Privacy Notice

1. Personal data we collect

• Account data: name and email address;
• Login credentials: authentication identifiers used to sign you in;
• Pool and chat content: details about your pool, test strip photos, and messages you send to the AI assistant;
• Support messages: communications you send to us;
• Usage and telemetry: how you interact with the Service, device identifiers, and IP address.

2. How and why we use your data

• Account creation and authentication — to create and secure your account;
• Providing the Service — to read test strips, generate treatment plans, run the AI assistant, and send reminders;
• Security and fraud prevention — to protect the Service and our users;
• Product improvement — to understand usage and improve features;
• Customer support — to respond to your inquiries.

Payment-related data is collected and processed by our payment provider, Stripe. We do not store your full card details.

3. Legal basis

Where applicable law requires a legal basis, we rely on:

• Performance of a contract — to provide the Service you request;
• Legitimate interests — to secure, maintain, and improve the Service;
• Consent — where required, e.g. for certain analytics or marketing;
• Legal obligation — to comply with applicable law.

4. How we share your data

We share personal data with the following categories of recipients:

• Service providers / subprocessors — hosting, AI processing, analytics, and support tooling that operate on our behalf;
• Stripe (payment processing) — to process payments, prevent fraud, and issue invoices and receipts;
• Professional advisers — such as legal and accounting advisers;
• Authorities — where required by law.

5. Data retention

We keep personal data only for as long as necessary to provide the Service and for the purposes described above, after which it is deleted or anonymised. Where we are required to retain data to comply with legal obligations, we retain it for the period required.

6. Your rights

Depending on your location, you may have rights to access, correct, delete, restrict, or object to the processing of your personal data, to data portability, and to withdraw consent. If you are in the UK or EEA, you also have the right to lodge a complaint with your local supervisory authority, and we will respond to requests within the timeframe required by law (generally one month). To exercise your rights, contact us through the support options within the Service.

7. International transfers

Your data may be processed in countries outside your own, including outside the UK or EEA. Where this happens, we rely on appropriate safeguards such as standard contractual clauses or adequacy decisions to protect your data.

8. Security

We use appropriate technical and organisational measures — including encryption in transit and access controls — to protect your personal data against unauthorised access, loss, or misuse.

9. Cookies

We use essential cookies required to operate the Service (for example, to keep you signed in). Where we use analytics or marketing cookies, we do so in accordance with applicable law and, where required, with your consent. You can manage cookie preferences through your browser settings.

10. Contact

For any privacy questions or to exercise your rights, contact DEVA TRADING INC. through the support options available within the Service.