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Legal Document

Privacy Policyfor SugarCare

✓ UK GDPR Compliant

Last Updated: February 15, 2026

1

Introduction

Welcome to SugarCare — a digital health platform available via mobile app and web, designed to help individuals with diabetes monitor, track, and manage their blood sugar levels through data analytics and AI-powered insights.

SugarCare is operated by SugarCare Technologies Ltd. ("we", "our", or "us").

This Privacy Policy explains how we collect, use, store, and protect your personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

By using SugarCare, you agree to this Privacy Policy. If you do not agree, please discontinue use of the app and web platform.

2

Data Controller

The data controller responsible for your personal data is:

SugarCare Technologies Ltd.

📍Registered Office: London, United Kingdom

📧Email: support@sugarcare.cloud

3

What Data We Collect

We may collect and process the following categories of personal data:

aAccount Information

  • Name, email address, and password
  • Demographic data (e.g., age, gender, region)

bHealth and Lifestyle Data

  • Blood glucose readings (manual or device-synced)
  • Meal details and nutritional logs
  • Exercise, medication, and sleep patterns
  • HbA1C levels and related health data
  • Fasting and daily habits

cAI/ML Data

  • Uploaded food images (for nutrition estimation)
  • Chat interactions with the AI assistant
  • Predictive glucose alerts and insight data

dDevice & Technical Information

  • Device model, operating system, and IP address
  • Usage analytics, app activity, and crash reports
  • Location data (if enabled by user)
4

Lawful Basis for Processing

Under UK GDPR, we process your personal data based on the following legal grounds:

PurposeLegal Basis
To provide app services and account accessPerformance of a contract
To deliver AI-driven recommendationsLegitimate interest
To process health data and analyticsExplicit consent
To improve features, UI, and AI modelsLegitimate interest
To send updates or notificationsConsent
To comply with legal obligationsLegal requirement

You may withdraw your consent at any time via your account settings or by contacting us at support@sugarcare.cloud.

5. How We Use Your Data

We use your information to:

  • Track and display your glucose readings and health progress
  • Generate AI insights and recommendations based on your patterns
  • Forecast possible sugar spikes or drops
  • Suggest meals and fasting plans tailored to your lifestyle
  • Predict long-term risks (e.g., neuropathy, retinopathy)
  • Conduct anonymised analytics to improve the platform
  • Ensure compliance and maintain system security

6. AI and Machine Learning Use

SugarCare integrates Artificial Intelligence (AI) and Machine Learning (ML) models to personalize your experience responsibly.

  • Predictive Models: Use historical glucose and lifestyle data to predict trends.
  • Food Image Recognition: Automatically estimate nutritional values from uploaded food photos.
  • Explainable AI: We employ Explainable AI techniques (e.g., SHAP, IG) to make our predictions transparent.
  • Personalised Risk Forecasting: Identifies potential long-term health risks based on trends.
  • Community Insights: Aggregated and anonymised data may be used to identify broader lifestyle trends without identifying individual users.

All AI processing involving sensitive health data is done securely and only with explicit user consent.

7. Data Sharing and Transfers

We do not sell or rent your personal data.

We may share limited data only under these circumstances:

  • Service Providers: With trusted partners who assist in cloud hosting, analytics, or communication — all bound by data protection agreements.
  • Medical Professionals: Only with your explicit consent.
  • Legal Authorities: When required by law or government request.
  • Aggregated Research: Non-identifiable data may be used for public health research or product improvement.

If we transfer your data outside the UK (e.g., to secure cloud servers), we ensure appropriate safeguards such as UK International Data Transfer Agreements (IDTA) or adequacy decisions approved by the UK ICO.

8. Data Security

We implement strong encryption (SSL/TLS) and industry-standard measures to protect your personal and health data from unauthorized access, loss, or alteration.

Access to data is strictly limited to authorized personnel bound by confidentiality agreements.

9. Data Retention

We retain your data only for as long as necessary to provide our services or comply with legal obligations.

You can request account deletion at any time by contacting support@sugarcare.cloud.

Upon deletion, your data will be securely erased within 30 days unless retention is required by law.

10. Your Rights (Under UK GDPR)

As a UK user, you have the following rights:

  • Right to Access – Request a copy of your personal data.
  • Right to Rectification – Correct inaccurate or incomplete data.
  • Right to Erasure ("Right to be Forgotten") – Request deletion of your data.
  • Right to Restrict Processing – Limit how your data is used.
  • Right to Data Portability – Receive your data in a machine-readable format.
  • Right to Object – Object to data processing under legitimate interests.
  • Right to Withdraw Consent – Withdraw consent for any processing at any time.

To exercise these rights, please contact us at support@sugarcare.cloud.

If you are not satisfied with our response, you may file a complaint with the Information Commissioner's Office (ICO) at https://ico.org.uk/.

11. Cookies and Tracking

Our website uses cookies and similar technologies to enhance functionality and analyze traffic.

You can manage or disable cookies through your browser settings.

For more details, see our Cookie Policy.

12. Children's Privacy

SugarCare is not designed for children under 13 years old.

We do not knowingly collect personal data from minors.

If we discover such data, it will be promptly deleted.

13. Policy Updates

We may update this Privacy Policy from time to time.

All updates will be posted on our website and within the app, indicating the "Last Updated" date above.

Significant changes will be communicated to users via email or in-app notifications.

14

Contact Us

If you have questions, concerns, or requests related to your personal data, please contact:

Data Protection Officer (DPO)

📧support@sugarcare.cloud

📍SugarCare Technologies Ltd., London, United Kingdom