Privacy Notice

We at Sweetch Health Ltd. (“Company“, “us“, “we“, or “our“) recognize and respect the importance of maintaining the privacy of users of the Clarity App (as defined in the Terms, as defined below). This Privacy Notice describes the types of information we collect from you when you use the Clarity App and the services provided thereon (“Services“). This Privacy Notice also explains how we collect, process, transfer, store and disclose the information collected. If not otherwise defined herein, capitalized terms have the meanings given to them in the Terms of Service, available at https://sweetch.com/clarity-terms/ (“Terms“). “You” means any user of the Clarity App and the Services as a participant of the Feasibility Study (as defined in the Terms).

Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected by us in connection with the provision of the Services.

 

Personal Data We Collect

The Clarity App enables people with Type 2 diabetes to track their insulin therapy regimen including food intake, diabetes medications, activity levels and blood glucose values in order to calculate their intake estimated insulin likelihood. The Personal Data we collect, as listed below, will help us calculate your estimated insulin likelihood and to customize your experience using the clarity app. In order to use the Clarity App and Services, you will need to provide us with certain Personal Data, as outlined below.

Registration Data. In order to use the Clarity App and/or receive related Services, you will be required to register and provide us with certain Personal Data, such as your username, password, full name, date of birth, email address, phone, gender, height, weight, and the year you were diagnosed. We collect this information in order to calculate your estimated Insulin Likelihood and personalize and customize your experience using the Clarity Application as well as to assist in resolving any issue you may have (e.g. password reset).

BG Levels. While using the Clarity App, you will be asked to provide us with your blood glucose levels (“BG Levels“). You will be asked to input your BG levels seven times a day, 0-15 minutes before each meal, 60-90 minutes after the meal has begun, and once at night at a specified hour, as well as the time when each was measured.

Meals. We will ask you to provide us with the types of foods you ate for breakfast, lunch, and dinner or report if you skipped a meal. You will also be asked to report on any additional drinks and/or snacks you consume outside of mealtimes as well as the time you began eating each meal and/or snack. We will also ask you to provide us with the portion size and serving size for each data entry.

Medications. Upon registration, you will be asked to provide us with data regarding any diabetes-related medication you are taking, including the dosage, amount, and frequency you take, which days you take the medication (if applicable), and if daily, how many times a day and at what times you take the medication.

Physical Activity. We will ask you to provide us with data regarding any physical activity you engage in throughout the day. For reporting physical activities, you will need to input the type of activity, the start time, duration, and intensity of the workout. Physical activity tracking can be done automatically, subject to your consent, by carrying your phone during your workout, or manually, by inputting the information afterwards.

Location. Subject to your consent, we collect location data from your mobile device. We use your phone’s location to automatically identify and log your activity for calculating your estimated Insulin Likelihood and sending you personalized notifications.

In addition, when you use the Clarity App, certain information may be automatically gathered about your mobile device, such as your operating system, your IP address, device ID, and subject to your consent as may be required under applicable law, geo location, and any information regarding your use and viewing history on the Clarity App. Furthermore, and subject to your consent, we may collect data, including Personal Data, from your device, including to recognize your motion and/or activity, background app refresh (iOS), battery optimization (Android), and connection using Bluetooth. We use this information for personalizing your experience, improving the service and/or calculating your Insulin Likelihood.

You are under no legal obligation to provide us with any such Personal Data. It is your voluntary decision whether to provide us with any Personal Data, but if you refuse to provide such information we may not be able to register you to the Clarity App and/or provide you with the Services.

 

How We Use Your Personal Data

General

We and any of our trusted business partners, third-party subcontractors and service providers (“Study Partners”) use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you with the Clarity App and/or Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (6) to review the usage and operations of the Clarity App and/or Services; (7) to use your data in a de-identified manner for analytical purposes (as detailed below); (8) to prevent fraud, protect the security of the Clarity App and Services, and address any problems with the Clarity App and/or Services and (9) to provide technical support.

Statistical Information and Analytics

We use analytics tools to collect and analyze information about the use of the Clarity App and/or Services, such as how often users visit the Clarity App and what pages they visit when they do so. By analyzing the information, we receive, we may compile statistical information across a variety of platforms and users, which helps us improve the Clarity App and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires.

 

Sharing the Personal Data We Collect

We share your information, including Personal Data, as follows:

Business Partners, Service Providers, Affiliates, and Subcontractors

We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers, including the Feasibility Study coordinator business partners, affiliates, subcontractors, who use such information to: (1) help us provide you with the Clarity App and/or the Services and (2) aid in their understanding of how users are using the Clarity App and Services.

By accepting this Privacy Notice, you acknowledge that we may use subcontractors and service providers who are located in countries other than your own and may send them information we receive (including Personal Data). All of our subcontractors and service providers will be subject to non-disclosure and non-use obligations.

Law Enforcement Related Disclosure

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may share your Personal Data with third parties: (i) subject to applicable law, if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.

Legal Uses

We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

 

Security

We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the device you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

 

Data Retention

We retain information as necessary for the duration of the Feasibility Study, after which, any personal data we retain will be anonymized. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.

 

Communications

We reserve the right to send you service-related communications, including service announcements, administrative messages, or phone calls from the Feasibility Study coordinator, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account.

 

Children

We do not knowingly collect Personal Data from or market our Services to children under the age of 13.

 

Changes to the Privacy Notice

We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business.  We will notify you of any updates to this Privacy Notice and ask you to accept the terms of the latest version. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site or per email.

 

Comments and Questions

If you have any comments or questions about this Privacy Notice, please contact us support@sweetch.com

Last updated: March 2022