Last updated: 18 June 2026
The Sugar Sense application (“App”) is licensed, not sold, to you (“you” or “your”) by Retarget OÜ, a private limited company registered in Estonia (VAT EE102572290), with its registered office at Sepapaja tn 6, 15551 Tallinn, Estonia (“Retarget OÜ,” “we,” “us,” “our,” or “Licensor”). This End User License Agreement (“EULA”) is a binding agreement between you and Licensor that governs your licence to use the App software.
By downloading, installing, or using the App, you acknowledge that you have read, understood, and agree to be bound by this EULA. If you do not agree, you may not use the App.
This EULA covers the software licence. Your use of the Sugar Sense services is also governed by our Terms of Use and our Privacy Policy, which are incorporated into this EULA by reference. In the event of any conflict between this EULA and the Terms of Use regarding your use of the Services, the Terms of Use prevail. Capitalised terms not defined here have the meaning given in the Terms of Use.
1. Eligibility
The App is not directed to children. You must be at least the age at which you can validly consent to information-society services under the law of your country of residence (in Estonia, 13 years), and any minor who uses the App must do so with the active involvement of a parent or guardian who has read and accepted this EULA. Because the App processes health data, parental or guardian involvement is required for any permitted use by a minor.
2. Scope of License
Subject to your compliance with this EULA, Licensor grants you a limited, non-exclusive, revocable, non-sublicensable, and non-transferable licence to install and use the App on Apple-branded devices that you own or control, for your personal, non-commercial use, in accordance with the Apple App Store Terms of Service and the usage rules set out therein.
You may not transfer, redistribute, or sublicense the App. Except only to the extent permitted by applicable law or by the licence terms of any open-source components included in the App, you may not copy, reverse-engineer, disassemble, attempt to derive the source code of, modify, or create derivative works of the App. You may not remove, alter, or obscure any proprietary notices, and you may not disable or circumvent any security feature of the App.
3. Ownership
a. As between you and Licensor, you retain ownership of the content and personal data you provide through the App. Licensor’s use of that content and data is governed by the Privacy Policy.
b. Licensor and its licensors own the App, the associated services, and all intellectual-property and proprietary rights in them. All names, logos, designs, and marks associated with the App are trademarks of Licensor or its licensors and may not be used without prior written consent.
c. If you provide suggestions or feedback about the App, you grant Licensor a non-exclusive, royalty-free, worldwide licence to use that feedback to improve the App and the services, without obligation to you.
4. Privacy and Data
The App connects to your existing CGM provider account (Abbott LibreLinkUp or, optionally, Dexcom Share) and processes health data such as your glucose readings and the events you log. All personal data collected through the App is processed in accordance with our Privacy Policy, which describes what we collect, the legal bases on which we rely (including your explicit consent for health data under GDPR Article 9(2)(a)), the recipients and sub-processors involved, international transfers, retention, and your rights. By using the App you acknowledge the Privacy Policy.
5. Medical and Safety Disclaimer
The App is not a medical device and is not a substitute for professional medical advice, diagnosis, or treatment, or for your primary CGM reader or receiver and its built-in alarms.
The App is intended to provide supplemental information and convenience features only, to assist you in viewing, recording, and reviewing your diabetes-related data. It is not intended to diagnose, cure, mitigate, treat, or prevent any disease or condition, and it does not make treatment or dosing decisions for you. Where the App is used in connection with a CGM or other medical device, you must use the manufacturer-approved reader, receiver, or app as the primary and authoritative display, and keep its urgent alarms enabled.
Glucose data, alerts, notifications, and the optional emergency-call feature depend on third-party CGM services, the internet, and Apple’s push system, and may be delayed, missing, or fail. Any AI-assisted feature provides estimates only and is dose-free: it never provides insulin doses, units, carbohydrate ratios, or correction factors. You must not rely on the App as your sole means of detecting low or high glucose, and in an emergency you must call your local emergency number (such as 112 or 911) and seek professional medical care. Further detail is set out in the Terms of Use.
6. Disclaimer of Warranty
To the maximum extent permitted by applicable law, the App and the services are provided on an “as is” and “as available” basis, with all faults and without warranty of any kind, whether express, implied, or statutory, including any implied warranties of merchantability, satisfactory quality, fitness for a particular purpose, accuracy, security, and non-infringement. Licensor does not warrant that the App will meet your requirements, be uninterrupted, timely, secure, or error-free, or that data will not be lost.
Nothing in this Section affects the mandatory statutory rights and guarantees you have as a consumer under Estonian and European Union law, which cannot be excluded or limited.
7. Limitation of Liability
To the maximum extent permitted by applicable law, Licensor shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or for any loss of data, profits, or goodwill, arising out of or in connection with your use of, or inability to use, the App or the services, regardless of the theory of liability.
However, nothing in this EULA excludes or limits Licensor’s liability for:
- death or personal injury caused by our negligence;
- our gross negligence or wilful misconduct;
- fraud or fraudulent misrepresentation; or
- any other liability that cannot lawfully be excluded or limited under applicable mandatory law, including Estonian and EU consumer-protection law.
Subject to the carve-outs above and to the extent permitted by law, Licensor’s total aggregate liability to you for all claims arising in any 12-month period shall not exceed the amount you paid for the App or the services in that period.
8. Indemnification
To the extent permitted by applicable law, you agree to indemnify and hold harmless Licensor from and against third-party claims, losses, and reasonable costs arising out of (a) your breach of this EULA, (b) your unlawful use of the App or the services, or (c) your submission of another person’s personal data (for example, an emergency-contact phone number) without that person’s required consent. This indemnity is limited to claims arising from your own fault or breach and does not apply to the extent any loss results from Licensor’s own act or omission.
9. Term and Termination
This EULA is effective until terminated. Your rights under this EULA terminate automatically if you fail to comply with its terms. You may terminate at any time by ceasing to use and deleting the App; you can permanently delete your account and associated data from within the App (Settings → Terms & account → Delete Account). Upon termination, you must cease all use of the App. Sections that by their nature should survive termination (including Sections 3, 6, 7, 8, 10, and 11) will continue to apply.
10. Governing Law and Dispute Resolution
This EULA and any non-contractual obligations arising out of or in connection with it are governed by the laws of Estonia and applicable European Union law. If you are a consumer, you benefit from the mandatory consumer-protection provisions of the law of your country of residence in the EU/EEA, and you may bring proceedings in the competent courts of that country; nothing in this EULA deprives you of that protection. For users acting in a business or non-consumer capacity, the courts of Tallinn, Estonia have exclusive jurisdiction.
If you have a dispute, please contact us first at [email protected] so we can try to resolve it informally. Consumers in the EU/EEA may also refer a dispute to their national consumer-dispute body; in Estonia this is the Consumer Disputes Committee (Tarbijavaidluste komisjon) at the Consumer Protection and Technical Regulatory Authority.
11. Export Compliance
You agree to use the App in compliance with all applicable export-control and sanctions laws, and you represent that you are not located in, and will not use the App in, any territory subject to comprehensive sanctions that would make such use unlawful.
12. Severability
If any provision of this EULA is held to be unenforceable under applicable law, that provision will be modified to the minimum extent necessary to make it enforceable, or severed if it cannot be so modified, and the remaining provisions will continue in full force and effect.
13. Apple-Specific Terms
The following terms apply to your use of the App obtained through the Apple App Store. This EULA is concluded between you and Licensor only, not with Apple Inc. (“Apple”), and Apple is not responsible for the App or its content. Apple has no obligation to furnish any maintenance or support services for the App. In the event the App fails to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price (if any) for the App to you; to the maximum extent permitted by law, Apple has no other warranty obligation whatsoever with respect to the App. Apple is not responsible for addressing any claims relating to the App, including product-liability claims, claims that the App fails to conform to any legal or regulatory requirement, and claims arising under consumer-protection, privacy, or similar legislation (including in connection with the App’s use of the HealthKit framework). In the event of any third-party claim that the App infringes intellectual-property rights, Licensor, not Apple, is solely responsible for the investigation, defence, settlement, and discharge of such claim. You must comply with applicable third-party agreement terms when using the App. Apple and its subsidiaries are third-party beneficiaries of this EULA and, upon your acceptance, will have the right to enforce it against you as a third-party beneficiary.
14. Changes to This EULA
We may update this EULA from time to time, for example to reflect changes to the App or to legal requirements. We will post the updated EULA on our website and update the “Last updated” date above, and for material changes will take reasonable steps to notify you. Your continued use of the App after changes take effect constitutes your acceptance of the updated EULA.
15. Entire Agreement
This EULA, together with the Terms of Use and the Privacy Policy, constitutes the entire agreement between you and Licensor regarding the App and supersedes all prior understandings on that subject.
16. Contact
Questions, complaints, or claims regarding the App should be directed to:
By email: [email protected]
By mail:
Retarget OÜ
Sepapaja tn 6, 15551 Tallinn, Estonia
VAT number: EE102572290