BP & SugarBP & Sugar › Privacy Policy
Privacy Policy
1. Data controller
Controller: Eneko Careaga, an individual resident in Spain (the “Owner”). Tax ID (NIF) and postal address are provided free of charge on request at tostorifapps@proton.me.
Contact for any privacy matter and to exercise your rights: tostorifapps@proton.me. Appointing a Data Protection Officer is not mandatory (art. 37 GDPR, art. 34 Spanish LOPDGDD).
2. Core principle: your health data never leaves your device
BP & Sugar (the “App”) works locally. The readings you enter (blood pressure, blood sugar, weight, heart rate, SpO2, temperature, cholesterol, symptoms, medications and notes) and your profile details (name, health conditions) are stored only on your device, encrypted with a key kept in the iOS secure keychain. The Owner runs no servers that receive this data and cannot access, sell or share it.
This is special-category data (art. 9 GDPR). It is processed on your device on the basis of your explicit consent, given when you accept this policy during setup (art. 9.2.a GDPR), and to provide the service you request (art. 6.1.b GDPR). You can withdraw consent at any time by deleting your data or the App, without affecting the lawfulness of prior processing.
3. What data, why, on what legal basis and for how long
| Processing | Data | Purpose | Legal basis | Retention |
|---|---|---|---|---|
| Health journal | Readings and profile you enter | Logging, charts, reminders and reports | Explicit consent (art. 9.2.a) and performance of the service (art. 6.1.b) | On your device until you delete it |
| Apple Health (optional) | Weight, heart rate, steps, oxygen | Import and, if you choose, write readings | Explicit consent via iOS permissions (art. 9.2.a) | On your device; revoke any time in Settings |
| Pulse check (optional) | Camera frames | Estimate your pulse | Consent (camera permission) | Not stored; processed in memory |
| Local reminders | Times you choose | Check and medication reminders | Performance of the service (art. 6.1.b) | On your device |
| Push notifications (optional) | Push token, language, app version, Premium status | Send reminders and tips | Consent (notification permission, art. 6.1.a) | Until you withdraw permission or ask us |
| Advertising (free users) | Advertising ID (if allowed), IP, device data, ad interactions | Show and measure ads | Personalized: consent (art. 6.1.a GDPR, art. 22.2 LSSI). Non-personalized: legitimate interest in funding the free App (art. 6.1.f) | Per Google’s privacy policy |
| Purchases | Anonymous app user ID, receipts | Unlock and keep Premium | Performance of the contract (art. 6.1.b) | While the subscription exists and legal periods apply |
| Email contact | Your email and message | Answer your request | Consent and legitimate interest (art. 6.1.a and f) | Until resolved, then max. 12 months |
We never send your health readings or medical conditions to third parties. The App makes no automated decisions with legal effects on you (art. 22 GDPR); zones and estimates are informational.
Analytics: the App currently sends no usage analytics. If this changes, we will ask for your prior consent and update this policy.
4. Recipients and processors
- Apple Distribution International Ltd. (Ireland): App distribution, payments and Apple Health.
- Google Ireland Ltd. / Google LLC: advertising (AdMob) and the consent form (UMP).
- OneSignal, Inc. (USA): push notifications, if enabled.
- RevenueCat, Inc. (USA): subscription management.
No data is disclosed to third parties unless required by law.
5. International transfers
Some providers are in the United States. Transfers rely on the EU-US Data Privacy Framework (Commission adequacy decision of 10 July 2023) where the provider is certified and otherwise on the European Commission’s Standard Contractual Clauses (art. 46.2.c GDPR). Ask us for details at tostorifapps@proton.me.
6. Your rights
You can exercise free of charge your rights of access, rectification, erasure, objection, restriction and portability, and withdraw consent at any time, by writing to tostorifapps@proton.me. If we have reasonable doubts about your identity we may ask for additional information. We reply within one month (art. 12 GDPR).
As your health data is on your device, you can also view, export (PDF/CSV) and delete it directly in the App.
You may lodge a complaint with the Spanish Data Protection Agency (AEPD), C/ Jorge Juan 6, 28001 Madrid — www.aepd.es, or with the authority of your country of residence.
7. Minors
The App is not directed to children under 14. Under art. 7 LOPDGDD, children under 14 may only use it with consent from a parent or guardian, who can manage a family profile on their behalf.
8. Security
We apply appropriate technical and organizational measures (art. 32 GDPR): local database encryption, encrypted connections to providers and minimization of the data leaving your device.
9. Changes
We may update this policy for legal or App changes. The date at the top shows the latest version and relevant changes will be announced in the App.