Terms of Service – Sugar Sense

Last updated: 18 June 2026

These Terms of Use (“Terms”) are a legally binding agreement between you and Retarget OÜ, a private limited company registered in Estonia (VAT EE102572290), with its registered address at Sepapaja tn 6, 15551 Tallinn, Estonia (“Retarget OÜ,” “we,” “us,” “our,” or the operator of “Sugar Sense”). They govern your access to and use of the Sugar Sense mobile application for iOS and watchOS (the “App”) and all related features and services (together, the “Services”).

Please read these Terms together with our Privacy Policy, which explains how we process your personal data. Capitalised terms used but not defined in these Terms have the meaning given to them in the Privacy Policy.

1. Acceptance of Terms

By downloading, accessing, or using the App or the Services, you confirm that you have read, understood, and agree to be bound by these Terms. If you do not agree with any part of these Terms, you must not use the App or the Services.

Where you also accept Apple’s standard Licensed Application End User License Agreement as part of installing the App through the App Store, that agreement applies as between you and Apple for the licensed application. As between you and us, these Terms are the controlling agreement governing your use of the App and the Services, and they prevail in the event of any conflict.

2. Description of the Services

Sugar Sense is a diabetes monitoring and self-management companion app for iOS and watchOS. Depending on your settings and subscription, the Services may include:

viewing and graphing continuous glucose monitoring (“CGM”) readings and trend information sourced from supported third-party CGM services, namely Abbott LibreLinkUp and, optionally, Dexcom Share;
a LogBook for manually recording diabetes-related events (meals and carbohydrates, insulin doses, activity, medication, and notes), a personal “My Foods” library, and glycemic statistics (such as time-in-range, GMI, and average-glucose summaries);
configurable low, high, and predictive (“heading-low”) glucose alerts and notifications;
an optional, premium automated emergency-call feature that can place voice calls (see Section 6);
optional, premium AI-assisted features: a food scanner that estimates carbohydrate ranges from a photo or barcode, and AI Insights narratives (see Section 7);
an optional integration with Apple Health (HealthKit);
a “Family messages” / “Message Group” feature, which sends a simple ping or acknowledgement notification carrying only a display name. It does not share your glucose history, logged events, or other data with anyone.

You agree to use the App and the Services only for lawful purposes and in accordance with these Terms and all applicable laws and regulations.

3. Accounts and Third-Party CGM Credentials

To use the Services you create a Sugar Sense account (name, email, and password). To receive glucose data, you also connect a supported third-party CGM service by entering your LibreLinkUp or Dexcom Share login credentials. We use those credentials only to authenticate with, and retrieve glucose data from, that provider on your behalf; we store them in encrypted form as described in the Privacy Policy. These are your provider’s credentials, not Sugar Sense credentials, and are governed by your separate agreement with that provider.

You are responsible for keeping your account and provider credentials confidential and for all activity under your account. You must provide accurate information and promptly update it if it changes. Please notify us if you believe your account has been compromised.

4. Health and Safety Disclaimer

Sugar Sense 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. It is not intended to diagnose, cure, mitigate, treat, or prevent any disease or health condition, and it does not make treatment or dosing decisions for you.

You acknowledge and agree that:

all glucose values, trends, statistics, alerts, and insights shown in the App are for informational and tracking purposes only;
you should never disregard, avoid, or delay obtaining professional medical advice from a qualified healthcare provider because of anything shown in the App;
you remain solely responsible for your own diabetes-management decisions, which you should make together with your healthcare team;
the App does not replace your manufacturer-provided CGM reader, receiver, or app, and you must keep your CGM’s own urgent low/high alarms enabled and rely on them as your authoritative source;
you assume the risks of relying on a supplemental, third-party-data-dependent tool.

5. Alert Reliability and Third-Party CGM Data

Alerts, notifications, and the emergency-call feature are provided on a best-effort basis only. They may be delayed, suppressed, or fail to arrive, and you must not rely on Sugar Sense as your sole or primary means of detecting low or high glucose.

All glucose readings, trends, and timestamps are obtained from third-party CGM services (Abbott LibreLinkUp and, optionally, Dexcom Share). We do not control those services and cannot guarantee the accuracy, completeness, timeliness, or availability of the data they provide. Readings may be delayed, missing, or incorrect because of sensor warm-up or failure, an expired or removed sensor, credential or authorisation problems, or provider outages. The App relays such data on an “as is” and “as available” basis, and your CGM manufacturer’s own reader remains authoritative.

The delivery of alerts and notifications depends on these third-party CGM services, your internet connection, and Apple’s push notification system — all outside our control. As a result, alerts (including predictive low alerts):

may be delayed, may arrive out of order, or may not arrive at all;
may be silenced or deferred by your device settings, including Focus / Do Not Disturb, Low Power Mode, Silent mode, notification permissions, or operating-system delivery limits;
depend on a recent reading: data older than 15 minutes is shown as stale (“No Data”) and will not produce a current-value alert.

You must keep the urgent alarms on your primary CGM reader or receiver enabled and treat Sugar Sense as a supplemental convenience, never as a guaranteed safety mechanism.

6. Emergency-Call Feature

If you enable it (a premium feature), Sugar Sense can place an automated voice call to a phone number you provide when a confirmed low-glucose condition is detected, and, if you do not acknowledge that call and you have opted in, escalate the call to an optional emergency-contact number you provide. These calls are placed through our telephony provider, Twilio (United States), as described in the Privacy Policy.

The emergency-call feature is a best-effort convenience and is NOT an emergency dispatch, medical, or guaranteed life-safety service. It does not contact emergency services and will not call 112, 911, or any local emergency number on your behalf.

The call may be delayed, fail to connect, or not be placed at all due to factors outside our control, including CGM-data, network, carrier, or telephony-provider conditions, the same alert-delivery limits described in Section 5, and the staleness rules. In any medical emergency you must call your local emergency number (such as 112 or 911) and seek professional medical care.

If you enter another person’s number as an emergency contact, you confirm that you have that person’s consent for us to store their number and to place automated calls to it for this purpose, and that you will inform them of how the feature works. The emergency-call and AI features are premium features and will become unavailable if your subscription is cancelled or lapses (see Section 8).

7. Artificial Intelligence Features

The optional AI features (the food scanner and AI Insights) use a third-party AI provider, Anthropic, PBC (United States), as described in the Privacy Policy. The food scanner sends a meal photo for transient analysis (the photo is not stored), and AI Insights sends aggregated, de-identified glucose and health statistics.

AI outputs are estimates only, are presented as ranges, may be inaccurate or incomplete, and are informational and educational only. They are explicitly dose-free.

The AI features will never provide insulin doses, units, bolus or basal recommendations, carbohydrate ratios, or correction factors, and you must not use any AI output to calculate or adjust insulin doses or any other treatment. You should independently verify carbohydrate counts and consult your healthcare team for any dosing or treatment decision.

8. Subscriptions, Payments, and Right of Withdrawal

Some features are available only with a paid subscription. Premium features currently include the AI food scanner and AI Insights, the automated emergency-call feature, Apple Watch and Live Activity / Dynamic Island support, and the calendar integration. The current subscription titles, lengths, and prices are shown on the App Store and on the in-app paywall before you purchase. Free features always include your glucose readings, graph, statistics, all notification and alert settings, and event logging.

Subscriptions are billed through your Apple ID and managed by Apple. Payment is charged to your Apple ID at confirmation of purchase, and your subscription automatically renews at the then-current price for the same period unless you turn off auto-renewal at least 24 hours before the end of the current period. You can manage or cancel your subscription in your App Store account settings. We do not collect or process your payment card details; subscription and entitlement metadata is processed by Apple and by our subscription-management provider, Adapty, as described in the Privacy Policy.

EU right of withdrawal. If you are a consumer in the EU/EEA, you have a statutory right to withdraw from a distance purchase of digital content within 14 days. Because subscriptions provide immediate access to digital content, by starting a paid subscription or accessing premium content you expressly consent to immediate performance and acknowledge that you thereby lose your 14-day right of withdrawal once performance has begun. Refund requests are handled by Apple through the App Store, and nothing in these Terms limits any mandatory refund or cancellation rights you have under applicable law.

9. Data Handling

We do not collect your payment or credit-card details. The personal data we process — including your account details, CGM provider credentials (stored encrypted), glucose readings and trends, logged events, alert settings and thresholds, glycemic statistics, any phone numbers you provide for the emergency-call feature, food photos (processed transiently and not stored), and any Apple Health metrics you choose to share — is handled as described in our Privacy Policy, which forms part of these Terms.

You grant us a limited right to use genuinely anonymised and aggregated data (data that cannot reasonably be used to identify you) for internal analytics and to operate, maintain, and improve the Services. We do not sell your personal data, and we do not sell or share any data obtained from Apple Health (HealthKit) with third parties for advertising, marketing, or data-mining purposes.

10. Intellectual Property

All trademarks, service marks, software, designs, text, and other content included in the App and the Services are the property of Retarget OÜ or its licensors and are protected by intellectual-property laws. Subject to these Terms, we grant you a limited, non-exclusive, non-transferable, revocable licence to use the App for your personal, non-commercial use. You may not reproduce, distribute, modify, reverse-engineer, or create derivative works from the App or its content without our prior written consent, except to the extent such restriction is prohibited by applicable law.

11. Disclaimer of Warranties

To the maximum extent permitted by applicable law, the App and the Services — including all alerts, notifications, emergency calls, AI features, statistics, and third-party CGM data — are provided on an “as is” and “as available” basis, without warranties of any kind, whether express or implied. We do not warrant that the Services will be uninterrupted, timely, secure, accurate, or error-free, or that any defects will be corrected, and we disclaim all implied warranties of merchantability, fitness for a particular purpose, and non-infringement, to the extent permitted by law.

Nothing in this Section affects the mandatory statutory rights and guarantees that you have as a consumer under Estonian and EU law, which cannot be excluded or limited.

12. Limitation of Liability

To the maximum extent permitted by applicable law, Retarget OÜ 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.

However, nothing in these Terms excludes or limits our 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.

The exclusions and limitations above apply only to the extent permitted by law and are subject to the carve-outs in this Section. Where liability cannot be excluded but can be limited, and to the extent permitted by law, our total aggregate liability to you for claims arising in any 12-month period shall not exceed the amount you paid us for the Services in that period.

13. Indemnification

To the extent permitted by applicable law, you agree to indemnify and hold harmless Retarget OÜ from and against third-party claims, losses, and reasonable costs arising out of (a) your breach of these Terms, (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 our own act or omission.

14. Eligibility

The Services are not directed to children and are not intended for use by children. Because the App processes health data, 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.

15. Termination

You may stop using the Services at any time. You can permanently delete your account and associated data from within the App at Settings → Terms & account → Delete Account, which is irreversible and removes the data described in our Privacy Policy; you can also log out per device, which keeps your account.

We may suspend or terminate your access to the App or the Services where you materially breach these Terms, where your use is unlawful or harmful to others or to us, or where we are required to do so by law. Other than where immediate action is necessary (for example, to address a security, legal, or safety issue), we will give consumers reasonable notice and a reason before terminating. On termination, your data is handled in accordance with the retention provisions of the Privacy Policy. The provisions of these Terms that by their nature should survive termination — including Sections 9 to 13, 16, and 17 — will continue to apply.

16. Governing Law and Jurisdiction

These Terms and any non-contractual obligations arising out of or in connection with them 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 these Terms deprives you of that protection. For users acting in a business or non-consumer capacity, the courts of Tallinn, Estonia have exclusive jurisdiction.

17. Dispute Resolution and Consumer Complaints

If you have a complaint or dispute, please contact us first at [email protected] so we can try to resolve it informally.

If you are a consumer in the EU/EEA and we cannot resolve the matter, you may be entitled to refer it to your national consumer-dispute body. In Estonia, this is the Consumer Disputes Committee (Tarbijavaidluste komisjon) at the Consumer Protection and Technical Regulatory Authority. Nothing in these Terms limits your right to bring proceedings before the competent courts of your home country.

18. Changes to These Terms

We may update these Terms from time to time, for example to reflect changes to the Services or to legal requirements. We will post the updated Terms in the App or on our website and update the “Last updated” date above. For material changes, we will take reasonable steps to notify you. Your continued use of the App or the Services after changes take effect constitutes your acceptance of the updated Terms; if you do not agree, you should stop using the Services and may delete your account.

19. Contact

If you have questions or concerns regarding these Terms, please contact us:

Email: [email protected]
Company: Retarget OÜ
Address: Sepapaja tn 6, Tallinn, 15551, Estonia
VAT number: EE102572290