Privacy Policy

1. Introduction

Flona ("Flona," "we," "us," or "our") provides a mobile and web application designed to help people living with diabetes manage insulin doses, carbohydrate intake, and day-to-day diabetes-related decisions. This Privacy Policy explains what personal and health-related information we collect, why we collect it, how we use and protect it, and what choices and rights you have.

Because Flona handles sensitive health information, we have written this policy to be as clear and specific as possible about our data practices. By creating an account or using Flona, you agree to the collection and use of information as described here. If you do not agree, please do not use the application.

This policy is designed to be consistent with common privacy regulations, including the EU/UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and other applicable data protection laws. Depending on your location, you may have additional rights beyond those described below, and where local law provides greater protection, that law controls.

2. Information we collect

We collect the following categories of information:

2.1 Account information

• Name, email address, and password (or authentication token if you sign in via a third-party identity provider).
• Optional profile details such as date of birth, sex, diabetes type, and diagnosis date, where you choose to provide them.

2.2 Health and diabetes-management data

• Blood glucose readings (manually entered or imported from a connected device or CGM, where supported).
• Insulin dose logs, including type of insulin, units, and timing.
• Carbohydrate, protein, and other nutritional data associated with logged meals.
• Notes, tags, symptoms, or other diabetes-related entries you choose to record.
• App usage patterns related to your logging and review habits, used to power reminders and summaries.

2.3 Food images

• Photos you take or upload of meals for the purpose of AI-based nutritional estimation.

2.4 Device and technical data

• Device type, operating system, app version, and unique device identifiers.
• IP address, general location (derived from IP), crash logs, and diagnostic data.

2.5 Communications

• Waitlist and account emails, support requests, and any messages you send us.

3. Food images and AI analysis

Flona offers an optional AI-powered feature that analyzes photos of your meals to estimate nutritional values, including carbohydrates, protein, and other relevant information.

• When you use this feature, your food image is securely transmitted to our AI processing service (operated by us or a contracted third-party AI provider, see Section 7) for analysis.
• The AI-generated nutritional estimate is returned to the app and, if you choose to save it, stored as part of your meal log.
• Images may be temporarily processed by our AI provider to generate results. We do not use your food images to identify you personally, and we do not sell food images to third parties.
• We retain uploaded food images only as long as reasonably necessary to provide the feature and maintain your meal history, or until you delete the associated log entry or your account, whichever is sooner. You can remove individual images and logs at any time from within the app.

4. USDA food search

As an alternative to AI-based estimation, Flona provides a food search feature that draws nutritional information from the USDA FoodData Central database, a public database maintained by the U.S. Department of Agriculture.

• When you search for a food item, your query is used to retrieve matching entries and their published nutritional values (including carbohydrates and protein) from USDA FoodData Central.
• You are required to enter the food weight or serving size so Flona can calculate nutritional values accurately based on the USDA reference data.
• Search queries may be logged in aggregate to improve search relevance and app performance, but are not combined with USDA data in a way that identifies you to the USDA or any third party.

Because USDA FoodData Central values are drawn from a verified public database rather than an AI estimate, users who want the highest confidence in nutritional accuracy are encouraged to use food search rather than photo-based AI analysis.

5. How we use your information

We use the information described above to:

• Provide, operate, and maintain the core features of Flona, including logging, tracking, reminders, and daily summaries.
• Generate AI-powered insights, patterns, and food-image estimates to help you understand your data.
• Calculate nutritional values from USDA FoodData Central based on your search and serving-size input.
• Personalize reminders, insights, and app content based on your logged history.
• Maintain the security, integrity, and reliability of the app, including fraud prevention and abuse detection.
• Communicate with you about your account, product updates, and, where you have consented, marketing or waitlist communications.
• Analyze aggregated, de-identified usage trends to improve Flona's features and user experience.
• Comply with legal obligations and enforce our Terms of Service.

We do not use your health data to make automated medical decisions on your behalf, and we do not sell your personal or health data.

6. Legal basis for processing (GDPR)

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with similar requirements, we rely on the following legal bases to process your personal data:

• Consent — for health data, food images, AI analysis, and marketing communications, we rely primarily on your explicit, freely given consent, which you may withdraw at any time.
• Performance of a contract — to provide the core functionality of the app that you have signed up to use.
• Legitimate interests — for security, fraud prevention, and product improvement, balanced against your rights and interests.
• Legal obligation — where processing is required to comply with applicable law.

Health data is treated as a "special category" of data under GDPR. We only process it with your explicit consent, obtained during account setup and reaffirmed whenever you use health-related features for the first time.

7. Third parties and sharing

We work with a limited number of trusted service providers to operate Flona. We share only the data necessary for each provider to perform its function, under contractual confidentiality and data-protection obligations.

We do not sell your personal information or health data. We may disclose information if required by law, to protect the rights and safety of Flona, our users, or the public, or in connection with a merger, acquisition, or sale of assets, subject to continued protection under a policy at least as protective as this one.

8. Data security

We apply industry-standard technical and organizational measures to protect your data, including:

• Encryption of data in transit (TLS) and at rest.
• Access controls limiting employee and contractor access to personal and health data on a need-to-know basis.
• Regular review of our security practices and infrastructure.
• Secure authentication, including support for strong passwords and, where available, additional verification steps.

No method of transmission or storage is 100% secure. While we work hard to protect your information, we cannot guarantee absolute security. If we become aware of a data breach affecting your personal data, we will notify you and relevant authorities as required by applicable law.

9. Data retention

We retain your personal and health data for as long as your account is active, or as needed to provide you with Flona's features. If you delete your account, we will delete or anonymize your personal and health data within a reasonable period, except where we are required to retain certain information for legal, tax, security, or dispute-resolution purposes.

You can request deletion of specific entries (such as a food image or log) at any time within the app, or request full account deletion as described in Section 10.

10. Your rights

Depending on your location, you have some or all of the following rights regarding your personal data:

• Access — request a copy of the personal data we hold about you.
• Correction — request that we correct inaccurate or incomplete data.
• Deletion — request deletion of your personal data, including full account removal.
• Portability — request a copy of your data in a structured, machine-readable format.
• Restriction & objection — request that we limit certain processing, or object to processing based on legitimate interests.
• Withdraw consent — withdraw consent for health data processing or AI features at any time, without affecting the lawfulness of processing before withdrawal.
• Non-discrimination — you will not receive discriminatory treatment for exercising your privacy rights.

You can exercise most of these rights directly within the app under Account Settings, including editing your profile, deleting individual entries, or deleting your account. For requests you cannot complete in-app, contact us using the details in Section 15. We will respond within the timeframe required by applicable law (generally within 30 days).

11. Children's privacy

Flona is intended for use by adults and, where a parent or legal guardian manages the account on behalf of a minor with diabetes (for example, a child with Type 1 Diabetes), by that parent or guardian. Flona is not directed at children for independent, unsupervised use. If we become aware that a child has created an account without appropriate parental or guardian involvement, we will take steps to remove the relevant data, consistent with applicable law such as COPPA or GDPR provisions on children's data.

12. International data transfers

Flona may store and process data in countries other than your own, including countries that may have different data protection laws. Where we transfer personal data internationally, we use appropriate safeguards, such as standard contractual clauses or equivalent mechanisms recognized under applicable law, to protect your information.

13. Medical disclaimer

14. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. If we make material changes, we will notify you via the app or by email before the changes take effect. The "Effective date" at the top of this page indicates when this policy was last revised. Continued use of Flona after changes take effect constitutes acceptance of the updated policy.

15. Contact us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us: