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.
1. 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, processed securely through our third-party payment processors and not stored on our servers.
- Health Information: The App allows you to track various health metrics, including blood glucose levels, insulin usage, medication details, weight, and blood pressure. This information is sensitive and essential for 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.
- Cookies and Tracking Technologies: We may use cookies and similar technologies to track your activity on our App and store certain information. You can manage your cookie preferences through your browser settings.
2. 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.
3. How We Use Your Information
- To provide and improve the Services, such as tracking your health metrics, generating personalized reports, and improving the user experience.
- To manage subscriptions and process transactions.
- To personalize your experience and tailor the App’s features to your needs.
- To communicate with you, including important notifications, updates, and reminders. You can opt out of these communications at any time.
- To ensure legal compliance, resolve disputes, and enforce our agreements.
4. Legal Bases for Processing (GDPR)
- Consent and explicit consent: health data (such as blood glucose, insulin, medication, weight and blood pressure) is a special category of personal data under Article 9 GDPR. We process it only on the basis of the explicit consent you give within the App, and you may withdraw that consent at any time. We also rely on your consent for optional communications and analytics.
- Contractual necessity: processing your data is necessary to provide you with the App’s services.
- Legal obligations: we may process your data to comply with legal obligations.
- Legitimate interests: we may process your data to improve our App and services, provided those interests are not overridden by your rights.
6. Data Security
We implement industry-standard security measures including encryption of data in transit and at rest, access controls limiting data to authorized personnel, and regular monitoring of our systems. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. In the event of a personal data breach that affects your information, we will notify the competent supervisory authority without undue delay and, where required by law, within 72 hours of becoming aware of it, and we will inform you without undue delay where the breach is likely to result in a high risk to your rights and freedoms.
7. Data Retention
- 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.
8. Your Data Rights (GDPR & CCPA)
You have the right to access your personal data; to rectification of inaccuracies; to erasure under certain conditions; to restrict processing; to data portability; to object to processing (including direct marketing); to withdraw consent at any time; and, under the CCPA, to non-discrimination for exercising your privacy rights. To exercise any of these rights, please contact us at info@glucoly.app. We will respond within one month, and for your protection we may need to verify your identity before acting on a request. If you are in the EEA or the UK, you also have the right to lodge a complaint with your local data protection supervisory authority.
9. International Data Transfers (GDPR)
Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. Where we transfer your personal data internationally, we ensure that appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission.
11. Health Information and U.S. Users
Glucoly is a consumer self-management tool. We are generally not a “covered entity” or “business associate” under the U.S. Health Insurance Portability and Accountability Act (HIPAA), and the Services are not intended to create any HIPAA-regulated relationship. Regardless of whether HIPAA applies, we treat the health information you record as sensitive and protect it with administrative, physical, and technical safeguards, and we do not use or disclose it without your consent except as permitted or required by law.
12. Children’s Privacy
Glucoly is intended only for users who are at least 18 years old. We do not knowingly collect personal information from anyone under 18, and we do not knowingly collect data from children under 16 in the EEA or under 13 in the United States. If you are a parent or guardian and believe a minor has provided us with personal information, please contact us so we can take appropriate actions, such as deleting the data.
13. 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. If we make significant changes, we will notify you through the App or via email.
14. 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@glucoly.app.
15. California Residents (CCPA)
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), California residents may request information about the categories and specific pieces of personal information we have collected, the sources, the purpose for collecting it, and the categories of third parties with whom we share it. You also have the right to delete your personal information, to correct inaccurate personal information, to opt out of the “sale” or “sharing” of personal information, and to limit the use of sensitive personal information. We do not sell or share your personal information as those terms are defined under the CPRA. To make a request, please contact us at info@glucoly.app, and we will not discriminate against you for exercising these rights.
Glucoly is published on the App Store and Google Play by BZS Corp. OÜ (Registry Code 14839962). All rights in the Glucoly app and brand belong to Glucoly. Contact: info@glucoly.app.