Privacy Policy

Last Updated: January 2025

1. Introduction

System D Labs ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how our Glucose Analytics application ("the App") handles information.

2. Information We DO NOT Collect

The App is designed with privacy first. We do NOT collect:

• Glucose readings or CGM data
• Meal logs or food entries
• Health metrics or calculations
• Personal identification information
• Location data
• Device identifiers
• Usage analytics
• Crash reports

3. How the App Works

Local Processing Only

All data processing occurs locally on your iPhone. The App:

• Stores all data in your device's local database
• Performs all calculations on your device
• Does not require an internet connection to function
• Does not communicate with any external servers for app functionality

Apple Health Integration

With your explicit permission, the App may:

• Read glucose data from Apple Health
• Read activity and workout data from Apple Health
• Write meal entries to Apple Health (if enabled)

This data remains within Apple's secure Health ecosystem and your device. We never have access to this information.

4. Data Storage and Security

On-Device Storage

Your data is stored using iOS's built-in Core Data framework, which:

• Encrypts data when your device is locked
• Is protected by your device passcode/Face ID/Touch ID
• Is included in your device's encrypted backups (if enabled)
• Cannot be accessed by other apps

Data Export

You can export your data at any time through the App's export feature. Exported files are saved to your chosen location and remain under your control.

5. Third-Party Services

App Store

The App is distributed through Apple's App Store. Apple may collect download and update statistics, but this information is not linked to your health data or shared with us in an identifiable way.

No Third-Party Analytics

We do not use Google Analytics, Firebase, or any other third-party analytics services.

No Advertising

The App contains no advertisements and does not use any advertising SDKs or tracking technologies.

6. Communications

Support Emails

If you contact us for support:

• We will only use your email to respond to your inquiry
• We do not add you to any mailing lists
• We do not share your email with third parties
• You may request deletion of our email correspondence at any time

7. Children's Privacy

The App is not intended for children under 13. We do not knowingly collect information from children under 13. If you are a parent or guardian and believe we have inadvertently collected information from your child, please contact us.

8. International Users

The App stores all data locally on your device, regardless of your location. No data is transmitted internationally.

9. Your Rights

You have complete control over your data:

• Access: View all your data within the App
• Export: Export your data at any time
• Delete: Delete any or all data through the App's interface
• Portability: Export data in standard formats for use elsewhere

10. Data Breach Notification

Since we do not collect or store your data on our servers, a breach of our systems would not expose your health information. Your data's security depends on your device's security measures.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by:

• Updating the "Last Updated" date at the top of this policy
• Providing a notice within the App for significant changes
• Publishing release notes with App updates

12. Compliance

HIPAA

While the App handles health information, we are not a covered entity under HIPAA as we do not transmit or have access to your health information.

GDPR and CCPA

The App is designed to exceed GDPR and CCPA requirements by not collecting personal data at all.

13. Open Source Libraries

The App may use open-source libraries for functionality. These libraries operate locally on your device and do not transmit data externally.

14. Deletion of the App

If you delete the App from your device:

• All locally stored data is immediately deleted
• No data remains on our servers (as we never had it)
• Apple Health data remains in Apple Health unless separately deleted