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← Back to HomeVersion 1.0 | Effective: November 5, 2025

Privacy Policy

Effective Date: November 5, 2025
Version: 1.0

1. INTRODUCTION

This Privacy Policy explains how Gluvi ("we," "us," "our") collects, uses, and protects your personal data when you use our Service. We are committed to protecting your privacy and complying with the EU General Data Protection Regulation (GDPR).

Controller: Gluvi, Germany
Data Protection Officer (DPO): dpo@gluvi.care
Legal Basis: GDPR Article 9(2)(a) - Explicit consent for health data processing

2. WHAT DATA WE COLLECT

2.1 Account & Authentication Data

What we collect:

  • Email address (stored in Firebase Authentication only)
  • Password (hashed, never stored in plain text)
  • Firebase user identifier (sub) - unique ID used internally
  • Account creation date
  • Last login date

Why we collect it:

  • To create and manage your account
  • To authenticate you securely
  • To send password reset emails
  • To communicate important service updates

Legal basis: GDPR Article 6(1)(b) - Performance of contract

2.2 Health & Wellness Data (Special Category)

What we collect:

  • Meal data: Food items, portion sizes, nutritional values (carbohydrates, fats, proteins, calories)
  • Blood glucose readings: Manual entries of glucose levels with timestamps
  • Medications & insulin: Names, dosages, schedules, timestamps
  • Care events: Symptoms, exercises, stress levels, sleep patterns
  • Appointments: Healthcare provider appointments, reminders
  • Checklists: Custom health tracking items

Why we collect it:

  • To provide diabetes management features
  • To generate health reports and trends
  • To send reminders and notifications
  • To improve your health tracking experience

Legal basis: GDPR Article 9(2)(a) - Explicit consent (required separately)

⚠️ Important: This data is classified as special category data under GDPR Article 9 because it relates to your health. We process this data ONLY with your explicit consent, which you can withdraw at any time by deleting your account.

2.3 Technical & Usage Data

What we collect:

  • IP address (anonymized - last octet replaced with .0)
  • Device type and operating system
  • Browser type and version
  • User agent string
  • Session duration
  • Feature usage patterns (which pages you visit, which features you use)
  • Error logs and crash reports

Why we collect it:

  • To ensure security and detect fraud
  • To improve Service performance and stability
  • To understand how users interact with Gluvi
  • To troubleshoot technical issues

Legal basis: GDPR Article 6(1)(f) - Legitimate interest (security, service improvement)

2.4 Cookies & Local Storage

What we collect:

  • Session cookies (required for authentication)
  • Preference cookies (theme, language)
  • Cached food search results (temporary, local only)

Why we collect it:

  • To keep you logged in
  • To remember your preferences
  • To improve app performance

Legal basis: GDPR Article 6(1)(f) - Legitimate interest (essential functionality)

Note: We use only first-party cookies. No third-party tracking or advertising cookies.

3. HOW WE USE YOUR DATA

3.1 Primary Uses

Account Management:

  • Create and maintain your user account
  • Authenticate your login sessions
  • Send password reset emails

Health Tracking:

  • Store and display your meals, glucose readings, medications
  • Calculate nutritional totals (carbs, fats, proteins, calories)
  • Generate health reports and trend visualizations
  • Send appointment reminders and notifications

Service Improvement:

  • Analyze usage patterns to improve features
  • Debug technical issues
  • Optimize app performance

3.2 AI/ML Development (Optional)

If you consent to AI/ML data usage (optional):

Anonymization Process:

  1. Remove all personally identifiable information (PII):
    • Email, name, location, IP address
    • Dates replaced with relative time deltas (e.g., "Day 1", "Day 2")
    • Unique IDs replaced with random hashes
  2. Aggregate data across minimum 5 users
  3. Apply differential privacy techniques
  4. Verify anonymization with k-anonymity (k ≥ 5)

Usage of Anonymized Data:

  • Train AI models for better meal recommendations
  • Improve nutritional calculations
  • Develop predictive glucose algorithms
  • Research diabetes management patterns

⚠️ Important: Once data is anonymized, it is no longer personal data under GDPR Recital 26 and cannot be deleted or re-identified. AI/ML consent is entirely optional - you can opt-out in account settings without affecting your ability to use Gluvi.

4. DATA SHARING & THIRD PARTIES

4.1 Who We Share Data With

We share your data with the following third parties:

Firebase Authentication (Google Cloud Platform):

  • What we share: Email, password hash, authentication tokens
  • Why: To provide secure login and password reset
  • Legal basis: GDPR Article 6(1)(b) - Performance of contract
  • Location: Production: EU data centers (europe-west3, Frankfurt, Germany); Development: US data centers (test data only, no real patient information)
  • Data Processing Agreement (DPA): ✅ In Effect (Google Cloud Data Processing Terms, auto-applied)

MongoDB Atlas (Cloud Database):

  • What we share: Health data, meal records, care events (NO email - only Firebase sub identifier)
  • Why: To store and retrieve your health tracking data
  • Legal basis: GDPR Article 9(2)(a) - Explicit consent (health data)
  • Location: EU data centers (Frankfurt, Germany)
  • Data Processing Agreement (DPA): ✅ In Effect (MongoDB Standard DPA, November 2025)

Note: We do NOT share data with:

  • ❌ Advertising networks
  • ❌ Social media platforms
  • ❌ Data brokers
  • ❌ Healthcare insurers
  • ❌ Employers

4.2 International Data Transfers

All data is stored within the European Union (EU):

  • Firebase: EU region (Belgium or Frankfurt)
  • MongoDB: EU region (Frankfurt, Germany)

No data transfers outside the EU unless:

  • Required by law (e.g., court order)
  • You explicitly request it (e.g., data export)
  • Emergency access for technical support (logged and limited)

4.3 Legal Disclosures

We may disclose your data if required by law:

  • Court orders or subpoenas
  • Law enforcement requests (only with valid legal basis)
  • Emergency situations (threat to life or public safety)

Transparency: We will notify you of legal requests unless prohibited by law.

5. DATA RETENTION & DELETION

5.1 How Long We Keep Your Data

Active accounts:

  • Account data: Retained while account is active
  • Health data: Retained while account is active
  • Session logs: 90 days
  • Error logs: 1 year

Deleted accounts:

  • Personal data: Deleted within 30 days of account deletion request
  • Anonymized data: Retained indefinitely (no longer personal data)
  • Legal compliance data: 6 years (e.g., GDPR consent records)

5.2 How to Delete Your Account

Self-service deletion (planned for post-MVP):

  • Go to Account Settings > Delete Account
  • Confirm deletion with password
  • Data deleted within 30 days

Manual deletion (current MVP process):

  • Email dpo@gluvi.care with subject "Account Deletion Request"
  • Include your registered email address
  • We will confirm deletion within 30 days

What gets deleted:

  • ✅ Email address (from Firebase)
  • ✅ All health data (meals, glucose, medications, care events)
  • ✅ Account settings and preferences
  • ✅ Session cookies and cached data

What is NOT deleted:

  • ❌ Anonymized data (cannot be re-identified, no longer personal data)
  • ❌ Legal compliance records (consent logs, deletion requests)
  • ❌ Aggregated statistics (no PII)

6. DATA SECURITY

6.1 Technical Safeguards

Encryption:

  • Data in transit: TLS 1.3 (HTTPS)
  • Data at rest: AES-256 encryption (MongoDB, Firebase)
  • Passwords: bcrypt hashing with salt

Access Controls:

  • Multi-factor authentication (MFA) for admin accounts
  • Role-based access control (RBAC)
  • Principle of least privilege

Network Security:

  • Firewall protection
  • IP whitelisting for admin access
  • DDoS protection

Monitoring:

  • 24/7 security monitoring
  • Automated intrusion detection
  • Regular security audits

6.2 Organizational Safeguards

  • Staff training on GDPR and data protection
  • Strict access policies (need-to-know basis)
  • Confidentiality agreements with employees
  • Incident response plan for data breaches

6.3 Data Breach Notification

If a data breach occurs:

  • We will notify the relevant supervisory authority within 72 hours (GDPR Article 33)
  • We will notify affected users without undue delay if high risk to rights (GDPR Article 34)
  • Notification includes: nature of breach, affected data, mitigation measures, contact information

7. YOUR RIGHTS UNDER GDPR

You have the following rights:

7.1 Right of Access (Article 15)

What: Request a copy of all personal data we hold about you

How to exercise:

  • Email dpo@gluvi.care with subject "Data Access Request"
  • Include your registered email address
  • We will respond within 30 days (may extend to 60 days for complex requests)

What you'll receive:

  • JSON export of all your health data
  • Account information
  • Consent records
  • Data processing information

7.2 Right to Rectification (Article 16)

What: Correct any inaccurate or incomplete personal data

How to exercise:

  • Update directly in account settings (meals, glucose, medications)
  • Email dpo@gluvi.care for data you cannot edit yourself

7.3 Right to Erasure / "Right to be Forgotten" (Article 17)

What: Request deletion of your account and personal data

How to exercise:

  • Email dpo@gluvi.care with subject "Account Deletion Request"
  • Data deleted within 30 days

Exceptions (we may refuse deletion if):

  • Legal obligations require retention (e.g., consent records: 6 years)
  • Data is anonymized (no longer personal data under GDPR Recital 26)

7.4 Right to Data Portability (Article 20)

What: Receive your data in machine-readable format (JSON)

How to exercise:

  • Email dpo@gluvi.care with subject "Data Portability Request"
  • Receive JSON file within 30 days

Included data:

  • All meal records with nutritional calculations
  • All glucose readings
  • All medications and care events
  • Appointments and checklists

7.5 Right to Object (Article 21)

What: Object to certain types of processing

How to exercise:

  • Opt-out of AI/ML anonymization in account settings
  • Email dpo@gluvi.care with subject "AI/ML Opt-Out Request"

Note: You cannot object to essential processing (e.g., storing health data to provide the Service). To stop essential processing, delete your account.

7.6 Right to Restrict Processing (Article 18)

What: Limit how we use your data temporarily (e.g., during accuracy disputes)

How to exercise:

  • Email dpo@gluvi.care with subject "Restrict Processing Request"
  • Explain reason for restriction

7.7 Right to Withdraw Consent (Article 7(3))

What: Withdraw your consent for health data processing at any time

How to exercise:

Important: Withdrawing consent does not affect past lawful processing. The Service requires health data consent to function - withdrawing consent means you cannot continue using Gluvi.

7.8 Right to Lodge a Complaint (Article 77)

What: File a complaint with your national data protection authority

Germany (for EU users):

How to file:

  • Contact your national DPA directly
  • Provide details of your complaint
  • Include evidence (emails, screenshots)

8. CHILDREN'S PRIVACY

Age requirement: Users must be at least 16 years old (GDPR Article 8).

Parental consent:

  • Users aged 13-15 may use Gluvi with verifiable parental consent
  • Parent must email consent@gluvi.care with subject "Parental Consent for [Child's Email]"
  • We will verify parent identity before granting access

Children under 13:

  • Not permitted to use the Service
  • If we discover a user is under 13 without parental consent, we will immediately delete their account

9. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes:

  • We will notify you via email to your registered address
  • We will display an in-app notification
  • You will be required to re-consent to continue using the Service
  • Previous versions available at: https://gluvi.care/legal/privacy-history

Version tracking:

  • Each version has a unique version number and hash
  • Changes logged in version history
  • Material changes require new consent

Definition of "material changes":

  • New purposes for data processing
  • Sharing data with new third parties
  • Changes to data retention periods
  • Changes to legal basis for processing

10. CONTACT US

For questions about this Privacy Policy or to exercise your rights:

General privacy inquiries: privacy@gluvi.care
Data Protection Officer (DPO): dpo@gluvi.care
Data access/deletion requests: dpo@gluvi.care
AI/ML opt-out requests: dpo@gluvi.care
Complaints: dpo@gluvi.care

Mailing address:
Gluvi
Data Protection Officer
[Street Address]
[City, Postal Code]
Germany

Response time: We will respond to all inquiries within 30 days (may extend to 60 days for complex requests, with notification).

Last updated: November 1, 2025
Version: 1.0
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