Privacy Policy

Effective Date: January 11, 2025

DiabetesFit ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal information when you use the DiabetesFit mobile application (the "App").

1. Data Controller

The data controller responsible for your personal data is:

DiabetesFit
Email: support@diabetesfit.ch
Location: Switzerland

2. What Data We Collect

2.1 Health Data (Stored Locally Only)

The App allows you to track the following health information:

• Blood glucose readings
• Insulin doses (basal and bolus)
• Meal information and carbohydrate intake
• Exercise and activity data
• Notes and observations

Important: All health data is stored ONLY on your device and in your personal iCloud account (if you enable iCloud sync). We do NOT have access to this data.

2.2 HealthKit Data

With your explicit permission, the App integrates with Apple HealthKit to:

• READ: Glucose data from your CGM device (Dexcom, Freestyle Libre, etc.)
• READ: Insulin doses from compatible smart pens
• WRITE: Your logged data back to the Health app for your records

This data exchange happens entirely on your device. We do not access your HealthKit data.

2.3 Technical Data (Anonymous Only)

We may collect limited, anonymous technical data through Apple's App Store Connect analytics:

• App crashes and performance data (anonymized)
• Device type and iOS version
• App usage statistics (no personal identifiers)

This data helps us improve the App's stability and performance but cannot identify you personally.

2.4 Subscription Data

If you subscribe to DiabetesFit Premium:

• Apple processes your payment (we never see your payment details)
• We receive a receipt identifier to verify your subscription status
• This identifier cannot be linked to your personal health data

3. How We Use Your Data

3.1 Your Health Data

Your health data is used solely by YOU, on YOUR device, for:

• Tracking your diabetes management
• Generating insights and visualizations
• Creating PDF reports for your healthcare team (Premium feature)
• Learning insulin timing through interactive tools

All processing happens locally on your device. We do not access, analyze, or store your health data on our servers.

3.2 iCloud Sync (Optional)

If you enable iCloud sync:

• Your data syncs between your Apple devices using your personal iCloud account
• Data is encrypted in transit and at rest by Apple
• We do not have access to your iCloud data
• You control syncing through iOS Settings

4. Data Sharing and Disclosure

We do NOT share your personal health data with anyone.

The only data sharing that occurs is:

• Apple: Subscription management and App Store analytics (anonymous)
• You: When you export PDF reports to share with your healthcare team

We will only disclose your information if required by law or to protect our legal rights.

5. Data Security

We implement appropriate security measures:

• Local Storage: Your data is protected by iOS encryption and your device passcode
• iCloud Sync: Data is encrypted in transit (TLS/SSL) and at rest by Apple
• No Central Database: We don't maintain servers storing your health data
• App Security: Regular security updates and code reviews

6. Your Rights (GDPR & Swiss FADP)

Under GDPR and Swiss data protection law, you have the right to:

• Access: Request a copy of your data (stored on your device only)
• Rectification: Correct inaccurate data (edit in the App)
• Erasure: Delete your data (delete the App or disable iCloud sync)
• Data Portability: Export your data (PDF export feature)
• Withdraw Consent: Revoke HealthKit permissions in iOS Settings
• Object: Object to data processing (delete the App)

To exercise these rights, contact us at support@diabetesfit.ch

7. Children's Privacy

DiabetesFit is suitable for users of all ages, including minors with diabetes. However:

• We do not knowingly collect personal data from children without parental consent
• All data remains on the user's device (or parent's iCloud account for family sharing)
• Parents/guardians should supervise minors' use of health apps

8. International Data Transfers

Your data is stored on your device and in your Apple iCloud account. If you use iCloud:

• Apple may store data in data centers globally
• Apple complies with GDPR and international data protection standards
• We do not transfer your data internationally (we don't access it)

9. Third-Party Services

The App integrates with:

• Apple HealthKit: Subject to Apple's Privacy Policy
• Apple iCloud: Subject to Apple's Privacy Policy
• Apple StoreKit: For subscription management

We do not use third-party analytics, advertising, or tracking services.

10. Food Database Sources

The App includes food databases from:

• Swiss Federal Food Safety (BLV): Official public nutritional data
• Open Food Facts: Open-source food database
• USDA FoodData Central: Public nutritional information

Searches in these databases are performed locally or anonymously. No personal data is shared.

11. Data Retention

Your health data is retained:

• On your device: Until you delete the App or manually delete entries
• In iCloud: Until you disable sync or delete from iCloud settings
• We retain: Nothing - we don't store your health data

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted:

• On this webpage with a new effective date
• In the App (for significant changes)
• Via App Store update notes (for material changes)

13. Medical Disclaimer

Important: DiabetesFit is a tracking and educational tool, not a medical device. It:

• Does NOT provide medical advice, diagnosis, or treatment
• Does NOT replace professional medical supervision
• Should NOT be used for medical emergencies

Always consult your healthcare provider before making changes to your diabetes therapy.

14. Contact Us

If you have questions about this Privacy Policy or your data:

Email: support@diabetesfit.ch
Website: https://www.diabetesfit.ch

We aim to respond to all inquiries within 48 hours.

15. Supervisory Authority