Privacy Notice
Sugar App

Last updated 27/12/2021


We are Alty Inc., and we understand how privacy is important especially in relation to health data. This Privacy Notice explains who we are, why we collect your personal data and other information about your privacy.


Contents of the document

Who we are

Processing of personal data

Children’s privacy

Retention of data

Transfer of data

Your data subject rights

Contact details


Who we are

We are Alty Inc., registered at 160 Greentree Drive, Suite 101, Dover, Country of Kent, 19904, Delaware, USA. We act as the controller of personal data we are processing.

Processing of personal data

This section describes what personal data we process, when and why.

Note: to use Health App (“App”) you do not need to register, therefore we do not collect your name, age and contact details.

Your personal data listed below is being stored on your phone, it will not be stored or uploaded to our data servers.

When you download the App, we may receive from the AppStore data about your device (identifier, type of device, time of download). To ensure joint operation of the App and transmitter device we process technical data of your device (type of device), phone (Bluetooth ID and name, type of device, etc.) and the app (information about performance of the app).


When
Personal data
Purpose of processing
Lawful basis for processing
When
Registration
Personal data
Device data
Purpose of processing
To connect transmitter to the App for data visualisation
Lawful basis for processing
Performance of the contract
When
App usage
Personal data
Level of sugar in your blood
Purpose of processing
To provide it to you via transmitter device or the App
Lawful basis for processing
Consent
When
App usage
Personal data
Time and date when the level of sugar in your blood was assessed
Purpose of processing
To list level of sugar by time and date
Lawful basis for processing
Consent
When
App usage
Personal data
Technical data
Purpose of processing
To provide download of App in App Store
Lawful basis for processing
Performance of the contract
When
App usage
Personal data
Technical data of your transmitter device and phone
Purpose of processing
To connect transmitter device and the App
Lawful basis for processing
Performance of the contract

Children’s privacy

App is available for minors aged 6+ too. If you are under 16 years old and want to transfer data to the App, we will need consent of your parent or guardian (legal representative). To verify that a person who consented is your legal representative, we will need to collect your and representative’s name, marital/family status and other related information.

If you are parent of a child who is using App, depending on age requirements in your country you are entitled to send a request about processing of child’s data at [email protected]

Note: Some members of the European Union can require a lower age when a representative's consent is not required.

Retention of data

By default your personal data is being stored on your device. Data transferred to the App is being stored on your phone until you delete it. That data which is transferred to our services is stored during.

Transfer of data

We do not transfer your data to third parties in commercial meanings. We transfer it to a scope that is strictly limited to service provision.

This means that we’ve engaged independent developers to create and maintain the App. They may process your personal data to ensure sustainable work of the App. Some of our developers are based in Ukraine and some in the US. We make our best efforts to keep it secure.

Also we transfer your data to servers which are located in the USA.

Your data subject rights

You have the following data protection rights:


Right
Description
Right
Right to access
Description
You can request an explanation of the processing of your personal data.
Right
Right to rectification
Description
You can change the information if it is inaccurate or incomplete.
Right
Right to erasure
Description
You can send us a request to delete your personal data from our systems.
Right
Right to data portability
Description
You can request all the data that you provided to us, as well as request to transfer data to another controller.
Right
Right to object
Description
You can object to the processing of your data.
Right
Right to restriction
Description
You may partially or completely prohibit us from processing your personal data.
Right
Right to withdraw consent
Description
You can withdraw your consent at any time.
Right
Right to lodge a complaint
Description
If your request was not satisfied, you can file a complaint to the regulatory body.

To exercise your rights or ask a privacy question you can send a letter to [email protected].

Please note that we may ask you to verify your identity before responding to a request.

Indemnification

This Privacy Notice and the relationships falling under its effect are regulated by Delaware Online Privacy and Protection Act and GDPR. Moreover, we comply with Ukrainian laws.

Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on our website.

Note: if significant material changes are made that affect your privacy and confidentiality, we will notify you via App and ask you to read.