Privacy Policy

Last updated: [date]

Draft — not yet legally reviewed. This is a working draft describing what the Oriva OS software actually collects and does today. Before relying on it with real clients, have it reviewed by a South African attorney, and fill in the placeholders below — in particular, POPIA requires you to appoint and register an Information Officer.

1. Who this applies to

Oriva OS is white-label software used by independent health practices ("Practices") to manage their own clients. [Your business name] operates the underlying platform. Each Practice is responsible for its own relationship with its clients; this policy describes how the platform itself collects, stores, and processes personal information on behalf of Practices and their clients.

2. Information we collect

Account information: name, email address, password (stored securely by our authentication provider, never in plain text), and whether you're a practitioner or a client.
Health and nutrition information: date of birth, sex, height, weight, activity level, allergies and food exclusions, calorie/macro/micronutrient targets, food and symptom logs, wellness check-ins (sleep, mood, water, steps, and similar), body measurements and progress photos you choose to log, and conversations with the AI Coach.
Practice content: recipes, meal plans, clinical notes, and messages between a practitioner and their client.
Photos and voice recordings used for logging: when you log a meal by photo or voice, the image or audio is sent to our AI providers to identify the food, then discarded — only the resulting food entry (what and how much) is stored, not the original photo or recording.
Device information: if you enable push notifications, we store the technical subscription details your browser provides so we can send them.
Usage and audit data: a tamper-resistant log of access to health records, kept for security and compliance purposes.

3. How we use this information

To provide the service you or your Practice signed up for: generating meal plans and nutrition targets, logging food and wellness data, enabling communication between a practitioner and their client, powering the AI Coach, and keeping your account secure. We do not sell personal information, and we do not use client health data for advertising.

4. Who we share it with

We use the following service providers (subprocessors) to run the platform. Each only receives what it needs to perform its function:

Supabase — database, authentication, and file storage.
Vercel — application hosting.
Anthropic — AI Coach conversations and photo-based food recognition.
OpenAI — voice-to-text transcription for voice logging and note dictation.
FatSecret — food and nutrition database lookups.

Your practitioner and the owner of your Practice can also see the health and logging data relevant to your care. We don't share your information with anyone else without your consent, unless required by law.

5. How long we keep it

We retain your information for as long as your account is active, and for as long afterward as your practitioner's professional body requires health records to be kept. If you request deletion of your account (available from your Account page), we log and act on that request — note that some records may need to be retained rather than immediately erased where a legal or professional retention obligation applies.

6. Your rights

Under South Africa's Protection of Personal Information Act (POPIA), you have the right to access, correct, or request deletion of your personal information, to object to certain processing, and to lodge a complaint with the Information Regulator. You can export a copy of your data or submit a deletion request at any time from your Account page.

7. Security

Access to health data is restricted to your own account, your assigned practitioner, and the owner of your Practice, enforced at the database level. Access to sensitive records is logged. No system is completely secure, and we can't guarantee absolute security of information transmitted over the internet.

8. Children

Oriva OS is not intended for use by children without the involvement and consent of a parent or guardian, and a practitioner should exercise appropriate professional judgment before working with a minor through the platform.

9. Cookies

We use only the minimum cookies needed to keep you signed in. We don't use advertising or third-party tracking cookies.

10. Changes to this policy

If we make material changes to this policy, we'll update the date at the top of this page.

11. Contact us

Questions about this policy or your personal information can be sent to [Information Officer name and contact email]. [Business name and address].