Terms of Service

ZIVALA LTD

Terms of Service

Last Updated: 21st July 2026

IMPORTANT: These Terms of Service constitute a legally binding agreement between you and Zivala Ltd. Please read them carefully before using the Platform. Zivala is not a healthcare provider and does not offer medical advice, diagnosis, or treatment. If you are experiencing a medical emergency, stop using this Platform and contact the emergency services immediately.

1  Definitions

In these Terms, the following terms have the meanings set out below:

Term	Meaning
"Zivala / we / us / our"	Zivala Ltd, a company incorporated in England and Wales with company number 17115921, whose registered office is at 131 Finsbury Pavement, London, England, EC2A 1NT. ICO Registration Number: ZC144836.
"Platform"	The Zivala mobile application and all associated services, including the Explore, Care, Track, Publish, Community, Direct Messages, Follow, Activity, and Profile features described in these Terms.
"User / you / your"	Any individual who accesses or uses the Platform.
"Content"	All data, text, audio, images, files, stories, journey updates, community posts, messages, and other material submitted to or generated on the Platform by a User.
"Health Data"	Any Content relating to a User's physical or mental health, medical conditions, treatments, tracking logs, consultations, care records, or health outcomes.
"Care Data"	Clinical documents, test results, referral letters, discharge summaries, conditions and diagnoses, medications and supplements, care timeline entries, safety notes, consultation recordings, and appointment records you enter into the Care section of the Platform.
"Track Data"	Data entered into the Track section of the Platform, including: daily check-in, pain log, GI/bowel/urine log, energy and fatigue log, pelvic floor log, menstrual cycle log, mood and cognition log, sleep log, skin log, food and triggers log, medications, supplements, goals, and wearable data.
"Story"	A structured personal health journey narrative created and published by a User on the Platform through the Publish feature, which may include AI-assisted creation support, journey updates, and structured journey information.
"AI Features"	Artificial intelligence tools within the Platform, including: Zivala AI (conversational health AI), Care AI Report, Track AI Report, story generation assistance, story drafting assistance, and appointment preparation support.
"My Insights"	A feature within the Track section that analyses a User's own tracking data to identify patterns, trends, and correlations.
"Subscription"	A paid tier of access to the Platform as described in Section 23.
"App Store"	The Apple App Store or Google Play Store through which the Platform is distributed.
"Health Data Policy"	Zivala's Health Data Policy, a supplementary document describing how Health Data is collected, processed, stored, and deleted, is available within the Platform and on the Zivala website.
"Privacy Policy"	Zivala's Privacy Policy, which governs the processing of your personal data, is available within the Platform and on the Zivala website.
"Community Guidelines"	The Community Guidelines published by Zivala and available within the Platform, setting out standards for User behaviour and Content.

2  Acceptance of Terms

By accessing, downloading, or using the Platform in any way, you confirm that you have read, understood, and agree to be bound by these Terms, our Privacy Policy, Health Data Policy, and Community Guidelines. If you do not agree to these Terms in full, you must immediately cease using the Platform.

These Terms apply to all Users. Where we introduce specialised user categories in the future, separate terms may apply to those categories and will be published at the relevant time.

3  Eligibility and Account Responsibilities

3.1  Eligibility

To use the Platform you must: be at least 18 years of age; have the legal capacity to enter into binding agreements; and not be prohibited from using the Platform under applicable law.

3.2  Account Accuracy

You must provide accurate, complete, and current information when creating your account. You agree to promptly update your account information if it changes. Providing false or misleading information, including false Health Data, is a breach of these Terms and may result in account suspension or termination.

3.3  Account Security

You are responsible for maintaining the security of your account. You must not share your account with any other person. Notify us immediately at security@zivala.health if you suspect unauthorised access to your account. Zivala is not liable for losses arising from unauthorised access caused by your failure to maintain adequate account security.

4  Privacy by Default

Your Health Data is private by default. No one can see your personal health records, tracking data, AI conversations, or clinical documents unless you deliberately choose to publish or share that specific information.

Private by default — never visible to others unless you choose to share:

• All Care Data — clinical documents, conditions, medications, supplements, appointments, consultations, safety notes, and care timeline
• All Track Data — daily check-in, pain log, GI/bowel/urine log, energy and fatigue log, pelvic floor log, menstrual cycle log, mood and cognition log, sleep log, skin log, food and triggers log
• All Zivala AI conversations — Zivala AI chat history, Care AI Reports, Track AI Reports
• Consultation recordings and transcripts
• Wearable and device data
• My Insights
• Goals and appointment preparation notes

User-controlled sharing — you choose what to share, with whom, and when:

• Published health Stories and journey updates — you set the visibility (Public, Followers-only, or Private)
• Community posts and comments — visible within the relevant community space or group
• Profile information — you control your display name, biography, country, and profile visibility
• Health conditions on your profile — off by default; you may choose to display them
• Follow activity — visible on your profile if your profile is set to Public

Private Health Data is never made public without a deliberate action by you. The default privacy setting for every Health Data category is maximum protection.

5  Nature of the Service

Zivala is a personal health intelligence and lived-experience platform that helps people organise their health information, track symptoms and outcomes, understand their care, use AI-powered health insights, publish structured health journeys, and learn from the experiences of others.

The Platform consists of the following core features:

• Explore — story discovery, search, filters, and story detail pages
• Care — clinical records management, conditions, medications, supplements, consultations, appointments, safety notes, care timeline, and Care AI Reports
• Track — daily check-in, specialist tracking logs, goals, wearables, My Insights, and Track AI Reports
• Zivala AI — conversational health AI, health summaries, pattern analysis, appointment preparation, and record understanding
• Publish — story creation, story drafting, story updates, story analytics, and My Stories
• Community — posts, groups, events, comments, and reactions
• Direct Messages — private messaging between Users
• Follow — following other Users and managing follow requests
• Activity — reviewing recent social and platform interactions
• Profile and Settings — managing account, privacy, and notification preferences

What Zivala is not:

• A healthcare provider, medical practice, or regulated health service
• A medical device or clinical decision support system
• A telemedicine or remote consultation platform
• A substitute for professional medical advice, diagnosis, or treatment
• A clinician discovery or clinician booking marketplace
• An appointment booking platform — Zivala does not facilitate the booking of healthcare appointments with third-party clinicians
• An emergency service or crisis support platform

Use of the Platform does not create a doctor-patient relationship, a therapeutic relationship, or any professional duty of care between Zivala and any User.

6  Licence to Use the App

6.1  Licence Grant

We grant you a personal, non-exclusive, non-transferable licence to download and use the Platform on any mobile device that you own or control, on the following terms: (a) the licence is for your personal, non-business use only; (b) it begins when you download the app and continues until it is terminated in accordance with these Terms; and (c) it covers the app together with any content, materials, services and support resources accessible through it, and any updates we provide (unless an update comes with separate terms, in which case we will give you an opportunity to review and accept them). 

6.2  Licence Restrictions

You do not own the app or any of its content. You must not, and must not allow anyone else to: (i) modify, adapt or interfere with the app or its code, or insert any code into it; (ii) reverse engineer, decompile or attempt to avoid, circumvent or manipulate any security feature of the app, except to the extent the law does not allow this restriction; or (iii) copy the app, pretend it is your own, or make it available for others to download or use. If you sell or give away any device on which the app is installed, you must remove the app from that device first.

6.3  App Updates

We may update the Platform from time to time, including to fix bugs, improve performance, enhance functionality, address a security issue, or reflect a change in the law. We may also change or remove features, but if we do, we will ensure the Platform still meets the description of it that was provided to you when you downloaded it. Depending on your device and its settings, updates may download automatically or you may need to install them yourself. We strongly recommend that you install all updates as soon as they become available. If you do not keep the Platform updated to the latest version we make available, it may not work properly (or at all), or you may be exposed to security vulnerabilities.

7  Medical and Safety Disclaimer

WARNING: All Content on the Platform — including Stories, AI outputs, health reports, community posts, My Insights, and direct messages — is provided for informational and experiential purposes only. It must never be used as the basis for any medical decision. Always consult a qualified, registered healthcare professional for diagnosis, treatment, or any health-related decision.

Individual health experiences described on the Platform reflect personal journeys and are not representative of typical outcomes. Outcomes described by other Users may not apply to your circumstances. Zivala does not review, validate, or endorse the medical accuracy of any Content.

7.1  Do Not Delay Care

Do not use the Platform as a reason to delay, avoid, or substitute for medical care. If you have a health concern, seek professional medical advice promptly.

7.2  Emergency Warning

EMERGENCY: Zivala is not an emergency service. If you or anyone around you is experiencing a medical emergency — stop using this Platform and call your local emergency services immediately. UK: 999 | EU/International: 112 | US: 911. Do not use this Platform in an emergency.

7.3  Mental Health and Crisis Support

If you are experiencing a mental health crisis, suicidal thoughts, or emotional distress:

• Samaritans (UK): 116 123 (free, 24/7) — samaritans.org
• Crisis Text Line (UK): Text SHOUT to 85258
• International crisis resources: iasp.info/resources/Crisis_Centres
• Your GP, local mental health crisis team, or nearest emergency department

Zivala is not a crisis support service. If you are in immediate danger, call 999 or your local emergency number.

8  User Content and Licence

8.1  Your Responsibility

You are solely responsible for all Content you submit to the Platform. You represent and warrant that: (a) you own or have the right to submit such Content; (b) your Content does not infringe any third-party rights; (c) your Content is accurate to the best of your knowledge; and (d) your Content does not violate applicable law or these Terms or the Community Guidelines.

8.2  Licence Grant

By submitting Content to the Platform, you grant Zivala a worldwide, non-exclusive, royalty-free licence to use, store, display, reproduce, and distribute your Content solely for the purpose of: (a) operating and providing the Platform to you and other Users; (b) enabling story discovery, search, filtering, and recommendations within the Explore section; (c) generating aggregated, non-identifying analytics; and (d) content safety review and moderation. This licence extends no further than what is necessary for these purposes.

8.3  Restrictions on Licence

The licence in Section 8.2 does not give Zivala the right to: sell your Content; share your identifiable Content with third parties for commercial purposes; or use your Content for purposes not described in Section 8.2 or our Privacy Policy.

8.4  AI Training

Your Health Data, Stories, Content, personal data, uploaded files, tracking data, and AI conversation content will never be used to train AI or machine learning models — by Zivala or any third-party AI provider — without your separate, explicit, and informed consent given at the relevant time. Our AI service provider(s) is contractually prohibited from using your data to train its models. Anonymised and aggregated data may be used to improve Platform features as described in our Privacy Policy.

8.5  Licence Duration

The licence in Section 8.2 terminates when you delete the relevant Content or your account, subject to any retention obligations described in our Privacy Policy, the 30-day backup retention period described in Section 9.5, and applicable law.

8.6  Consultation Recordings

If you record a consultation using the Platform: (a) you are solely responsible for informing and obtaining consent from any clinician and all other persons present before recording begins; (b) AI-generated transcripts and summaries are automated outputs that may contain errors — they do not constitute a clinical record or substitute for professional clinical documentation; (c) audio files are permanently deleted within 30 days of successful transcription or immediately on your request, whichever is earlier; (d) you must not share recordings or transcripts of another person's consultation without their explicit consent; and (e) you must only upload recordings to the Platform that you are lawfully entitled to process and share.

8.7 Feedback

If you send us feedback, suggestions, ideas or reports about the Platform (“Feedback”), you grant us a perpetual, irrevocable, worldwide, royalty-free and sub-licensable licence to use that Feedback for any purpose, including to develop and improve the Platform, without any obligation to compensate or credit you. You confirm that any Feedback you give is your own and does not infringe anyone else's rights. We are not obliged to act on or implement any Feedback.

9  Health Data, Consent, and Your Data Protection Rights

9.1  Special Category Data

Health Data constitutes special category personal data under Article 9 of the UK General Data Protection Regulation (UK GDPR) and Article 9 of the EU GDPR. By submitting Health Data to the Platform, you provide your explicit consent to Zivala processing such data for the purposes described in our Privacy Policy and Health Data Policy. Zivala maintains an Appropriate Policy Document (APD) as required by DPA 2018 Schedule 1, Part 4.

9.2  Withdrawal of Consent

You may withdraw your consent to the processing of your Health Data at any time by: deleting specific Content within the Platform; requesting account deletion through Platform Settings; managing per-feature consents through Settings > Privacy; or contacting us at security@zivala.health. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. Some processing — such as security logging and responding to lawful requests — does not depend on consent.

9.3  Your Rights Under UK GDPR and EU GDPR

To exercise any right, contact us at security@zivala.health. We will respond within one calendar month.

Right	Description
Right of Access (Art. 15)	Request a copy of the personal data we hold about you.
Right to Rectification (Art. 16)	Request correction of inaccurate or incomplete data.
Right to Erasure (Art. 17)	Request deletion of your personal data, subject to legal retention obligations.
Right to Restriction (Art. 18)	Request that we restrict processing of your data in certain circumstances.
Right to Data Portability (Art. 20)	Receive your data in a structured, machine-readable format where processing is based on consent or contract.
Right to Object (Art. 21)	Object to processing based on legitimate interests, including personalisation.
Automated Decision-Making (Art. 22)	No Platform feature makes automated decisions producing legal or similarly significant effects on you. AI outputs are informational only. Contact security@zivala.health to contest AI output or request human review.
Right to Withdraw Consent (Art. 7(3))	Withdraw your consent at any time as described in Section 9.2. Withdrawal does not affect prior lawful processing.

You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk (UK users) or with your EU member state supervisory authority (EU/EEA users — see our Privacy Policy).

9.4  Data Retention

We retain your personal data for as long as your account is active and for the periods described in our Privacy Policy Section 13. Published Stories are retained until you delete them, subject to the 30-day soft-deletion period in Section 9.5. Track Data, Care Data, and AI Data are retained for the duration of your account plus 30 days following account deletion.

9.5  Soft Deletion and Backup Retention

When you delete Content or your account, the content is immediately removed from public visibility and access within the Platform. Copies may be retained in encrypted backups for up to 30 days before permanent deletion. After this period, content is not recoverable. This applies to all Content including Stories, Track Data, Care Data, and AI conversations.

9.6  EU, EEA, and US Users

EU/EEA users: the EU GDPR applies to your personal data. You have the right to contact Zivala's EU Representative and to complain to the supervisory authority in your EU member state. See Privacy Policy Section 2 for details.

US users: please refer to Privacy Policy Section 3 for Zivala's HIPAA position, FTC Health Breach Notification Rule obligations, and your rights under applicable US state consumer health data laws including the Washington State My Health My Data Act, Nevada SB 370, Connecticut PA 23-16, and the Colorado Consumer Health Data Privacy Act.

10  Stories, Community Content, and Lived Experience

10.1  Story Publishing

The Publish feature allows you to create and share personal health Stories. Stories are structured personal health journey narratives and may include: your conditions and symptoms; treatments you have received; medications; outcomes and experiences; journey status; costs and wait times you choose to disclose; reflections; advice to others; journey updates; and supporting files. Story publishing is a deliberate act — all Health Data remains private until you choose to publish.

Before publishing a Story, you will be presented with a confirmation screen explaining: (a) that the story will be publicly visible according to the visibility setting you choose; (b) how to control or remove your Story after publication; and (c) the re-identification risk described in Section 10.3. By completing that confirmation step, you consent to publication on those terms.

10.2  Story Visibility

When publishing a Story, you choose: Public (visible to all Zivala Users and, where indexed, internet users), Followers-only (visible to Users who follow you), or Private (visible to you only). You may change the visibility of your Story after publication. Your display name and any profile information you have made public will be visible alongside published Stories.

10.3  Re-identification Risk

Even where a Story has been pseudonymised or does not use your full name, there remains a residual risk that you could be re-identified when health information is combined with other publicly available data, particularly where your Story describes rare conditions, unusual treatment timelines, specific named providers, or detailed personal narratives. You should carefully consider what personal information to include in publicly visible Stories. Once published, other Users, visitors, and third parties may have accessed, saved, or shared your Story. Removing published content does not guarantee removal of copies already viewed or saved by others.

10.4  Story Drafts

Draft Stories are private and visible to you only. Unsaved AI-assisted story drafts are discarded at the end of your session. You may save, continue, and revise drafts before publishing. Drafts are retained in your account until you delete them or your account.

10.5  Story Deletion and Removal

When you delete a Story, it is immediately removed from public visibility. Soft-deletion applies: encrypted copies may be retained in backups for up to 30 days before permanent deletion. After permanent deletion, your Story is not recoverable. Aggregated, non-identifying analytics derived from your Story may be retained beyond deletion to support Platform analytics.

10.6  Story Discovery and Explore

Published Stories and their structured metadata — including conditions, symptoms, treatments, journey status, and topics you associate with your Story — may be used by the Explore feature to make your Story discoverable to Users with similar health experiences. Story discovery in Explore does not constitute medical advice and should not be treated as such.

10.7  Aggregated Data

Aggregated and anonymised data derived from Platform Content may be used by Zivala to analyse health journey patterns, Story engagement, treatment experiences, and community trends to improve the Platform. Such analysis is performed only on data meeting our anonymisation standard as described in our Privacy Policy. We do not share aggregated Health Data with third parties for commercial research without your explicit consent. We do not sell personal data.

11  Appointments — Personal Health Record Management

The Appointments feature within the Care section is a personal health record management tool. It allows you to:

• Log upcoming and past healthcare appointments for your own records
• Add appointment details including provider name (for your own reference), date, type of appointment, and notes
• Add appointment preparation notes and questions
• Review past appointments as part of your care timeline
• Use the Zivala AI appointment preparation feature to prepare for upcoming appointments

Zivala does not provide appointment booking services. Zivala is not an appointment booking marketplace. Appointments logged on the Platform are personal records only — Zivala does not transmit appointment requests to any healthcare provider, does not confirm appointments with any healthcare provider, and is not a party to any arrangement for healthcare services between you and any clinician or healthcare organisation.

All appointment details you enter are private by default and visible to you only. They are not shared with any clinician, healthcare organisation, or third party unless you deliberately choose to share them.

12  Zivala AI Features

12.1  Nature of AI Outputs

AI DISCLAIMER: AI-generated outputs are not a substitute for professional medical advice. AI outputs may be inaccurate, incomplete, or inappropriate for your individual circumstances. Zivala AI is not a clinician, cannot diagnose conditions, and cannot recommend treatments. You must not rely on AI outputs for any clinical or health decision. Always consult a qualified, registered healthcare professional.

AI EMERGENCY WARNING: Do not use any AI feature on this Platform in a medical emergency. If you are experiencing a medical emergency, stop using this Platform and call 999 (UK), 112 (EU), or 911 (US) immediately.

12.2  Zivala AI — Conversational Health AI

Zivala AI is a conversational health AI that answers questions about your personal health information using a retrieval-augmented generation (RAG) approach. It retrieves relevant sections of your personal health record to generate personalised insights. Zivala AI does not access your entire health record for every query — retrieval is limited to information relevant to your specific question. A question about your sleep patterns does not retrieve your pelvic floor log or medication history unless directly relevant.

12.3  Care AI Report

The Care AI Report primarily uses information stored within the Care section. Where you have enabled the relevant feature and provided consent, it may also use relevant Track data, medication and supplement information, goals and wearable summaries to support appointment preparation and provide appropriate recent context.

12.4  Track AI Report

The Track AI Report generates a personalised report based on your Track section data — check-ins, specialist tracking logs, and wearable data (if connected and consented). It uses Track section data only. Track AI Reports are private and visible to you only.

12.5  Story Generation and Drafting Assistance

Story generation: you provide a brief description and the AI generates a draft Story for you to edit before publishing. Story drafting: AI offers writing suggestions as you write your Story. Both features use only the text you input in the story editor — your broader health record is not automatically accessed for story drafting purposes. Unsaved AI-assisted drafts are discarded at the end of your session.

12.6  Appointment Preparation Support

The appointment preparation feature uses your appointment details, conditions, medications, and recent tracking data to suggest questions, summarise recent health events, and organise information for an upcoming healthcare appointment. Output is private and accessible to you only. Appointment preparation outputs do not constitute medical advice.

12.7  AI and Your Data

When you use AI Features, relevant Health Data is processed by our AI service provider solely to generate your requested response. Your data is not used to train AI models. Our AI service provider operates under a Zero Data Retention arrangement — content sent to the AI is not retained beyond immediate processing. UK transfers to our AI service provider are safeguarded in accordance with applicable data protection laws. All data sent to the AI is encrypted in transit (TLS). See our Privacy Policy Section 6 for full details.

12.8  Data Minimisation in AI Retrieval

Zivala AI does not automatically process your entire health record for every request. Retrieval is both query-scoped (limited to data relevant to your specific question) and feature-scoped (each AI feature uses only the data category relevant to that feature). Your most sensitive Health Data — consultation recordings, safety notes, pelvic floor log — is not transmitted to the AI provider unless you specifically ask about that data or it is part of a feature that uses it.

12.9  Human Review

AI outputs are not reviewed by a human before being presented to you. Treat all AI-generated content as a starting point for your own informed assessment, not as authoritative information.

12.10  AI Limitations

AI outputs may be inaccurate, incomplete, outdated, or misleading, and may sometimes generate responses that appear plausible but are incorrect (commonly known as ‘hallucinations’). AI output reflects the information in your health record — if that information is incomplete, output will reflect those limitations. AI Features are not regulated medical devices and do not have regulatory approval as clinical decision support tools. No significant automated decisions affecting your rights or circumstances are made by AI Features.

12.11 AI Generation and Redaction of Content

Where you choose to create a Story, our AI generates or prepares a draft from the information and records you provide, and summarises, redacts or removes details (including identifying information such as clinician and hospital names) before the Story is published, subject to your review. You acknowledge that: (a) this generation and redaction is automated, may contain errors or omissions, and may change the meaning, accuracy or completeness of your Content; (b) you remain responsible for reviewing and approving any AI-generated or AI-redacted Content before it is published or shared, and the published Content remains your own; (c) where the AI redacts or removes identifying or sensitive information, we do not warrant that all such information has been detected or removed; and (d) to the fullest extent permitted by law, we are not liable for any loss or damage arising from the AI generating, redacting, modifying or failing to modify your Content, except for loss caused by our failure to use reasonable care and skill or any liability that cannot be excluded or limited by law.

13  Tracking Features, My Insights, and Wearables

13.1  Track Section

The Track section allows you to record and monitor your health over time. It includes the following specialist tracking logs, all of which constitute special category Health Data under Article 9 UK GDPR / EU GDPR:

• Daily Check-In — daily health state, mood, and energy level
• Pain Log — pain location, intensity, character, duration, and associated factors
• GI, Bowel, and Urine Log — gastrointestinal and urinary symptoms
• Energy and Fatigue Log — energy levels and fatigue patterns
• Pelvic Floor Log — pelvic floor symptoms, exercises, and outcomes
• Menstrual Cycle Log — cycle dates, flow, and associated symptoms
• Mood and Cognition Log — mood ratings, cognitive function, emotional wellbeing, and mental health data
• Sleep Log — sleep duration, quality, and disturbances
• Skin Log — skin condition observations, flares, and treatments
• Food and Triggers Log — dietary intake, food triggers, and reactions
• Medications — current and past medications logged in the Track section
• Supplements — supplement records
• Goals — personal health and wellness goals

All Track Data is private by default. It is visible to you only and is never shared with other Users or third parties without your explicit consent.

13.2  My Insights

My Insights provides personalised health insights derived solely from your own tracking data. Specifically:

• My Insights analyses your own data only — it does not compare you to other Zivala Users or to any external benchmark
• It identifies patterns, trends, and correlations in your tracking history using check-in data, specialist tracking logs, and wearable data (if connected and consented)
• My Insights remains entirely private — it is never visible to other Users and is not used for any processing outside your personal health record
• My Insights does not make clinical recommendations; patterns identified are informational only and do not constitute medical or diagnostic guidance

My Insights data may be used to support Track AI Report generation when you use that feature (with your explicit consent). It is not otherwise shared with or transmitted to any third party.

13.3  Wearables and External Health Data

With your explicit consent, the Platform can connect to Apple HealthKit or Google Health Connect to import health metrics including step count, heart rate, heart rate variability, sleep data, blood oxygen levels, and other biometric data. Wearable data is treated as special category Health Data. You may disconnect a wearable integration at any time through Platform Settings, which stops further data import. Previously imported data is subject to the retention and deletion provisions in Section 9.

14  Story Analytics and Performance Data

When you publish a Story, Zivala may provide analytics to help you understand how your Story or health journey is performing. Depending on the features currently available within the Platform, analytics may include:

• Likes, bookmarks and saves
• Comment engagement
• Engagement trends over time
• Journey-level analytics where applicable

We may introduce additional analytics features in future, including metrics relating to reach, discovery, referrals or engagement, which will be described within the Platform when available.

Story analytics are presented in aggregated form. Individual readers are never identified to Story authors.

Analytics are aggregated. Individual readers are not identified to Story authors by name, username, or any other identifier. A Story author will know how many views their Story received but will not know which specific Users viewed it.

15  Trust and Content Integrity Framework

15.1  Overview

Zivala is committed to the safety, authenticity, and integrity of content published on the Platform. This section describes the framework Zivala uses to maintain content quality and how this framework may develop.

15.2  Story Review Process

When you submit a Story for publication, it passes through the following steps:

a)  Privacy and safety review:

An automated review scans for content that could identify third parties without consent, sensitive information you may not have intended to make public, content violating our Community Guidelines, and potentially harmful health claims.

b)  AI-assisted content review:

AI assists in identifying content that may require additional review, including content that may constitute health misinformation or pose a safety concern to Users.

c)  Human moderation:

Where automated review identifies potential issues, content may be held for human moderation before publication. You will be notified if your Story is held for review.

15.3  Story Authenticity

Stories on Zivala represent the lived experiences of individual Users. Zivala does not independently verify the medical accuracy of personal health Stories. By submitting a Story, you represent that it describes your own genuine health experience and does not knowingly contain false or misleading health information.

15.4  Data Processed During Content Review

The content of your Stories is processed during the review steps above. This review processing does not alter the storage of your Story content, its lawful basis, or your rights in respect of that content. Our lawful basis for this review processing is legitimate interests in platform safety and integrity.

15.5  Content Trust Indicators

Zivala may, from time to time, introduce voluntary systems that allow Story authors to indicate the basis and context of their health Stories — for example, whether a Story is supported by clinical documentation or reflects ongoing lived experience. Any such systems will: be entirely voluntary; be disclosed in these Terms and in product guidance before they take effect; and not affect the fundamental principle that all Zivala content represents personal lived experience and does not constitute medical advice.

No content trust indicator system currently exists as an active feature. This section contains forward-compatible language only. If and when a content trust system is introduced, these Terms and the Privacy Policy will be updated to describe it specifically before it becomes active.

15.6  Community Moderation and Reporting

Published content may be reported by community members using the in-Platform reporting function. We promptly act on reports in accordance with our Community Guidelines. See also Section 18.

15.7  Platform Integrity

We reserve the right to remove, restrict, or flag Content that: violates our Community Guidelines; constitutes health misinformation creating a risk of harm to Users; or is published in a manner inconsistent with the Platform's purpose. Where content is removed, we will inform the affected User except where doing so would compromise a safety investigation.

16  Community Content, Stories, and Medical Advice

IMPORTANT: Content shared on the Zivala Platform — including published health Stories, journey updates, community posts, comments, and direct messages — represents the personal lived experiences and individual opinions of other Users. It does not constitute medical or clinical advice.

• Community content does not create a clinician-patient relationship between any User and any other User.
• Stories, community posts, and discussions should not replace professional medical guidance. Always consult a qualified healthcare professional about your health, diagnosis, treatment, medication, or care decisions.
• Individual experiences described in Stories may not be representative of outcomes for other people, including those with similar conditions, diagnoses, or treatment histories.
• Comments and discussions reflect personal opinions and should not be treated as clinical, diagnostic, or treatment guidance.
• Direct messages are personal communications and do not constitute professional health advice.
• AI-generated content is informational only. See Section 12.

Zivala does not endorse, verify, or accept responsibility for the clinical accuracy of user-generated content published on the Platform. The content review processes described in Section 15 are focused on safety and community standards, not on verification or accuracy.

If you are in a medical emergency, contact emergency services immediately. Do not rely on Platform content in an emergency.

17  Community and Messaging Features

17.1  Community Features

The Platform includes community spaces where Users can connect around shared health experiences. Community features include: posts and discussions; condition-specific and interest-based groups; comments and reactions; saving posts; community events and RSVPs; and community moderation. Content in public community groups is visible to all Zivala Users. Content in private groups is visible to group members only.

17.2  Direct Messages

Direct messages are private conversations between Users. Messages are visible only to you, the recipient and Zivala’s administrators where reasonably necessary for the purposes of moderation, safeguarding, security, legal compliance or investigating suspected misuse of the Platform. Message data is handled in accordance with our Privacy Policy.

17.3  Prohibited Conduct

When using any community or messaging features, you must not:

• Share unlawful, harmful, defamatory, or materially misleading content
• Harass, threaten, bully, stalk, or abuse other Users
• Impersonate any person, including other Users or Zivala staff
• Attempt to identify, de-anonymise, or expose the identity of any User who has chosen to share content anonymously or pseudonymously
• Share content that infringes third-party intellectual property rights
• Solicit personal, financial, or sensitive information from other Users
• Use community features to advertise, promote, or sell products or services without Zivala's prior written consent
• Share or distribute malware, viruses, harmful code, phishing links, or spam
• Use automated tools, bots, scrapers, crawlers, or scripts to collect data from the Platform without Zivala's prior written consent
• Encourage, glorify, or provide instructions for self-harm, suicide, disordered eating, dangerous self-medication, or other harmful behaviours
• Provide medical advice, diagnosis, or treatment recommendations that you are not qualified or registered to give
• Coordinate inauthentic behaviour, including fake reviews, fake engagement, or manipulation of Platform metrics

17.4  Blocking and Safety

You may block any User to prevent them from sending you messages or interacting with your content. Blocked Users are listed in Settings. You may also report any User or content using the in-Platform reporting tools.

17.5 User-Created Communities and Community Roles

Where the Platform allows it, you may create community groups and apply to take on community roles (such as advocate or moderator). If you create a community or take on such a role, you must run it in line with these Terms and our Community Guidelines, including by moderating content fairly and acting promptly on reports. Holding a community role does not make you our employee, agent or partner. We may grant, vary, suspend or withdraw any community or role at our discretion, acting reasonably - for example, where it is not being run in line with these Terms or our Community Guidelines, or where we need to do so to meet our legal obligations. Delegating moderation to Users does not reduce our own responsibilities for content on the Platform.

18  Content Moderation

Zivala reserves the right to monitor, review, edit, or remove any Content at its sole discretion. We may take action including removing Content, issuing warnings, restricting features, suspending accounts, or terminating accounts where we determine that Content violates these Terms, our Community Guidelines, or applicable law. Users may report Content using the reporting tools available on the Platform. Zivala will review reports in good faith but cannot guarantee a specific outcome or timeframe.

19  Public Content and Publication Consent

Before publishing a Story, community post, or other public content that contains personal or health information, you will be presented with a confirmation step within the Platform explaining: (a) the visibility setting of the content; (b) how other Users and (for Public stories) internet users may access it; (c) the re-identification risk described in Section 10.3; and (d) how to control or remove your Content after publication. By completing that confirmation step, you consent to publication on those terms.

You should carefully consider what personal and health information to include in publicly visible Content. Once Content is published, other Users, visitors, and third parties may have accessed, saved, or shared it. Removing published Content does not guarantee removal of copies already viewed or saved by others.

20  Third-Party Services

The Platform relies on, and connects to, third-party services to provide its functionality, including cloud hosting, email delivery, AI processing (under zero data retention terms), push notifications, subscription management, and analytics, billing, the App Stores through which the Platform is distributed, and external integrations you choose to connect (including Apple HealthKit, Google Health Connect and other wearable or heath-data services). These services and integrations are provided by third-parties and are not controlled by us, and operate under their own terms and privacy practices. Where they process personal data on our behalf, they do so under data processing agreements with Zivala. A list of key data processors is available in our Privacy Policy. Zivala is not responsible for the performance, availability, security, accuracy, completeness or continued operation of any third-party service, integration, connected device or the data it provides. A third party may change, suspend, withdraw or stop supporting its service or integration at any time, and an integration may stop working, for reasons outside our control. We may also add, change, suspend or remove any integration or third-party feature ourselves, for example where a provider changes its service or terms. Where an integration you use is materially affected, we will let you know if it is reasonably practicable to do so. We are not liable for any loss arising from a third-party service or integration being unavailable, discontinued, changed, withdrawn or inaccurate, or from the acts, omissions or data practices of third-party providers beyond what is contractually agreed with you. Nothing in this section limits our responsibility for loss caused by our own failure to use reasonable care and skill, or any liability that cannot be excluded or limited by law.

21  Intellectual Property

All intellectual property rights in the Platform — including its design, code, branding, data architecture, materials, content (other than your or other users’ content), AI tools, processing pipelines, and aggregated datasets — belong to Zivala Ltd or its licensors. You retain ownership of Content you submit, subject to the licence granted in Section 8.2.

22  Technical Requirements

To use the Platform, your device must meet the following minimum requirements shown on the App Store listing for the Platform. If your device does not meet these requirements, some or all of the Platform may not function correctly.

23  Subscriptions, Billing, and App Store Terms

23.1  Subscription Tiers

Zivala offers both free and paid subscription tiers. Current pricing and features for each tier are displayed within the Platform at the point of purchase.

23.2  Billing and Renewal

Subscriptions renew automatically at the end of each billing period (monthly or annual, as selected) unless you cancel before the renewal date. By subscribing, you authorise Zivala (or, for App Store purchases, Apple or Google) to charge the applicable subscription fee to your payment method on each renewal date. You will receive a reminder before each renewal where required by applicable law.

23.3  Failed Payments

If a payment fails, we may: retry the charge; temporarily suspend or downgrade your access to the paid tier; and notify you by email. Where payment cannot be collected after reasonable attempts, your subscription may be cancelled and your account reverted to the free tier.

23.4  Cancellation

You may cancel your subscription at any time through: Platform Settings; the App Store subscription management page; or by contacting support@zivala.health. Cancellation takes effect at the end of your current billing period. You will retain access to paid features until that date.

23.5  Free Trials and early-access features

Where a free trial is offered, the trial duration and post-trial charge will be clearly described at sign-up. If you do not cancel before the trial ends, you will be charged the applicable subscription fee. You may cancel during the trial period at any time without charge.

We may make features available on a beta, trial, preview or early-access basis (Beta Features), and we will identify them as such. Beta Features are provided "as is" and "as available", may be incomplete or unstable, and may be changed or withdrawn at any time. You should not rely on a Beta Feature, and you use it at your own discretion. To the fullest extent permitted by law, Beta Features are excluded from any availability or performance commitments, and we are not responsible for any loss arising from your use of them. Nothing in this clause limits our liability for death or personal injury caused by our negligence, for fraud, or for any liability that cannot be excluded or limited by law, including your rights under the Consumer Rights Act 2015.

23.6  Refunds

Subscription fees are non-refundable except: (a) where required by applicable consumer protection law, including the Consumer Rights Act 2015 where it applies to digital content and/or subscriptions; (b) where Zivala has made a material billing error; or (c) where Zivala agrees to a refund at its sole discretion. For App Store purchases, refund requests must be submitted through the relevant App Store, not through Zivala directly, and are subject to the App Store's own refund policies.

23.7  Price Changes

Zivala may change subscription pricing at any time. For existing subscribers, price changes take effect at the next renewal date after at least 30 days' written notice. If you do not agree to a price change, you may cancel before the new price takes effect.

23.8  VAT and Taxes

Prices displayed to UK consumers are inclusive of applicable VAT. For users in other jurisdictions, prices are displayed as indicated at the point of purchase and may be subject to local taxes, which will be shown before payment is confirmed.

23.9  App Store Subscriptions

If you subscribe through the Apple App Store or Google Play Store: payment will be charged to your App Store account at confirmation of purchase and will auto-renew unless cancelled at least 24 hours (Apple) or one day (Google) before the end of the current period. Manage and cancel through your App Store account settings. For App Store purchases, Apple or Google is your billing party. In the event of a conflict between these Terms and App Store terms on billing matters, App Store terms take precedence.

23.10  Account on Cancellation or Downgrade

On cancellation of your subscription, your account will revert to the free tier at the end of your current billing period. Your Content and account data will be retained unless you also request account deletion.

24  Prohibited Territories and Persons

By using the Platform you confirm that you are not located in, or a national or resident of, any country that is subject to a UK, EU or US government embargo or that has been designated by those governments as supporting terrorism, and that you are not on any UK, EU or US government list of prohibited or restricted parties. You must not use the Platform if any of these apply to you.

25  Platform Availability

Zivala does not guarantee that the Platform will be available on an uninterrupted, error-free, or secure basis. We may modify, suspend, or discontinue any part of the Platform at any time for maintenance, security, legal, or commercial reasons. Where possible, we will provide advance notice of planned outages. If we permanently discontinue the Platform or any major feature, we will provide reasonable advance notice and a reasonable opportunity to export your data.

26  Failures of Networks or Hardware

The Platform depends on a number of things working properly, many of which are outside our control, including your internet connection, your device and the App Store. Although we will do everything we reasonably can to resolve problems, we are not responsible to you if you cannot use all or part of the Platform because of a poor internet connection, a fault in your device, an App Store failure, or anything else that it would not be reasonable to expect us to control.

27  Data Security

Zivala implements industry-standard technical and organisational security measures to protect personal data, including: encryption at rest and in transit (TLS); role-based access controls; secure session management; regular security reviews; and incident response procedures. No method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach affecting your rights and freedoms, we will notify you and the ICO in accordance with our obligations under UK GDPR (within 72 hours of becoming aware). If you become aware of any unauthorised access to your account, contact security@zivala.health immediately.

28  No Warranties

To the fullest extent permitted by applicable law, the Platform is provided 'as is' and 'as available' without warranty of any kind, whether express, implied, or statutory. Zivala makes no warranty that: the Platform will meet your requirements; content is accurate or complete; the Platform will be available at any particular time; or AI outputs will be accurate, complete, or appropriate for your individual circumstances. Nothing in these Terms excludes warranties that cannot be excluded under applicable law, including the Consumer Rights Act 2015.

29  Limitation of Liability

If we fail to comply with these Terms or are negligent, we are responsible for loss or damage you suffer that is a foreseeable result of our breach or of our failure to use reasonable care and skill. Loss or damage is foreseeable if, at the time you accepted these Terms, either it was obvious that it would happen or both you and we knew it might happen. We are not responsible for any loss or damage that was not foreseeable, that was not caused by our breach or negligence, or that arises from your use of the Platform for any business purpose, as the Platform is provided for personal use only.

If the Platform damages your device or any software installed on it as a result of our failure to use reasonable care and skill, please let us know. If we can, we will repair the damage. If that is not possible, we will compensate you. We may ask you for information (including photographs) about what has happened so that we can understand the nature of the problem.

Nothing in these Terms limits Zivala's liability for: death or personal injury caused by our negligence; fraud or fraudulent misrepresentation; breach of terms implied by the Consumer Rights Act 2015 or equivalent consumer protection legislation in your jurisdiction that cannot be excluded or limited; or any other liability that cannot be limited by applicable law.

30  Termination

Zivala may suspend or terminate your access to the Platform on reasonable notice, except where your breach or  conduct is serious (for example, where you are causing harm or a risk of harm to other users, to us, or to the Platform), in which case we may suspend or terminate your access immediately and, where we are able, restrict your access remotely, telling you as soon as we reasonably can afterwards. We may take such action where we reasonably believe you have: (a) breached these Terms or our Community Guidelines; (b) engaged in fraudulent or unlawful activity; (c) submitted false or misleading Content; or (d) created a legal risk or safety risk for Zivala or other Users.

You may delete your account at any time through Platform Settings. On account deletion, your personal data will be handled in accordance with our Privacy Policy and applicable data retention obligations. Content you have published will be removed from public visibility following the soft-deletion period described in Section 9.5.

31  Changes to These Terms

We may update these Terms from time to time to reflect changes in the Platform or its features, to address a security or safety issue, to reflect changes in our business arrangements, or to comply with a change in law, regulation or regulatory guidance. Where changes are material, we will provide at least 30 days' notice via email or prominent in-Platform notice before changes take effect. Your continued use of the Platform after the effective date of updated Terms constitutes acceptance of those changes. If you do not agree to updated Terms, you must stop using the Platform and may request account deletion. Previous versions of these Terms are available on request by contacting security@zivala.health.

32  Transferring These Terms

We may transfer our rights and obligations under these Terms to another organisation, for example if our business or the Platform is sold or transferred. We will tell you in advance if this happens and will make sure the transfer does not reduce your rights under these Terms. You may not transfer your rights or obligations under these Terms to anyone else without our prior written consent.

33  Online Safety

33.1 Our online safety duties

The Platform includes user-to-user features, and Zivala is a regulated user-to-user service under the Online Safety Act 2023. We comply with our duties under that Act, which are overseen by Ofcom, and we have regard to your rights to freedom of expression and to privacy when we design and apply our safety measures.

33.2 Protecting you from illegal content

We operate systems and processes designed to stop you encountering illegal content, to minimise how long any illegal content is present, and to take it down quickly once we become aware of it. In particular, we carry out and regularly review a risk assessment of the illegal content that could appear on the Platform; set rules in these Terms and our Community Guidelines that prohibit illegal content; use automated and AI-assisted moderation tools (including OpenAI's moderation models) to help detect and assess such content when it is submitted and published; operate an in-Platform reporting system so you and others can flag content to us; review reports and act on them promptly, removing or restricting content that breaches these Terms; and, where the law requires, report relevant content to the appropriate authorities.

33.3 Use of automated tools

We use automated and AI-assisted technology to help us detect, assess and remove illegal content. Our automated tools, including OpenAI's moderation models, scan Content such as Stories, community posts, comments and direct messages when it is submitted and when it is published, screening for illegal content and other material that breaches these Terms or our Community Guidelines. Content that is flagged is held or routed to our team for human review before a final decision is taken. Where automated tools remove or restrict content, you can ask for a person to review that decision using our complaints process.

33.4 Reporting content

You can report illegal content to us at any time using the in-Platform reporting tool or by emailing [support@zivala.health]. Tell us where the content is and why you are reporting it. We review all reports and act on them promptly.

33.5 Complaints and challenging our decisions

You can complain, and ask us to review a decision, if: we take down or restrict your Content; we suspend, ban or restrict your account; you think we have failed to act on illegal content you reported; or an age check has wrongly assessed your age. Our complaints process is free and easy to use. Email us at support@zivala.health, and we aim to respond within 7 days.

33.6 Your right to bring a claim

If we take down or restrict your Content, or suspend or ban you, in breach of these Terms, you have the right to bring a claim against us for breach of contract.

33.7 Keeping children off the Platform

The Platform is for adults only. We carry out a children's access assessment and use age-assurance measures designed to prevent under-18s from accessing the Platform.

34  App Store Terms

These Terms are between you and Zivala only. They are not between you and Apple Inc. or Google LLC, each referred to as an “App Store Provider”.

You acknowledge that:

1. Zivala, and not the App Store Provider, is responsible for the Platform and its content.
2. The App Store Provider is not required to provide maintenance or support services for the Platform.
3. If the Platform does not meet an applicable warranty, you may notify the relevant App Store Provider. Where the app was purchased, the Provider may refund the purchase price.
   
   To the maximum extent permitted by law, the App Store Provider has no other warranty obligations. Zivala remains responsible for any other claims, losses, liabilities, damages, costs or expenses resulting from a failure to meet a warranty.
4. The App Store Provider is not responsible for handling claims relating to the Platform, including product liability, regulatory or intellectual property claims.
5. If a third party claims that the Platform infringes their intellectual property rights, Zivala, and not the App Store Provider, is responsible for investigating and resolving the claim.
6. You must comply with all applicable third-party terms, including the relevant App Store rules, when using the Platform.
7. Where you download the Platform from Apple’s App Store, you may use it only on an Apple-branded product that you own or control and in accordance with the Usage Rules in the Apple Media Services Terms and Conditions. This includes any permitted sharing with members of your family or household.

Zivala Ltd’s name, registered address and contact details for questions, complaints or claims relating to the Platform are provided in the Contact section of these Terms.

Apple Inc. and its subsidiaries are third-party beneficiaries of these Terms and may enforce them against you.

Except for the App Store Providers described above, no person who is not a party to these Terms may enforce them under the Contracts (Rights of Third Parties) Act 1999.

35 Notices

We may give you notices and other important communications about the Platform or these Terms by any of the following methods: a notification or message within the Platform; an email to the address linked to your account; or any other contact details you have provided to us. It is your responsibility to keep your contact details accurate and up to date, and to check for notifications within the Platform. A notice is treated as received when we send the email or post it within the Platform, or otherwise at the time it would ordinarily have reached you. If you need to contact us, please use the relevant details in the Contact section of these Terms.

36  Governing Law and Disputes

These Terms are governed by the law of England and Wales. If you are a consumer, you will continue to benefit from any mandatory protections of the law of the country in which you live, and nothing in these Terms affects your rights to rely on those mandatory protections. Legal proceedings may be brought in the courts of England and Wales; however, if you live in another part of the United Kingdom you may also bring proceedings in the courts of the part of the UK in which you live, and we will only bring proceedings against you in the courts of the part of the UK in which you live.

Before initiating formal proceedings, we encourage you to contact us to seek resolution. We aim to respond to all complaints within 14 days. If we cannot resolve your complaint informally, you may refer the matter to the ICO (for data protection issues) or to your local consumer protection authority.

Contact

Company	Zivala Ltd
Data Protection Officer	Zeeshanali
Data Protection / GDPR / Rights Requests	security@zivala.health
Legal Enquiries	security@zivala.health
Security Incidents	security@zivala.health
General Support	support@zivala.health
Registered Address	Zivala Ltd, 131 Finsbury Pavement, London, England, EC2A 1NT
ICO Registration	ZC144836