Vagus Health Ltd.
St Johns Innovation Centre, Cowley Rd, Cambridge, CB4 0WS, United Kingdom.
Reg Nr: 11101252
PRIVACY POLICY
1. THIS PRIVACY POLICY
1.1. What this policy covers. This privacy policy sets out when and how we use your personal
information that you or others provide to us. Capitalised terms which are not defined in this
privacy policy have the meanings given to them in our Terms of Service, available at
WWW.VAGUS.CO
2. INFORMATION ABOUT US AND HOW TO CONTACT US
2.1. Who we are. We are Vagus Health Ltd (“we” “us” or “our”), a company registered in
England and Wales. Our company registration number is 11101252 and our registered office I at
St Johns Innovation Centre, Cowley Rd, Cambridge, CB4 0WS, United Kingdom.
2.2. How to contact us. You can contact us by writing to us at our registered office or emailing
us at [email protected].
3. HOW WE MAY USE YOUR PERSONAL INFORMATION
3.1. When you create an Vagus Health Account. To set up an Vagus Health Account with the
Vagus Health application or place an Order for the Product, you will need to provide us with
certain information including your name, email address, address, birth year, birth month and
gender (together the “Required Information”). We will use the Required Information to create
your Vagus Health Account and to provide you with our Products and services.
3.2. To complete the creation of your Vagus Health Account, we may share your personal
information with our subcontractors who are involved in the application process, such as
payment providers, as well as credit reference agencies who we use to assess fraud, credit
and/or security risks.
3.3. We need to process your personal information in this way to enter into and perform our
obligations under our contract with you – i.e. to register your Vagus Health Account and to
provide our products and ongoing services to you. Failure to provide the Required Information
will prevent us from providing you with an Vagus Health Account – which will prevent us
from providing our Products and services to you.
3.4. When you purchase products from our website. When you purchase a Product from our
website, we will use your personal information to complete your purchase. The details we
collect from you will include your name, address, email address, phone number and payment
details.
3.5. To complete your purchase, we may share your personal information with our
subcontractors who are involved in the purchase and delivery process (including the onward
delivery of your ECG recording for analysis), such as payment providers and postal or courier
service providers.
3.6. We need to process your personal information in this way to enter into and perform the
contract for the item you have purchased from us.
Vagus Health Ltd.
St Johns Innovation Centre, Cowley Rd, Cambridge, CB4 0WS, United Kingdom.
Reg Nr: 11101252
3.7. Your ECG, your ECG smartwatch data and our user data bank. During the order process,
we will ask you to consent to: a) receipt of a sample of your ECG for the purposes of producing
your biosignal data; b) the analysis of that ECG as set out in our Terms of Service, available at
https://vagus.co/ToS.pdf, which includes sending the sample to our processing servers in EU,
or the U.S.; c) storage of your ECG recording for future anonymous testing; and d) eventual
destruction of the ECG recording.
3.8. We will only do these things on the basis of your consent. You can withdraw this consent
at any time by revoking your user consent in the Vagus Health smartphone application.
When you have revoked the consent and you have confirmed it in writing by email/letter –
then we will delete user data that which has not or can not be anonymised. However, if you
withdraw that consent then we will no longer be able to provide you with access to your bio
signal data.
3.9. Your bio signal data will then be re-anonymised and form part of our bio signal data
bank. This bank of anonymous information allows us to enhance our Products and bio signal
analysis services. At no time will any third party have access to your personal data or any other
information which may identify you unless we ask your explicit consent to share your
information.
3.10. When you email or phone us. When you contact us by email or phone with general
queries, we may also handle your personal information (your name, contact details and the
other details you provide to us) in order to provide the customer services you have asked us
to. This could be when you ask us to provide more information about our products or services,
or explain how our products work.
3.11. We rely on your consent to handle your personal information in this way. If you do not
provide us with the personal information we request from you for customer services purposes,
we may not be able to fully answer your queries.
3.12. When you have expressed an interest in our products or services. This section applies if
you have opted in to receive marketing communications from us.
3.13. We will handle your personal information (such as your name, email address, postal
address, telephone number and preferences) to provide you with marketing communications
in line with any preferences you have told us about.
3.14. When we send you marketing emails because you have opted-in to receive them, we rely
on your consent to contact you for marketing purposes.
3.15. If you have not opted-in and we send you marketing emails, we do this because of our
legitimate interest to promote the success of our business.
3.16. Every email we send to you for marketing purposes will also contain instructions on how
to unsubscribe from receiving them.
3.17. You are not under any obligation to provide us with your personal data for marketing
purposes.
Vagus Health Ltd.
St Johns Innovation Centre, Cowley Rd, Cambridge, CB4 0WS, United Kingdom.
Reg Nr: 11101252
3.18. You can tell us that you do not want your personal information to be processed in this
way at any time by using the relevant user account settings for approvals, where relevant, by
following the unsubscribe link shown in every marketing communication you receive from us.
3.19. To improve our website, Products and the services that we provide to you and other
customers. In order to enhance and develop the uses of our Products and the information that
we are able to provide to you and our other customers, you may also be asked to provide
additional information including, but not limited to, details of your, ethnicity, personal health
and family health history and other health-related information (“Additional Information”).
Additional Information may be requested during the Vagus Health Account registration, the
order process, throughout the analysis, during the change of information with the automated
smartwatch app bot, smartwatch collected data which you have agreed to share with us, user
service person in the app or after the personal bio signal data has been provided. Failure to
supply any Additional Information may limit the information, analysis and diagnostics that we
are able to provide to you.
3.20. Where we process any Additional Information relating to your health (“Health Data”), we
will only do so on the basis of your consent, which we will obtain at the time that you provide
your Health Data. We will not share your Health Data with any third party in a way that it can
be linked back to you, but we may anonymise it and combine it with other anonymised
information relating to you, in accordance with paragraph 8.7 below).
3.21. Our use of your information in this way means that your experience of our site and our
Products and services will be more tailored to you, and that the information that you see on
our site may differ from someone accessing the same site with a different history or browsing
habits.
3.22. We may also share your aggregated, anonymous data with third party analytics and
search engine providers that assist us in the improvement and optimisation of our site. 3.23.
We will also use your personal information for the purposes of making our site more secure,
and to administer our site and for internal operations, including troubleshooting, data
analysis, testing, research, statistical and survey purposes.
3.24. We process your data for this reason because we have a legitimate interest to provide you
with the best experience we can, and to ensure that our site is kept secure.
3.25. You can prevent us from using your personal information in this way by using the 'do not
track' functionality in your internet browser. If you enable do not track functionality, our site
may be less tailored to your needs and preferences.
3.26. If our business is sold. We will transfer your personal information to a third party: a) if
we sell or buy any business or assets, we will provide your personal information to the seller or
buyer (but only to the extent we need to, and always in accordance with data protection
legislation); or b) if Vagus Health Ltd or the majority of its assets are acquired by somebody
else, in which case the personal information held by us will be transferred to the buyer.
3.27. We process your personal information for this purpose because we have a legitimate
interest to ensure our business can be continued by the buyer. If you object to our use of your
personal information in this way, the relevant seller or buyer of our business may not be able
to provide services to you.
Vagus Health Ltd.
St Johns Innovation Centre, Cowley Rd, Cambridge, CB4 0WS, United Kingdom.
Reg Nr: 11101252
3.28. To comply with a legal obligation. In some circumstances we may also need to share your
personal information if we are under a duty to disclose or share it to comply with a legal
obligation.
3.29. Anonymisation of personal data. All requested information will be either necessary or aid
the delivery and production of the Products and our services. We will anonymise all of the
information that you provide before sharing it with third parties or making it available to our
other customers (see section 16.4 of our Terms of Service, available at www.vagus.co. Data
sent to our processing centre for biosignal analysis may be anonymised and we will never
share your personal data or any other information you provide to us which may identify you.
4. WHAT ABOUT TECHNICAL INFORMATION AND ANALYTICS?
4.1. Information we collect about you. When you visit our site we will automatically collect the
following information: a) technical information, including the Internet protocol (IP) address
used to connect your computer to the internet, your login information, browser type and
version, time zone setting, browser plug-in types and versions, screen resolution, operating
system and platform; and b) information about your visit, including the full Uniform Resource
Locators, clickstream to, through and from our site (including date and time), page response
times, download errors, length of visits to certain pages, page interaction information (such as
scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
4.2. Information we receive from other sources: We are also working closely with third party
advertising networks, analytics providers, hosting providers and search information providers
from whom we may also receive general aggregated anonymous information about you.
4.3. We will combine the information you provide to us with information we collect about
you.
5. COOKIES
5.1. Our site uses cookies to distinguish you from other users of our site. This helps us to
provide you with a good experience when you browse our site and also allows us to improve
our site. By continuing to browse the site, you are agreeing to our use of cookies.
5.2. A cookie is a small file of letters and numbers that we store on your browser or the hard
drive of your computer. We only use (and store) non-essential cookies on your computer's
browser or hard drive if you provide your consent.
5.3. We currently use the following cookies on our site:
5.4. Please note that third parties (including, for example, advertising networks and providers
of external services like web traffic analysis services) may also use cookies, which we do not
have any control over. These cookies are likely to be analytical/performance cookies or
targeting cookies.
5.5. You can block cookies by activating the setting on your browser that allows you to refuse
the setting of all or some cookies. However, if you use your browser settings to block all
cookies (including essential cookies) you may not be able to access all or parts of our site.
5.6. Except for essential cookies, all cookies will expire after 2 years.
Vagus Health Ltd.
St Johns Innovation Centre, Cowley Rd, Cambridge, CB4 0WS, United Kingdom.
Reg Nr: 11101252
6. INFORMATION STORAGE
6.1. Information that you provide to us is mainly stored in EU based cloud servers on our own
secure machines or those of our third party data storage providers in the EEA unless the user
countries and local laws specifically prohibit such storage in the EU.
6.2. Where you are a customer of Vagus Health, we will retain your data for a period of 5 years,
to ensure that we are able to assist you should you have any questions, feedback or issues in
connection with your Vagus Health Account, our Products or if any legal issues arise.
6.3. Where we have used your personal information to contact you for marketing
communications, if you have opted-in: a) we will contact you at least every 2 years to ensure
you are happy to continue receiving electronic communications from us.
6.4. If you tell us that you no longer wish to receive marketing communications from us, we
promise to stop sending them to you.
6.5. Where we have processed your data for any other reason (such as where you have
contacted us with a general support question) we will retain your data for 2 years.
6.6. Otherwise, we will only retain your personal information for as long as necessary to fulfill
the purposes we collected it for, including for the purposes of satisfying any legal, accounting
or legal requirements
6.7. To determine the appropriate retention period for the personal information we hold, we
consider the amount, nature and sensitivity of the personal information, the risk of harm from
unauthorised use or disclosure of your personal information, the reasons why we handle your
personal information and whether we can achieve those purposes through other means, and
the applicable legal requirements.
6.8. When we anonymise your personal data (including User Health Data) so that it can no
longer be associated with you, we may use this information indefinitely without further notice
to you.
6.9 Google: In the case, you permit access to Google login, Google devices, Google Fit, or any
other Google Apps, we may store under your account the following user data from Google:
name, age, gender, weight, height, steps, optical pulse, optical HRV and any other general- or
health-related data which you have specifically approved to share with Vagus Health Ltd.
6.10: The Vagus Health Apps and storage adheres to Google API User Data Services including
the limited use requirements. Google API User Data Services Policy:
https://developers.google.com/terms/api-services-user-data-policy
7. WHAT ARE MY RIGHTS UNDER DATA PROTECTION LAWS?
7.1. You have various rights under the data protection laws, which you can exercise by
contacting us. The easiest way to do this is by email at [email protected].
7.2. Right of access. You are entitled to receive confirmation as to whether your personal
information is being processed by us, as well as various other information relating to our use
of your personal information.
7.3. You also have the right to access your personal information which we are handling.
Vagus Health Ltd.
St Johns Innovation Centre, Cowley Rd, Cambridge, CB4 0WS, United Kingdom.
Reg Nr: 11101252
7.4. Right to rectification. You have the right to require us to rectify any inaccurate personal
information we hold about you. You also have the right to have incomplete personal
information we hold about you completed, by providing a supplementary statement to us.
7.5. Right to restriction. You can restrict our processing of your personal information where: a)
you think we hold inaccurate personal information about you; b) our handling of your
personal information breaks the law, but you do not want us to delete it; c) we no longer need
to process your personal information, but you want us to keep it for legal reasons; or d) where
we are handling your personal information because we have a legitimate interest (as described
in the "How We Use Your Data" section above, and are in the process of objecting to this use
of your personal information.
7.6. Where you exercise your right to restrict us from using your personal information, we will
then only process your personal information when you agree, except for storage purposes and
to handle legal claims.
7.7. Right to data portability. You have the right to receive your personal information in a
structured, standard machine-readable format and to send this to another organisation
controlling your personal information.
7.8. This right only applies to your personal information we are handling because you
consented to us using it or because there is a contract in place between us.
7.9. Right to object. You have the right to object to us handling your personal information
when: a) we are handling your personal information based on our legitimate interests (as
described in the "How do you use my data" section above). If you ask us to stop handling your
personal information in this way, we will stop unless we can show you that we have
compelling grounds as to why our use of your personal information should continue; or b) for
marketing purposes. If you ask us to stop handling your personal information on this basis, we
will stop.
7.10. Right to erasure. You have the right to require us to erase your personal information
which we are handling in the following circumstances: a) where we no longer need to use your
personal information for the reasons we told you we collected it for; b) where we needed your
consent to use your personal information, you have withdrawn your consent and there is no
other lawful way we can continue to use your personal information; c) when you object to our
use of your personal information and we have no compelling reason to carry on handling it; d)
if our handling of your personal information has broken the law; and e) when we must erase
your personal information to comply with a law we are subject to.
7.11. Right to complain. You have the right to lodge a complaint with the Information
Commissioner's Office, the supervisory authority for data protection issues in England and
Wales.
7.12 Vagus Health Ltd is compliant with the EU General Data Protection Regulation (GDPR),
similar types of rules and regulations in the USA and other main user’s groups countries.
8. VAGUS NON FUNGIBLE TOKEN (V-NFT)
8.1 These data ownership rights, rights to delete and acccess rights to the data are amended in
the case that you in writing inform us that you have decided to accept the creation of Vagus
Vagus Health Ltd.
St Johns Innovation Centre, Cowley Rd, Cambridge, CB4 0WS, United Kingdom.
Reg Nr: 11101252
Non Fungible Tokens (V-NFT) from the data collected by you and analysed by Vagus Health
Ltd.
8.2 The terms of the non-fungible token, its data ownership and other terms are described in
www.vagusnft.com
9. WHAT ABOUT WEBSITES WE LINK TO?
8.1. Our site may, from time to time, contain links to and from the websites of our partner
networks and affiliates.
8.2. Our site connects you to different websites. If you follow a link to any of these websites or
use our services, please note that you have left our site and these websites have their own
privacy policies.
8.3. We do not accept any responsibility or liability for these policies or websites. Please check
their policies before you submit any personal information to these websites.
9. WHEN WILL YOU CHANGE YOUR PRIVACY POLICY?
9.1. Any changes we make to our privacy policy in the future will be posted on this page and,
where appropriate, notified to you by e-mail or post.
9.2. Please check back frequently to see any updates or changes to our privacy policy.
10. HOW DO I CONTACT YOU WITH FEEDBACK?
10.1. Questions, comments and requests regarding this privacy policy are welcomed and
should be addressed to info@Vagus.co
10.2. This privacy policy was last updated on 2023/04/05.
