Gloe

Privacy Policy

1. Introduction

Gloe Health ("we," "our," or "us") operates the Gloe mobile application (the "App"). This Privacy Policy explains how we handle information in connection with your use of the App.

Data Controller: Dor Soft, 60 rue François 1er, 75008 Paris, France. For questions regarding data protection, contact us at contact@gloe.health.

2. Where Your Data Is Stored

Storage Location: Your information is stored on your iOS device or in your private iCloud container (handled by Apple), depending on whether iCloud is active and whether Gloe is enabled in your iOS Settings > [Your Name] > iCloud > Apps Using iCloud (or "Saved to iCloud"). We cannot access your information in either location.

No Account Required: No account registration is required. We do not operate servers that collect, store, or process your personal information.

2.1 Information We Store

Gloe stores the following information:

• Profile Details: Your chosen nickname, profile image, physical characteristics (height, sex, birth date), and application settings
• Treatment Records: Medication strategies, dose history, observed effects, inventory levels, body weight entries, blood glucose readings, and health objectives
• Configuration Data: Notification preferences, unit system choices, language settings, and other App customization options

This information is stored using SwiftData, Apple's storage framework. When iCloud is active and Gloe is enabled in your iCloud settings, the information is synchronized to your private CloudKit container, which is managed by Apple. If iCloud is not active or Gloe is disabled in your iCloud settings, the information remains only on your device.

2.2 iCloud Synchronization

iCloud synchronization requires:

• iCloud to be active on your device
• Gloe to be toggled on in your iOS Settings > [Your Name] > iCloud > Apps Using iCloud (or "Saved to iCloud")

When enabled, synchronization operates only between devices authenticated with your Apple ID, uses a private CloudKit database associated with your Apple ID, and is encrypted by Apple during transmission and storage. Apple manages the cloud infrastructure and processes data according to Apple's Privacy Policy. We do not control, access, or process CloudKit data.

2.3 HealthKit Integration

If you grant HealthKit permissions, Gloe can read weight and blood glucose measurements from the Apple Health app and write medication dose information to it. This connection is optional and managed by you. You can revoke HealthKit permissions at any time via Settings > Privacy & Security > Health. HealthKit data remains within Apple's Health app and is governed by Apple's Consumer Health Personal Data Privacy Policy.

2.4 Support Correspondence

When you voluntarily contact us for assistance via email, we receive and retain your message content, the email address used, and any technical details you may voluntarily include (App version, iOS version, device type). This information is used exclusively to respond to your inquiry and provide support. This email data is not linked to your user account or any health data stored in Gloe. We do not use support email communications for marketing purposes, and we do not add your email address to any marketing lists.

3. How We Use Your Information

We do not use your health information for any purpose. We cannot access your health information as it remains on your device or in your private iCloud container.

The only information we may receive is:

• Support Messages: Used exclusively to respond to your questions or requests (see Support Correspondence above)
• Aggregated Statistics: Anonymized download and usage data from Apple that contains no personal identifiers

Legal Basis for Processing (GDPR): No legal basis required for health information (not collected). For support emails: consent and legitimate interest.

Automated Decision-Making: We do not use automated decision-making or profiling.

App Tracking: We do not track you across apps or websites.

4. Data Sharing

We do not share, sell, rent, or otherwise disclose your health information to any third parties.

The only external service that may handle your information is Apple iCloud/CloudKit (if iCloud is active and Gloe is enabled in your iCloud settings). Your information is stored in your private CloudKit database, which Apple manages as a separate data controller. We cannot access this information. Apple's handling of your information is subject to Apple's Privacy Policy.

5. Data Security

Your information is stored on your device using SwiftData (encrypted at rest) or in your private CloudKit container (encrypted by Apple). Access is protected by your device's security features (passcode, Touch ID, Face ID). We do not store your information on our servers.

Data Breach Notification: Since we do not collect, store, or have access to your personal information, there is no personal information that could be subject to a data breach. In the unlikely event of a security incident affecting support emails, we will notify affected users and relevant authorities as required by applicable law.

6. Your Rights and Choices

You maintain complete control over your information. You can:

• View and Modify: All your information is accessible within Gloe. You can review, edit, or remove any entry at any time
• Export: Gloe allows you to export your information in JSON or CSV formats, which you can save to your device or share as needed
• Delete: You can remove individual entries or delete all information by uninstalling Gloe. Uninstalling the App permanently removes all local information
• Control iCloud Sync: You can enable or disable iCloud synchronization for Gloe at any time via Settings > [Your Name] > iCloud > Apps Using iCloud (or "Saved to iCloud"). Disabling Gloe in iCloud settings keeps your information on your device but stops synchronization across devices
• Control HealthKit: You can grant or revoke HealthKit permissions at any time through Settings > Privacy & Security > Health
• Contact Us: You can contact us at any time to exercise your rights or ask questions about your information

6.1 Rights Under GDPR (European Union and United Kingdom)

If you are located in the European Economic Area (EEA) or the United Kingdom, you have the following rights under the General Data Protection Regulation (GDPR) and UK GDPR:

• Right of Access: You have the right to access your personal data. Since your data is stored on your device or in your iCloud container, you can access it directly through the App
• Right to Rectification: You can correct any inaccurate data directly within the App
• Right to Erasure: You can delete your data at any time by deleting entries in the App or by deleting the App itself
• Right to Data Portability: You can export your data using the App's export functionality
• Right to Object: You can object to any processing of your data
• Right to Withdraw Consent: You can withdraw consent for HealthKit access or iCloud sync at any time through your device settings
• Right to Restrict Processing: You can restrict processing of your data
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your country. You can find your local supervisory authority at edpb.europa.eu (EU) or ico.org.uk (UK)

Data Protection Officer: We do not have a Data Protection Officer (DPO) as we do not engage in systematic monitoring or large-scale processing of personal data that would require one under GDPR Article 37. For data protection inquiries, contact us at contact@gloe.health.

6.2 Rights Under CCPA (California)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You have the right to know what personal information is collected, used, shared, or sold. Since we do not collect your health data, there is no personal information to disclose
• Right to Delete: You can delete your data at any time through the App
• Right to Opt-Out: You have the right to opt-out of the sale of personal information. We do not sell any personal information, and we do not share personal information for cross-context behavioral advertising
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

CCPA Data Categories: Under CCPA, personal information is categorized into specific types. Since we do not collect your health information on our servers, we have no personal information in any CCPA category to disclose. Any information stored on your device or in your iCloud container remains under your control and is not accessible to us.

6.3 Rights Under Other Jurisdictions

We respect privacy rights under all applicable laws worldwide, including:

• Canada (PIPEDA): Right to access, correct, and delete your personal information
• Brazil (LGPD): Rights to access, correction, deletion, portability, and information about data processing
• Australia (Privacy Act): Rights to access and correct your personal information
• United Kingdom (UK GDPR): Similar rights to EU GDPR

Since we do not collect or process your information, these rights are already fully respected. If you have questions about your rights in a specific jurisdiction, please contact us.

7. Data Retention

Your personal health information is retained on your device or in your private CloudKit container (handled by Apple), depending on whether iCloud is active and whether Gloe is enabled in your iCloud settings. We do not retain any copies of your data on our systems.

• Local Device Storage: Data remains on your device until you delete it through the App or delete the App itself. If iCloud is not active or Gloe is disabled in iCloud settings, all data remains only on your device
• CloudKit Storage: If iCloud is active and Gloe is enabled in your iCloud settings, data is stored in your CloudKit database until you delete it or disable Gloe in iCloud settings. You can manage CloudKit data through your device's iCloud settings
• App Deletion: If you delete the App from your device, all local data is permanently deleted. If iCloud was active and Gloe was enabled, CloudKit data may remain in your iCloud account until you manually delete it through iCloud settings
• Support Communications: We may retain support email communications for a reasonable period to assist with follow-up inquiries, but this does not include any health data

8. Children's Privacy

Gloe is not intended for children. Age restrictions and children's privacy requirements are handled by Apple for each country where the App is distributed through the App Store. Since we do not collect, store, or have access to any personal information from any users (including children), there is no personal information that could be collected from children or that we could delete.

9. International Data Transfers

Since we do not collect or store your health information on our servers, we do not engage in international data transfers of your health information. If iCloud is active and Gloe is enabled in your iCloud settings, your information may be stored in Apple's data centers, which may be located outside your country of residence. Such transfers are managed by Apple in accordance with their privacy policies and data processing agreements. Apple maintains appropriate safeguards for international data transfers, including standard contractual clauses and other mechanisms recognized under applicable data protection laws.

10. Consumer Health Data (Washington and Nevada)

If you are a resident of Washington or Nevada, you have additional rights under state consumer health data protection laws.

Since Gloe does not collect, store, or have access to your health information on our servers, we do not process consumer health data as defined by these laws. All your health information remains on your device or in your private CloudKit container (handled by Apple), depending on whether iCloud is active and whether Gloe is enabled in your iCloud settings. We cannot access this information. Therefore, we have no consumer health data to disclose, delete, or otherwise process.

11. Changes to This Privacy Policy

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

• Posting the updated Privacy Policy on this page with a new "Effective Date"
• Providing notice within the App if the changes are significant
• Requiring you to accept the updated policy when you next open the App, if required by applicable law

Your continued use of the App after any changes constitutes your acceptance of the updated Privacy Policy.

12. Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of France, without regard to its conflict of law principles. We respect and comply with privacy laws applicable in your jurisdiction, including GDPR, UK GDPR, CCPA, PIPEDA, LGPD, and other applicable regulations worldwide.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at contact@gloe.health. We will respond to your inquiry within a reasonable timeframe and in accordance with applicable law.

Last Updated: December 8, 2025 | Effective Date: December 8, 2025
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