This privacy policy is provided in English.

Privacy policy

Insulink is an open-source interoperability and research project. It is not a medical device and must never be the basis for dosing or treatment decisions. This policy explains which personal data the Insulink app, the web panel (panel.insulink.de), the backend (api.insulink.de) and this website process, why, and what rights you have.

Controller

Lukas Breuer
Im Gensem 9
53225 Bonn
Germany
E-Mail: contact@lukasbreuer.de

What we process

Your account

Your user name, your password (stored only as an Argon2 hash), your language and the time you accepted this policy and the terms. When you sign in we record the session: the device platform, your IP address and the city and country derived from it with a local copy of the MaxMind GeoLite2 database (no data is sent to MaxMind). When you sign up we store the device's model, brand, operating system and its device identifier.

Health data

The app stores the data you record or connect so that it is available on your other devices, in the web panel and after a reinstall: glucose readings and alarm events from your sensor, insulin doses, basal deliveries and pump (pod) records, meals, drinks and food products, meal photos and the nutrition estimated from them, HbA1c values, heart rate, steps, sleep, weight and other data imported from Health Connect, workouts and training routines, and your therapy settings (target range, correction and carb factor, basal profiles, automation limits). These are data concerning health within the meaning of Art. 9 GDPR.

Location

If you allow it, the app records your location, also in the background, to map GPS workouts and to let the glucose forecast take familiar places into account. The locations are stored on your account.

Pump and sensor keys

So that you can still reach a pod on your body after reinstalling the app, the app stores the pod's key and the sensor's session key on your account. Once you have signed in with a current version of the app, these keys are encrypted on your phone with a key derived from your password before they are uploaded; we cannot read them.

Purposes and legal basis

We process your account and usage data to provide the service you signed up for (Art. 6 (1) (b) GDPR). We process your health data and your location only with your explicit consent, which you give when you create your account and can withdraw at any time by deleting your account (Art. 9 (2) (a) and Art. 6 (1) (a) GDPR). We use your session records and IP addresses to protect your account against misuse, for example to block repeated failed sign-ins (Art. 6 (1) (f) GDPR).

Glucose forecast

If you use the forecast, a model is trained for your account only, from your own data, on our server. It is never shared with other users and is deleted after your account is deleted. The forecast shows patterns and is not a recommendation to act.

Recipients and processors

• Server: all account and health data are stored on a server we operate ourselves in Germany. No hosting provider has access to them.
• Meal photo estimate: when you photograph a meal, the photo is sent to Anthropic PBC (USA) to estimate its nutrition. Anthropic receives the photo only, no name or account. Anthropic is based in the USA, a country without an EU adequacy decision for it; the photo is transferred on the basis of your explicit consent, which you give each time you choose to have a photo estimated (Art. 49 (1) (a) GDPR). The risk is that authorities in the USA could access it. If you do not want this, do not use the photo estimate; entering meals by hand works without it.
• Maps: the app and the web panel load map tiles for your workout routes from Esri (Environmental Systems Research Institute, USA). Esri receives your IP address and which map area is shown. Esri is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR).
• Food search in the web panel: search terms you enter are sent directly from your browser to Open Food Facts (France), together with your IP address. No account data is sent.
• This website is hosted on GitHub Pages (GitHub Inc., USA), which processes your IP address to deliver it. GitHub is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR). It uses no cookies, no analytics and no third-party fonts; your theme and language choice stay in your browser's local storage.

We do not sell your data and do not use it for advertising.

Storage and deletion

Your data are stored for as long as your account exists. You can delete your account with all of its data at any time in the app (Profile, Delete account) or in the web panel (Settings, Account). Sessions you do not use expire after 90 days. Backups of the database are kept for 7 days and then overwritten, so deleted data disappear from them within a week.

Security

All connections are encrypted (TLS 1.2 or newer). Passwords are stored as Argon2 hashes, session tokens only as hashes, and the pump and sensor keys are encrypted on your device before upload. Repeated failed sign-ins are blocked for a while.

Your rights

You have the right to access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20; the app can export all of your data) and to object (Art. 21). You can withdraw your consent at any time with effect for the future. Write to the e-mail address above.

You also have the right to lodge a complaint with a supervisory authority, for example the State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia (LDI NRW), Kavalleriestraße 2-4, 40213 Düsseldorf.