurance Portability and Accountability Act (HIPAA), and other applicable data protection laws.

Please read this Privacy Policy carefully. By downloading, installing, or using our app or Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please do not use our Services.

1. Information We Collect

We collect information that you provide directly to us when you register on our platform, create or modify your profile, set up preferences, sign up for, or make purchases through the platform. We adhere to the principle of data minimization and only collect data that is necessary for the functioning of our Services.

1.1 Information You Provide Directly

Contact Information: Name, email address, date of birth, location, and phone number.
Account Information: Username, password, profile preferences, and permissions to access your account.
Health and Wellness Information: Personal health data, metrics, symptoms, wearable device data (automatic or manually entered), medication records, communications with healthcare providers, and appointment details.
Payment Information: Billing details and transaction records necessary to process purchases. We do not directly access your payment card details; purchases made through Apple's In-App Purchase system are processed by Apple.

1.2 Information Collected Automatically

Usage Data: Information about how you interact with our Services, including pages visited, features used, time spent in the app, and interaction patterns.
Device Information: Device type, operating system version, unique device identifiers, and general diagnostic data.
Log Data: IP address, access times, app crashes, and system activity logs used for troubleshooting and improving our Services.

1.3 Information from Third Parties

We may receive information from third-party health devices or wearables that you choose to connect to our platform, as well as from healthcare providers you authorize to share data with us.

2. How We Use Your Information

Provide, maintain, and improve our Services
Process transactions and send related information
Connect you with healthcare providers
Generate personalized health insights and recommendations using AI
Send administrative messages and service communications
Respond to your comments, questions, and support requests
Comply with legal obligations
Monitor and analyze usage trends to improve user experience

We do not sell or rent your personal information to third parties. We do not use your data for targeted advertising.

2.1 Legal Bases for Processing

For users in the European Economic Area, United Kingdom, and other jurisdictions with similar requirements, we process personal data under one or more of the following legal bases:

Contract: To create and manage your account, provide the Services, process subscriptions and purchases, and respond to service-related requests.
Legitimate Interests: To secure the Services, prevent fraud and abuse, improve functionality, perform analytics, troubleshoot issues, and enforce our Terms.
Legal Obligation: To comply with applicable laws, regulations, lawful requests, tax and accounting obligations, and recordkeeping requirements.
Consent: Where required, including for certain optional features, certain health-data processing activities, and transmission of personal or sensitive data to third-party AI service providers.
Special Category Data: Where we process health data or other special category personal data, we do so only where a valid condition under applicable law applies, including your explicit consent where required.

3. Health Information, AI Content & Third-Party AI Disclosure

3.1 Health Data Handling

Certain personal information you provide may be considered health or sensitive data, which is treated with heightened care under applicable data protection laws (e.g., GDPR, HIPAA). We use this data only to offer and improve platform functionality and personalized features, and we apply additional safeguards including encryption at rest and in transit.

3.2 AI-Generated Content

Our Services incorporate artificial intelligence (AI) technologies to generate health-related insights, personalized content, and recommendations based on information you provide. You acknowledge and agree that:

AI-generated content is for informational purposes only and does not constitute medical advice, diagnosis, or treatment.
AI outputs may be limited or inaccurate, and suggestions should not be interpreted as clinical recommendations.
You should always consult a licensed healthcare professional for medical advice, diagnoses, treatment plans, prescriptions, and decisions regarding your health.
AI content and recommendations are provided "as-is," and we expressly disclaim any warranty or liability arising from your use of AI-generated content.

3.3 Third-Party AI Services – Data Sharing Disclosure

In compliance with Apple App Store Guideline 5.1.2(i), we clearly disclose that certain data you provide may be transmitted to contracted third-party AI service providers in order to deliver the AI-powered features of our platform. These providers may include OpenAI, Anthropic, or other contracted providers disclosed within the app as they change.

We de-identify or pseudonymize data before transmission. In cases where that is not possible for a specific service, we obtain explicit consent before transmitting personal or sensitive data. Third-party AI providers are contractually required to process your data solely for the purpose of providing our Services and are prohibited from using your data for their own training, marketing, or any other unrelated purpose.

4. Data Security

We implement appropriate technical and organizational measures to protect the security of your personal information, including encryption in transit (TLS) and at rest, access controls, and regular security audits.

4.1 HIPAA and Other Health Data Safeguards

Where salusO processes protected health information ("PHI") on behalf of a HIPAA covered entity or business associate, and only to the extent HIPAA applies to the relevant processing activity, we implement appropriate administrative, physical, and technical safeguards and enter into Business Associate Agreements where legally required.

4.2 GDPR Compliance

For users in the European Economic Area (EEA), we comply with the General Data Protection Regulation (GDPR). You may have the following rights regarding your personal data:

The right to access your personal data
The right to rectify inaccurate personal data
The right to erasure ("right to be forgotten")
The right to restrict processing of your personal data
The right to data portability
The right to object to processing of your personal data
The right to lodge a complaint with a supervisory authority

5. Sharing and Disclosure of Personal Information

We may share your information in the following circumstances:

Service Providers: With trusted service providers who support our operations (e.g., cloud hosting, payment processing, analytics), subject to contractual obligations to protect your data.
Third-Party AI Providers: As described in Section 3.3, with your explicit consent and solely for the purpose of delivering AI-powered features.
Legal Obligations: To comply with applicable law, regulation, legal process, or enforceable governmental request.
Safety and Rights: To protect the rights, property, or safety of salusO, our users, or others.
With Your Consent: In any other case where you have provided explicit consent.

We do not share personal health information with unaffiliated third parties for their direct marketing purposes without your explicit consent.

6. Data Retention and Deletion

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected.

Active Accounts: Your data is retained for the duration of your active account and use of our Services.
Inactive Accounts: If your account becomes inactive, we may retain your data for a limited period in accordance with applicable law before initiating deletion.
Deletion Requests: You may request deletion of your personal data at any time. Upon receiving a verified request, we will delete or anonymize your data within 30 days, except where retention is required by law.
Third-Party Data: Upon account deletion, we will instruct all third-party processors, including AI service providers, to delete your data from their systems.

7. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal data:

Access: Request a copy of the personal data we hold about you.
Correction: Request correction of inaccurate or incomplete personal data.
Deletion: Request deletion of your personal data ("right to be forgotten").
Restriction: Request restriction of processing of your personal data.
Portability: Request a portable copy of your data in a structured, commonly used, machine-readable format.
Objection: Object to certain processing activities, including profiling.
Revoke Consent: Withdraw consent for AI data processing or other optional features at any time via the app's Settings menu.

To exercise any of these rights, please contact us at info@saluso.com from the email registered in your account. We will respond to verified requests within 30 days.

8. Consent and Permissions

In accordance with Apple's App Store Review Guidelines, we respect your permission settings and will never attempt to manipulate, trick, or force you into consenting to unnecessary data access.

We will request only the permissions necessary for the features you choose to use.
We provide clear in-app explanations of why each permission is needed before requesting it.
You may change or revoke any permission at any time through your device's Settings or within the app.
Where features require data to be sent to third-party AI services, explicit in-app consent will be obtained before any transmission occurs.

9. Tracking and Advertising

We do not track you across apps or websites owned by other companies for the purposes of advertising or ad measurement. We do not use the Apple Advertising Identifier (IDFA) and we do not participate in data broker activities.

If we ever introduce tracking in the future, we will request your explicit permission through Apple's AppTrackingTransparency framework before any tracking occurs.

10. Children's Privacy

Our Services are intended for individuals aged 18 years or older (or the age of majority in your jurisdiction). We do not knowingly collect or retain personal information from children under the applicable age limit. If you believe a child has provided us with personal data, please contact us at info@saluso.com.

11. International Data Transfers

Your information may be transferred to and processed in countries other than the country in which you reside. When we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or other legally recognized transfer mechanisms.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy within the app and on our website, and by updating the "Last Updated" date at the top of this document. Your continued use of our Services after any modification constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

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

Your Health One Place, Lda.
Company registration number: 518839702
Email: info@saluso.com
Telephone: +351928497707
Address: Rua Mário Azevedo Gomes 5 2D, 1500-467 Lisboa, Portugal
Website: https://saluso.com