Privacy Notice

1. Who we are

VITAPING LTD is a private limited company registered in England and Wales under company number 17205180. Our registered office is 23 De Morgan Road, London, England, SW6 2RP. We operate the VitaPing UK website and develop emergency identity products, software and controlled programmes. You can contact us at contact@vitaping.uk or +44 (0)7346 785 452.

2. Scope

This notice applies to the UK website, enquiries, demonstrations, pilot discussions and any VitaPing account or emergency identity service that expressly links to this notice. A school, care provider, employer, healthcare organisation or other partner may act as a separate or joint controller for its own deployment and may provide an additional privacy notice.

3. Information we collect

Depending on how you interact with VitaPing, we may collect contact details; organisation and role; account and identity details; guardian or nominated-contact details; emergency information selected by the user or authorised representative; product or device identifiers; activation and access records; incident notes where enabled; support messages; security and diagnostic logs; consent and preference records; and information collected through essential website technologies.

We design emergency profiles around data minimisation. Users and organisations should provide only information that is relevant to the emergency purpose and should not upload a full medical history where a smaller, current emergency summary is sufficient.

4. How we use information

We use information to respond to enquiries; create and manage accounts; provide the user-controlled emergency view; route approved contact or notification actions; support pilot and organisation programmes; protect and maintain the service; investigate misuse or security incidents; meet legal obligations; evaluate agreed pilots; and carry out separately approved TGMNI work. Marketing is optional and is kept separate from essential service communications.

5. Lawful bases and health information

Our lawful basis depends on the activity. We may rely on contract or steps requested before a contract, legal obligation, legitimate interests, consent or vital interests where the relevant legal test is met.

Health information is special-category data. Where VitaPing processes it, we also identify an appropriate condition under Article 9 of the UK GDPR. Depending on the service and deployment, this may include explicit consent, vital interests, health or social care, substantial public interest, public health, or research and statistical purposes with the required safeguards. The applicable basis is documented for each processing purpose and deployment.

6. Emergency view and access

A tap or scan may open a limited emergency view containing only the fields approved for that view. Additional professional or organisation access, where offered, requires an authenticated and authorised route. An activation record shows that a technical interaction occurred; it does not prove that an emergency occurred, that the information was read or that assistance was provided.

7. Guardians, children and vulnerable people

A parent, guardian or authorised representative must have a valid basis to create or manage a profile for another person. VitaPing uses age-appropriate explanations, proportionate authority checks, role-based access and data minimisation. Organisation staff must use the approved safeguarding and authorisation process rather than creating informal profiles.

8. TGMNI and secondary use

Emergency identity data does not automatically become TGMNI research or intelligence data. Any secondary use requires a separately defined purpose, lawful basis, institutional governance, data-minimisation plan, access controls and human oversight. Identifiable information is not used where anonymous or appropriately de-identified information is sufficient. TGMNI is not used for public tracking, underwriting, employment screening or autonomous medical decisions.

9. Sharing information

We may share information with the user’s chosen contacts; authorised users of a participating organisation; emergency or healthcare professionals where an approved route exists; contracted service providers; professional advisers, insurers or authorities where required; and approved TGMNI partners only under a separate governance framework. VitaPing does not sell personal health information.

10. Service providers and international transfers

We may use providers for hosting, authentication, communications, security, support and professional services. Where a provider processes information for us, it is bound by contractual and security requirements. Where information is transferred outside the UK, we use an applicable adequacy decision, the UK International Data Transfer Agreement or Addendum, or another lawful safeguard and complete the required assessment.

11. Retention

We keep information only for as long as needed for the stated purpose, legal obligations and agreed deployment requirements. Our default schedule is: enquiries for up to 24 months after the last meaningful contact; active account and emergency profile information while the account is open and normally up to 90 days after validated closure; emergency access logs for up to 24 months unless an agreed deployment or legal requirement sets another period; security logs for up to 12 months; and contracts, invoices and related business records for the period required by law. Backups are overwritten through the normal protected backup cycle.

12. Security

We use proportionate administrative, technical and organisational measures, including access controls, encryption in transit, protected storage, logging, secure development practices and incident response. No online service is completely risk-free. VitaPing publishes certification, audit or penetration-test claims only where the exact scope has been completed and can be evidenced.

13. Your rights

Depending on the circumstances, you may have rights to access, correct, delete, restrict or object to processing, receive portable data, withdraw consent and complain to the Information Commissioner’s Office. We may need to verify your identity or authority before acting. Contact contact@vitaping.uk to exercise a right.

14. Cookies and similar technologies

The public website is intended to operate with essential technologies only unless optional analytics or other technologies are introduced with an appropriate consent mechanism. See the Cookie Policy and Cookie Settings for the current inventory and choices.

15. Complaints

Please contact us first at contact@vitaping.uk so we can review the concern. You also have the right to complain to the UK Information Commissioner’s Office.

16. Changes to this notice

We may update this notice when our products, providers, processing or legal obligations change. The effective date and version will be shown at the top of the page, and material changes affecting registered users will be communicated through an appropriate channel.

17. Contact

VITAPING LTD Company number 17205180 Registered office: 23 De Morgan Road, London, England, SW6 2RP Email: contact@vitaping.uk Phone and WhatsApp: +44 (0)7346 785 452