Terms & Conditions

syncsulin GmbH  ·  Version 1.4  ·  Last updated: July 2026

A note before you begin

We built syncsulin because managing blood sugar is demanding, and because you deserve tools that make it feel less like a chore and more like having a knowledgeable companion by your side. These Terms and Conditions govern your use of the syncsulin app (available on the Apple App Store) and our website at www.syncsulin.com. We have written them to be as clear and human-readable as we possibly can. If you have any questions, please reach out - we are a small, dedicated team and we genuinely want to hear from you.

1. Definitions

The following terms are used throughout these Terms with the meanings set out below:

2. Acceptance of these Terms

By downloading, installing, or using the App, or by using the Website (including signing up for our newsletter or making a donation), you confirm that you have read these Terms, that you understand them, and that you agree to be bound by them. If you do not agree, please do not use the App or Website.

These Terms apply to all users wherever you are located - EU, US, or elsewhere. Where the mandatory consumer protection laws of your country of residence grant you rights beyond what is set out here, those rights remain fully unaffected.

Age: You must be at least 18 years old to use the App independently. Users aged 16–17 may use the App only with documented parental or guardian consent. The App is not intended for children under 16 (or under 13 in the United States).

3. What syncsulin does and what it doesn’t

syncsulin is a personal AI-powered tool for collecting, visualising, and making sense of your blood sugar and lifestyle data. It brings together data from multiple sources: Apple HealthKit (including glucose readings from CGM devices that write to Apple Health), activity and sleep data from wearables, manually entered insulin doses and meals, direct CGM and pump integrations, and food diary entries.

syncsulin is not a medical device. It is not regulated under the EU Medical Device Regulation (MDR), the US FDA framework, or equivalent regulations in other jurisdictions. The App is designed for personal awareness and data tracking, not for clinical decision-making.

In particular:

• CGM sensor readings can vary depending on hydration, calibration, sensor placement, and other factors. Always cross-check clinically important readings with a certified blood glucose meter (glucometer).
• For any treatment decision - including adjusting insulin doses, medication, or meal plans - follow the guidance of your doctor, endocrinologist, or certified diabetes educator.
• In a medical emergency, contact emergency services immediately.
• Hypoglycaemia (dangerously low blood glucose) is a medical emergency. The App does not replace the low-glucose alert systems of your CGM device, insulin pump, or other prescribed medical equipment. Never rely on the App as your primary or sole alert mechanism for hypoglycaemia. Always ensure your prescribed medical devices and their alarm functions are active and functioning correctly.
• syncsulin does not provide medical advice, diagnosis, or treatment recommendations.

3.1 Regulatory status and intended purpose

syncsulin is a personal data tracking and awareness tool. Its sole intended purpose is to help people understand and manage their blood sugar - in particular those living with diabetes - by collecting, visualising, and reflecting on their own data for personal, non-clinical use.

syncsulin is not a medical device within the meaning of Regulation (EU) 2017/745 (MDR), the US Federal Food, Drug, and Cosmetic Act (FD&C Act) and 21 CFR Parts 800–898, or any equivalent national regulation. It does not perform any function that would constitute a medical device under those frameworks: it does not diagnose, prevent, monitor, treat, or alleviate any disease or injury; it does not compensate for any physiological or pathological process; and it produces no output intended for any clinical purpose.

syncsulin does not constitute Software as a Medical Device (SaMD) as defined by the IMDRF SaMD Framework and the MDCG 2019-11 Guidance on Qualification and Classification of Software under Regulation (EU) 2017/745. The AI-generated patterns, insights, and trend visualisations produced by the App are informational outputs based on data you provide. They do not constitute clinical decision support, diagnostic output, or therapeutic recommendations of any kind.

By using the App, you expressly acknowledge and agree that: (i) syncsulin is not a medical device and is not subject to medical device regulation in any jurisdiction; (ii) the App is not a substitute for professional medical advice, diagnosis, or treatment; and (iii) you will not use the App as the basis for any clinical decision without first consulting a qualified healthcare professional.

3.2 AI-generated insights

syncsulin uses machine learning algorithms to identify patterns in your data and present personalised insights and trend visualisations. These outputs are generated automatically based on the data you provide and are informational in nature only.

AI-generated insights do not constitute medical advice, clinical recommendations, or diagnostic output. They have not been validated as clinical tools and are not intended to guide treatment decisions. syncsulin GmbH makes no representation as to the clinical accuracy, completeness, or suitability of any AI-generated insight for any particular individual or health situation.

In particular, AI-generated insights: (i) may not reflect real-time glucose values or clinically relevant trends; (ii) are based solely on the data you have provided or connected to the App, which may be incomplete or inaccurate; and (iii) are subject to the inherent limitations of statistical modelling applied to individual health data.

syncsulin’s AI features are not classified as high-risk AI systems under Annex III of Regulation (EU) 2024/1689 (EU AI Act). Nothing in these Terms creates or implies any regulatory approval or certification of any AI feature of the App.

4. Data sources and integrations

syncsulin connects to health and lifestyle data through the following channels. You control which connections are active and can disconnect any source at any time in the app settings.

4.1 Apple HealthKit

syncsulin reads health data from Apple Health on your iPhone, including CGM glucose readings, steps, heart rate, HRV, sleep, and activity data. When you manually log an insulin dose in syncsulin, that entry is also written back to Apple Health to keep your records consistent. HealthKit data is never used for advertising and never shared with third parties for their own commercial purposes.

4.2 Direct CGM and pump integrations

syncsulin can connect directly to your CGM or insulin pump data provider using your account credentials. This enables automatic background synchronisation of glucose readings and insulin delivery data.

Important notes on these integrations:

• Dexcom, Abbott, and Glooko are independent data controllers. You already have a direct relationship with them through your medical devices and/or clinic.
• With your authorisation, we read your data from their systems. The copy we ingest is stored exclusively in our EU database (Supabase, Ireland).
• We never send health data back to these vendors - only the credentials or authorisation needed to fetch your data.
• You can disconnect any integration at any time in the app. Your credentials will be deleted from our systems immediately.

4.3 Food diary and nutrition analysis

The app includes a food diary with AI-powered nutrition analysis. When you photograph a meal, the image is sent to Spike Nutrition AI for carbohydrate and nutrition estimation. The estimated values are returned to you and saved in your food diary in our EU database.

• Spike receives a pseudonymous user identifier and the meal photo for analysis. Spike does not retain personal data from this process.
• Meal photos are stored in our own Supabase file storage (Ireland) so you can view them in your diary history. You can delete individual entries at any time.

4.4 Third-party services (general)

Your use of any third-party service or device that connects to syncsulin is also governed by that third party’s own terms and privacy policy. We are not responsible for the data practices, availability, or accuracy of any third-party service.

syncsulin has no control over the accuracy, completeness, currency, or integrity of health data received from any third-party service or device. Any insights, trends, or visualisations generated by the App are entirely dependent on the quality and completeness of the underlying data. syncsulin GmbH accepts no liability for any health-related consequences arising from reliance on App outputs that are based on inaccurate, incomplete, or incorrectly formatted third-party data.

5. Your responsibilities

• Provide accurate information when setting up your account and connecting your data sources.
• Use the App only for its intended purpose: personal data tracking and visualisation.
• Keep your login credentials confidential and tell us immediately if you believe your account has been compromised (privacy@syncsulin.com).
• Not attempt to reverse-engineer, decompile, or tamper with the App or its infrastructure.
• Not use the App in a way that could harm yourself, others, or the integrity of the service.
• Not use the App for commercial purposes, to provide medical advice to others, or in any clinical setting without appropriate regulatory authorisation.

6. Data protection and your privacy rights

6.1 General

Your health data is sensitive and personal, and we treat it as such. A full account of what we collect, why, how long we retain it, and who we share it with is set out in our Privacy Policy, which forms part of these Terms. You can find it in the App and at www.syncsulin.com/privacy-policy.

We do not sell your personal data. We do not use it for advertising. We use it only to provide, maintain, and improve syncsulin.

6.2 EU/EEA and UK residents (GDPR)

Your data is processed on the basis of your explicit consent (GDPR Art. 6(1)(a) and Art. 9(2)(a)). You may withdraw consent at any time without affecting the lawfulness of prior processing.

Your rights under the GDPR, exercisable at any time by contacting privacy@syncsulin.com:

• Right of access (Art. 15) - obtain a copy of the personal data we hold about you
• Right to rectification (Art. 16) - correct inaccurate or incomplete data
• Right to erasure (Art. 17) - request deletion of your data
• Right to restriction of processing (Art. 18) - limit how we process your data
• Right to data portability (Art. 20) - receive your data in a structured, machine-readable format
• Right to object (Art. 21) - object to processing based on our legitimate interests
• Right to lodge a complaint with your national supervisory authority

6.3 US residents

California (CCPA/CPRA): Right to know, delete, correct, opt out of sale/sharing (we do not sell or share your data), limit use of sensitive personal information, and non-discrimination. Contact: privacy@syncsulin.com. We respond within 45 days.

Washington State (WPA): Right to access, correct, delete, and port your personal data, and to opt out of targeted advertising and automated profiling. We do not engage in either. Contact: privacy@syncsulin.com.

Other US states: Similar rights apply under Virginia, Colorado, Connecticut, Texas, Oregon, Montana, and other enacted state privacy laws. Contact us at privacy@syncsulin.com.

We do not knowingly collect personal information from US residents under 18, consistent with COPPA and applicable state laws.

6.4 Security

We implement encryption in transit (TLS 1.3+) and at rest (AES-256), per-user Row-Level Security at the database level (Supabase, Ireland), multi-factor authentication for all admin access, and principle-of-least-privilege access controls. Health data is not stored on your device; only authentication tokens are stored, in the iOS Keychain.

CGM and pump account credentials are stored AES-256 encrypted, with encryption keys held exclusively in our backend environment - never in the database. Direct database access is limited to an allowlist of approved IP addresses.

In the event of a personal data breach, we will notify the relevant supervisory authority within 72 hours and affected users without undue delay (GDPR Art. 33-34).

7. Intellectual property

syncsulin and all associated content, software, code, design, trademarks, and technology are the exclusive property of syncsulin GmbH, protected under applicable intellectual property laws in Germany, the EU, and the United States.

Your use of the App grants you a limited, personal, non-exclusive, non-transferable right to use the App on your own device for the purposes described in these Terms - nothing more.

You agree not to copy, modify, distribute, sell, sublicence, reverse-engineer, or create derivative works from any part of the App without our prior written consent. Any feedback or suggestions you share with us may be used freely and without obligation to you.

8. Pricing and donations

syncsulin offers a freemium model: a meaningful set of features is available for free, while additional features are available through an optional paid subscription or one-time purchase, processed through the Apple App Store.

8.1 Voluntary donations (via our website)

We offer an optional way to support syncsulin financially through a donation feature on our website at www.syncsulin.com, powered by Stripe. Donations are entirely voluntary. They are non-refundable and confer no right to specific features, priority support, or any other contractual benefit.

Donations are processed by Stripe, Inc., which acts as an independent payment processor and data controller for the transaction. By making a donation, you also agree to Stripe’s terms and privacy policy. We never see or store your card details.

EU consumers: Because donations are voluntary and non-service-linked, the 14-day right of withdrawal under EU consumer protection law does not apply to completed donation transactions.

8.2 In-app purchases

Subscriptions and one-time purchases are processed through the Apple App Store and governed by Apple’s standard terms for in-app purchases (apple.com/legal/internet-services/itunes/dev/stdeula/). For billing or payment issues, contact Apple directly. We do not process any in-app payments independently.

9. Disclaimers and limitation of liability

9.1 “As is” provision

The App is provided on an “as is” and “as available” basis. To the extent permitted by applicable law, syncsulin GmbH makes no warranties, express or implied, regarding the App, including but not limited to fitness for a particular purpose, merchantability, accuracy of data, or uninterrupted operation.

9.2 Limitation of liability

To the maximum extent permitted by applicable law, syncsulin GmbH is not liable for any damages arising from your use of or inability to use the App - including but not limited to loss of data, health outcomes, missed glucose readings, device malfunctions, or any indirect, incidental, or consequential damages of any kind.

Our total aggregate liability for any claim arising from these Terms or the App shall not exceed EUR 100 or the total amount you have paid us in the preceding 12 months, whichever is greater.

These limitations do not apply where liability cannot be excluded or limited under applicable mandatory law, including liability for death or personal injury caused by our negligence, for wilful misconduct, or under the German Product Liability Act (Produkthaftungsgesetz).

9.3 Indemnification (US users)

If you are based in the United States, you agree to indemnify and hold harmless syncsulin GmbH and its affiliates, officers, employees, and agents from any claims, damages, losses, or expenses (including reasonable legal fees) arising from your violation of these Terms or your misuse of the App.

10. Termination and suspension

You may stop using the App at any time by deleting it from your device. To request deletion of your account and associated health data, contact privacy@syncsulin.com or use the in-app account deletion function. We will confirm deletion within 30 days.

We reserve the right to suspend or terminate your access at any time, including if you breach these Terms or if we are required to do so by law. We will give reasonable advance notice where possible.

Upon termination, your right to use the App ceases immediately. Sections 3, 6, 7, 9, 11, and 12 survive termination.

11. Governing law and dispute resolution

11.1 Governing law

These Terms are governed by the laws of Germany, excluding conflict of law provisions. If you are a consumer resident in the EU, the mandatory consumer protection provisions of your country of residence also apply.

For users in the United Kingdom: these Terms are also governed by the laws of England and Wales insofar as UK-specific mandatory consumer protection law (including the Consumer Rights Act 2015 and the UK GDPR) applies to you as a UK resident. The UK Information Commissioner’s Office (ICO) is the relevant supervisory authority for data protection matters. For users in all other jurisdictions: these Terms are governed by German law, and you may also benefit from any mandatory consumer protection provisions applicable in your country of residence.

11.2 Dispute resolution

We would always rather talk to you than litigate. If you have a complaint, please contact us first at legal@syncsulin.com.

EU users: You may also use the European Commission’s Online Dispute Resolution platform at ec.europa.eu/consumers/odr. Our ODR email address is legal@syncsulin.com.

US users: Any dispute that cannot be resolved informally shall be subject to binding individual arbitration under the AAA Consumer Arbitration Rules of the American Arbitration Association (AAA), conducted in English. The arbitration shall be conducted on an individual basis; class arbitration and class actions are not permitted. If the class action waiver is found unenforceable for any reason, the remainder of this arbitration clause shall also be deemed unenforceable, and the dispute shall be resolved in a court of competent jurisdiction. This clause does not apply to claims that qualify for small claims court, nor to claims arising under California’s CLRA or UCL where applicable law prohibits arbitration. Nothing in this clause prevents either party from seeking emergency injunctive relief.

12. Changes to these Terms and general provisions

12.1 Amendments

We may update these Terms as syncsulin evolves. For material changes, we will notify you through the App or by email at least 30 days before the changes take effect. Your continued use after the effective date constitutes your acceptance of the updated Terms. For changes that affect how we process your health data, we will ask for fresh, explicit consent.

12.2 Severability

If any provision of these Terms is found to be invalid or unenforceable, it will be modified to the minimum extent necessary, and the remaining provisions will continue in full force.

12.3 Language

These Terms are written in English. If a translated version is provided, the English version prevails in the event of any inconsistency.

12.4 Entire agreement

These Terms, together with our Privacy Policy, constitute the entire agreement between you and syncsulin GmbH regarding your use of the App and Website.

13. Website and App content, and external links

13.1 Content liability

The syncsulin website and App are intended for informational and personal tracking purposes only. Content provided through either does not constitute professional, medical, or legal advice. We make every effort to keep information accurate and up to date; however, we assume no liability for the correctness, completeness, or currency of any content provided through the website or the App.

As a service provider, we are not obliged to monitor transmitted or stored third-party information or to investigate circumstances indicating illegal activity. Obligations to remove or block content under applicable law remain unaffected. Liability in this respect arises only from the moment a specific legal violation becomes known to us; upon becoming aware of such violations, we will remove or correct the relevant content without undue delay.

13.2 External links

Our website may contain links to external third-party websites. When you follow such a link, you are leaving the syncsulin.com domain. While we select links with care, we do not adopt the contents of linked sites as our own and accept no liability for their accuracy, legality, or functionality. The respective operators of those sites are solely responsible for their content. At the time of linking, we verified that no obvious legal violations were present; if we become aware of any such violation, we will remove the link without undue delay.

13.3 Intellectual property

All intellectual property rights in the website and the App - including content, design, software, trademarks, and technology - are governed by Section 7 (Intellectual property) of these Terms, which applies equally to the website and the App.

14. Contact us

We are a small team building something we believe in. If you have a question, a concern, or just want to say hello - please reach out.

Thank you for being part of the syncsulin® journey.