Privacy Policy for VerteGuard

# VerteGuard Privacy Policy


**Last Updated: September 2, 2026


Your privacy matters to us. C-Tech Inc., the owner of the VerteGuard application, is committed to protecting your personal information and ensuring transparency in how we collect, use, and safeguard your data.


## Disclaimer


PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE APP OR ENGAGE IN COMMUNICATIONS WITH US CONCERNING OUR SERVICES.


## Introduction and Purpose


The VerteGuard mobile application ("VerteGuard," "App," "we," "us," and "our") is wholly owned by C-Tech Inc. We are committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. This Privacy Policy (the "Policy") describes how we process and use the personal information that we collect through the VerteGuard mobile application (the "App"), any website that directs to or otherwise contains a link to this Privacy Policy (the "Site"), or that you otherwise provide to us in connection with our products, devices, software, and services (the "Services").


VerteGuard is a personal-safety and wellness application designed to help protect at-risk and older adults. The App works together with a compatible wearable device to detect and monitor activity and posture, . VerteGuard is intended to support personal health and wellness. It is not intended to diagnose, treat, cure, or prevent any disease or medical condition, and it is not a substitute for professional medical care or emergency services.

This Privacy Policy is incorporated into our Terms and Conditions. By using our App, Site, or Services, you acknowledge and agree to this Privacy Policy and our Terms and Conditions.


## Information We May Collect


We collect and process the following types of personal information for the purposes described below. The information we collect depends on the nature of our relationship, how you communicate with us, the Services you use, and the choices you make.


**Contact Information:** When you register for an account, contact us, or otherwise interact with the App, we may collect your first and last name, email address, telephone number, and similar contact details.


**Account Information:** To create an account, we collect information such as your name, email address, password, telephone number, and the VerteGuard-compatible device registered to your account.


**Health and Activity Information:** When paired with a compatible wearable device, the App may collect activity and motion-related information such as movement, step or activity estimates, posture, and event information related to posture. This information is used to provide the App's health and wellness features.


**Location Information:** With your permission, the App collects location information from your mobile device. Location is used to support  in emergency alerts sent to your designated emergency contacts so they can locate and assist you. Depending on the feature and your device permissions, location may be collected while the App is in use and, where you enable background/"Always" location, while the App is running in the background — this background collection is used only for emergency-response features. You can control location collection through your device settings, though disabling it will limit the App's safety features.


**Device and Usage Information:** We may automatically collect certain information from your device, such as a unique device identifier, device and operating-system type, App version, IP address, and information about how you interact with the App.


**Communications Data:** If you contact us, provide feedback, or otherwise communicate with us, we collect the content of your communication and the information needed to respond.


Device permission requests are limited to those necessary to provide the App. You may change your device-permission preferences at any time in your device settings; opting out will disable the associated features.


## How We Use Your Information


We use the information described above, including personal information, for the following purposes:


- **Providing the App and Services:** To operate the App's safety and wellness features, including posture monitoring,  to create and manage your account; to troubleshoot and improve the App; and to respond to your requests.
- **Communicating With You:** To send you service-related communications and to respond to your inquiries.
- **Operating and Securing Our Business:** To maintain, secure, and improve the App; to prevent fraud and abuse; to comply with legal obligations; and to enforce our Terms and Conditions.


We may create and use de-identified or aggregated data, which is no longer treated as personal information under this Policy.


## How We May Disclose Your Information


**Emergency Contacts:** When an emergency is detected and not cancelled, we share the relevant alert information, including your name and location, with the emergency contacts you have designated in the App, so they can assist you.


**Service Providers:** We share personal information with third-party service providers who perform services on our behalf, such as cloud hosting and database services, push-notification delivery, and telecommunications providers who deliver SMS text messages and voice calls on our behalf. These providers are permitted to use your information only as necessary to provide services to us.


**Legal and Protective Disclosures:** We may disclose personal information as required by law, court order, or legal process, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others.


**Corporate Transactions:** If we are involved in a merger, acquisition, reorganization, or sale of assets, personal information may be transferred as part of that transaction.


**With Your Consent:** We may share your information with other parties when you direct us to or otherwise consent.


**De-identified or Aggregated Data:** We may share de-identified or aggregated information that does not identify any specific individual.


## Text Messaging (SMS) Terms and Disclosures


**No Sharing of Mobile Information:** We do not sell, rent, or share mobile telephone numbers collected for the purpose of sending emergency alerts with any third parties or affiliates for their marketing or promotional purposes. Mobile telephone numbers and related consent are used solely to deliver the emergency-alert and safety notifications described in this Policy, and are shared only with the telecommunications service providers that deliver those messages on our behalf. No mobile information is shared with third parties or affiliates for marketing or promotional purposes.


**Message Frequency:** Message frequency varies.  VerteGuard does not send recurring marketing or promotional text messages.


**Message and Data Rates:** Message and data rates may apply. Your mobile carrier's standard messaging and data charges may apply to messages you send or receive.


**Opt-Out:** Recipients of VerteGuard emergency text messages may opt out of receiving further messages at any time by replying STOP to a received message. Because these are safety-critical alerts, opting out will prevent that person from receiving future emergency notifications for the associated user. For help, reply HELP.


## Retention of Personal Information


We retain and use your personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. We take reasonable steps to delete personal information when we no longer have a purpose for retaining it, when we are legally required to do so, or upon your valid request, subject to our legal and operational obligations. When we delete data, it is removed from our active servers and databases but may remain in archives where deletion is not practical.


## Account Deletion


You may request deletion of your account and associated personal information at any time. Please see our separate Account Deletion Policy, or use the "Contact Us" details at the end of this Policy, for information on how to delete your account and what data is removed or retained.


## Security and Protection of Personal Information


We maintain reasonable and appropriate physical, technical, and organizational safeguards designed to protect your personal information against loss and unauthorized access, use, alteration, or disclosure. Information you provide to us is encrypted in transit. However, no security system is perfect and no data transmission is completely secure, so we cannot guarantee the absolute security of your information.


## Your Rights and Choices


Depending on where you reside, you may have rights regarding your personal information, including the right to access, correct, or delete your information, and to opt out of certain processing. To exercise your rights or manage your information, use the "Contact Us" details at the end of this Policy or the account settings within the App. You may opt out of email communications using the unsubscribe link in our emails, and out of emergency SMS messages by replying STOP.


## Children's Privacy


The App is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without appropriate consent, we will take steps to delete it. If you believe we may have information from a child under 13, please contact us using the details below.


## Third-Party Services


This Policy applies only to the App, Site, and Services and does not apply to third-party websites, applications, or services. Information collected by third parties is governed by their own privacy policies.

Cookies

A cookie is a small data file that is sent to your device when you first visit a website. Cookies usually include an identification number that is unique to the device you are using. Such identifier can help us better understand our users and how they are using the Site and the Services. Cookies also enable recognition of a user when they re-visit the Site, keeping their settings and preferences and ability to offer customized features.

The Services may implement the following types of cookies: (i) cookies implemented by us for the purposes described above (“First Party Cookie”); and (ii) third party cookies which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access or online advertisers on our Services. Ads appearing on our Site and/or through the Services may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer.  Among other things, this information allows ad networks to deliver targeted advertisements that they believe will be of most interest to you. These interest-based ads may be presented to you while you are browsing our Site or third-party sites not owned by us. This Privacy Policy covers the use of cookies by us alone and does not cover the use of cookies by any advertisers.

You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Services may not operate properly and your online experience may be limited.

Analytics

We may use third parties, such as Google Analytics, Tableau, Amplitude, Flurry, or other analytics providers, to analyze traffic to and optimize our Site or Services. Our analytics may include cookies, clear GIFs, pixel tags, and other similar technologies. Our analytics partners do not create individual profiles for visitors and only collect aggregate data. To disable Google Analytics, for example, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy of our analytics partners, please consult information provided by such analytics partners. You may have the option to opt out of analytics partners’ use of cookies by changing your browser settings.

With whom we share the information we collect

We do not rent, sell or share your Personal Information with third parties except as described in this Privacy Policy.

We may transfer or share Personal Information, including PHI, to our subsidiaries, affiliated companies, subcontractors, your coach or mental health service provider; SDKs or such other trusted third parties and/or service providers or partners (who may be located in various countries across the world) to perform services for us on our behalf.

In addition, under your specific acknowledgment and consent, we may share your Personal Information and PHI with third party service providers in the healthcare ecosystem, such as hospitals, physicians, insurance companies, coaching services providers and others to allow them to obtain a holistic view of your needs and interests. Please note that under such consent, we may disclose to third party service providers in the healthcare ecosystem all relevant Personal Information and PHI that you share with us on an ongoing basis through the Services.

Please note: When we share PHI with third parties, such information is either anonymized or encrypted (as required by applicable laws) in order to effectively protect personal and/or health related information of users.  To the extent PHI is shared with third parties, the third parties must first agree to be bound by HIPAA privacy and security protections.

We may also share Personal Information, including PHI, or any information you submitted via the Services, if we have a good faith belief that the sharing of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) collaborate with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.

With respect to PHI, you have both the right and choice to tell us to share information with your family, close friends or others involved in your care and to share information in a disaster relief situation.  If you are unable to tell us your preference (for example, if you are unconscious), we may go ahead and share your PHI if we believe it is in your best interest.  We may also share your PHI when needed to lessen a serious and imminent threat to health or safety.  We will never share your PHI for marketing purposes or sell your PHI, unless you give us written permission. 

We are allowed or required to share your PHI in other ways that contribute to the public good (such as public health and research), provided we meet many conditions under HIPAA before doing so.  These disclosures include those that help with public health and safety issues (such as preventing disease, helping with recalls, reporting adverse reactions, suspected abuse, neglect or domestic violence or preventing or reducing a serious threat to anyone‘s health or safety).  We can also share your PHI for health research or if state or federal laws require it, to respond to court or administrative orders or to address workers’ compensation, law enforcement and other government requests.  In addition, we may share your PHI to respond to organ and tissue donation requests or to work with a medical examiner, coroner or funeral director.

Information shared through HealthKit

You may instruct us to share information (including Personal Information and PHI) with systems such as Apple Inc.’s HealthKit and to access and collect information from those systems, for the purpose of improving the Services which we provide to you. If you grant our App access to HealthKit, our App can add information such as glucose measures and carbs, amongst other data, to HealthKit. VerteGuard is in no way responsible for the protection of data and information stored within the Apple HealthKit database. It is strongly recommended that you review Apple’s applicable policies and procedures before synching and backup your Apple HealthKit data  You can remove access at any time either inside our App or inside the Apple Health app.

We do not use or share with third parties any information gained through the use of the HealthKit for advertising or similar services, other than for purposes of improving health or for purposes of health or medical research and, with respect to PHI, only to the extent permitted under HIPAA.

Third party collection of information

Our policy only addresses the use and sharing of information we collect from you. To the extent that you share your information with other parties via our Services (e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their use or sharing of the information that you disclose to them.  We shall have no liability whatsoever with respect to such third party sites and services and your usage of them.

User Rights and Choices

You can access, update, and delete certain Personal Information by logging into your user account. If you have questions about Personal Information we have about you, please email us at vitaleyehealth@gmail.com You can opt-out of receiving marketing and promotional e-mails from vital eye health by using the opt-out or unsubscribe feature contained in the e-mails. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you Service-related updates and notifications. If you wish to unsubscribe from marketing text message communications, you may respond to any marketing message from us with a STOP or similar command.

EEA users:

This section applies to all Personal Information (or “personal data”) collected by us from users and customers in the European Economic Area (“EEA”), the United Kingdom, and Switzerland. The processing of Personal Information is governed by the General Data Protection Regulation (“GDPR”) in the EEA, and similar data privacy laws in the United Kingdom and Switzerland. These laws require us to provide certain information regarding our processing of your Personal Information. 

  • Our Processing of Personal Information: Unless otherwise stated, we are the data controller of Personal Information you provide to us, and the purposes of our processing of Personal Information are described in this Policy and outlined below.  We may also process Personal Information on other bases permitted by the GDPR and applicable laws. In general, we process Personal Information on the following legal grounds: 
    • Providing our products and services to you or performing a contract we have with you: In certain circumstances, we need your Personal Information to comply with our contractual obligation to deliver products you order from us and to provide our Services. For example, if you buy our products from us, we must collect certain information, including Personal Information from you. Similarly, we need your name and contact details so that we can communicate with you and deliver the products to you. In this case, your Personal Information is necessary to provide you with the Services.
    • When the processing is necessary for purposes of our legitimate business interest in conducting our business: For example, we have a legitimate interest in communicating information about our company and (subject to marketing authorizations) our commercial products, events, and company initiatives; and improving our website content and functionality. We take into account any risks to your fundamental rights and freedoms in assessing these purposes (including your right to privacy);
    • When the processing is necessary for us to comply with our legal obligations; and 
    • When you give us the consent to process your Personal Information. 
  • Categories of Personal Information: All categories of Personal Information collected and processed by us are described in this Policy.
  • Health and other Special Categories of Personal Information: To the extent that Personal Information we collect is health data or another special category of personal data subject to the GDPR, we ask for your explicit consent to process such data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you pair your device to your account. You may be able to use your account settings and tools to withdraw your consent at any time, including by stopping use of a feature, removing our access to a third-party service, unpairing your device, or deleting your data or your account.
  • Recipients of Personal Information: We use various service providers to manage our website, help us fulfill product orders, and assist us as described in this Policy.  Our service providers change from time to time.  Note that we require our service providers to treat your Personal Information in a manner that is consistent with this Policy. If you would like specific information about our service providers who have received your Personal Information, please contact us at vitaleyehealth@gmail.com and we will provide that information to you.
  • Transfers of Personal Information outside of the EEA: We are based in the U.S. and that’s where we process Personal Information.  When you provide Personal Information to us, we transfer that Personal Information to the U.S. We treat the Personal Information of EEA users in accordance with this Policy.  We take appropriate steps to protect your privacy and implement reasonable security measures to protect your Personal Information in storage. We also enter into contracts with our data processors that require them to treat Personal Information in a manner that is consistent with this Policy.
  • Personal Information retention: We retain Personal Information so long as it is necessary for the purpose for which it was collected, and delete Personal Information after it is no longer needed for these purposes.  This does not affect your right to request that we delete your Personal Information before the end of its retention period.  We may archive Personal Information (which means storing it in inactive files) for a certain period of time prior to its final deletion, as part of our ordinary business continuity procedures.
  • Your rights:
    • You have the right to access to your Personal Information, to have it corrected if the Personal Information we have is incorrect, to request that we restrict or delete your Personal Information, and to object to our processing of your Personal Information. Your rights may be subject to various limitations under applicable privacy laws.  If you wish to exercise any of these rights, or if you have any concerns about our processing of your Personal Information, please contact us at vitaleyehealth@gmail.com
    • You have the right to file a complaint concerning our processing of your Personal Information with your national data protection authority.
    • You have the right to file a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Information relating to you infringes applicable data protection laws.
  • Workplace Options:

Some of our global users may have access to services provided by WorkPlace Options LLC (“WPO”).  Please note that WPO is an independent third party.  If you provide Personal Information to WPO, WPO is an independent data controller of that information, and Dario has no control over WPO’s use of your information or Personal Information. Please read WPO’s privacy policy carefully for information about how WPO’s uses your Personal Information. If you wish to exercise of your rights under applicable data protection laws with respect to Personal Information that you have provided to WPO, please contact WPO to exercise those rights.

California residents: 

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, visit the Privacy Notice for California Residents.

How to Exercise Your Rights; Complaints:

If you wish to exercise any of your rights with respect to your Personal Information, or raise a complaint regarding how we have handled your Personal Information or PHI, please contact us at vitaleyehealth@gmail.com

In addition, if you believe your privacy rights with respect to PHI have been violated, or if you are dissatisfied with our privacy practices or procedures regarding your PHI, you may file a complaint with the U.S. Department of Health and Human Services by sending a letter to U.S. Department of Health and Human Services Office for Civil Rights, 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775 or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

Other State-specific Disclosures

California residents:  We do not respond to Do Not Track requests or signals at this time.  California’s “Shine the Light” law (Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of “personal information” (as defined in the Shine the Light law) to third parties for their direct marketing purposes. We do not share your “personal information” with third parties for their own direct marketing processes.

Nevada residents:   Nevada residents can opt out of the sale of their Personal Information.   We do not sell Personal Information today, and we do not have plans to sell Personal Information in the future.   However, Nevada residents have the legal right to opt out of the sale of their Personal Information, even if their information is not currently being sold.  You may opt out by emailing a request to vitaleyehealth@gmail.com.  In your request, please specify that you wish to “Opt-out of Sale of Personal Information in Nevada.”   Please allow 60 days for a response.

Retention

We will retain your personal information for the duration required to provide our services, and as necessary to comply with our legal obligations, resolve disputes and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected. 

How do we safeguard and transfer your information?

We take great care in implementing and maintaining the security of the Services and your Personal Information in accordance with the requirements of all applicable laws (including with requirements under HIPAA). We have implemented appropriate administrative, technical, and physical security procedures to help protect the Personal Information you provide to us.  However, the Internet is not a risk-free environment, and we cannot guarantee the security of information you submit via our Services while it is in transit over the Internet, and any such submission is at your own risk.

As an additional safeguard to your Personal Information, the Company employs a Data Protection Officer (“DPO”).  The DPO also serves as our HIPAA privacy officer.

Since we operate globally, we may be required to transfer your Personal Information to countries outside of the United States. The data protection and other laws of these countries may not be as comprehensive as those in the United States − in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information. You hereby consent to transfer of your Personal Information to countries outside the United States.

Affiliates and corporate transaction

We may share your information, including your Personal Information and PHI, with any subsidiaries, joint ventures, or other companies under our common control (collectively, “Affiliated Companies”). We may share Information, including Personal Information and PHI, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale) or steps taken in anticipation of such events (e.g., due diligence in a transaction). In the event of the above, our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Privacy Policy and, with respect to PHI, under HIPAA.

Minors

The Services are not designed for the use by children under 13 years of age.  However, users in the EEA must be 16 years of age, and users of our VerteGuard services must be at least 18 years of age. If you have reason to believe that a child under the age of 13 (or under the age of 16 in the EEA) has provided Personal Information to us through the use of any of the Services without the consent of their parent or legal guardian, you should immediately contact us and we will endeavor to delete that information from our records.

Additionally, no information should be submitted to or posted to any of the Services by users under 18 years of age without the consent of their parent or legal guardian. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Information and PHI on any of the Services without their permission.


## Updates and Changes to This Policy


We may update this Privacy Policy from time to time. Changes are effective upon posting. If we make material changes, we will provide notice through the App or by other means. Your continued use of the App after the "Last Updated" date constitutes acceptance of the updated Policy.


## Contact Us


If you have questions or concerns about this Privacy Policy, please contact us:


**C-Tech Inc.**
216 W 6th Street, San Bernardino, CA 92401


**Email:** vitaleyehealth@gmail.com