Privacy Policy

1. Introduction

This Privacy Policy describes how F-T srl ("Company", "we", "us", or "our"), a company registered under Italian law, collects, uses, stores, and protects your personal data when you use the SWEETPAL mobile application (the "App").

SWEETPAL is a personal diary and memory assistant for people living with diabetes. It is not a medical device — it does not perform diagnoses, generate predictions, or provide medical recommendations.

We process personal data in compliance with GDPR (EU) 2016/679, the Italian Privacy Code (Legislative Decree 196/2003 as amended), and all applicable data protection laws.

2. Data Controller

• –Company: F-T srl
• –Address: Via Bianca di Savoia 17, 20122 Milan, Italy
• –Email: info@ef-ti.com

3. Data We Collect

3.1 Diary Entries and Personal Logs

Blood glucose readings, insulin records, carbohydrate counts, meal descriptions, activity notes, and any other entries you voluntarily record. These may contain health-related information and are treated as special category data under Article 9 GDPR, processed solely on the basis of your explicit consent.

3.2 Account Information

Name, email address, date of birth, and authentication credentials.

3.3 Alpha Waitlist Data

If you register for the alpha programme, we collect your email address and phone number exclusively to:

• –Manage your access to the alpha programme
• –Contact you for helpline support if needed

This data is never used for marketing and is never shared with third parties.

3.4 Device and Usage Data

Device type, OS version, app version, language settings, crash logs, and anonymized usage analytics — used only to improve the App.

3.5 AI Context Data

Interactions with the AI assistant, used exclusively to retrieve relevant past diary entries. Never used for advertising or profiling.

4. Legal Basis for Processing

• –Explicit Consent (Art. 9(2)(a) GDPR) — for diary entries containing health data and for alpha waitlist data. You may withdraw consent at any time.
• –Performance of a Contract (Art. 6(1)(b) GDPR) — for account information necessary to provide the App's services.
• –Legitimate Interest (Art. 6(1)(f) GDPR) — for device and usage data to maintain, secure, and improve the App.

5. How We Use Your Data

• –Provide core App functionality: diary storage and AI-assisted recall
• –Perform basic mathematical calculations (e.g. carbohydrate counting)
• –Manage alpha programme access and helpline support
• –Maintain and improve App quality, safety, and performance
• –Manage your account and subscription
• –Communicate service updates, security alerts, and support
• –Comply with legal obligations

6. Data Storage and Security

• –Encrypted in transit (TLS 1.3) and at rest (AES-256)
• –Stored on servers within the European Economic Area (EEA)
• –Access controls, regular security audits, and secure infrastructure

7. Data Retention

We retain your data for as long as your account is active. Alpha waitlist data is retained only for the duration of the programme. Upon account deletion, all personal data is permanently deleted within 30 days.

8. Data Sharing and Third Parties

We do not sell, rent, or trade your personal data. We may share it only:

• –With trusted service providers operating the App infrastructure, under strict data processing agreements
• –Where required by law, regulation, or enforceable governmental request
• –In connection with a merger or acquisition, with prior notification to you

9. Your Rights

• –Access (Art. 15) — request a copy of your personal data
• –Rectification (Art. 16) — correct inaccurate or incomplete data
• –Erasure (Art. 17) — request deletion of your personal data
• –Restriction (Art. 18) — limit processing in certain circumstances
• –Portability (Art. 20) — receive your data in machine-readable format
• –Object (Art. 21) — object to processing based on legitimate interest
• –Withdraw Consent — at any time via app settings or by contacting us

Contact us at info@ef-ti.com — we respond within 30 days. You may also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).

10. Children's Privacy

SWEETPAL is not intended for children under 16 without parental consent, in accordance with Article 8 GDPR and Italian law.

11. Changes to This Policy

We may update this policy from time to time. We will notify you of material changes through the App or by email.

12. Contact Us

• –F-T srl
• –Via Bianca di Savoia 17, 20122 Milan, Italy
• –Email: info@ef-ti.com