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7. Privacy Policy

Last updated: June 06, 2025

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.

We use your Personal Data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions​

Interpretation​

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions​

For the purposes of this Privacy Policy:

  • Account means a unique account created for you to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Application refers to VitaliT, the software program provided by the Company.
  • Company (referred to as either "the Company," "We," "Us," or "Our" in this Agreement) refers to Colakin, Level 3/480 Collins St, 3000, Melbourne.
  • Country refers to: Victoria, Australia
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Application.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Data Collection​

Types of Data Collected​

Personal Data​

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City

Sensitive Information​

We may also collect sensitive information, such as:

  • Race
  • Religion

Device Information​

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to:

  • Device ID
  • Precise location
  • Other diagnostic data

Usage Data​

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

Information from Third-Party Social Media Services​

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

  • Google

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Information Collected while Using the Application​

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

  • Information regarding your location

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Additional Types of Data Collected (New Features)​

In addition to previously listed data types, we now collect the following due to new feature rollouts:

AI Chatbot Interactions​

  • We collect chat messages and responses you exchange with the AI chatbot to improve conversational services and provide personalized support.

Community Engagement​

  • Posts, comments, and interactions in public and private groups are stored and may be visible to other users.
  • Any personal information you voluntarily disclose in community spaces may be collected and publicly displayed.
  • If you submit images for "Before & After" galleries, we collect and store those images along with metadata such as timestamps and descriptions.
  • Images are only shared publicly with your explicit consent.

Challenges​

  • Participation data (e.g., challenge sign-up, progress, completion status) is collected to help manage and personalize your challenge experience.
  • We collect subscription plan data (type, start/end date, transaction status) to provide appropriate access to premium or standard features.

Payment Information​

  • We use third-party payment processors. We collect only limited payment details, such as your plan type, billing cycle, and status.
  • Pricing for the plans is as follows:
Plan TypePrice in AUDPrice in USDBilling Cycle
MonthlyAUD $39USD $24.99Every 30 days
YearlyAUD $209USD $133.93Annually

Note: All payment details such as card or account info are handled securely by our payment providers. We do not store this data directly.

Data Use​

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
  • To facilitate community and social interactions through groups, forums, and challenge participation.
  • To generate personalized experiences via AI chatbot and progress tracking.
  • To display visual transformation stories through submitted before/after images, with consent.
  • To differentiate access to features and services based on your subscription type (free vs paid).
  • To manage subscriptions and process payments securely via third-party services.

Data Sharing​

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures, and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You, and view Your profile.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.
  • With community participants: If you post in public groups or communities, your content may be visible to all users.
  • With AI system: AI interactions may be shared internally for training and quality improvements but are not publicly disclosed.
  • With consent: Before & After images or any personal success stories will only be publicly displayed with your explicit permission.

User Rights​

You have the right to:

  • Access your Personal Data.

  • Correct any inaccurate Personal Data.

  • Delete your Personal Data.

  • Restrict the processing of your Personal Data.

  • Object to the processing of your Personal Data.

  • Portability of your Personal Data.

  • You may request removal of any shared images, comments, or community posts.

  • You can opt out of AI chatbot data usage for improvement purposes by contacting us.

To exercise these rights, please contact us at ramesh@colakin.com

Data Security​

We implement industry-standard measures to safeguard your data against unauthorized access, disclosure, or destruction. These measures include:

  • Encryption of sensitive data.
  • Secure storage of data.
  • Access controls to limit access to authorized personnel.
  • Regular security audits to identify and address vulnerabilities.

Retention of Your Personal Data​

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data​

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Children's Privacy​

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Here's the additional content to append to your Privacy Policy under a new section (e.g., ## Feature Integrations and Attributions), covering the Chat, Community, and 5 Cognitive Games:

Feature Integrations and Attributions​

AI Chat Integration (AnythingLLM)​

To provide intelligent and personalized conversational experiences, we have integrated an AI-powered chat system into the VitaliT application using AnythingLLM (GitHub Link).

  • Hosting Model: This tool is fully self-hosted and runs securely on our local infrastructure. It is not a third-party cloud-based system, ensuring data remains under our direct control.

  • Security and Privacy:

    • Chat interactions are not shared externally and remain encrypted on our servers.
    • AnythingLLM ensures conversation tokens are sandboxed within secure memory.
    • API calls to Large Language Models (LLMs) are routed through internal firewalls.

  • User Data Handling:

    • All messages are stored temporarily to enhance response quality and user experience.
    • Personally identifiable information is not logged or retained for training purposes.
    • Access to chat logs is restricted to authorized personnel for debugging or feature enhancement only.

  • Reference: AnythingLLM Documentation

This integration aligns with our commitment to offering secure, local-first AI solutions with transparent user data handling policies.

Community Platform Integration (Discourse)​

VitaliT features a full-fledged Community Forum built on top of the open-source platform Discourse (GitHub Link).

  • Hosting Model: The community is hosted locally and not deployed to a third-party cloud provider.

  • Security Compliance:

    • Discourse enforces strong authentication protocols, including optional 2FA.
    • All data exchanged is encrypted using HTTPS/SSL.
    • Activity logs, moderation tools, and admin access are secured through permissioned roles.

  • Community Participation:

    • Posts, comments, likes, and shares are retained for enhancing engagement but are only visible to users who have consented to be part of the community.
    • All community interactions comply with GDPR and similar data protection regulations.

  • Core Features:

    • Rich text posting and threaded conversations
    • Notification and alert system
    • Member badges, trust levels, and moderation controls
    • Built-in anti-spam filters and moderation queues

More info: Discourse Features

This platform fosters peer-to-peer support and knowledge-sharing in a secure and transparent environment.

Game Integrations for Cognitive Enhancement​

The following five games have been integrated into the VitaliT app as part of our scientifically backed cognitive health program. All games are MIT-licensed and have been modified for accessibility and senior usability.

Game 1: Master Mind​

  • Developer: hush2
  • Source Code: GitHub
  • License: MIT
  • Adaptation Summary: Redesigned UI and transitions for better usability.
  • Demo: Video Link
  • Cognitive Focus: Logical reasoning, executive function, adaptive strategy.

Game 2: 2048​

  • Developer: Anuran Barman
  • Source Code: GitHub
  • License: MIT
  • Adaptation Summary: Interface modernized, accessibility improved.
  • Demo: Video Link
  • Cognitive Focus: Working memory, spatial logic, numerical fluency.

Game 3: Word Wizard (Original: Hangman)​

  • Developer: Reza Tavasoli
  • Source Code: GitHub
  • License: MIT
  • Adaptation Summary: Language-focused gameplay reimagined for clarity and complexity.
  • Demo: Video Link
  • Cognitive Focus: Verbal fluency, memory recall, language comprehension.

Game 4: Flip Card (Original: Memory Match)​

  • Developer: alupa
  • Source Code: GitHub
  • License: MIT
  • Adaptation Summary: Visual assets enhanced, card themes senior-friendly.
  • Demo: Video Link
  • Cognitive Focus: Visual memory, spatial recognition, pattern analysis.

Game 5: Block Drop (Original: Tetris)​

  • Developer: Priyanshu Dutta
  • Source Code: GitHub
  • License: MIT
  • Adaptation Summary: Re-skinned interface and gameplay speed adjusted for motor planning.
  • Demo: Video Link
  • Cognitive Focus: Spatial reasoning, reaction time, visual-motor coordination.

Changes to this Privacy Policy​

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us​

If you have any questions about this Privacy Policy, You can contact us: