Privacy Policy

# 🛡️ 2Zone Therapy – Privacy Policy v5.1

**Effective Date:** 30 November 2025
**Last Updated:** 30 November 2025

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## 1. Who We Are

We are **2Zone Therapy**, based in Israel.

This Privacy Policy explains how we collect, process, and protect your personal information when you use our services or visit our websites, in compliance with the **General Data Protection Regulation (GDPR)** and other applicable privacy laws.

**We own and operate the following sites:**

- [https://www.2ZoneTherapy.co.il](https://www.2ZoneTherapy.co.il)
- [http://www.iBellaBeauty.com](http://www.iBellaBeauty.com)
- [http://www.HealthProtocolToday.com](http://www.HealthProtocolToday.com)
- [http://www.2ZoneTherapy.com](http://www.2ZoneTherapy.com)
- [https://www.HealthGPT.co.il](https://www.HealthGPT.co.il)

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## 2. Information We Collect

We collect information strictly necessary to provide and improve our wellness and AI-driven health-protocol services.

### 2.1 Personal Identification & Security Data
- **Personal Identification:** Name, email, secondary recovery email, IP address, and contact details.
- **Account Security Data:** Login history, failed attempts, device/browser info, and session data.
- **Account Security:** PassPhrases hashed (**Argon2/bcrypt**) for maximum security (as detailed in our Data Security Statement).

### 2.2 Health & Protocol Data
- **Reported Symptoms & Lifestyle:** Intake responses, reported symptoms, emotional indicators, and lifestyle data.
- **AI Interaction Logs:** Conversations with **ERRIC** and **HealthGPT**.
- **Generated Protocols:** Generated health protocols and progress reports.

### 2.3 Data Processing Engine (TEL) - NEW in v5.1
- **Unstructured Input:** We use the internal **TEL (Tracking Engine Logic)** system to parse and categorize unstructured messages you send to ERRIC (e.g., "I ate eggs for breakfast," "My blood pressure was 120/80").
- **Structured Metrics:** TEL converts this unstructured input into structured, time-stamped metrics (e.g., Fasting status, Blood Pressure readings) to automatically build charts and provide personalized advice.

### 2.4 Financial & Optional Data
- **Payment & GC Transactions:** Guidance Credit (GC) purchases, invoices, Stripe or PayPal confirmations. *(We do not store card data.)*
- **Optional Contributions:** Surveys, testimonials, or images voluntarily provided.

We **do not** collect national IDs, government identifiers, or biometric data.

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## 3. Legal Bases for Processing (GDPR)

We process data under the following legal bases:

- **Contractual Necessity:** To deliver HealthGPT, ERRIC, the new TEL tracking features, and protocol generation.
- **Explicit Consent:** For wellness AI interactions and optional communications.
- **Legal Obligation:** For invoicing, tax, and anti-fraud compliance.
- **Legitimate Interests:** For service improvement, analytics, platform security, and the development/refinement of the TEL system (using anonymized data).

Membership plans (Silver, Gold, Platinum) are managed under **contractual necessity**, as defined in our [Terms & Conditions](../terms_conditions_v5.0.md).

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## 4. Your GDPR Rights

You have the right to:

- Access and review your stored data
- Request correction of inaccuracies
- Request **permanent deletion** of personal and health data (“Right to Erasure”)
- Object to non-essential processing or marketing
- Request data portability
- Withdraw consent at any time without affecting past lawful processing

Requests may be made to **privacy@2zonetherapy.com** with identity verification.

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## 5. Data Retention & Archiving

| Data Type | Retention Period | Notes |
|---|---|---|
| Active Account Data | As long as account remains active | Full functionality retained |
| Dormant Account (no login for 60 days) | Archived for 12 months | To allow reactivation |
| GC & Payment Records | 7 years | Required for tax and audit compliance |
| Deleted Accounts | Erased within 30 days of verified deletion request | Irreversible |
| Anonymized Metrics | Indefinite | Used only for aggregated analytics |

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## 6. Data Deletion (Protocols & Logs)

You may request **complete deletion** of your ERRIC logs, protocols, and health data if closing your account, from the **Services** section of your dashboard.

Deleted data is **lost forever** and cannot be recovered under any circumstances.

**Verification Process:**
1. Submit a deletion request in your dashboard.
2. Confirm your **Secret PassPhrase**.
3. Verify via security codes sent to both registered emails.
4. Final confirmation using both tokens and your PassPhrase.

⚠ **Once confirmed:** - All related data (logs, protocols, chat history, **and TEL-generated metrics**) are **permanently erased**.
- This process cannot be reversed.
- A deletion receipt will be emailed for your records.

This triple-verification system protects against accidental or unauthorised deletion.

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## 7. HealthGPT & ERRIC Addendum

- **Purpose:** AI-generated content is for **educational and wellness support** only. It does not diagnose or prescribe medication.
- **Emergency Use:** HealthGPT and ERRIC are **not emergency medical tools**. In urgent cases, contact local emergency services.
- **Data Handling:** AI logs are encrypted, anonymised for analytics, and deleted upon verified request.
- **Reseller / Practitioner Access:** Only allowed with explicit, time-limited client consent.

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## 8. Account Security & PassPhrase Recovery

We use **zero-knowledge encryption**:

- Your **Secret PassPhrase** is encrypted and never stored in plain text.
- We **cannot recover** forgotten passphrases without user verification.
- Recovery requires a verified email and/or WhatsApp code.
- Abuse controls limit resets to **3 attempts per 24 hours**, with temporary lockout after repeated failures.

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## 9. Cookies & Analytics

We use cookies to:

- Maintain secure login sessions
- Analyse site usage and performance
- Remember language and preference settings

If you are a **Free User**, third-party advertising cookies or similar technologies may be used **only with your consent** to deliver and measure ads. Pay-As-You-Go and Members (Silver/Gold/Platinum) do not receive third-party advertising and therefore no third-party advertising cookies are used for those accounts.

You may disable cookies entirely, though some features may be limited.

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## 10. Advertising & Membership

We operate on a simple principle — you choose between **Free with Ads** or **Paid without Ads**.

- **Free Users:** Free accounts are supported by advertising.
You may select which ad categories you prefer to see (for example: Wellness & Supplements, Fitness, Healthy Food, Technology, Lifestyle).
If you do not choose, general non-personalised ads will be shown automatically.
These ads may come from third-party partners, but we **do not sell your personal data**, and all ad delivery is handled under strict data-processing contracts.

- **Withdrawing Ad Consent:** You can withdraw your consent to advertising at any time.
However, if you withdraw consent while on a Free plan, you will need to upgrade to a **Paid Ad-Free Membership** (currently USD $20 per month) to continue using the service.
This ensures we can operate fairly while giving you full control over your experience.

- **Pay-As-You-Go & Members (Silver, Gold, Platinum):** These accounts already operate without third-party advertising.
They may occasionally see promotions for our own products and services only.

- **Consent & Control:** You can review or change your ad preferences or upgrade to the Ad-Free plan at any time in your dashboard under **“Ad Preferences.”** Your advertising choices are stored securely and can be updated or deleted whenever you wish.

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## 11. Children’s Privacy

Our services are **not intended for users under 16**.

We delete any such data upon discovery.

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## 12. Policy Updates

We may update this Privacy Policy periodically.

Significant updates will be announced via email and dashboard notifications.

Continued use after notice implies acceptance of the new version.

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## 13. Contact & Data Protection Officer (DPO)

**2Zone Therapy – Data Protection Officer** Email: **privacy@2zonetherapy.com** Emergency Contact: **erric@healthgpt.co.il**