Privacy Policy

At WHOLE, privacy is not simply a legal obligation—it is an extension of our commitment to compassionate, ethical and evidence-based care.

We recognise that the information you share with us may include deeply personal details about your health, lifestyle, emotions, habits, goals and wellbeing. We understand that trust must be earned, not assumed.

For this reason, every feature within WHOLE is designed according to the principles of Privacy by Design, Ethical AI, Human Dignity, and Responsible Digital Health.

Our philosophy is built upon seven commitments:

• Transparency before complexity — We explain what information we collect and why.
• Choice before assumption — You remain in control of your personal information wherever reasonably possible.
• Privacy before profit — WHOLE does not sell your personal health information.
• Security before convenience — We implement appropriate safeguards to protect your information.
• Evidence before opinion — Health recommendations are grounded in scientific evidence rather than commercial interests.
• Compassion before judgement — Your information is used to support your health journey, never to shame or manipulate you.
• Continuous improvement — As technology, healthcare and privacy laws evolve, WHOLE will continue to strengthen its privacy practices.

WHOLE is a digital Lifestyle Medicine and Preventative Health platform that provides evidence-based health education, digital wellbeing tools, AI-assisted health guidance, educational consultations and personalised health journeys.

For any privacy-related enquiries, please contact:

Depending on how you use WHOLE, we may collect the following categories of information.

Personal Information

• Full name
• Email address
• Telephone number
• Date of birth
• Country of residence
• Preferred language
• Profile photograph (optional)

Health Information

Where voluntarily provided by you:

• Height
• Weight
• Lifestyle goals
• Medical history
• Current health conditions
• Medications
• Allergies
• Dietary preferences
• Women's health information
• Menstrual cycle information
• Pregnancy information
• Menopause information
• Exercise habits
• Sleep information
• Mood tracking
• Stress levels
• Laboratory values
• Biomarkers
• Uploaded medical reports
• Health assessments
• WHOLE Journey progress

Technical Information

We automatically collect:

• Device type
• Browser type
• Operating system
• IP address
• Time zone
• Session information
• Device identifiers
• Crash reports
• Log files
• Cookies
• Analytics information

Payment Information

Payments are processed through authorised third-party payment providers.

WHOLE does not store complete credit card or banking information.

AI Conversations

Conversations with Eira may be securely processed to:

• respond to your requests;
• improve your personalised experience;
• maintain continuity across conversations where applicable;
• improve platform quality;
• monitor safety.

AI conversations should never be considered confidential communication with a healthcare professional.

Your information may be used to:

• create and manage your account;
• personalise your experience;
• provide WHOLE services;
• generate personalised recommendations;
• deliver educational content;
• improve WHOLE Academy;
• personalise health journeys;
• provide AI responses through Eira;
• process consultations;
• send notifications;
• manage subscriptions;
• process payments;
• improve platform functionality;
• conduct analytics;
• detect fraud;
• maintain platform security;
• comply with legal obligations.

Where applicable, WHOLE processes information on one or more of the following grounds:

• your consent;
• performance of our agreement with you;
• compliance with legal obligations;
• protection of legitimate interests;
• protection of vital interests where permitted by law.

Some information processed by WHOLE may constitute sensitive personal information.

We only process health information:

• with your consent;
• to provide requested services;
• to personalise your experience;
• to support educational recommendations;
• to improve your health journeys.

WHOLE does not sell health information.

Some of the information you choose to share with WHOLE may be classified as sensitive personal information under applicable privacy legislation.

This may include, but is not limited to:

• Physical health conditions
• Mental wellbeing information
• Neurodivergent conditions
• Lifestyle habits
• Women's health information
• Pregnancy information
• Fertility information
• Menstrual health
• Menopause information
• Laboratory results
• Biomarkers
• Medications
• Disabilities
• Health assessments
• Consultation notes

WHOLE processes this information solely for the purposes of providing the services you request, improving your personalised experience, supporting your health journey and complying with applicable legal obligations.

Sensitive information is never processed for unrelated marketing purposes without your explicit consent.

WHOLE is designed to adapt to every individual rather than presenting the same experience to every user.

Based on the information you choose to provide, WHOLE may personalise:

• your dashboard;
• recommended health journeys;
• educational content;
• reminders;
• health insights;
• AI conversations;
• notifications;
• Academy recommendations;
• wellbeing challenges;
• progress reports.

Our goal is to reduce information overload by presenting information that is relevant to your individual circumstances.

Personalisation is intended to improve your experience—not to manipulate your behaviour.

WHOLE uses artificial intelligence to assist users.

AI may process information you voluntarily provide to generate personalised educational responses.

AI recommendations are intended for informational and educational purposes only.

Artificial intelligence does not replace healthcare professionals.

Eira has been designed according to human-centred AI principles.

This means Eira is intended to:

• educate rather than diagnose;
• support rather than replace healthcare professionals;
• encourage rather than manipulate;
• explain rather than intimidate;
• promote informed decision-making rather than dependence.

Artificial intelligence should never become a substitute for human judgement, compassion or professional healthcare.

WHOLE is committed to responsible AI.

Accordingly, we strive to ensure that artificial intelligence operating within WHOLE:

• respects human dignity;
• promotes fairness;
• avoids unnecessary bias where reasonably possible;
• maintains appropriate transparency;
• supports evidence-based recommendations;
• protects user privacy;
• continuously improves through responsible development practices.

Although we work to improve AI accuracy, artificial intelligence remains an evolving technology and should always be used responsibly.

WHOLE uses artificial intelligence to support education, personalisation and wellbeing guidance. However, WHOLE does not use artificial intelligence or automated systems to make decisions that, without meaningful human oversight, produce legal effects or similarly significant consequences for users.

Recommendations generated by WHOLE and Eira are intended to support informed decision-making, encourage healthier lifestyle choices and personalise your experience. They are not intended to determine your eligibility for healthcare, insurance, employment, financial products, legal rights, medical treatment or any other decision that could significantly affect your life.

Where WHOLE provides personalised recommendations, these are generated using the information you choose to provide and are intended solely to assist you in understanding and managing your health. Final decisions regarding your health, medical care and wellbeing should always be made by you in consultation with appropriately qualified healthcare professionals.

WHOLE does not rely solely on automated processing to make decisions that have legal or similarly significant effects on individuals.

WHOLE is committed to preserving the independence of healthcare decision-making.

Neither WHOLE nor Eira will recommend treatments, medications, healthcare providers or health products based on commercial influence, sponsorship or advertising. Where products or services are referenced, recommendations are based on educational relevance and available evidence rather than commercial arrangements.

WHOLE's primary responsibility is to support informed, ethical and evidence-based health decision-making in the best interests of its users.

WHOLE does not sell your personal information.

Information may be shared only where necessary with:

• payment processors;
• cloud hosting providers;
• email delivery providers;
• analytics providers;
• authorised consultation providers;
• regulatory authorities where legally required.

Every reasonable effort is made to ensure third parties maintain appropriate security standards.

Some service providers used by WHOLE may process information outside South Africa.

Where this occurs, WHOLE takes reasonable steps to ensure appropriate safeguards are implemented.

WHOLE retains information only for as long as reasonably necessary to:

• provide services;
• comply with legal obligations;
• resolve disputes;
• maintain records;
• protect legal rights.

Information no longer required will be securely deleted or anonymised.

• Consultation records are retained in accordance with applicable legal and professional obligations.
• Billing records are retained for tax, accounting and regulatory purposes.
• AI conversation history may be retained to improve continuity of your experience unless deleted or otherwise restricted by the user.
• Users may request deletion of eligible information at any time, subject to legal obligations requiring retention.

WHOLE uses appropriate technical and organisational safeguards including:

• encrypted communication;
• secure authentication;
• role-based access control;
• secure cloud infrastructure;
• monitoring for unauthorised access;
• secure payment processing.

Although we strive to protect your information, no electronic system can be guaranteed to be completely secure.

WHOLE uses cookies and similar technologies to:

• maintain login sessions;
• improve performance;
• remember preferences;
• analyse usage;
• improve security.

Users may manage cookie preferences through their browser settings.

Subject to applicable law, you may:

• access your information;
• correct inaccurate information;
• update your information;
• request deletion;
• request restriction of processing;
• withdraw consent where applicable;
• object to certain processing activities;
• request a copy of your information.

WHOLE will respond within a reasonable period and in accordance with applicable law.

At WHOLE, we believe every individual should have meaningful control over their digital health information.

Where applicable, you may:

• access your information;
• correct inaccuracies;
• update your profile;
• download available information;
• request deletion;
• withdraw consent;
• object to certain processing activities;
• manage notification preferences;
• manage AI personalisation settings;
• request clarification regarding automated recommendations.

WHOLE is intended for individuals legally permitted to use digital health services in their jurisdiction.

Parents and guardians are responsible for supervising any use by minors.

Users may opt in to receive:

• newsletters;
• educational updates;
• WHOLE announcements;
• promotional communications.

Marketing preferences may be changed at any time within account settings or by using the unsubscribe link.

WHOLE continuously improves its educational resources, artificial intelligence systems and digital health services.

Where anonymous or de-identified information is used to improve platform performance, research or product development, every reasonable effort is made to ensure that individuals cannot be identified.

Any future research involving identifiable information will only occur where appropriate consent has been obtained or where otherwise permitted by law.

If WHOLE becomes aware of a data breach that is likely to affect users, we will investigate promptly and notify affected individuals and relevant authorities where required by applicable law.

WHOLE may update this Privacy Policy from time to time.

Where significant changes are made, users will be notified through the platform or via email where appropriate.

Continued use of WHOLE after changes become effective constitutes acceptance of the updated Privacy Policy.

Questions regarding this Privacy Policy may be directed to:

At WHOLE, privacy is more than legal compliance—it is a commitment to trust.

We believe your health information belongs to you. We are committed to protecting your information, respecting your choices, being transparent about how we use your data, and continuously improving our privacy practices as technology, science and the law evolve.

Your trust is one of our greatest responsibilities, and we are committed to earning it every day.