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Effective Date
01 July 2025

Last Updated
01 July 2025

Privacy Policy

1. INTRODUCTION

Innovation Zed Ltd (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the InsulCheck SAOR mobile application (the "App"), which integrates with the InsulCheck DOSE device and compatible Continuous Glucose Monitoring (CGM) systems.

By using the App, you agree to the practices described in this policy. If you do not agree with the terms, please do not use the App.

Innovation Zed Ltd is the data controller for personal data processed via the InsulCheck SAOR App. For full contact details, refer to Section 10.

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2. HOW WE COLLECT YOUR DATA

  • When you create or update your profile in the App

  • Automatically through your paired InsulCheck DOSE device

  • From authorized third-party services such as CGM providers via secure APIs (data from third-party services is collected only with the user’s consent; API security is CGM providers responsibility).

  Important: No data is collected without user knowledge or      interaction.

3. PURPOSE OF DATA PROCESSING

For users in the European Economic Area (EEA), we process your data under the General Data Protection Regulation (GDPR) based on:

  • Consent (Article 6(1)(a)): When you authorize access to CGM data or input personal health information

  • Legitimate Interests (Article 6(1)(f)): To improve app features and ensure device compatibility

For users in the European Economic Area (EEA), we process your data under the General Data Protection Regulation (GDPR) based on:

  • Consent (Article 6(1)(a)): When you authorize access to CGM data or input personal health information

  • Legitimate Interests (Article 6(1)(f)): To improve app features and ensure device compatibility

4. LEGAL BASIS FOR PROCESSING

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We apply rigorous security protocols to protect your information:

  • End-to-end encryption for Bluetooth and cloud transmissions

  • Encrypted databases with role-based access controls

  • Regular penetration testing and security audits

  • Secure authentication for user accounts

5. DATA SECURITY MEASURES

We retain your personal data only for as long as necessary to provide you with the App’s services or to comply with our legal obligations. We do not automatically delete your data after periods of inactivity. Your information stays securely stored unless you delete your account.

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You can delete your account at any time using the Delete Account option within the App. When you do so:

  • All personally identifiable information (PII) is permanently removed.

  • Any health or usage data previously linked to your account is anonymized and disassociated from you.

  • Certain general usage data (e.g., crash reports or feature usage patterns) may be retained for analytics and product improvement purposes, but this data is fully anonymized and cannot be linked back to your deleted account.

 

This process complies with data protection laws, including GDPR, UK GDPR, and applicable US and Swiss privacy laws.

We may retain anonymized data to help us improve our services. This data is no longer considered personal information and cannot identify you. We regularly review our retention and deletion practices to ensure compliance across the regions in which we operate.

6. DATA RETENTION

 We do not sell, trade, or rent your personal or health data. Your information is not shared with any third parties unless:

  • You provide explicit consent

  • It is required by law, regulation, or legal process

Note: We use trusted third-party providers, like cloud services (e.g., AWS) and our support partner, who process data only under our instructions and strict Data Processing Agreements. Authorized personnel have limited access only for maintenance, security, and support. Third-party providers are contractually obligated to comply with equivalent data protection standards.

7. DATA SHARING AND DISCLOSURE

You have the right to:

  • Access the data we hold about you

  • Rectify inaccurate or outdated information

  • Withdraw consent for data processing at any time

  • Delete your account and all associated data upon request (Note: Uninstalling the App does not automatically delete your account or personal data. Please contact us to request full data deletion.)

To exercise any of these rights, contact us via email listed below. (For full contact details, refer to Section 11.)

8. YOUR RIGHTS AND CHOICES

If you are in the European Economic Area (EEA), your data may be transferred outside the region to jurisdictions that may not provide equivalent data protection. Our app uses Amazon Web Services (AWS) to store and process data in regions including the United States, European Union (Ireland), and United Kingdom. If you are in the EEA or UK, this may involve transferring your personal data to jurisdictions with different data protection laws.

 We take your privacy seriously. We use industry-standard safeguards, such as encryption, access controls, and European Commission-approved Standard Contractual Clauses (SCCs) to ensure your data is protected at every stage. We ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs).

9. CROSS BORDER DATA TRANSFERS

 We may revise this Privacy Policy to reflect changes in legal or operational requirements. If updates are significant, we will notify you within the App and request your review and acceptance.

10. UPDATES TO THIS POLICY

 If you have any questions or concerns about your privacy or this policy, please contact us:
 

 Innovation Zed,

 2 Dublin Landings,

 North Wall Quay,

 Dublin 1,

 D01 V4A3,

 Ireland

support@innovationzed.com

11. CONTACT INFORMATION

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