Privacy Policy 

Effective Date: 26 August 2024

1. Introduction

Welcome to Glucoly (“App”), a health management application designed to assist users in monitoring and managing their diabetes. This Privacy Policy describes how we collect, use, and protect your personal information when you use our App, website, and associated services (collectively referred to as “Services”). By using Glucoly, you agree to the collection and use of your information in accordance with this policy.

2. Information We Collect

  • Personal Information: When you register or use the App, we may collect personal details such as your name, email address, gender, and date of birth. This information is necessary to create and manage your account and provide personalized services.

  • Payment Information: If you subscribe to paid services, we may collect payment information such as your credit card details or payment processor information. This data is processed securely through our third-party payment processors and is not stored on our servers.

  • Health Information: The App allows you to track various health metrics, including but not limited to blood glucose levels, insulin usage, medication details, weight, and blood pressure. This information is considered sensitive and is essential for providing the App’s core functionalities.

  • Device and Usage Information: We collect data related to your device, such as IP address, browser type, operating system, and usage patterns within the App. This helps us understand how users interact with the App and improve our services.

  • Cookies and Tracking Technologies: We may use cookies and similar technologies to track your activity on our App and store certain information. Cookies are used to enhance your experience by remembering your preferences and visits. You can manage your cookie preferences through your browser settings or opt-out of certain types of cookies.

3. How We Collect Information

  • Directly from You: Through registration, account settings, and when you input data into the App.
  • Automatically: Through the use of cookies and tracking technologies when you interact with the App.
  • From Third Parties: Such as payment processors, analytics providers, and advertising networks.

4. How We Use Your Information

  • To Provide and Improve the Services: Your personal and health information is used to deliver the features of the App, such as tracking your health metrics, generating personalized reports, and improving the user experience.
  • To Manage Subscriptions: If you purchase a subscription, we use your payment information to process transactions.
  • To Personalize Your Experience: We use your data to tailor the App’s features to your needs and preferences.
  • To Communicate with You: We may use your contact details to send important notifications, updates, and reminders regarding your use of the App. You can opt-out of these communications at any time.
  • To Ensure Legal Compliance: Your information may be used to comply with legal obligations, resolve disputes, and enforce our agreements.

5. Legal Bases for Processing Your Information (GDPR Compliance)

We rely on the following legal bases to process your personal data:

  • Consent: By using our App, you consent to the collection and use of your personal and health information as described in this policy.
  • Contractual Necessity: Processing your data is necessary to fulfill our contract with you, such as providing you with the App’s services.
  • Legal Obligations: We may process your data to comply with legal obligations, such as maintaining accurate records for tax and accounting purposes.
  • Legitimate Interests: We may process your data for our legitimate interests, such as improving our App and services, provided that those interests are not overridden by your rights.

6. Sharing Your Information

We respect your privacy and do not share your personal information with third parties except in the following circumstances:

  • With Your Consent: We may share your information with others if you give us explicit permission to do so.
  • With Service Providers: We may share your information with third-party service providers who assist in operating the App, processing transactions, or providing services on our behalf. These providers are obligated to protect your information and use it solely for the purposes for which it was provided.
  • With Analytics and Advertising Partners: We may share anonymized and aggregated information with analytics and advertising partners to help us analyze usage patterns and deliver relevant ads.
  • Legal Compliance: We may disclose your information if required to do so by law, such as to comply with a subpoena or similar legal process, or in response to valid requests by public authorities (e.g., a court or government agency).
  • Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

7. Data Security

We take the security of your personal and health information seriously and implement industry-standard security measures to protect it. These measures include:

  • Encryption: Data in transit and at rest is encrypted using industry-standard protocols.
  • Access Controls: Access to your data is limited to authorized personnel who need it to perform their job functions.
  • Monitoring: We regularly monitor our systems for possible vulnerabilities and attacks.

However, please be aware that no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

8. Data Retention

We retain your personal and health information for as long as your account is active or as needed to provide you with the App’s services. We may also retain and use your information to comply with our legal obligations, resolve disputes, and enforce our agreements. Specific retention periods are as follows:

  • Account Information: Retained for the duration of your account.
  • Health Data: Retained until you request deletion.
  • Payment Information: Retained as long as necessary to process transactions and comply with legal obligations.

9. Your Data Rights (GDPR and CCPA Compliance)

You have the following rights regarding your personal data:

  • Right to Access: You have the right to request access to the personal data we hold about you.
  • Right to Rectification: You can request correction of any inaccuracies in your personal data.
  • Right to Erasure: You have the right to request deletion of your personal data under certain conditions.
  • Right to Restrict Processing: You can request the restriction of processing your data under certain circumstances.
  • Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
  • Right to Object: You can object to the processing of your data, including for direct marketing purposes.
  • Right to Withdraw Consent: You can withdraw your consent to our processing of your data at any time.
  • Right to Non-Discrimination (CCPA): You will not be discriminated against for exercising any of your privacy rights under the CCPA.

To exercise any of these rights, please contact us at [Insert Contact Information].

10. International Data Transfers (GDPR Compliance)

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. Where we transfer your personal data internationally, we ensure that appropriate safeguards are in place to protect your information, such as standard contractual clauses approved by the European Commission.

11. Do Not Track Signals (CCPA Compliance)

Our App does not currently respond to “Do Not Track” (DNT) signals. We do not track users over time and across third-party websites to provide targeted advertising. However, we use third-party analytics services that may collect information about your online activities over time and across different websites.

12. HIPAA Compliance

As part of our commitment to protecting your health information, we comply with the Health Insurance Portability and Accountability Act (HIPAA) where applicable. We implement administrative, physical, and technical safeguards designed to protect the privacy and security of your health information. We do not use or disclose your health information without your explicit consent, except as permitted or required by law.

13. Children’s Privacy

Glucoly is not intended for use by individuals under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us so we can take appropriate actions, such as deleting the data.

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy regularly to stay informed about how we are protecting your information. If we make significant changes to this policy, we will notify you through the App or via email.

15. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, or if you wish to exercise your data rights, please contact us at:

info@appim.io

16. California Residents (CCPA Compliance)

Under the California Consumer Privacy Act (CCPA), California residents have specific rights regarding their personal information. In addition to the rights listed above, California residents have the right to:

  • Request Disclosure: You can request information about the categories and specific pieces of personal information we have collected about you, the categories of sources from which the personal information is collected, the purpose for collecting or selling the personal information, and the categories of third parties with whom we share personal information.
  • Opt-Out of Sale: We do not sell personal information. However, if we ever decide to sell your personal information, you will have the right to opt-out.

To make a request under the CCPA, please contact us at info@appim.io