Privacy Policy

This Privacy Policy applies to the Insulin Buddy application (the browser version and any iOS and Android versions) and its marketing website insulinbuddy.fi.

1. Data Controller

Cavalier Venues Oy
Business ID: 3649639-4
VAT ID: FI36496394
Postal address: Lönnrotinkatu 40, 00180 Helsinki, Finland
Privacy matters: tietosuoja@insulinbuddy.fi

2. The app does not send your health data

Insulin Buddy runs entirely on the user's device. The app does not create a personal user profile, does not send the data you enter to servers, does not collect analytics, and does not display advertisements. Health data is never stored on a server, not even when you buy access or use an organisation account.

The browser version is signed in to with the shared tester credentials, with purchased access (section 7) or with an organisation's shared account (section 8). Signing in stores a strictly necessary cookie in the browser, which contains no health data and does not track use. The cookie is valid for 30 days with tester credentials, 365 days with purchased access and at most 7 days with an organisation account.

3. What the app stores on your device

The app stores the following only on your device or in your browser:

• meal profiles: carbohydrate ratio, insulin sensitivity factor (ISF), glucose target and most common carbohydrate amount
• previous insulin doses for the insulin-on-board calculation, and the active insulin time (AIT)
• a dose log, from which entries older than 90 days are removed automatically
• the parental lock PIN, the maximum dose and the dose step
• the age group (child or young person / adult), the hypo timer, the glucose unit, the language and theme settings, a record that you have accepted the start-up guidance, which version's news (“What's new?”) you have already seen, and whether the Home Screen tip has been closed
• in the Android app, the start time of the free trial

Data leaves your device only when you share or export it yourself: for example the dose log as a CSV file, the dose log summary, a calculation, the care card, or your personal values as a file for another device. You then choose the recipient yourself using your device's share function, and the app never sends anything on its own.

The controller never receives this data. You can clear the dose log and reset the settings in the app. Uninstalling the mobile app deletes the data from the device, but copies saved in device backups (e.g. iCloud or Google) remain until the backup is deleted or replaced. In the browser version, the data remains until you clear the site data for app.insulinbuddy.fi in your browser settings; removing the home-screen icon may not be enough.

4. Network connectivity

The app does not send the data you enter over the network. The browser version connects to the network only when you sign in and when it downloads updates. The mobile apps are updated through the App Store or Google Play.

5. Delivering the pages and the browser version

The marketing website, the app's browser version and its server side (purchase, sign-in and orders) are delivered by Vercel Inc. It processes technical data from your browser, such as your IP address, on behalf of the controller to deliver the pages and for security purposes. The legal basis is the controller's legitimate interest in delivering a working and secure service (Article 6(1)(f) GDPR). Vercel is a processor under a data processing agreement. Data may be transferred to the United States, and such transfers are based on the European Commission's standard contractual clauses; a copy of the clauses is available from tietosuoja@insulinbuddy.fi. Logs containing technical data are kept for at most 30 days. Vercel may also keep technical logs for its own purposes under its privacy policy.

6. Contacting us and launch notifications

When you email us – for example to request test credentials, to give feedback, or to ask to be notified when the app launches in the app stores – we process your email address, your name if you give it, and the content of your message.

• Purpose: to reply to your message, to send test credentials and to send the launch notification you asked for.
• Legal basis: for enquiries, the controller's legitimate interest in replying to messages (Article 6(1)(f)); for launch notifications, your consent (Article 6(1)(a)). You can withdraw your consent at any time by writing to support@insulinbuddy.fi. For a child under 13, consent is given by a guardian.
• Retention: messages for 12 months from the last message; addresses received for the launch notification are deleted once the notification has been sent.
• Recipients: Google (email mailbox), which stores the messages on the controller's behalf. Data may be transferred to the United States, and such transfers are based on the European Commission's standard contractual clauses; a copy of the clauses is available from tietosuoja@insulinbuddy.fi.

Please do not send us health data by email – we do not need it to answer support requests.

7. Purchases

When you buy access to the browser version, we process your email address, billing country (to determine the tax), Stripe's payment and session identifiers, the amount and the timestamps of the purchase, any refund and the sign-in links. The sign-in code sent with the sign-in link is stored only as a hash in the same row as the link, and it is deleted with the link. No health data reaches the server.

• Purpose: to provide the access, send sign-in links, handle refunds, keep accounts and prevent abuse.
• Legal basis: contract (Article 6(1)(b)); for the accounting records of the purchase, the accounting obligation (Article 6(1)(c)); for IP addresses, the controller's legitimate interest in protecting the service against abuse (Article 6(1)(f)). Your email address is needed to deliver the access; without it the purchase cannot be made.
• Retention: data on valid access for as long as the access is valid; data on refunded or revoked access is deleted within 97 days of the refund or revocation; sign-in links and IP addresses stored to prevent abuse within 8 days. Accounting records of the purchase are kept for the period required by the Finnish Accounting Act.
• Recipients: Resend (sending sign-in links) and Neon (access and account database, data stored in the EU) are processors under data processing agreements. They are US companies, and any transfers to the United States are based on the European Commission's standard contractual clauses; a copy of the clauses is available from tietosuoja@insulinbuddy.fi.

Payment is processed by Stripe on its own checkout page. Your card and other payment details go to Stripe, never to us. Stripe acts as our processor for payment processing and as an independent controller for its own purposes, such as fraud prevention and its legal obligations. Our contracting party is Stripe Payments Europe, Limited (Ireland). Data may be transferred to Stripe's US group company; such transfers are based on the EU-U.S. Data Privacy Framework and the European Commission's standard contractual clauses; a copy of the clauses is available from tietosuoja@insulinbuddy.fi. Stripe passes us the data listed above. Stripe's own processing is described in its privacy policy.

Mobile apps. In the iOS app, the trial and the purchase are handled by Apple (App Store), and in the Android app, the purchase is handled by Google (Google Play), under their own terms; the start of the Android app's free trial is stored only on the device (section 3). The app only asks them whether the trial or purchase is active and does not send purchase data to us. Apple and Google are independent controllers for the purchases. We receive sales and payout information from them for bookkeeping (for example the order number, time, price and country), but not your payment details, and keep it for the period required by accounting law (legal obligation, Article 6(1)(c)). Apple's and Google's own processing is described in their privacy policies (Apple, Google).

8. Organisation access

When an organisation orders access, we process the contact person's name, email address and phone number and the organisation's billing details. The organisation's account stores the organisation's name, its shared login name and the order details; the contact person's details are not part of the account data. The contact person sets the account's password with a link sent by email.

• Purpose: to deliver and invoice the order, to manage the organisation's account and to prevent abuse.
• Legal basis: for the contact person's data, the controller's legitimate interest in performing the contract with the organisation (Article 6(1)(f)); for billing data, the accounting obligation (Article 6(1)(c)); for IP addresses, the controller's legitimate interest in protecting the service against abuse (Article 6(1)(f)).
• Retention: account data for the duration of the contract; the contact person's name, email address and phone number for the duration of the customer relationship; data of a closed account is deleted 12 months after closing; billing data for the period required by the Finnish Accounting Act; IP addresses of sign-in and order attempts within 8 days.
• Recipients: Resend (order confirmations and password links) and Neon (account register), as in section 7.

9. Children's data

The app may also be used by children and adolescents together with the people close to them. The app does not send a child's data to the controller, so using the app does not require a guardian's consent to data processing. Subscribing to the launch notification is based on consent, and for a child under 13 it is given by a guardian (Finnish Data Protection Act, section 5).

10. Medical disclaimer

Insulin Buddy is intended solely for educational and illustrative purposes. The app does not replace the instructions of a treating physician or diabetes care team. Always follow the guidance of your diabetes clinic.

11. Your rights

You have the right to access the data concerning you, to have it rectified or erased, to restrict its processing, to object to processing based on legitimate interest, to data portability and to withdraw your consent. Requests concerning email, purchases, organisation accounts and technical data: tietosuoja@insulinbuddy.fi.

The app data stored on your device is in your hands alone: you can view, change and delete it yourself (see section 3).

You also have the right to lodge a complaint with a supervisory authority. In Finland: the Office of the Data Protection Ombudsman, tietosuoja.fi.

12. Marketing website (insulinbuddy.fi)

The marketing website uses no cookies and no analytics, and none of its pages loads third-party content or connects to third parties. The buy button takes you to Stripe's checkout page, which is covered in section 7. If you switch the site's theme, your choice is stored in your browser; it contains no personal data and never leaves your device. Delivery of the pages is described in section 5.

13. Contact

Privacy matters: tietosuoja@insulinbuddy.fi
General app feedback: support@insulinbuddy.fi

14. Changes to this policy

This policy may be updated. Material changes will be announced on this page. The latest update date is shown at the top of this page.