Privacy Policy

Last updated: 2026-05-15

This Privacy Policy explains how Nexdoz (“we”, “us”, the “Service”) collects, uses, and protects your personal data when you use the Nexdoz mobile or web application. We comply with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), the UK GDPR, the California Consumer Privacy Act (CCPA/CPRA), and applicable laws in other jurisdictions where Nexdoz is offered.

1. Data Controller

The data controller responsible for processing your personal data is:

Hossein Bagherzadegan
Berlin, Germany
Email: [email protected]

Postal address available on written request via the email above.

2. What Personal Data We Collect

2.1 Account data

  • Email address, password hash, optional display name
  • Subscription tier and billing status (when you subscribe)
  • Language and accessibility preferences

2.2 Health data (special category data, GDPR Art. 9)

  • Blood glucose readings (manual or imported from connected devices)
  • Meal logs, including carbohydrate estimates and optional meal photos
  • Medication records, including type, dose, and timing
  • Sleep, activity, heart rate, weight, and nutrition data imported via Android Health Connect (only categories you explicitly grant)
  • Symptom logs and clinician notes (where applicable)

2.3 Operational data

  • Device type, operating system version, app version
  • IP address (truncated for analytics; full address only when required for security)
  • Session logs, error reports, performance metrics
  • Audit logs of access to your data (for security)

2.4 Communications

  • Support emails and any messages you send to our team

3. Lawful Basis for Processing (GDPR / UK GDPR)

  • Contract performance (Art. 6(1)(b)) — to provide the Service you signed up for
  • Explicit consent (Art. 9(2)(a)) — for processing health data; you can withdraw at any time
  • Legitimate interest (Art. 6(1)(f)) — for security, fraud prevention, and service reliability
  • Legal obligation (Art. 6(1)(c)) — when required by law (e.g. accounting, tax)

4. How We Use Your Data

  • Authenticate your account and protect your session
  • Display your health data, charts, time-in-range, and other insights
  • Estimate carbohydrates from meal photos using AI providers (see §5)
  • Generate optional AI-assisted care suggestions reviewed by your clinician (only if you enable clinician sharing)
  • Process subscription payments via Google Play Billing
  • Provide customer support
  • Detect abuse, debug crashes, monitor service health

4.1 Support access (“view-as”)

If you ask us for help with a problem in your account, you can request a support session in which an authorised staff member temporarily views your account read-only— exactly as you see it — solely to reproduce and resolve the issue you reported. The lawful basis for this access is your support request (GDPR Art. 6(1)(a)/(f); for health data, Art. 9(2)(a)). Such sessions cannot modify your data, expire automatically after 15 minutes, and every session is recorded in an internal audit log capturing the staff member, the time, and the stated reason. We never use view-as for marketing, profiling, or any purpose other than the support you requested. Access by a clinician to data you have explicitly shared with their clinic is separate and governed by the consent you give when you join that clinic.

5. Sub-Processors and Third Parties

We use the following service providers as data sub-processors. Each is bound by a Data Processing Agreement and where applicable by Standard Contractual Clauses (SCCs) for international transfers:

  • DigitalOcean LLC — application hosting, EU region (Frankfurt)
  • Better Stack — operational logging
  • Google LLC — Google Play Billing for in-app subscriptions; Health Connect for on-device health data sync
  • OpenAI L.L.C., Anthropic PBC, Google Generative Language API — AI providers used only for meal-photo carbohydrate estimation and care-plan suggestions, and only when you actively use those features. These providers do not retain your data for training and process content as “zero data retention” or equivalent contractual guarantees.

We do not sell your personal data. We do not share it with advertisers, data brokers, or analytics platforms.

6. International Data Transfers

Most of your personal data is stored on EU-based servers (Frankfurt, Germany). When we use US-based AI providers (e.g. OpenAI, Anthropic) to process meal photos or generate care suggestions, the relevant content is temporarily transferred to the United States under Standard Contractual Clauses (SCCs) and the EU-US Data Privacy Framework where applicable. You can avoid international AI transfers by not using AI features.

7. Data Retention

  • Account data — until you delete your account or request deletion
  • Health logs — until you delete them or close your account
  • Backups — encrypted backups retained for up to 30 days for disaster recovery
  • Operational logs — up to 90 days for security and debugging
  • Audit logs — up to 12 months for compliance
  • Billing records — up to 10 years where required by German tax law (§ 147 AO)

8. Your Rights (GDPR Articles 15–22, UK GDPR equivalents)

  • Right of access — request a copy of your personal data (Art. 15)
  • Right to rectification — correct inaccurate data (Art. 16)
  • Right to erasure — “right to be forgotten” (Art. 17)
  • Right to restriction — limit how we process your data (Art. 18)
  • Right to data portability — receive your data in machine-readable form (Art. 20)
  • Right to object — to processing based on legitimate interest (Art. 21)
  • Right not to be subject to automated decision-making — including profiling (Art. 22)
  • Right to withdraw consent — at any time, without affecting the lawfulness of processing before withdrawal
  • Right to lodge a complaint — with your local supervisory authority. In Germany: Berliner Beauftragte für Datenschutz und Informationsfreiheit. In the UK: Information Commissioner’s Office (ICO).

To exercise any right, email [email protected]. We respond within 30 days (extendable by 60 days for complex requests, with notice).

9. California Residents (CCPA / CPRA)

If you reside in California, in addition to the GDPR rights above you have:

  • The right to know what personal information we collect, use, disclose, or sell
  • The right to delete personal information
  • The right to correct inaccurate personal information
  • The right to opt out of the “sale” or “sharing” of personal information — we do not sell or share your personal information
  • The right to limit use of sensitive personal information (such as health data)
  • The right to non-discrimination for exercising these rights

To exercise these rights, email [email protected].

10. Children’s Privacy

Nexdoz is not intended for children under 16 in the EU/EEA, under 13 in the United States (per COPPA), or under 16 in the UK. We do not knowingly collect personal data from children below these ages. If you believe a child has provided us with data, please email us so we can delete it.

11. Security

We protect your data with: TLS encryption in transit; encryption at rest for databases and backups; least-privilege access controls; multi-factor authentication for staff access; comprehensive audit logging; regular security reviews; and an incident response process. No system is 100% secure — we will notify you and the relevant supervisory authority within 72 hours of any personal-data breach affecting you.

12. Cookies and Tracking

We use only essential cookies required for authentication and CSRF protection. We do not use advertising cookies, third-party analytics trackers, fingerprinting, or cross-site tracking.

13. Health Connect

On Android, Nexdoz integrates with Google Health Connect to read and (for glucose and nutrition) write health data. Health Connect access is opt-in per data type. Data flows on-device between Health Connect and Nexdoz; you can revoke any permission at any time in your Android settings.

14. Not a Medical Device

Nexdoz is a personal-tracking and information tool. It is not a medical device under EU MDR (Regulation (EU) 2017/745) or US FDA Software-as-a-Medical-Device (SaMD) classification. It does not provide medical diagnoses or autonomous treatment recommendations. Always consult a qualified healthcare professional for medical decisions.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email and via in-app notice at least 30 days before the changes take effect.

16. Contact

For privacy questions, requests, or complaints, email [email protected].

Legal Notice (Impressum) • Terms of Service