Medical Data Policy

1. Scope

This Policy applies to all medical and health-related data that users voluntarily provide or upload to the Service, including but not limited to:

• laboratory test results and medical examination data;
• genetic data and DNA test results;
• anthropometric and physiological measurements;
• nutrition data and nutritional indicators;
• personalized AI recommendations based on medical data.

This Policy applies to all users of the Service, regardless of their jurisdiction, and supplements the general NutriFit Privacy Policy.

2. Types of medical data

2.1. Laboratory tests

Blood test results (complete blood count, biochemistry, hormones, vitamins, inflammatory markers), urinalysis results, and other laboratory examinations that the user uploads or enters manually.

2.2. Genetic data

DNA test results, genetic markers, polymorphisms, predispositions, and other genetic characteristics. Genetic data is subject to special protection under the GINA Act (see Section 8 for details).

2.3. Health metrics

Anthropometric and physiological measurements, including:

• weight, height, body mass index (BMI);
• blood pressure, heart rate;
• body composition (fat percentage, muscle mass, hydration);
• physical activity and workout data;
• nutrition data, caloric intake, macro- and micronutrients.

2.4. AI recommendations

Personalized recommendations generated by the artificial intelligence system based on the user's medical data. AI recommendations are for informational purposes only and do not constitute medical prescriptions, diagnoses, or a substitute for consultation with a qualified healthcare professional.

3. Legal basis for processing

Medical data is processed on the following legal grounds:

• Explicit user consent (GDPR, Article 9(2)(a)) — before uploading or entering medical data, the user provides separate, informed consent for its processing.
• HIPAA Privacy Rule — medical data (Protected Health Information, PHI) is processed in accordance with the Minimum Necessary Standard.
• Performance of a contract — processing is necessary to provide health-related features and personalized recommendations within the Service.
• Legitimate interests — improving algorithms and Service quality (using only de-identified and aggregated data).

4. Data collection and input

Medical data enters the Service through the following methods:

• Manual input — the user independently enters health indicators (weight, blood pressure, test results) through the Service interface.
• File upload — the user uploads documents with laboratory test results or genetic test reports.

We do not collect medical data automatically, from third-party medical institutions, or from electronic health records (EHR) without explicit user action. All medical data is provided voluntarily by the user.

5. Storage and encryption

We employ a multi-layered security system for medical data:

• Encryption in transit — all connections are protected with TLS 1.2+ to prevent data interception.
• Encryption at rest — medical data is encrypted using the AES-256 algorithm at the database level.
• Isolated storage — medical data is stored separately from general user data with an additional layer of access control.
• Regular backups — encrypted backups are created on a regular schedule and stored in geographically distributed data centers.

6. Access control

Access to medical data is strictly limited:

• User — full access to their own medical data (view, edit, export, delete).
• Assigned coach/nutritionist — access only to data that the user has explicitly authorized for viewing within the coaching program.
• Technical staff — access only when necessary for technical support, with mandatory auditing of each access event.

All access to medical data is recorded in an audit log with details of the subject, time, action type, and scope of requested data. Audit logs are retained for a minimum of 6 years in accordance with HIPAA requirements.

7. Third-party disclosure

Medical data is not shared with insurance companies, employers, advertising networks, or other third parties, except:

• AI providers — to generate personalized recommendations, data is transmitted to artificial intelligence providers exclusively in a de-identified form (without name, email, user ID, or other direct identifiers).
• Legal requirements — when disclosure is required by court order or a lawful request from a competent government authority.

We never sell user medical data or use it for targeted advertising.

8. Genetic data and GINA Act

Genetic data is subject to special protection under the Genetic Information Nondiscrimination Act (GINA) and analogous legislation. NutriFit guarantees:

• Non-discrimination — genetic data is not used or disclosed for employment, insurance, or lending decisions.
• Separate consent — uploading and processing genetic data requires separate, informed consent that can be withdrawn at any time.
• Complete deletion — upon request for genetic data deletion, it is destroyed from all systems, including backups, within 90 days (GDPR Erase).
• Limited use — genetic data is used exclusively to provide the user with personalized recommendations within the Service.

9. Retention and deletion

Medical data is retained in accordance with the following principles:

• Active account — data is retained for the duration of the user's account.
• Account deletion — upon account deletion, all medical data is removed within 30 days from primary systems and within 90 days from backups, except where longer retention is required by law.
• Selective deletion — the user may delete individual records (test results, genetic data) without deleting the entire account.
• Audit logs — retained for a minimum of 6 years in accordance with HIPAA requirements, even after the corresponding medical data has been deleted.

10. User rights

Regarding medical data, the user has the following rights:

• Right of access — view all medical data stored in the Service through the user interface.
• Right to export — obtain a copy of all medical data in a machine-readable format (JSON or CSV) by request to office@nutrifit.company.
• Right to rectification — edit and correct previously entered data.
• Right to erasure — complete deletion of medical data (selectively or in full) through the Service interface or by email request.
• Right to restriction of processing — suspend processing of medical data without deleting it.
• Right to withdraw consent — withdraw consent for medical data processing at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, contact us at office@nutrifit.company with the subject line "Medical Data — Request". We will respond within 30 days.

11. Breach notification

In the event of a security incident affecting medical data:

• Users — will be notified within 72 hours of incident discovery (in accordance with GDPR Article 33).
• Regulators — the HHS Office for Civil Rights will be notified within 60 days (in accordance with the HIPAA Breach Notification Rule) along with relevant Data Protection Authorities (DPA).
• Investigation — an internal investigation will be conducted by the security team, with results documented and retained for a minimum of 6 years.

12. Policy changes

We may update this Policy to reflect changes in our data processing practices or legal requirements. For material changes, we will notify users through the Service or by email at least 30 days before the changes take effect. Continued use of the medical data features of the Service after the changes take effect constitutes your acceptance of the updated Policy.

13. Contact information

For questions related to medical data processing, please contact us:

• Email: office@nutrifit.company
• Subject line: "Medical Data — [request type]"
• Legal address: 30 N Gould St Ste R, Sheridan, WY 82801-6317, United States