Sweet PalPrivacy Notice
This is a translation. If the two versions differ, the Italian text prevails.
1. Who processes your data
The data controller is F-T srl, Via Bianca di Savoia 17, 20122 Milan, Italy — info@ef-ti.com.
2. What Sweet Pal is
Sweet Pal is an iPhone app for people living with type 1 diabetes. It keeps the diary of the day — glucose, meals, insulin, movement — and reasons about it with you: it shows charts and statistics, recognises recurring habits, shows how your glucose went after a meal or an activity, projects the trend of the next hours and lets you simulate, for illustration, the effect of a meal, an activity or a bolus.
Part of this work is done by artificial intelligence models: the chat conversation, reading meal photos, the texts that accompany the charts.
Sweet Pal is not a medical device and does not suggest insulin doses. The doses you see in the app are the ones you record; forecasts and simulations help you understand your data and can be wrong. You decide your therapy, with your diabetes doctor.
3. What data we process
3.1 Account data
Email address; name; profile photo, if you upload one; date of birth, to check that you are an adult; how you sign in (Apple, Google, or email with a verification code). We never see your credentials: sign-in is handled by our authentication provider.
3.2 Health data (special category, Art. 9 GDPR)
- Glucose readings: read from Apple Health (so from the sensor or meter that writes to it) and those you enter by hand, with time and circumstance.
- Therapy profile: diabetes type, years since diagnosis, sensor use, basal insulin schedule, insulin-to-carb ratio, insulin sensitivity factor, rapid insulin type, target glucose range.
- Insulin: the doses you record, including the usual ones you tell us.
- Meals: foods, quantities, carbohydrates and other nutrients, time; the photos of meals you choose to take.
- Physical activity: steps, workouts, exercise minutes, energy, heart rate.
- Other parameters: weight, body mass index, blood pressure, water intake.
- What you write or dictate: chat messages, notes, answers to the initial questions. They are free text and can contain whatever you decide to tell. Voice dictation is transcribed by Apple's speech recognition service; we only receive the text.
3.3 Context data
If you connect your calendar, we read the title and time of the day's appointments, read-only, to take them into account in the conversation. No event is changed and the calendar is not copied.
3.4 What we derive
Daily, weekly and time-of-day summaries; glucose response to meals and activities; correlations between habits and glucose; recognised recurrences; forecasts; summaries of past conversations and an archive of facts you told us, which the app uses so it does not ask you the same thing twice. You can make it forget these facts from the chat or from settings.
3.5 Subscription and credits
Your plan (Expert or Pro), start, renewal and expiry dates, any trial period, credit packs bought and credits used. Payment is handled by Apple: we receive the signed transaction confirmation from the App Store, never your card details.
3.6 Technical data
A log of calls to the AI models: request identifier, model used, number of tokens, cost, duration, outcome and any error. It does not contain the text of the question or the answer.
3.7 App usage analytics
Which screen you open and for how long, which features you use, which proposals you accept or decline, the assistant's response time, plus technical information (app and system version, device model, language, session identifier) and the current plan. No health data enters these events: no glucose value, no carbohydrate amount, no dose, no food name, no text. This is a technical constraint, not a policy: event parameters only accept numbers, durations, yes/no values and predefined labels, and the database rejects free text.
3.8 Consents
Every consent and every withdrawal is recorded with the date and the version of the document in force at that moment: consent to health data processing, acceptance of the Terms and this notice, data study, use of real data in simulators, calendar access, analytics.
4. Why we process it, and on what legal basis
| Purpose | Legal basis |
|---|---|
| Providing the service: diary, charts, statistics, forecasts, simulations, conversation | Explicit consent to health data processing — Art. 9(2)(a) GDPR — collected in the app before use; for non-health data, performance of the contract — Art. 6(1)(b) |
| Creating and managing the account, checking you are an adult | Performance of the contract — Art. 6(1)(b) |
| Managing subscription, free trial and credits | Performance of the contract — Art. 6(1)(b) |
| Security, abuse prevention, control of processing costs | Legitimate interest — Art. 6(1)(f) |
| Usage analytics on our servers | Legitimate interest — Art. 6(1)(f); you can object from settings |
| Usage analytics through Google Analytics | Consent, off until you give it, revocable from settings |
| Improving the product by studying data in aggregate form | Separate, revocable consent ("Study my data"), off by default |
| Legal obligations (including tax) | Legal obligation — Art. 6(1)(c) |
You can withdraw consent to health data processing at any time. Since it is the basis on which the app works, withdrawing it means stopping using the app: from then on we will no longer process your health data, and you can ask for its deletion or delete the account directly.
5. Where the data goes, and who sees it
Data is stored with Supabase, which provides us with database, authentication, file storage and server functions, in a data centre in the European Union (Frankfurt, Germany).
For features that need artificial intelligence, the content needed to answer is sent to the model providers, who process it on our behalf as processors and do not use it to train their models:
| Provider | What it receives | Where |
|---|---|---|
| Fireworks AI | Conversation messages and their context: the day's data, the therapy profile, the day's appointments if you connected the calendar | United States |
| Anthropic | Depending on the feature and the plan: meal photos, to recognise what they contain, or parts of the conversation | United States |
| OpenAI | The text of the question, turned into a numeric vector to search the diabetes knowledge base; depending on the plan, parts of the conversation | United States |
| Passio | The name of the food you search for, to find its nutritional values. No data that identifies you | United States |
Other services the app uses:
| Service | What for |
|---|---|
| Apple | Sign in with Apple, Apple Health, App Store payments, speech recognition for dictation |
| Sign in with Google, if you choose it; Google Analytics for Firebase, only if you consent to analytics (§3.7) |
Transfers outside the European Union rely on the Standard Contractual Clauses approved by the European Commission or, for providers that adhere to it, on the EU-US Data Privacy Framework.
We do not sell your data. We do not pass it on to advertisers. There is no advertising in the app. We do not use the device advertising identifier (IDFA) and we do not track you across other companies' apps or websites.
6. Apple Health
The app reads glucose, nutrients, activity and vital signs from Apple Health, and writes to it the nutrients of the meals you record, so they remain available to the other apps you use. You grant the permission, metric by metric, and can revoke it whenever you want from iOS settings. Apple Health data is not used for advertising or marketing profiling, and is not passed on to third parties other than the providers in §5, to answer you.
7. Notifications
The app can send you reminders and summaries as local notifications, generated by the iPhone. If the text of a notification was prepared by the server, it was prepared with the same providers listed in §5.
8. The sweetpal.ai website
- Visit statistics. The site uses Google Tag Manager and Google Analytics 4 to understand which pages are read and which buttons are used. On your first visit we ask you to choose; until you choose, and if you decline, Google Tag Manager is not even loaded: your browser does not contact Google and receives no analytics cookies. They are enabled only if you accept. You can change your mind at any time from "Cookie preferences", at the bottom of every page. There are no advertising cookies and no profiling.
- Contact form. If you write to us, we keep the reason, email, name and phone if you leave them, the message, the language and the time of consent, to answer you and to improve the app when it is feedback. Legal basis: your request and the consent you give by sending the form.
- Spam protection. The form uses Cloudflare Turnstile, which evaluates technical browser signals to tell people from automated programs.
9. How long we keep data
| Data | How long |
|---|---|
| Account, diary, conversations, memory | As long as the account exists |
| Raw analytics events | 13 months, then only in aggregate, anonymous form |
| Technical log of model calls | 12 months |
| Subscriptions and purchases | As long as required by tax and accounting obligations |
| Consent records | As long as the account exists, to be able to prove consent was given |
| Messages sent from the website | Until you ask us to delete them |
When you delete your account in the app, the linked data is removed from the database immediately; backups are overwritten within 30 days. The subscription is cancelled from your Apple account settings: deleting the account does not stop it by itself, and the app reminds you.
10. Minors
Sweet Pal is intended for adults. Anyone who indicates an age under 18 cannot access the app's features. If you believe a minor has given us data, write to us and we will delete it.
11. Your rights
You can request: access to your data, rectification, erasure, restriction, portability, objection to processing based on legitimate interest, and withdrawal of consent at any time (withdrawal does not affect processing already carried out).
Inside the app you can already: edit your profile data, make the assistant forget what you told it, turn off optional consents and analytics, delete the account and with it the data.
For everything else: info@ef-ti.com. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or with the authority of your country.
12. Automated decisions
Sweet Pal calculates statistics, forecasts and simulations automatically, but no decision is taken in your place and none has legal effects on you: the app does not suggest doses, does not administer anything and does not control any device.
13. Security
Data travels encrypted. Each database row is accessible only to its owner, through rules enforced by the database itself and not by the app. The AI providers' keys are not contained in the app: they live on the server.
14. Changes
When this notice changes substantially, the app asks you to accept it again: every acceptance is recorded with the version of the text it refers to. The version in force is shown at the top of this document.