I. Introduction

In order to comply with the current legislation of Ukraine in full, DiaDaily considers its most important tasks to be compliance with the principles of legality, fairness and confidentiality in the processing of personal data, as well as ensuring the security of their processing. This Policy is characterized by the following features: a) developed to implement the requirements of the current legislation of Ukraine in the field of processing and protection of personal data; b) discloses the methods and principles of processing personal data by DiaDaily, the rights and obligations of DiaDaily in the processing of personal data, the rights of personal data subjects, and also includes a list of measures taken by DiaDaily to ensure the security of personal data during their processing. DiaDaily ("DiaDaily" or "we") is the declared responsible person and data controller in accordance with the data protection regulations. In other words, DiaDaily is the company that decides on the purpose and means of processing your personal data ("User Data") and is therefore responsible for the security and compliance with the current legislation of Ukraine. This Policy, together with the User Agreement, applies to your use of the DiaDaily application (the "Application"). "DiaDaily reserves the right to change the Policy at any time by updating the version of the Application for download and directing the user to the new text of the Policy.

II. Information about DiaDaily.

The app serves as a tool that helps users effectively manage diabetes by tracking blood glucose levels, insulin injections, carbohydrate intake, physical activity, sleep, and more. The algorithm organizes data, calculates trends, and finds patterns. By recording data and providing information about diabetes, users can understand the dependence of blood sugar on the amount and type of insulin injected, the amount of carbohydrates consumed, physical activity and rest, and manage their health. The DiaDaily app is a data tracking tool that collects and analyzes information related to the course of the disease, either manually entered or imported from third-party programs.

II. General provisions

This Policy has been drawn up in accordance with the following list of legal documents in force as of the date of drawing up and enactment of this Policy: - Constitution of Ukraine; - Decision of the Constitutional Court of Ukraine No. 2-rp/2012 of January 20, 2012; - Convention for the Protection of Human Rights and Fundamental Freedoms; - Law of Ukraine "On Ratification of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data and the Additional Protocol to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data concerning Supervisory Authorities and Transborder Flows of Data". This privacy policy explains how we collect, use, share and protect your personal and health data (collectively, "personal data") when you use the DiaDaily Application. This Policy applies to the use of all data collected by DiaDaily while using the Application. Please read this Privacy Policy carefully and make sure that you understand it. Your acceptance of the Privacy Policy is considered your first use of the DiaDaily Application. If you do not accept and agree to this Privacy Policy, you must immediately stop using the DiaDaily Application.

IV. The scope of the privacy policy

This privacy policy applies only to the use of DiaDaily. It does not apply to any other applications that are in any way related to DiaDaily. DiaDaily does not control how your data is collected, stored or used by other resources, and DiaDaily advises you to check the privacy policy of each of them before providing any data to them.

V. The procedure for collecting personal data

Please note that the information is not collected by the Application independently, but is entered by the User manually or automatically read from third-party services, at their own discretion and under their own responsibility. For example, with the consent of the User, DiaDaily may import Personal Data about your health and activities from third-party services such as Apple HealthKit into the Application. The information that DiaDaily collects depends on what information you have provided in these programs and devices, as well as on your privacy settings for sharing such information in these applications. If you wish, you can activate synchronization between DiaDaily and the Health app, and other connected services that allow you to share data between DiaDaily and other health apps. This synchronization only occurs if you activate it in the settings and select the data you want to share. DiaDaily will process any such third-party information in accordance with this Privacy Policy. Also, personal data may be collected when you contact DiaDaily support.

VI. Personal data that may be provided by the User

Personal data is information that can identify you directly or indirectly. It therefore does not include any information that does not identify you, such as impersonal information. Since DiaDaily's offer is aimed exclusively at people with diabetes, your use of DiaDaily products generally already provides information about your health status. Therefore, DiaDaily only processes User Data as health data with your consent. The DiaDaily app does not collect any personal data without your permission. The use of the application does not require the creation of an account, you decide what information about yourself to provide. Any user data that is collected and processed when you use the DiaDaily services is provided by you, if you wish, when using the Application. The following are the data that the user may provide and the purposes for which they are collected: **Blood sugar level and time of event, amount of insulin injected and time of event, amount of carbohydrates consumed and time of event, sleep onset and duration, exercise onset and duration, type of diabetes, insulin use start and name, diabetes control targets hyperglycemia limit, hypoglycemia limit, time in range, time in hypoglycemia, glucose control score, normal sugar. DiaDaily only processes User Data that you actively and voluntarily provide to DiaDaily. However, entering the requested user data is a prerequisite for the full use of the DiaDaily services. If you do not enter the optional data, the related functionality of the Application may be limited. The above personal data of the mobile Application users stored on the user's mobile phone is not uploaded from the Application to third-party servers, except for the data on the name of the insulin selected by the user and the date of the relevant selection (hereinafter referred to as the "Insulin Data"). The purpose of storing the Insulin Data is to improve DiaDaily, new features of which will be available in updated versions of the Application. When you uninstall the Application, the personal data specified in this paragraph, except for insulin data, will be deleted without the possibility of their recovery. **Data obtained during surveys: **In order to control the provision and improve the quality of services, conduct statistical, analytical and other studies of the use of the Application, surveys of Users, create new features and functions, DiaDaily may collect personal data provided by Users on a voluntary basis, in particular: surname, name, phone number, email address, age, type of diabetes and answers about the experience of using the Application. In this regard, we will always maintain a balance between our own interests and the protection of your personal data, with the latter prevailing. Upon completion of the study, the data collected for this purpose is depersonalized and stored by the Company indefinitely in order to assess the quality of product evolution. Once the data is depersonalized, it is no longer personal data.

Data received through DiaDaily's support channels:

The services also include customer support, where you can send information about the problem you encountered while using the service. Regardless of whether you contact the Application user support service, directly communicate with one of the DiaDaily representatives or otherwise interact with the support team, you will be asked to provide contact information, a brief description of the problem you have encountered, and any other documentation, screenshots or information that may be useful in resolving the problem. Employees who have access to your personal data must provide a written undertaking not to disclose the relevant data that they have been entrusted with or that they have become aware of in connection with the performance of their professional or official duties. For example, your email address may be used to contact you if it is necessary to support or troubleshoot DiaDaily. The information and personal data you wish to share with DiaDaily's customer support team is solely your decision, and DiaDaily will never request any personal data that is not necessary to provide you with the information or support you request. Email may be required to contact you in order to provide you with important security tips, as well as assistance related to the use of the Application. If you provide feedback on the Application or contact DiaDaily by email, DiaDaily will receive your name and email address, as well as any other content included in the email, in order to send you a response. This personal data is automatically stored by the email service and will not be used for any purpose other than to provide technical support. **Data obtained through analytical tools: **DiaDaily constantly analyzes, develops, tests and improves the product to ensure that DiaDaily content benefits users in the most effective way. To achieve this, DiaDaily conducts usability and safety tests, and the knowledge gained is incorporated into improved new versions of our products. These improvements are also provided to you through regular updates of the Application.When you install and use the Application, DiaDaily also collects information about the device you are using and generates crash and error reports if necessary to troubleshoot and determine the circumstances of a potential problem. DiaDaily uses personal data that it collects from you using the integrated data statistics tools in the Application to better understand and analyze DiaDaily users, including the formation of aggregate statistics on the use of the Application. This information can then be used to tailor the content of the Application and provide a better user experience for DiaDaily users. To make DiaDaily more useful for you (for example, to fix errors), the Application collects the following information from you: - age category; - gender; - user interests; - application version; - device information - brand, model; - information about the operating system and its version, platform; - language; - country, region, continent. Usage data is stored for 60 calendar days, except when this data is used to strengthen security or to improve the functionality of our Application, or DiaDaily is legally obliged to store this data for longer periods of time. We use and process your personal data only for the purpose of achieving the above purposes and to the extent necessary to achieve the above purposes.

VII. The procedure for transferring personal data

Your information, including Personal Data, is processed by a company with offices in Delaware. This means that this information may be transferred to and maintained on servers located outside of your country where the data protection laws may differ from those of your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information constitutes your agreement to this transfer. DiaDaily will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. DiaDaily may transfer your personal data to the following third parties:

Analytics

DiaDaily uses third-party analytics tools - Google Analytics to measure traffic and trends in the use of the Application. DiaDaily may use the information received from Google Analytics only to customize and personalize the Application for statistical and analytical purposes.

For business transfer

DiaDaily may share or transfer your personal information in connection with or during negotiations for any merger, sale of the Company's assets, financing or acquisition of all or part of DiaDaily to another company.