Last Updated: April 15, 2025
This "Privacy Policy" shall apply to your access to and use of the Sugar Sense application, its related applications, cloud-based service, and any other associated websites or services owned and operated by Sugar Sense (the "Services") provided to you and your Authorized Users (collectively, "you," "your," or "User") by Sugar Sense Imaginations, Inc. ("we," "us," "our," or "Sugar Sense"). Your use or continued use of the Services constitutes your consent to this Privacy Policy. Capitalized terms not otherwise defined in this Privacy Policy shall have the meaning provided in the Sugar Sense End User License Agreement found at https://sugarsense.io/eula.
This Privacy Policy describes the information we collect from those who access and use the Services. It also describes how we use that information, and, in some instances, how we share that information.
We use your information to provide and improve the Site and the Services.
By accessing or using the Site or the Services, you agree to the collection and use of your information in accordance with this Privacy Policy.
"Cookies" means small data files stored on your device (computer or mobile device).
"Data Controller" means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information is, or is to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Information collected by us.
"Data Processors" means any natural or legal person who processes Personal Information on behalf of the Data Controller. For purposes of this Privacy Policy, we are a Data Processor for any Personal Information of others collected by you.
"Data Subject" (or "User") means any living individual who is accessing and using the Services, or ordering, purchasing, and using the Services, and is the subject of Personal Information.
"Personal Information" means information about a living individual who can be identified from that information (or from that information and other information either in our possession or likely to come into our possession).
"Usage Data" means data collected automatically which is either generated by the access and use of the Site or the Services, or from the Site infrastructure itself (for example, the duration of a page visit).
We collect several different types of information for various purposes to provide the Site and the Services to you, as well as to constantly improve our offerings in that regard.
While accessing and using the Services, we may automatically collect or ask you to provide us with certain Personal Information that can be used to contact or identify you. This Personal Information may include:
When you use the Services, we may ask for information such as your name and email address, or collect certain diagnostic and usage information automatically. We do not collect payment or credit card information, mailing addresses, telephone numbers, or other personal identifying details unrelated to the functioning of the app.
Sugar Sense uses this collected information to improve the functionality of the app, provide technical support, communicate important updates, conduct research, and generate aggregated, non-identifiable reporting for internal analysis and service improvement.
We may use your Personal Information to contact you with optional newsletters, promotional content, or feature announcements. You may opt out of receiving any or all such communications by following the unsubscribe link in our emails or by contacting us directly.
All of your and your SugarGroup's activity in using the Services, including text messages, photographs, diary entries, medicine application, prescription(s) and dosage information, meal records, medical device data, and all other data, information, or content entered by you or your SugarGroup, is collected into a Glycemic Event Log (the "GEL").
We collect data from medical devices used in conjunction with the Services. Specifically, from continuous glucose monitors ("CGM") and insulin pumps used in conjunction with the Services we collect CGM-reported blood-glucose levels and pump-entered data including food announcements and insulin dosing amounts/changes.
We may also collect Usage Data about your access and use of the Services. This Usage Data may include information such as your device's Internet Protocol (IP) address, geographical location[MBA1], operating system, the features of the Services that you access and use, the time and date of your access and use, unique device identifiers, and other diagnostic data.
We may check clipboard data for an invitation URI at appropriate times to coordinate and simplify interactions. When accessed implicitly there is an accompanying on-screen disclosure and the clipboard data is only processed when it generated by Sugar Sense.
We use Cookies and similar tracking technologies to track the activity on the Site and to hold certain information. Cookies are sent to your browser or app from a web server and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze the Site and our services.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the Services.
Examples of Cookies we may use include, but are not limited to:
Sugar Sense uses the collected information and data described in this Privacy Policy for various purposes:
Sugar Sense takes reasonable technical and procedural steps to maintain the security and integrity of your personal information. Specific measures we use include, but are not limited to, encryption at rest.
If you are from the European Economic Area (EEA), Sugar Sense's legal basis for collecting and using your Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.
Sugar Sense may collect and process your Personal Information because:
Sugar Sense will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Sugar Sense will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer periods.
Your information, including Personal Information, may be transferred to, and maintained on, servers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your home jurisdiction.
If you are located outside of the United States and choose to provide information to us, please note that we may transfer the data, including Personal Information, to the United States and process it there. The Services and Sugar Sense's operations in providing the Services are conducted in the United States.
Your acceptance of and agreement to this Privacy Policy, followed by your submission of Personal Information represents your agreement to such transfers.
Sugar Sense will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Information and other data and information.
Specific measures we use include, but are not limited to, encryption, and user authentication and authorization controls. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed as being 100% secure.
If Sugar Sense is involved in a merger, acquisition, or asset sale, your Personal Information may be transferred to the acquiror. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.
Sugar Sense may donate, sell, or otherwise provide data and information from you GEL to third parties, especially third parties involved in projects related to the understanding, diagnosis, and/or treatment of diabetes or other medical conditions, provided such data and information is de-identified and/or aggregated with other data and information such that your data and information is not discernable from the data and information of others.
Under certain circumstances, Sugar Sense may disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Sugar Sense may disclose your Personal Information in the good faith belief that such disclosure is necessary to:
Sugar Sense may disclose your Personal Information (specifically, email address), to third parties for their direct marketing purposes, to provide you with news, special offers, and general information about other goods, services, and events which are offered by such third parties, unless you have, if applicable, opted to not have your personal information sold to third parties for their direct marketing purposes.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Sugar Sense aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.
If you wish to be informed about what Personal Information we hold about you, and if you want it to be removed from our systems, please contact us.
In certain circumstances, you may have the following data protection rights:
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
To the extent you include the Personal Information of others (for instance, employee names, identification numbers, physical descriptions, descriptions of events/incidents which may tend to identify individuals, etc.) in the content, data, or other information you submit in using the Services (your "User Content and Data"), you are the Data Collector of such Personal Information, and Sugar Sense is a Data Processor acting at your instruction. Your instruction to Sugar Sense is solely to store, sort, and present such Personal Information on demand via the interface provided by the Services. You are solely responsible for ensuring your collection of such Personal Information is compliant with all applicable laws and regulations, including, but not limited to, the GDPR and CCPA.
We may employ third-party service providers to facilitate our provision of the Services, to provide the Services on our behalf, perform Service-related services, or assist us in analyzing how the Services, are used.
These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated to not disclose or use it for any other purpose.
We may conduct user surveys to better target our content to our audience. Participation in these surveys is completely voluntary, and you therefore have a choice whether or not to disclose such information. We sometimes share the aggregated demographic information in these surveys with our partners. We never share Personal Information collected through surveys with such third parties
Sugar Sense would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.
If you have agreed to receive marketing, you may always opt out at a later date.
You have the right at any time to stop Sugar Sense from contacting you for marketing purposes or giving your data to Sugar Sense's affiliates for marketing purposes.
If you no longer wish to be contacted for marketing purposes, please email [email protected] with your request.
The Services may contain links to other services or websites that are not operated by us, specifically including, but not necessarily limited to, the ability for you to choose to share your GEL with a NightScout instance (and/or other data storage options which may be available to you). If you click or use such a third-party link, product, or service, you will be directed to that third party's website, product, or service. We strongly advise you to review the privacy policy of every third-party website, product, or service you visit or use. Sugar Sense is not responsible for any of your Personal Information or User Content and Data that you permit to be accessed by such a third-party website, product, or service.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.
While you are in complete control of who may join and remain in your SugarGroup, it is important to note that we are not responsible for the acts or failures to act of your SugarGroup members. SugarGroup members will have access to all of the data and information stored and communicated among SugarGroup members via the Services, including past data and information. It is your responsibility to ensure your SugarGroup members do not further disclose the data and information collected via the Services.
In accordance with the California Online Privacy Protection Act (CalOPPA) Amendment of 2013, we inform you that Sugar Sense Imaginations Inc. does not respond to Do Not Track requests or signals at this time.
To avoid any ambiguity, user data retrieved via Google Health Connect data will not be sold to any third party.
Persons under eighteen (18) years old ("Children" or "Child") are not permitted to access or use the Services without the permission and active supervision of an adult parent or guardian.
We do not knowingly collect Personal Information from Children under the age of thirteen (13) without express consent of an adult parent or guardian. If you are a parent or guardian and you are aware that your Child has provided us with Personal Information without your consent, please contact us. If we become aware that we have collected Personal Information from a Child without verification of parental consent, we will take steps to remove that information from our servers.
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on the Site, prior to the change becoming effective and will update the "Last Updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued (or new) access and use of the Site or Services, shall be your acceptance and agreement with this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us:
By email: [email protected]
By mail:
Name: Retarget OÜ
Address: Sepapaja tn 6, Tallinn, 15551, Estonia
VAT number: EE102572290