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Privacy Policy: GluEase: Blood Sugar Tracker

Privacy Policy

App: GluEase: Blood Sugar Tracker

Provider: GRAVLOOM – FZCO (“GRAVLOOM”, “we”, “us”, “our”), a free-zone company registered in Dubai, United Arab Emirates.

Effective date: 25 June 2026

Last updated: 25 June 2026

1. Introduction

This Privacy Policy explains how GRAVLOOM – FZCO handles information in connection with the GluEase mobile application (the “App”). GluEase is a personal health-tracking tool that lets you record and review your blood sugar, blood pressure, and sleep, set reminders, and view trends.

GluEase is designed to be **anonymous and local-first**: you do not create an account, and the health information you enter is stored **on your device**. We do not operate a server that receives your health records.

By using the App, you agree to this Policy. If you do not agree, please do not use the App.

2. Definitions

Personal Data: information relating to an identified or identifiable individual.

Health Data: your blood sugar, blood pressure, and sleep entries, related notes, and health profile details you enter.

On-device: stored locally on your iPhone/iPad and not transmitted to us.

Third-Party Service: an independent service we integrate (Apple, RevenueCat, Adjust).

Processing: any operation performed on Personal Data.

3. Information We Collect

3.1 Health Data (stored on your device only)

When you use the App you may enter: blood sugar readings, blood pressure readings, sleep quality and hours, and optional notes; and profile details such as your name, gender, height, weight, diabetes/blood-pressure diagnosis status, medication information, and goals. **This information is stored only on your device** (in iOS secure storage and the app’s local storage) and is **not transmitted to GRAVLOOM or to any third party**. We have no access to it.

3.2 Account Information

**None.** The App has no account or login system. We do not collect your email address, phone number, or any social/Apple/Google identity. The App does not implement Sign in with Apple, Google Sign-In, or any other authentication.

3.3 Device & Usage Information (collected by analytics/attribution)

Through our attribution provider (Adjust), we may receive technical identifiers and event information associated with your device, including: device identifiers (such as the Identifier for Vendors and an Adjust-generated identifier; and, **only if you grant App Tracking Transparency permission**, the Advertising Identifier/IDFA), IP address, and information about how you installed and interacted with the App (for example, that a free trial or purchase occurred). This is used to measure which marketing campaigns lead to installs. **Adjust does not receive your Health Data.**

3.4 Subscription Information

When you purchase a subscription, the transaction is processed by **Apple** and managed through **RevenueCat**. We (via RevenueCat) receive purchase and subscription-status information associated with a pseudonymous app user identifier, together with device, platform, and country metadata. We do **not** receive your full payment card details — those are handled by Apple. **RevenueCat does not receive your Health Data.**

3.5 HealthKit

The App does **not** integrate with Apple HealthKit and does not read from or write to the Apple Health app.

3.6 Notifications

The App uses **local notifications** for optional reminders that you schedule. These are generated on your device. The App does not use remote push notifications and does not collect a push token.

4. How We Use Information

– To provide the App’s core functionality (recording and displaying your Health Data on your device).

– To deliver optional reminders you configure (local notifications).

– To process and restore your subscription (Apple, RevenueCat).

– To measure marketing-campaign effectiveness and improve the App (Adjust).

– We do **not** use your Health Data for advertising, and we do **not** sell your Personal Data.

5. Health Data

Your Health Data is sensitive. It is stored **only on your device**. You can view, edit, and delete individual entries, and you can erase all data at any time using **Settings → Clear All Data**. Because we do not receive your Health Data, we cannot retrieve or restore it for you; please use the in-app export/backup feature to keep your own copy.

6. Tracking & App Tracking Transparency (iOS)

We use Adjust for marketing attribution. On iOS, before any tracking that relies on the Advertising Identifier (IDFA), the App presents Apple’s **App Tracking Transparency** prompt. If you decline, the IDFA is not used and attribution is limited to non-IDFA signals. You can change this choice anytime in iOS Settings → Privacy & Security → Tracking.

7. Third-Party Services

| Service | Provider | Purpose | Data involved | Policy |

| In-app purchases | Apple Inc. | Process subscription payments | Purchase/transaction data | apple.com/legal/privacy |

| Subscription management | RevenueCat, Inc. | Manage entitlements & restore | Pseudonymous app user ID, purchase data, device/country metadata | revenuecat.com/privacy |

| Attribution analytics | Adjust GmbH | Measure marketing campaigns | Device identifiers, IP, install/event data | adjust.com/terms/privacy-policy |

These providers process data under their own privacy policies. We encourage you to review them.

8. Data Storage

Health Data and app settings are stored on your device. Sensitive profile and medication details are stored in the iOS Keychain (encrypted by the operating system); other entries are stored in the app’s local storage. Subscription and attribution data are stored by Apple, RevenueCat, and Adjust on their infrastructure.

9. Data Retention

**On-device data:** retained until you delete it or uninstall the App.

**Subscription data (Apple/RevenueCat):** retained per their policies and applicable law.

**Attribution data (Adjust):** retained per Adjust’s policy.

10. Security

We rely on iOS platform protections and store sensitive profile information in the iOS Keychain. All data transmitted to Apple, RevenueCat, and Adjust is sent over encrypted (HTTPS/TLS) connections. No method of storage or transmission is completely secure; we cannot guarantee absolute security. (See also the in-app export feature, which produces an unencrypted file you choose where to share.)

11. International Transfers

GRAVLOOM is based in Dubai, UAE. Our third-party providers (Apple, RevenueCat, Adjust) may process limited data described above in the United States, the European Union, and other countries. Where required, such transfers rely on appropriate safeguards (e.g., standard contractual clauses) under the providers’ own programs.

12. Your Rights

Depending on your location (including under the UAE PDPL, the EU/UK GDPR, and the California CCPA/CPRA), you may have rights to access, correct, delete, or restrict processing of your Personal Data, to object to processing, to data portability, and to withdraw consent. Because your Health Data is on your device, you can exercise access/correction/erasure directly in the App. For data held by our providers, contact us at contact@gravloom.com and we will assist, including relaying deletion requests to Apple, RevenueCat, or Adjust. We do not sell your Personal Data; California residents may opt out of any “sharing” for cross-context advertising via the App Tracking Transparency choice described in 6.

13. Account Deletion

The App has no account. To delete your data, use **Settings → Clear All Data** in the App, which erases your on-device Health Data, profile, reminders, and preferences. Uninstalling the App also removes its local data.

14. Children’s Privacy

The App is intended for adults managing their health and is **not directed to children under 16 (or under 13 where applicable)**. We do not knowingly collect Personal Data from children. If you believe a child has provided data through a third-party service, contact us and we will assist.

15. Changes to This Policy

We may update this Policy from time to time. We will update the “Last updated” date and, where appropriate, provide notice in the App. Continued use after changes constitutes acceptance.

16. Contact

**GRAVLOOM – FZCO**

Dubai, United Arab Emirates

Support: contact@gravloom.com