Privacy Policy

Version 1.1, 15 October 2026 · Phoenix Luna Investments Limited

1. Who we are

PEPTIDAL is run by Phoenix Luna Investments Limited, a company registered in England and Wales (company number 14659396), with its registered office at 128 City Road, London, EC1V 2NX, United Kingdom. In this policy, "we", "us" and "our" mean Phoenix Luna Investments Limited.

We are the "controller" of your personal data. That means we decide why and how it is used.

You can contact us at: [email protected]

2. What PEPTIDAL does and does not do with your data

• We keep your account and the things you log so you can see them on any device you sign in on.
• We do not sell your personal data.
• The app has no advertising, ad tracking, analytics or crash-reporting tools.
• We do not send you remote push notifications. Reminders are set up and shown by your own device.
• The app needs an account to work. Nothing can be saved or calculated before you have signed in.
• Our optional AI chat, AL, only runs if you say yes (see section 6).
• The app does not tell you what dose to take and does not sell or link to any medicine or product. See our Terms of Service.

3. The data we collect and why

Account data

• Your email address and a password. We never see your password in plain text.
• A unique account ID that links your entries to you.
• Optionally, a display name.

Why: to create your account, sign you in, and keep your entries private to you. Sign-up confirmation emails are sent as part of the sign-in system.

Health and body information you enter

• Your stack (protocols): the medicines, compounds and supplements you choose to log. For each: the name you enter or pick from the Learn library, an optional brand, its form and route (for example injectable, oral, nasal or topical), the amount and unit you record, how often, the times of day, start and end dates, and any note you add.
• Dose log: each time you log taking, or skipping, an item: the amount and unit, the date and time, the injection site if you pick one, and any note.
• Vials: vial size, water added, concentration, amount left, where it is stored, and dates.
• Body logs: weight, body fat percentage, lean mass, waist measurement and hours of sleep, with a label showing whether each came from you or from Apple Health or Health Connect.
• Health readings (only if you sync from Apple Health or Health Connect): heart rate variability, resting heart rate and VO2 max, with the date, the unit and where each came from. One value is kept for each measure for each day.
• Lab results: the marker names, values, units, any reference range you enter, dates and notes.
• Daily check-ins: your own 1 to 5 ratings for energy, mood, sleep quality, appetite and nausea, and an optional note.
• Sessions: fasting, sauna, cold, red light or other sessions you log, with start and end times, an optional temperature and notes.
• Settings: for example kg or lb, whether notifications are on, and whether you finished the welcome steps.

Why: to run the calculator and reminders, show your history, charts and insights, and let you use the app on more than one device.

This is "special category data" under the UK GDPR because it is data about your health. Section 4 explains the extra protection it gets.

Apple Health and Health Connect (only if you connect them)

If you choose to sync from Apple Health (iPhone) or Health Connect (Android), PEPTIDAL can read your sleep, weight, body fat percentage, lean body mass, heart rate variability, resting heart rate and VO2 max. It only reads. It does not write to or change anything in Apple Health or Health Connect. See section 7.

Subscription information

If you buy PEPTIDAL Premium, Apple or Google takes your payment. We never see your card details. Our subscription provider, RevenueCat, tells us whether your subscription is active. The app gives RevenueCat your PEPTIDAL account ID as your app user ID (not your email address). RevenueCat also receives purchase details, such as which plan you bought and when it renews, and the technical information any app store subscription service needs to work. See section 8.

AL, the optional AI chat

If you agree to use AL, your messages and certain parts of your logged data are sent to an AI provider to produce a reply. Section 6 lists exactly what.

AL records we keep

• Usage record: each time you send AL a message we record your account ID, the time, and how many tokens (units of AI usage) the message and reply used. We use this to apply a daily message limit and to keep costs and abuse under control. We do not store the text of your messages or AL's replies on our servers.
• Reply reports: if you tap the option to report an AL reply, we store your account ID, an ID for that message and the time. We do not store the message text.
• Consent record: we store which version of the AL consent you agreed to and when, whether you have since turned AL off, whether the separate Apple Health or Health Connect switch is on, and a log of those changes with dates.

Health storage consent

We store which version of the "Your health information" consent you accepted when you first set up your account, and when.

Messages you send to us

If you email us for support, we keep the email and our reply so we can help you.

What stays on your device

• Your AL chat history, kept for 7 days and then removed.
• Reminder settings and the reminders themselves, including the optional weekly Letter reminder.
• Your sign-in session.
• A saved copy of the latest weekly Letter and Learn library content so they open quickly.
• If you turn on the optional app lock, your PIN, which is kept in your device's secure storage. Face ID or Touch ID is handled by your phone and we never receive your biometric data.

Clinician summary PDF

The app can build a PDF summary of your own data (your stack with the amounts you recorded, lab results, body measurements, check-in averages and session totals, and your display name if you set one). It is created on your phone. We do not receive it. You choose where to share it, using your phone's share sheet. Once you share it, it is outside our control.

What we do not collect

• Your location, contacts, photos or microphone.
• Advertising IDs or data from any analytics or ad tools.
• Anything from Apple Health or Health Connect that you have not allowed.

Apple and Google also give us aggregated reports and, if you have chosen to share them with developers, crash reports through their own developer consoles.

4. Our lawful bases, and how we get your explicit consent

UK data protection law says we need a "lawful basis" for using personal data. For health data we also need an extra legal condition. This table sets out ours.

How we ask for your explicit consent

• Storing your health information in your account. After you sign in for the first time, a screen called "Your health information" explains what the app will store and asks you to say yes with a tap on "Agree and continue". You cannot use the app without this, because it cannot work without storing what you log. If you tap "No thanks", you are signed out. The wording of this screen was updated on 15 October 2026 (consent version 2) to name heart rate variability, resting heart rate and VO2 max, so people who agreed to the earlier wording are asked again once.
• AL. Before your first chat, a screen tells you exactly what is sent, to whom and why, and has two buttons: "Agree and chat with AL" and "No thanks". Nothing is sent until you tap Agree. The rest of the app works the same if you tap No thanks.
• Health data for AL. A separate switch in Settings, off by default, lets AL see values that came from Apple Health or Health Connect. It is independent from the AL consent above and can only be turned on once AL is on.
• Apple Health and Health Connect. Your phone asks you for permission for each type of data. You can say yes to some and no to others.

You can change your mind at any time (see sections 6, 7 and 11). Withdrawing consent does not affect anything we did before you withdrew. If you change what AL sends in a way that matters, we will ask for your consent again.

5. How we use your data

• To run the app: calculator, stack, reminders, vial tracking, body logs, labs, check-ins, sessions, charts, insights and the clinician summary.
• To let you use the app on more than one device.
• To provide AL if you have agreed to it.
• To confirm your subscription and unlock Premium.
• To keep the app secure and fix problems.
• To reply to your messages.

We do not use your data for advertising or marketing, we do not build profiles to sell, and we do not make decisions about you that have legal or similarly significant effects by automated means.

The weekly Letter and the Learn library

The Learn library and the weekly evidence Letter are the same for every user. No information about you is used to write them or to choose what you see. The app downloads them from our servers in the same way it downloads everything else. If you turn on the optional Letter reminder, it is a local reminder set up on your phone, not a message from us.

6. AL: the optional AI chat and Anthropic

What is sent to Anthropic each time you send AL a message

• Your last 20 chat messages, including the one you just wrote.
• Your active stack items (medicines, compounds and supplements), with the name, amount, unit and frequency you entered.
• Your last 8 logged doses (amount, unit, date and time, and whether skipped).
• Your latest body log: weight, body fat, lean mass, waist and sleep hours.
• Your last 8 lab results (marker name, value, unit and date).
• Apple Health or Health Connect values (sleep, weight, body fat, lean body mass) only if you have turned on the separate switch for that. Otherwise these values are left out.

AL does not receive your heart rate variability, resting heart rate or VO2 max readings. The separate Health data switch for AL does not cover them.

Our instructions to AL travel with these. They contain no personal data.

What is not sent

• Your name, email address or account ID.
• Your password or payment details.
• The notes you write on items, doses, labs, check-ins or sessions.
• Your daily check-ins and sessions, your vials and your injection sites.
• Anything else in your account that is not listed above.

Please be aware that what you type can still identify you (for example, if you write your name or doctor's name). Health information is personal data even without your name attached, and we treat it that way. Please do not put names or contact details into AL.

How it travels and what we keep

Your phone sends the request to a secure function we run on Supabase, and asks for it to run in the London region. The function checks that you are signed in and that you have agreed, reads the data listed above from your account, asks Anthropic for a reply and passes it back to you. The function does not store your messages or AL's replies, and we do not log their text. It only records the usage counts described in section 3. AL chat history is kept on your phone for 7 days.

What Anthropic does with it

We use Anthropic as our "processor", meaning it handles this data for us and on our instructions. Based on Anthropic's own published pages (as read on 11 October 2026):

• Retention: Anthropic says it automatically deletes API inputs and outputs from its backend within 30 days of receipt or generation. Anthropic: how long it stores organisations' data
• Safety flags: if Anthropic's automated safety systems flag a chat, Anthropic says it may keep the inputs and outputs for up to 2 years, and the safety classification scores for up to 7 years.
• Training: Anthropic says that by default it does not use inputs or outputs from its commercial products, which include its API, to train its models. Anthropic: is my data used for model training

These are Anthropic's published terms, not promises we can control, and they can change. We have not agreed any special arrangement with Anthropic that changes them. If we learn of a material change, we will update this page.

Your choice and how to stop

You can turn AL off at any time in Settings. Nothing new is sent after that, and the app deletes your AL chats from your phone. Anthropic may still hold what it already received for up to 30 days (longer if flagged, see above). You can also delete your AL chats from your phone at any time without turning AL off.

AL is not medical advice

AL gives general information only. It does not diagnose, treat, or tell you what dose to take. Always speak to your prescriber or a pharmacist before making any decision about your medicines.

7. Apple Health and Health Connect

• What we read: sleep, weight, body fat percentage, lean body mass, heart rate variability, resting heart rate and VO2 max. Nothing else. Your phone asks permission for each type, and a type you refuse is simply not read.
• Read only: we do not write to or change your Apple Health or Health Connect data.
• When: only when you tap the sync button in Settings. The first time you sync heart rate variability, resting heart rate and VO2 max, the app reads the last 30 days. After that, and for sleep, weight, body fat and lean body mass, it reads the last 7 days each time. It does not read in the background. Nothing is read or stored until you have accepted the health information consent described in section 4.
• Why: to show these values next to your stack timeline and in your charts and insights. Values we read are saved to your account and marked with where they came from (manual, Apple Health or Health Connect). Heart rate variability, resting heart rate and VO2 max are shown in the Recovery section of Insights exactly as recorded. The app does not interpret them or tell you what they mean. A day with several readings is saved as the average for heart rate variability and the latest value for resting heart rate and VO2 max.
• Apple and Android numbers are different: Apple Health records heart rate variability as SDNN, and Health Connect records it as RMSSD. These are two different ways of measuring it, so the numbers are not comparable. PEPTIDAL keeps them separate, labels each one and never mixes or compares them.
• No advertising, no sale, no data mining. We do not use this data for marketing or advertising, or sell it or share it with data brokers.
• AL: sleep, weight, body fat and lean body mass are only shown to AL if you turn on the separate switch described in section 6. Heart rate variability, resting heart rate and VO2 max are never shown to AL.
• Stopping: you can turn off access at any time in the Health app on iPhone, or in Health Connect settings on Android. Values already saved in your PEPTIDAL account stay there until you delete your account, which deletes them. Heart rate variability, resting heart rate and VO2 max are kept until you delete your account and are deleted with it.

8. Who we share data with

We do not sell your data. We share it only with the following, to run the app:

• Supabase (database, sign-in and the secure function): stores your account and logs. Our project is hosted in the UK (London, AWS eu-west-2).
• Anthropic PBC (AL replies): only if you agree. See section 6.
• RevenueCat (subscription status): receives your PEPTIDAL account ID as the app user ID, and purchase details. See section 3.
• Expo (app updates): when the app opens it checks Expo's update service for new versions of the app's code. This involves technical information such as your IP address, app version and device type. It does not include anything you have logged.
• Apple and Google: they distribute the app and process payments under their own privacy policies. They are separate controllers of the data they hold about you.

We may also disclose data if the law requires it or in response to a valid legal request.

9. Sending data outside the UK

Some of the companies we use are based in the United States, so your data can be sent there.

• Anthropic (US): receives the AL information described in section 6 only if you agree. Anthropic's published data processing terms include the standard contractual clauses and the UK International Data Transfer Addendum approved by the ICO.
• Supabase, RevenueCat and Expo: our Supabase data is stored in London. Supabase, RevenueCat and Expo are US-headquartered companies, and data you send through them may be processed in the US. We rely on the transfer safeguards set out in their data processing terms.

Contact us if you would like more information about these safeguards.

10. How long we keep your data

We may keep some data longer where the law requires it.

11. Your rights

Under UK data protection law you have the right to:

• Be informed about how we use your data (this policy).
• Access the data we hold about you.
• Correct data that is wrong. You can edit most things in the app.
• Erase your data, including by deleting your account.
• Restrict how we use your data.
• Take your data with you (portability) in a common format. The app does not yet have a button that exports everything. Email us and we will send you a copy of your data in a common format such as CSV or JSON. The app can also build a clinician summary PDF (see section 3).
• Object to uses based on our legitimate interests.
• Withdraw consent at any time, as easily as you gave it. For AL and for Health data in AL, use Settings. For storing your health information in your account, delete your account (the app cannot work without it).

To use a right, email [email protected]. We will reply within one month. We may need to check who you are first.

If you are unhappy with how we handle your data, please tell us first so we can try to put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

12. How to delete your account

In the app, open Settings (the settings button at the top of the Today and Stack screens), find the Account section, tap Delete account, type DELETE to confirm and tap Permanently delete my account. This deletes your account and the data linked to it, including your stack, doses, vials, body logs, lab results, daily check-ins, sessions, profile and settings, AL usage record, AL reply reports, consent records and sign-in account. It does not cancel a subscription. You need to cancel that in your Apple or Google account (see our Terms of Service).

If you cannot use the app, email [email protected] from your account email address and we will delete it for you. Full steps, what is and is not deleted, and timings are on our account deletion page.

13. Children

PEPTIDAL is for people aged 18 and over. The app does not currently ask you to confirm your age, and we do not knowingly collect data from anyone under 18. If you think a child has made an account, contact us and we will delete it.

14. Security

• Data is encrypted in transit (HTTPS/TLS) between your phone, our servers and Anthropic.
• Our database uses row-level security, so each account can only read its own rows.
• The AL function only works for signed-in users who have agreed to AL.
• You can lock the app with a PIN, and with Face ID or Touch ID where your phone supports it.

No system is perfectly secure. If a breach is likely to put you at risk, we will tell you and the ICO as the law requires.

15. Automated decisions

We do not make decisions about you using automated processing that have legal or similarly significant effects. AL's replies, and the charts and insights in the app, are general or descriptive information that you may read and ignore. They are not decisions about you.

16. Our website

This website is a set of simple pages. It does not use advertising or analytics cookies and does not set cookies. Our hosting provider (Cloudflare) may keep ordinary server logs, such as your IP address and the pages requested.

17. Changes to this policy

We will update this page when our practices change and say what changed below. If a change affects what is sent to AL or Anthropic, we will ask for your consent again before it applies.

Changelog

• Version 1.1, 15 October 2026: added heart rate variability, resting heart rate and VO2 max to what the app can read from Apple Health and Health Connect and store in your account, how they are kept and deleted, that AL does not receive them, and the updated health information consent (version 2).
• Version 1.0, 14 October 2026: first published version.

18. Contact

Phoenix Luna Investments Limited
128 City Road, London, EC1V 2NX, United Kingdom
Email: [email protected]
Website: https://getpeptidal.com