Clear rules for private health information.

Privacy Policy

Effective: August 28, 2026

Controller: Nair Engineering, Inc. (“Nair Engineering,” “we,” “us,” or “our”)

This Privacy Policy explains how Vivral handles personal information. Our separate Consumer Health Data Privacy Policy provides the additional disclosures and rights that apply to consumer health data, including under the Washington My Health My Data Act and Nevada consumer-health privacy law where applicable.

1. Scope and Important HIPAA Notice

This Policy applies to the Vivral iOS App, Vivral account and billing services, connected-health integrations, response feedback, support, and the Vivral pages at nairengineering.com.

Nair Engineering is a consumer software company and is generally not a healthcare provider, health plan, healthcare clearinghouse, or business associate acting for one. Information you direct a provider or Apple Health to send to Vivral may therefore not be protected by HIPAA after Vivral receives it. Other federal and state privacy, security, breach-notification, consumer-protection, and health-data laws may still apply. If we later provide a service under a separate healthcare contract or business-associate agreement, the separate notice and contract will govern that service.

2. Our Core Boundaries

• We do not sell personal information or consumer health data.
• We do not use consumer health data for advertising, marketing profiles, cross-context behavioral advertising, data-broker activity, or unrelated data mining.
• Vivral does not contain third-party advertising or cross-app tracking.
• Chat model inference, Patient Passport search, document OCR, camera pulse estimation, motion analysis, and most App content processing occur on the device unless a feature clearly says it is connecting to a service.
• Apple Health and Clinical Health Records are read-only. Vivral does not write samples to HealthKit and does not place personal health information in iCloud.
• Chat text, Patient Passport records, Apple Health data, documents, and sensor results are not automatically submitted for model training.
• Vivral does not offer feedback upload for chats tagged as Clinical Record-grounded. Records imported through that feature and responses grounded in them remain on the device unless you explicitly export or share them. If you manually paste copied record text into an ordinary chat, Vivral cannot reliably identify its prior source; that text can be included in feedback only if you later review the exact redacted text and affirmatively approve submission.

3. Information We Process

Depending on the features you choose, we process:

Account and identity data

• Firebase account identifier; email address; authentication provider; Sign in with Apple or Google identifiers; any display name or profile image you choose; and a phone number only if an authentication provider makes one available through its sign-in service.
• Account-scoped age attestation, legal-document versions, acceptance time, sign-in state, security tokens, and app-lock preferences. A privacy-preserving token derived from your Firebase account can link an App Store purchase to the correct Vivral account.

Subscription and transaction data

• Product, billing cadence, trial and subscription status, renewal/expiration, transaction identifiers, storefront, Stripe customer identifier, App Store account token, and billing email.
• Apple or Stripe processes payment details. We do not receive or store full card numbers or card security codes.

Health, wellness, and user content

• Health questions, symptoms, answers, notes, preferences, conversations, and generated responses.
• Patient Passport profiles, family-profile labels, medical documents and images, locally extracted OCR text, FHIR/Clinical Health Records, medications, allergies, immunizations, labs, vital signs, conditions, procedures, encounters, and other records you import or enter.
• Health and fitness categories you authorize from Apple Health, which can include activity, body measurements, characteristics, sleep, heart rate and related metrics, mobility, respiratory, nutrition, reproductive, audiogram, electrocardiogram, and Clinical Health Records categories displayed by Apple’s authorization sheet.
• Selected activity, vitals, body-composition, sleep, nutrition, and hydration data from Google Health or Withings when you connect those providers.
• Wellness sensor data and derived results when a feature is available: fingertip camera frames and pulse estimate; microphone audio, voice level, breath-volume estimate, and transcript; and motion, gait, tremor, or recovery measurements. Camera frames and raw motion signals used by the App’s wellness tools are processed on-device and are not uploaded by those tools.
• Locally created reminders, notifications, trends, studio or recovery plans, and source labels.

Feedback and support data

• If you deliberately rate or report an eligible response: the redacted prompt and response shown for your approval, rating or report reason, message ID and time, model and App version, reasoning duration, Firebase account ID, and submission time. Text you approve can still contain health information you entered even after automated personal-identifier redaction. Feedback upload is unavailable for chats tagged as Clinical Record-grounded. If you manually paste copied Apple Health or Clinical Records text into an ordinary chat, Vivral cannot reliably identify its prior source; that text can remain in eligible feedback only if you review the exact redacted text and affirmatively approve submission.
• Emails or other communications you send to support, privacy, safety, or legal contacts.

Technical data

• Device model and operating-system information needed for compatibility; App version; feature and permission state; security and App Attest data; local-notification preference and scheduling state; model artifact identifiers, file hashes, download progress, and local settings.
• Firebase and Google authentication SDKs can collect an installation or device identifier, authentication and product-interaction events, user-agent/diagnostic metadata, and a coarse region inferred from IP address for authentication, fraud prevention, security, and service analytics. Vivral does not request GPS location for these services.
• Our service providers can automatically receive ordinary internet metadata needed to deliver a request, such as IP address, request time, response status, and network or browser information. Vivral suppresses App-owned Release diagnostic logs, but Apple and service providers may maintain security, transaction, or operational logs under their policies.

We do not intentionally collect precise location, contacts, advertising identifiers, or biometric templates. Authentication providers can infer a coarse region from an IP address for fraud prevention and security. Face ID or device-passcode authentication is performed by iOS; Vivral receives only the success or failure result.

4. Sources of Information

We receive information:

• directly from you, including text, files, sensor actions, preferences, feedback, support requests, and account choices;
• from your device and permissions, including Apple Health, Clinical Health Records, camera, microphone, motion sensors, notifications, and device compatibility information;
• from authentication and billing providers, including Apple, Google/Firebase, App Store, and Stripe;
• from Google Health or Withings only after you select categories and authorize a connection; and
• from service providers that return transaction, entitlement, authentication, security, or delivery results.

5. What Stays on the Device

Vivral stores chats, Patient Passport profiles and records, imported documents, OCR text, local search indexes, Apple Health/Clinical Records imports, normalized connected-provider measurements returned to the App, reminders, trends, recovery or Studio plans, sensor wellness results, account profile images, preferences, and downloaded model files in the App’s local container. Account-derived sensitive stores use iOS data protection and are excluded from iCloud/iTunes backup where the App controls that setting.

The App stores a versioned record of age and legal acceptance in account-scoped device storage and a synchronizable Keychain item so the same signed-in account can retain consent state across supported Apple devices. That Keychain item contains consent metadata—not chats, documents, or health records—and can be removed through account deletion.

Local AI inference uses your current chat conversation to generate an answer on-device. Patient Passport records remain separate from normal chat and are not automatically supplied to the language model. When you tap Ask Vivral on a supported Clinical Record, Vivral supplies bounded fields from that selected record to the on-device model for the educational explanation you requested; it does not send the selected record to a remote AI service. On-device processing does not mean the entire App is offline; the limited networked activities below still occur.

Clinical Records import is user-initiated. Vivral refreshes its protected local copy after the initial import, when you tap Check Now, and when the App becomes active while a connection exists. If Background Record Refresh is on, an authorized HealthKit observer event or an iOS discretionary background task can also trigger a refresh. Vivral requests a next background task no earlier than four hours later, but iOS controls whether and when it runs; this is not a guaranteed four-hour schedule or real-time monitoring. These refreshes do not upload the imported Clinical Records store.

In Settings → Health & Records, you can turn off background record refresh, generic new-record alerts, or future on-device Clinical Record explanations. Turning off background refresh stops Vivral's observer and scheduled background work; the user-invoked Check Now action and activation refresh remain available. You can revoke future Health access in Apple's Health app. Disconnect and remove imported data deletes Vivral's local imported copy without deleting the original records retained by Apple Health; saved chat text is deleted separately.

6. Networked Processing and Sharing

We disclose information only as needed for a feature you request, with your consent, or for legal and security purposes.

Apple. Apple processes App Store purchases, subscription management, Sign in with Apple, HealthKit permissions, Clinical Health Records delivery, local-notification permissions and scheduling, and App distribution. Apple Speech processes microphone audio and transcripts when on-device speech recognition is unavailable; where supported, Vivral requires on-device recognition. Apple may provide App analytics or diagnostics according to your Apple settings. Vivral does not send its local Patient Passport database to Apple, although Apple supplies records you explicitly authorize through HealthKit.

Google and Firebase. Firebase Authentication processes account identifiers, email, authentication-provider data, and any optional profile name, image, or phone number made available by the selected provider. Firebase/Google SDKs can process App Attest/App Check security data, entitlement and billing mappings, account-deletion requests, installation or device identifiers, authentication/product-interaction events, user-agent and other diagnostic metadata, and a coarse region inferred from IP address for authentication, fraud prevention, security, App functionality, and service analytics. Google Sign-In processes the data shown on its authorization screen. None of this data is used by Vivral for cross-app tracking or advertising.

Stripe. For eligible web checkout, Stripe processes billing contact, payment method, subscription, tax, receipt, fraud-prevention, and customer-portal data. Vivral receives customer and subscription status, not full card data.

Supabase. Nair Engineering’s Supabase project processes authenticated response feedback and connected-health requests. Approved feedback, including health text the user manually entered and left in the reviewed redacted text, is stored under the submitting Firebase account ID. Chats tagged as Clinical Record-grounded cannot be submitted as feedback. Directly imported Apple Health/Clinical Records data is not automatically included in feedback, but Vivral cannot reliably identify record text that a user manually copies into an ordinary chat; such text can be included only after the user reviews the exact redacted feedback and affirmatively approves submission. For connected health, the integration service stores encrypted OAuth/refresh tokens, provider user ID, selected categories, connection times, sync cursors, and profile/account identifiers. It transiently fetches and normalizes selected provider measurements and returns them to your device; it does not retain the provider measurement payloads as a health-history database.

Google Health and Withings. If you connect a provider, the provider receives authorization and sync requests and returns the selected health categories through Vivral’s integration service. Their separate privacy policies govern data in their systems. Disconnecting asks the integration service to revoke or remove the connection and deletes its stored credentials; provider-side records remain with the provider.

Hugging Face and delivery networks. Vivral downloads public, version-pinned model files from Hugging Face or its content-delivery providers. They can receive IP address and ordinary download metadata. Vivral does not include chat or Patient Passport text in model-download requests.

Professional advisers, legal process, and safety. We may disclose the minimum information reasonably necessary to lawyers, auditors, insurers, incident responders, law enforcement, regulators, or courts when required by law or reasonably necessary to protect rights, safety, and Service security. We may transfer information in a merger, financing, reorganization, bankruptcy, or sale, subject to this Policy and applicable health-data law.

Nair Engineering has no affiliate that receives consumer health data as of the effective date. Our processor categories are cloud identity/security, billing, database/edge-function, model-delivery, speech/operating-system, connected-health, and professional-adviser providers. We do not share consumer health data with data brokers, advertisers, or social-media advertising platforms.

7. Purposes

We use information to:

• provide authentication, account security, subscription access, model delivery, local AI, Patient Passport, wellness features, connected-provider imports, reminders, and support;
• display personalized information and trends to the same user whose data was provided;
• verify purchases, prevent fraud and abuse, protect the Service, debug failures without intentionally logging message contents in Release, and comply with law;
• process eligible feedback only after the submitting user reviews and approves the text, to investigate issues and improve the quality and safety of Vivral's health-management responses; Clinical Record-grounded chats cannot be submitted as feedback; and
• communicate material service, billing, privacy, legal, or security notices.

We will not collect, use, or share additional categories of consumer health data for undisclosed purposes without first updating this Policy and obtaining affirmative consent where required.

8. Consumer Health Data Collection and Sharing Summary

Categories collected or processed: health questions and inferences; Patient Passport and document contents; Apple Health and Clinical Health Records categories selected by the user; selected Google Health/Withings activity, vitals, body, sleep, and nutrition data; wellness sensor results; health-related reminders and plans; and manually entered health information remaining in eligible feedback text the user approves. Clinical Record-grounded chats cannot be submitted as feedback.

Purposes: provide the specific App feature the user requests, organize and display personal trends, generate local educational responses, maintain account security, and review explicitly submitted feedback for quality and safety.

Sources: the user, the user’s iPhone or iPad and authorized Apple Health store, documents the user imports, Google Health or Withings accounts the user connects, and App-generated wellness estimates or AI inferences.

Categories shared: selected provider categories and identifiers necessary to authorize/sync through the connected-health processors; audio/transcript data necessary for Apple Speech when local recognition is unavailable; and the exact eligible feedback text and metadata the user separately approves. Directly imported HealthKit/Clinical Records data and chats tagged as Clinical Record-grounded are excluded from feedback. If the user manually pastes copied record text into an ordinary chat, that text can be included only after exact review and affirmative approval. Local chats, Patient Passport records, documents, camera frames, and raw motion data are not otherwise shared by the App merely because they are stored locally.

Recipients: only the processors and connected providers listed in Section 6, plus legal/safety recipients when required. No specific affiliate receives consumer health data. We do not sell consumer health data.

9. Retention

• Local content remains until you delete it, use an applicable retention/clear control, delete your Vivral account, or remove the App. Removing the App ordinarily deletes its local container, but synchronized Keychain consent metadata can persist until account deletion or Keychain removal.
• Account and entitlement data remains while the account is active and afterward only as needed for deletion completion, security, dispute resolution, fraud prevention, tax/accounting, or legal obligations.
• Approved feedback is automatically deleted no later than 90 days after submission, or sooner if you delete your account or make an authenticated deletion request. We may retain a content-free record that a deletion or security action occurred without retaining the submitted text.
• Connected-health credentials remain until disconnect or account deletion. Provider measurements returned to the device are retained locally until removed there. Short-lived OAuth state expires after ten minutes and expired state is deleted by a daily retention job; operational security records and encrypted backups are retained only for reasonable service-recovery, security, and legal periods.
• Billing processors retain transaction records under their own legal, fraud, tax, and financial obligations even after a customer object is deleted.

Authenticated deletion removes active records from Vivral-controlled systems. Where deleted information remains in encrypted backup or disaster-recovery systems, it is isolated from ordinary use and deleted or overwritten under the backup cycle; where Washington law applies, backup deletion will not be delayed more than six months after authentication of the request.

10. Security

We use safeguards appropriate to the sensitivity of the information, including TLS in transit; iOS file protection; account- and profile-scoped storage; Keychain storage for limited secrets or consent state; encrypted connected-provider tokens; Firebase authentication; App Check/App Attest on supported endpoints; access controls; request-size limits; server-side entitlement checks; and deletion workflows. No storage or transmission method is guaranteed secure. You are responsible for device security, backups of original records, and protecting your account.

If a qualifying breach occurs, we will provide notice to affected users and regulators as required by applicable federal and state law, including the FTC Health Breach Notification Rule where it applies.

11. Your Choices and Controls

• Decline or revoke camera, microphone, motion, speech, notification, HealthKit, or Clinical Health Records permission in iOS Settings or the Health app. Revocation stops future access but does not automatically delete information already imported into Vivral.
• Do not connect Google Health or Withings, choose narrower categories, or use Disconnect and remove data to revoke the integration and remove locally stored provider measurements.
• Do not approve response feedback. For eligible non-Clinical-Record chats, the feedback screen shows the exact redacted text before sending and requires separate consent acknowledging that manually entered health information may remain. Feedback upload is unavailable for Clinical Record-grounded chats.
• Clear chats and feature-specific local data using App controls. Deleting a source document may also require deleting associated OCR, search, reminder, or trend data as presented by the App.
• Use Settings → Delete Account to revoke linked Apple or Google authorization and request deletion of the Firebase account, Vivral-controlled billing/customer mapping, Stripe customer and active Stripe subscription, connected-health credentials, submitted feedback, Firestore records, notification state, and scoped on-device data. For App Store subscriptions, also confirm status in Apple’s subscription manager.

12. Access, Deletion, Withdrawal, Correction, and Appeal

Depending on your jurisdiction, you may have rights to confirm processing, access information, obtain a list of recipients, correct inaccurate account information, delete information, withdraw consent for future collection or sharing, obtain portability, or appeal a refusal. We will not unlawfully discriminate against you for exercising a right.

The in-app authenticated deletion control is the fastest way to delete a full account. You may also email akhileshnair@nairengineering.com with subject Privacy Request. You do not need to create a new account to make a request, but we may ask for information reasonably necessary to authenticate you and protect health data from unauthorized access. Requests are free as required by law. Where the Washington My Health My Data Act applies, we will respond without undue delay and within 45 days, subject to the single lawful extension, and will decide an appeal within 45 days. To appeal, use the same email with subject Privacy Appeal. If a Washington appeal is denied, you may contact the Washington Attorney General.

Withdrawing consent does not affect processing already completed before withdrawal. Some records may be retained when law permits or requires, such as transaction, fraud, security, legal-claim, or request-verification records.

13. Children

Vivral is not directed to anyone under 18, and users must attest that they are at least 18. We do not knowingly collect personal information from a child through Vivral. Contact us if you believe a minor has used the Service so we can investigate and delete information as appropriate.

14. International Processing and Storefronts

Vivral’s availability varies by App Store storefront. Nair Engineering and its providers process information in the United States and in other locations where the listed providers operate, subject to their safeguards and applicable law. Location-specific features, billing options, and emergency resources may differ. Use the App’s safety-region setting and the emergency resources for where you are physically located.

15. Changes to This Policy

We may update this Policy to reflect App, provider, security, or legal changes. We will change the effective date and provide additional notice or request consent before materially new consumer-health-data collection, use, or sharing when required. Older versions may be retained for legal records.

16. Contact

Nair Engineering, Inc.
Registered office: 131 Continental Drive, Suite 305, Newark, Delaware 19713, United States
Privacy, health-data, and legal email: akhileshnair@nairengineering.com
Website: https://nairengineering.com/privacy/

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Consumer Health Data Privacy Policy

Effective: August 27, 2026

Regulated entity: Nair Engineering, Inc. (“Nair Engineering,” “we,” “us,” or “our”)

This is Vivral’s separate Consumer Health Data Privacy Policy. It describes how we collect, use, disclose, and protect consumer health data and how to exercise consumer-health-data rights. It applies where consumer health privacy laws, including the Washington My Health My Data Act or Nevada consumer-health privacy law, apply. The general Privacy Policy covers other personal information.

1. Consumer Health Data We Collect

Depending on the features you choose, Vivral can collect or process these categories of consumer health data:

• health questions, symptoms, answers, health-related conversations, notes, preferences, and inferences drawn from them;
• Patient Passport profile information, family-profile labels, medical documents and images, OCR text, medications, allergies, immunizations, laboratory results, vital signs, conditions, procedures, encounters, and other records you enter or import;
• Apple Health and Clinical Health Records categories you authorize, including activity, body measurements, sleep, heart rate, mobility, respiratory, nutrition, reproductive, audiogram, electrocardiogram, and clinical-record information;
• selected activity, vitals, body-composition, sleep, nutrition, hydration, and related information from Google Health or Withings when you connect an account;
• wellness sensor inputs and results, including fingertip camera frames and pulse estimates, microphone audio and transcripts, voice or breathing estimates, motion, gait, tremor, and recovery measurements when those features are available;
• health-related reminders, plans, trends, document classifications, and App-generated health or wellness inferences; and
• manually entered health information remaining in eligible response feedback that you separately review and approve for submission. Directly imported Apple Health/Clinical Records data and chats tagged as Clinical Record-grounded are excluded from feedback; manually pasted record text in an ordinary chat can be included only after exact review and affirmative approval.

A Vivral subscription, support request, device or App metadata, and account or transaction identifiers can also reveal that a person uses a health-related service. We treat that information as consumer health data where applicable law requires.

Vivral does not intentionally collect precise location for health-data purposes and does not use geofencing around healthcare facilities. We do not create biometric identity templates.

2. Sources

We collect consumer health data from:

• you, through text, files, images, feedback, support communications, profile choices, and sensor actions;
• your iPhone or iPad and the permissions you grant, including Apple Health, Clinical Health Records, camera, microphone, speech, and motion;
• healthcare institutions that provide records through Apple’s Clinical Health Records framework after your authorization;
• Google Health or Withings accounts that you affirmatively connect and the categories you select; and
• Vivral itself, when it creates local summaries, classifications, reminders, trends, wellness estimates, or other inferences from data you choose to process.

3. Why We Collect and Use It

We collect and use consumer health data only to:

• provide the Vivral feature you request, including local educational responses, record organization, search, trends, reminders, wellness tools, and connected-provider imports;
• display information and inferences back to the same user and maintain the user’s requested local content;
• operate, secure, troubleshoot, and prevent abuse of those requested features without intentionally placing message or record contents in Release diagnostic logs;
• process eligible response feedback only after you review the exact redacted text, acknowledge that manually entered health information may remain, and affirmatively approve submission; Clinical Record-grounded chats cannot be submitted as feedback;
• respond to a support, privacy, safety, or legal request that you initiate; and
• comply with law, enforce rights, investigate security incidents, and protect users or the Service.

We do not collect or use consumer health data for advertising, cross-context behavioral advertising, marketing profiles, eligibility decisions, data-broker activity, or unrelated data mining. We will obtain affirmative consent before collecting or using consumer health data for a materially different purpose when the law requires it.

4. Consumer Health Data We Share and Recipients

Most health content is stored and processed locally. We disclose consumer health data only for a feature you request, after a separate approval, or when legally necessary. Depending on your choices, the categories and recipients are:

• Apple: authorized HealthKit and Clinical Health Records requests, Apple Speech audio or transcripts when on-device recognition is unavailable, App Store subscription data, local-notification permissions/scheduling, and Apple diagnostics governed by your Apple settings;
• Google and Firebase: account and optional provider-profile data, security and App Attest/App Check information, entitlement or account-deletion records, installation/device identifiers, authentication/product-interaction events, user-agent and other diagnostic metadata, and coarse region inferred from IP address; Google Sign-In receives the information shown on its authorization screen;
• Stripe: billing contact, subscription, transaction, fraud-prevention, tax, and customer-portal information for an eligible web purchase; Stripe does not receive local chats, Patient Passport records, or HealthKit records from Vivral;
• Supabase: encrypted connected-provider credentials and connection metadata, transient selected provider measurements, and the exact eligible response-feedback text and metadata you separately approve. Directly imported Apple Health/Clinical Records data and chats tagged as Clinical Record-grounded are excluded from feedback; manually pasted record text in an ordinary chat can be included only after exact review and affirmative approval;
• Google Health and Withings: authorization, revocation, account, category, and sync requests necessary for the connection you initiate;
• Apple Speech: microphone audio and resulting transcript only when the device cannot provide the requested on-device speech recognition and the App discloses that network speech processing may occur; and
• legal, security, and professional recipients: the minimum necessary information to attorneys, auditors, insurers, incident responders, law enforcement, regulators, courts, or a transaction successor when required by law or reasonably necessary to protect users, rights, and Service security.

Nair Engineering has no affiliate that receives consumer health data as of the effective date. We do not disclose consumer health data to advertisers, social-media advertising platforms, or data brokers. Model-file delivery providers receive ordinary download metadata such as IP address but Vivral does not include chat, record, or sensor content in model-download requests.

5. No Sale of Consumer Health Data

We do not sell consumer health data. If that practice ever changes, we will update this Policy and obtain the separate, signed authorization required by applicable law before any sale. Accepting the Terms of Use, acknowledging this Policy, or using Vivral is not authorization to sell consumer health data.

6. Storage and Retention

Chats, Patient Passport data, documents, OCR text, imported health records, local search indexes, reminders, trends, plans, sensor results, and downloaded models ordinarily remain in the App’s protected local container until you delete them, delete the account, or remove the App. Removing the App ordinarily removes its local container; limited consent metadata in a synchronizable Keychain item can remain until account deletion or Keychain removal. When you tap Ask Vivral on a supported Clinical Record, only bounded fields from that selected record are supplied to the on-device model; the record and its explanation are not uploaded to a remote AI service.

Connected-provider credentials remain until you disconnect or delete the account. Provider measurements returned to the App remain locally until removed. Approved eligible response feedback is automatically deleted no later than 90 days after submission, or sooner if you delete the account or make an authenticated deletion request. We may retain a content-free record that a deletion or security action occurred without retaining the submitted text. OAuth authorization state expires after ten minutes and expired state is deleted by a daily retention job. Account, entitlement, transaction, security, request-verification, and legal records are retained only as needed for the active account and legitimate fraud-prevention, accounting, dispute, security, or legal obligations.

Authenticated deletion removes active records from Vivral-controlled systems. Deleted information in encrypted backup or disaster-recovery systems is isolated from ordinary use and deleted or overwritten under the backup cycle. Where Washington law applies, deletion from backups will not be delayed more than six months after authentication of the request.

7. Your Consumer Health Data Rights

Subject to applicable law, you may request to:

• confirm whether we collect, share, or sell your consumer health data;
• access the consumer health data we maintain and obtain a list of third parties and affiliates with whom it was shared;
• delete consumer health data, including data held by processors where required;
• withdraw consent for future collection or sharing;
• correct inaccurate account information or obtain a portable copy where applicable; and
• appeal a refusal to act on a request.

We will not unlawfully discriminate against you for exercising a right. Withdrawing consent does not affect processing completed before withdrawal and can make a requested feature unavailable.

8. How to Exercise Rights or Withdraw Consent

Use the relevant in-App control to clear content, revoke a feature permission, disconnect a provider, or select Settings → Delete Account. Account deletion revokes linked Apple or Google authorization and requests deletion of scoped Vivral-controlled data. You can revoke Apple Health or Clinical Health Records access in the Health app and other device permissions in iOS Settings. For App Store subscriptions, deleting a Vivral account does not itself cancel Apple’s billing; confirm cancellation in Apple’s subscription manager.

You may also email akhileshnair@nairengineering.com with subject Consumer Health Data Request. You do not need to create a new account to submit a request. We may ask for information reasonably necessary to authenticate you and prevent unauthorized disclosure or deletion. Requests are free where required by law.

Where the Washington My Health My Data Act applies, we will respond without undue delay and within 45 days, subject to the single extension permitted by law. To appeal a decision, email the same address with subject Consumer Health Data Appeal. We will decide a Washington appeal within 45 days. If a Washington appeal is denied, you may contact the Washington Attorney General.

9. Security and Breach Notice

We use safeguards appropriate to the sensitivity of consumer health data, including TLS for network requests, iOS file protection, account- and profile-scoped storage, limited Keychain storage, encrypted connected-provider tokens, authenticated endpoints, App Check/App Attest where supported, access controls, request-size limits, server-side entitlement checks, and deletion workflows. No method is guaranteed secure.

If a qualifying breach occurs, we will notify affected individuals, the Federal Trade Commission, state authorities, and others as required by the FTC Health Breach Notification Rule and applicable state law.

10. Changes and Contact

We will update the effective date when this Policy changes. Before collecting, using, or sharing consumer health data for a materially different purpose, we will provide required notice and obtain affirmative consent where required. Older versions may be retained as legal and consent records.

• Nair Engineering, Inc.
• Registered office: 131 Continental Drive, Suite 305, Newark, Delaware 19713, United States
• Consumer health data and privacy email: akhileshnair@nairengineering.com Website: https://nairengineering.com/privacy/#consumer-health

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Health & Wellness Notice

Effective: August 28, 2026

This Health & Wellness Notice is part of the Vivral Terms of Use and EULA. Read it before using any health-information, sensor, record, reminder, or AI feature.

Vivral Is Educational Software

Nair Engineering is a software company and is not acting as a healthcare provider. Vivral is a consumer educational and wellness application—not a medical device, clinician, emergency service, diagnostic system, or treatment service. It has not been cleared or approved by the FDA.

No Diagnosis, Treatment, or Monitoring

Vivral must not be used to diagnose, treat, cure, mitigate, monitor, or prevent disease or to make medication, emergency, exercise, or care decisions. No output creates a clinician-patient relationship or replaces an examination, original medical record, clinician-ordered test, or licensed professional judgment.

Pulse Wellness Check

The camera-and-flash feature is called Pulse Wellness Check. It estimates a pulse rate from fingertip color changes for general wellness awareness. It is not a heart-rate monitor, electrocardiogram, continuous monitor, diagnostic measurement, or tool for evaluating a pacemaker or implanted device. Results may be wrong because of movement, finger pressure, lighting, skin and circulation differences, temperature, camera hardware, or software limitations.

If a result seems unusual, repeat it only if you feel well and the flash is comfortable, then verify with an appropriate validated device or qualified clinician. Do not delay care or change activity or medication based on the estimate.

AI and Records Can Be Wrong

AI outputs may be false, incomplete, biased, or outdated. OCR, document imports, Apple Health, Clinical Health Records, connected providers, reminders, trends, and summaries can omit, duplicate, misclassify, or display stale information. Always compare information with the original source. Vivral is not a medical record maintained by a provider and not the sole place to keep important information.

Emergencies

Do not use Vivral in an emergency. If you think someone may be experiencing an emergency, call the applicable local emergency number immediately (911 in the United States). Do not wait for an App response. For poison exposure in the United States, call Poison Control at 1-800-222-1222. For a mental-health crisis in the United States, call or text 988. Availability can change; use local emergency resources where you are.

Professional Care

Consult an appropriately licensed clinician before changing medication, treatment, diet, exercise, or other health decisions. Never disregard professional advice because of Vivral content. Seek prompt care for new, severe, persistent, or worsening symptoms, regardless of what the App says.

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Terms of Use

Effective: August 28, 2026

Provider: Nair Engineering, Inc., a Delaware corporation (“Nair Engineering,” “we,” “us,” or “our”)

Product: Vivral (the “App” or “Service”)

These Terms of Use (“Terms”) are a binding agreement between you and Nair Engineering. By creating an account, selecting Finish Onboarding, purchasing a subscription, or using Vivral, you agree to these Terms, the End User License Agreement (“EULA”), and the Health & Wellness Notice, and you acknowledge the Privacy Policy and Consumer Health Data Privacy Policy. If you do not agree, do not use Vivral.

1. Eligibility, Territory, and Accounts

Vivral is offered for individual consumer use only in countries and regions where Nair Engineering makes it available through the applicable App Store storefront. Availability, features, language, emergency resources, and billing options can vary by location. You must be at least 18 years old and legally able to enter a contract. You must provide accurate account information, protect your credentials and device, and promptly tell us about suspected unauthorized access. You are responsible for activity through your account unless caused by our breach of these Terms or applicable law.

Do not add, import, or connect another person’s health information unless you have that person’s legally valid permission and authority. Vivral is not designed for employers, insurers, healthcare providers, or other organizations to make decisions about another person.

2. What Vivral Is—and Is Not

Nair Engineering is a software company. In providing Vivral, it is not acting as a physician, nurse, pharmacist, therapist, hospital, laboratory, emergency service, health plan, or other licensed healthcare provider. Vivral does not practice medicine, provide medical care, or create a clinician-patient relationship.

Vivral provides general educational information, organization tools, and optional wellness features. It is not a medical device, has not been cleared or approved by the U.S. Food and Drug Administration, and is not intended to diagnose, treat, cure, mitigate, monitor, or prevent any disease or condition. No App output is a prescription, diagnosis, treatment plan, medical record maintained by a healthcare provider, or substitute for professional judgment.

3. Health, Wellness, Sensor, and AI Limitations

Do not use Vivral for emergencies. If you believe anyone may be experiencing an emergency, call the applicable local emergency number immediately (911 in the United States). Do not wait for or rely on an App response.

Pulse Wellness Check. Vivral’s camera-and-flash feature is a wellness feature that estimates a pulse rate from fingertip color changes. It is not a heart-rate monitor, electrocardiogram, diagnostic test, medical device, continuous monitor, or tool for evaluating a pacemaker or other implanted device. Lighting, movement, pressure, skin characteristics, circulation, temperature, camera hardware, and software limitations can make the estimate incomplete, delayed, or wrong. Do not use it to make medication, exercise, emergency, or care decisions.

Other camera, microphone, motion, gait, tremor, breathing, recovery, or sensor features are also wellness or educational tools only. They may be unavailable in a public release and, when available, have not been validated for clinical use.

Vivral uses probabilistic artificial-intelligence models. Outputs can be inaccurate, outdated, incomplete, biased, internally inconsistent, or fabricated. The App cannot examine you, know your full history, confirm that imported information is complete, order tests, or observe changes in real time. Always verify important information with an appropriately licensed professional. Consult a qualified clinician before changing medication, treatment, diet, exercise, or other health decisions, and seek a second source when an answer matters.

Patient Passport, OCR, connected-provider imports, reminders, trends, and summaries may misread, omit, duplicate, misclassify, or display stale data. Compare all information against the original source and your clinician’s records. Vivral is not a system of record and must not be the sole place you keep important information.

4. Your Responsibilities

You assume the risks of choosing to use educational or wellness information. You agree not to:

• rely on Vivral as the sole basis for a diagnosis, treatment, emergency, medication, insurance, employment, legal, or financial decision;
• represent App output or a wellness estimate as a clinically validated measurement;
• use Vivral to provide professional medical services or to replace legally required professional review;
• enter information you do not have the right to use;
• violate privacy, intellectual-property, export-control, sanctions, or other laws;
• probe, disrupt, overload, bypass, scrape, reverse engineer, extract model weights, or defeat access, payment, safety, or security controls, except to the limited extent applicable law expressly permits; or
• use the Service to create malware, facilitate harm, impersonate another person, or develop a substantially similar competing service through unauthorized access to Vivral materials.

5. Privacy, Permissions, and User Content

The Privacy Policy explains how Vivral handles personal information. The separate Consumer Health Data Privacy Policy explains consumer-health-data categories, sources, purposes, recipients, retention, and rights. Device permissions are optional, but declining a permission can make the related feature unavailable.

You retain your rights in content you lawfully provide. You grant us a limited, non-exclusive license to process that content only as needed to provide, secure, maintain, and comply with law for the Service, and as otherwise described in the Privacy Policy or an additional consent you give.

Chat prompts, Patient Passport records, Apple Health data, documents, and sensor results are not automatically submitted for model training. Vivral does not offer feedback upload for chats tagged as Clinical Record-grounded, so records imported through that feature and responses grounded in them remain on the device unless you explicitly export or share them. If you manually paste copied record text into an ordinary chat, Vivral cannot reliably identify its prior source; that text can be included in feedback only if you later review the exact redacted text and affirmatively approve submission. For other eligible responses, Vivral shows the exact redacted prompt and response for review and asks for separate approval before sending. Submitted feedback may be reviewed only to investigate issues and improve the quality and safety of Vivral's health-management responses, as described at the time of submission and in the Privacy Policy.

6. Subscriptions, Trials, and Billing

Vivral Standard is offered in monthly and yearly billing cadences. The localized price, currency, billing period, taxes, trial eligibility, and renewal terms shown immediately before purchase control over any older or general price reference.

Eligible U.S. users may be shown a 7-day free trial for Stripe web checkout. That web trial is separate from App Store billing and does not imply that an Apple introductory offer is available. An Apple trial or offer applies only when StoreKit displays it on the Apple purchase sheet. Unless canceled before the applicable deadline, the selected monthly or yearly subscription begins or renews and the account is charged the full price for that billing period. Trial eligibility is limited and is determined separately by the payment provider; deleting an account or changing payment methods does not create new eligibility.

App Store purchases are billed and managed by Apple under Apple’s terms. Eligible U.S. users may also be offered Stripe web checkout, which is billed and managed by Stripe for the signed-in Vivral account. We do not receive full payment-card numbers. Cancel through Manage Subscription before the applicable trial or renewal deadline. Cancellation stops future renewal but ordinarily does not retroactively refund the current period. Refunds, taxes, failed payments, grace periods, and billing disputes are governed by the payment provider and applicable law.

We may change future prices or offerings with legally required notice. A price change does not take effect for an existing subscription except as allowed by the payment provider and law.

7. Ownership and License

Nair Engineering and its licensors own the App, models, software, interfaces, trademarks, documentation, and other Service materials. These Terms do not transfer ownership. Your license is limited by the EULA. Third-party and open-source components remain subject to their own licenses.

Subject to law and third-party rights, you may use App output for your personal, non-commercial purposes. Outputs may not be unique, and other users may receive similar output. We do not promise that output is accurate, protectable, or non-infringing.

8. Third-Party Services

Vivral can interact with Apple, Google/Firebase, Stripe, Supabase, Hugging Face, Google Health, Withings, and other services you choose. Their availability and separate terms and privacy practices are outside our control. We are not responsible for third-party content, accounts, outages, changes, or acts, except to the extent applicable law provides otherwise.

9. Availability, Changes, and Termination

Features may be beta, changed, limited by device, suspended, or removed. Background tasks, notifications, sync, and model downloads are not guaranteed to run continuously or at a specific time. We may suspend access when reasonably necessary for security, legal compliance, nonpayment, abuse, or a material violation of these Terms.

You may stop using Vivral at any time. Deleting your account is separate from canceling a subscription. Vivral cancels an active Stripe subscription during account deletion, but it cannot cancel App Store billing; manage any Apple subscription in Apple’s subscription manager before or after deleting the Vivral account. Confirm the final cancellation status with the applicable provider. Provisions that by their nature should survive—including ownership, warranty disclaimers, liability limits, dispute terms, and accrued payment duties—survive termination.

10. Disclaimer of Warranties

TO THE MAXIMUM EXTENT PERMITTED BY LAW, VIVRAL IS PROVIDED “AS IS” AND “AS AVAILABLE,” WITH ALL FAULTS. NAIR ENGINEERING AND ITS LICENSORS DISCLAIM EXPRESS, IMPLIED, AND STATUTORY WARRANTIES, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, QUIET ENJOYMENT, SECURITY, AVAILABILITY, AND ANY WARRANTY ARISING FROM COURSE OF DEALING OR USAGE.

We do not warrant that the Service, health information, AI output, sensor estimate, imported record, notification, sync, or download will be accurate, complete, timely, uninterrupted, secure, error-free, or suitable for any medical or other high-stakes purpose. Some jurisdictions do not permit certain disclaimers, so those disclaimers apply only to the extent permitted.

11. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, NAIR ENGINEERING, ITS OFFICERS, DIRECTORS, EMPLOYEES, CONTRACTORS, LICENSORS, AND SERVICE PROVIDERS (COLLECTIVELY, THE “COVERED PARTIES”) WILL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE, OR CONSEQUENTIAL DAMAGES; LOST PROFITS, REVENUE, GOODWILL, OR DATA; BUSINESS INTERRUPTION; OR DAMAGES ARISING FROM RELIANCE ON APP OUTPUT, WELLNESS ESTIMATES, MISSED OR DELAYED CARE, IMPORT OR OCR ERRORS, SERVICE INTERRUPTION, THIRD-PARTY SERVICES, OR UNAUTHORIZED ACCESS.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE TOTAL AGGREGATE LIABILITY OF THE COVERED PARTIES FOR ALL CLAIMS ARISING OUT OF OR RELATING TO VIVRAL WILL NOT EXCEED THE GREATER OF (A) US $100 OR (B) THE AMOUNT YOU PAID TO NAIR ENGINEERING FOR VIVRAL DURING THE 12 MONTHS BEFORE THE EVENT GIVING RISE TO THE CLAIM.

These limits allocate risk and are an essential basis of the bargain. They do not limit liability that cannot legally be limited, including liability for our fraud, willful misconduct, or other liability that applicable law makes non-waivable. Your jurisdiction may provide additional rights.

12. Indemnification

To the extent permitted by law, you will defend, indemnify, and hold harmless Nair Engineering and its personnel from third-party claims, losses, and reasonable costs arising from your unlawful use of Vivral, material violation of these Terms, infringement of another person’s rights, or submission of another person’s data without authority. This obligation does not apply to the extent a claim results from Nair Engineering’s own negligence, willful misconduct, or violation of law.

13. Dispute Resolution; Arbitration; Class-Action Waiver

PLEASE READ THIS SECTION. IT AFFECTS YOUR RIGHT TO A JURY TRIAL OR CLASS ACTION.

Before filing a claim, either party must send a written notice describing the dispute and requested relief. Send notices to akhileshnair@nairengineering.com with subject “Legal Dispute Notice” and to the address in Section 17. The parties will try in good faith to resolve the dispute for 60 days.

Except for an eligible individual small-claims action or a claim seeking temporary injunctive relief for misuse of intellectual property or security systems, any unresolved dispute arising from these Terms or Vivral will be resolved by binding individual arbitration administered by the American Arbitration Association under its Consumer Arbitration Rules and governed by the Federal Arbitration Act. The arbitrator may award the same individual remedies a court could award, but not relief for people who are not parties.

Claims may be brought only on an individual basis. The parties waive any right to a jury trial and to participate in a class, collective, coordinated, consolidated, mass, or representative action or arbitration, to the extent the law permits. If the class-action waiver is finally held unenforceable for a particular claim or remedy, that claim or remedy will proceed in court after the remaining arbitrable issues are resolved.

You may opt out of arbitration by emailing akhileshnair@nairengineering.com within 30 days after first accepting these Terms. Include your name, Vivral account email, and an unambiguous statement that you opt out of arbitration. Opting out does not affect the rest of the Terms.

Nothing in this section prevents you from contacting a government agency or exercising a non-waivable statutory right.

14. Governing Law and Venue

The Federal Arbitration Act governs arbitration. Otherwise, Delaware law governs without regard to conflict-of-law rules, except that mandatory consumer law of your home jurisdiction remains applicable. For disputes not subject to arbitration, the parties consent to the state and federal courts located in Delaware, unless applicable consumer law requires another forum.

15. Changes to These Terms

We may update these Terms for legal, safety, security, or product changes. Material changes will be presented in the App or by another reasonable notice, and we will request renewed agreement when required. The effective date identifies the current version. Changes do not retroactively reduce rights already accrued.

16. General Terms

If a provision is unenforceable, it will be enforced to the maximum lawful extent and the rest remains effective, except as Section 13 states. Failure to enforce a provision is not a waiver. You may not assign these Terms without our written consent; we may assign them in connection with a merger, financing, reorganization, or sale, subject to applicable privacy law. These Terms, the EULA, the Health & Wellness Notice, the Privacy Policy, the Consumer Health Data Privacy Policy, and purchase disclosures are the entire agreement for the Service.

17. Contact

Nair Engineering, Inc.
Registered office: 131 Continental Drive, Suite 305, Newark, Delaware 19713, United States
Email: akhileshnair@nairengineering.com
Website: https://nairengineering.com

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End User License Agreement

Effective: August 27, 2026

This End User License Agreement (“EULA”) is a binding agreement between you and Nair Engineering, Inc. (“Nair Engineering”) for the Vivral application (the “Licensed Application”). The Terms of Use, Health & Wellness Notice, Privacy Policy, and Consumer Health Data Privacy Policy are incorporated by reference. If this EULA conflicts with the Terms of Use on a licensing issue, this EULA controls; otherwise the Terms of Use controls.

1. Apple Acknowledgment

This EULA is between you and Nair Engineering only, not Apple Inc. (“Apple”). Nair Engineering—not Apple—is solely responsible for the Licensed Application and its content. This EULA does not create usage rules that conflict with the Apple Media Services Terms and Conditions, including the App Store Usage Rules.

2. Scope of License

Nair Engineering grants you a limited, revocable, non-exclusive, non-sublicensable, non-transferable license to install and use the Licensed Application for your personal, non-commercial use on Apple-branded products that you own or control, as permitted by the App Store Usage Rules. The Licensed Application may also be accessed and used by other accounts associated with the purchaser through Family Sharing or other Apple features to the extent the Usage Rules permit, but Vivral account, age, consent, and subscription requirements still apply.

This is a license, not a sale. Nair Engineering and its licensors reserve every right not expressly granted.

3. License Restrictions

Except where applicable law or an open-source license expressly permits, you may not copy, distribute, rent, lease, sell, sublicense, publicly host, modify, create derivative works of, decompile, reverse engineer, disassemble, extract models or weights from, bypass protections in, or use the Licensed Application to build a substantially similar competing product. You may not remove ownership notices or use the Licensed Application unlawfully.

4. Health and Wellness Limitation

The Licensed Application provides educational information and wellness tools only. It is not a medical device or healthcare provider, does not provide diagnosis or treatment, and must not be used for emergencies or clinical decisions. The Pulse Wellness Check is a non-clinical camera estimate, not a heart-rate monitor or diagnostic measurement. AI and imported information may be wrong. The Health & Wellness Notice contains essential safety terms and is part of this EULA.

5. Ownership; User Content; Feedback

Nair Engineering and its licensors own the Licensed Application, software, models, designs, trademarks, and documentation. You retain rights in content you lawfully provide and grant only the limited processing rights described in the Terms and Privacy Policy. Feedback is not uploaded merely because you use Vivral; eligible text is sent only after the App shows a review and you approve submission. Clinical Record-grounded chats cannot be submitted as feedback. Approved feedback may be used only to investigate issues and improve the quality and safety of Vivral's health-management responses, subject to the Privacy Policy.

6. Maintenance and Support

Nair Engineering is solely responsible for maintenance and support it elects or is legally required to provide. Apple has no obligation to furnish maintenance or support for the Licensed Application. Contact Nair Engineering using Section 15.

7. Updates and Changes

Updates may add, change, or remove functions and may be required for security, compatibility, subscription verification, or continued use. Unless accompanied by separate terms, this EULA governs updates. We do not promise to maintain any beta or particular feature indefinitely.

8. External Services and Third-Party Terms

You must comply with applicable third-party terms when using the Licensed Application, including your wireless-data agreement, Apple Media Services terms, and the terms of any connected account or provider. Apple, Google/Firebase, Stripe, Supabase, Hugging Face, Google Health, Withings, and other services may be governed by separate terms. Open-source components are licensed under their applicable notices.

9. Warranty; App Store Remedy

To the maximum extent permitted by law, the Licensed Application is provided “AS IS” and “AS AVAILABLE” and Nair Engineering disclaims the warranties listed in the Terms of Use. If the Licensed Application fails to conform to an applicable warranty that cannot be disclaimed, you may notify Apple, and Apple may refund the purchase price, if any, paid for the Licensed Application as provided by Apple. To the maximum extent permitted by law, Apple has no other warranty obligation. Nair Engineering is solely responsible for any other claim, loss, liability, damage, cost, or expense attributable to a failure to conform to an applicable warranty.

10. Product Claims

Nair Engineering—not Apple—is responsible for addressing claims relating to the Licensed Application or your possession or use of it, including product-liability claims, claims that it fails to meet legal or regulatory requirements, and claims under consumer-protection, privacy, or similar laws, including claims connected with HealthKit. Nothing in this EULA limits Nair Engineering’s liability beyond what applicable law permits.

11. Intellectual-Property Claims

If a third party claims that the Licensed Application or your possession and use of it infringes intellectual-property rights, Nair Engineering—not Apple—is solely responsible for investigating, defending, settling, and discharging that claim.

12. Disclaimers and Limitation of Liability

The warranty disclaimers, damage exclusions, and aggregate liability cap in Sections 10 and 11 of the Terms of Use apply to this EULA to the maximum extent permitted by law. They do not exclude non-waivable liability.

13. Legal and Export Compliance

You represent that you are not located in a country or region subject to a U.S. Government embargo or designated by the U.S. Government as supporting terrorism and that you are not on any U.S. Government prohibited- or restricted-party list. You will comply with applicable export-control, sanctions, and local laws.

14. Termination

This license terminates automatically if you materially breach the EULA. Upon termination, stop using and delete the Licensed Application. Sections concerning ownership, disclaimers, liability, disputes, and other terms that should survive will survive. Account deletion and subscription cancellation remain separate steps as described in the Terms.

15. Developer Name, Address, and Contact

Nair Engineering, Inc.
Registered office: 131 Continental Drive, Suite 305, Newark, Delaware 19713, United States
Email for questions, complaints, and claims: akhileshnair@nairengineering.com
Website: https://nairengineering.com

16. Apple as Third-Party Beneficiary

Apple and its subsidiaries are third-party beneficiaries of this EULA. When you accept this EULA, Apple has the right—and is deemed to have accepted the right—to enforce this EULA against you as a third-party beneficiary.

17. Governing Terms and Disputes

The dispute-resolution, arbitration, class-action waiver, governing-law, severability, and change provisions in the Terms of Use apply to this EULA.

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