Clinical Privacy Policy

Effective as of April 19, 2020

What We Collect

Personal data you provide us directly

General Information. We collect the minimum information that is necessary to fulfill the purpose of your interaction with us. This may include your name and email address. The data is securely stored, and we do not sell it to third parties - it is only used as this Privacy Policy describes. In some instances, your clinician may choose to sign you up as a user using an identifier - in this case, your name and email address are not collected by us. These users are identified by an identifier that are defined by the healthcare provider and have no significance to us beyond identifying the patient.

Health and Wellbeing information. When you use the app, you may provide personal information about your health such as:

Breath readings.
Details of meals you had (including images).
Medications or supplements you have taken.
Scores relating to sleep quality and stress levels.
Levels of symptoms experienced.
Breath tests attempted, including food intolerance tests, custom foods, and diagnostic tests such as glucose, lactulose, and sucrose for conditions like SIBO and CSID.
Stool logging, as per the Bristol Stool Scale.
Any notes you choose to make relating to a point in time or specific days.
Other information you choose to log about your health.

You may also choose to provide us with additional health information such as your weight and symptoms you experience through optional survey questions. This information may be used by authorised clinical staff, and may be used to identify clinically relevant patterns across the broader user base and to help make better and more useful recommendations to you.

This data processing requires your consent in accordance with Article. 9(2)(a) of GDPR legislation.

Personal data we may collect automatically

When you access or use the App, we may automatically collect the following information: This is done to see what features of the app people use, so we can prioritize our efforts at improving the app.

Device Information

Hardware model.
Information about operating system and its version.
Mobile network information.

Location Information

Time zone.
Information about your mobile service provider.

App usage data, including, among others

Frequency of use.
Areas and features of our App you visit.
Your use patterns generally.
Engagement with particular features.
App crash data.

We also use partner companies that conduct analyses on app usage on our behalf. These are the following companies

Firebase.
Crisp.

Why we collect data

We may use your Personal data, for the following purposes:

To analyse, operate, maintain and improve the App, to add new features and services to the App.
To customise content and materials you see when you use the App.
To send you technical notices, updates, security alerts and support and administrative messages.
To respond to your comments, questions and requests and provide customer service.
To help you retrieve your data if you change phones or have to re-install the App.
To monitor and analyse trends, usage and activities in connection with our App.
To link or combine with information we get from others or (and) from you to help understand your needs and provide you with better service (to use in training of neural networks, artificial intelligence).
For scientific and academic research purposes.
For any other purposes disclosed to you at the time we collect Personal data or any other purposes indicated in this Privacy Policy.

Principles of processing

Data minimisation and purpose limitation. We will not process Personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorised by you or collect any Personal data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of Personal data that is strictly needed for the mentioned purposes.

No sale of Personal data. We will never sell, rent, or disclose your Personal data.

Aggregated information

We may share aggregated, anonymised or de-identified information, which cannot reasonably be used to identify you, with our partners or research institutions. For example, we may share, including, without limitation, in articles, blog posts and scientific publications, general age demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users. Sharing such data contributes to the advancement of scientific research on digestive health.

Special circumstances

We may also share some of your Personal data in the following special circumstances:

In response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements).
When disclosure is required to maintain the security and integrity of the App, or to protect any user's security or the security of other persons, consistent with applicable laws. In such cases we may also delete some of your Personal data (e.g. resetting your password to avoid unauthorised access).
When disclosure is directed or consented to by the user who has input the Personal data.
In the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.

Retention of your Personal data

When you use the App

We will retain your Personal data as long as your account is active or needed to provide you Services, and only for as long as it serves purposes of processing identified in Section 2 of this Privacy Policy. At any time, you can erase your Personal data in accordance with the Privacy Policy.

After you stop using the App

If you choose to delete the App, deactivate your account, we retain your Personal data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services.

You should be aware that we may retain certain Personal data and other information after your account has been terminated or deleted in an aggregated, anonymised form. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical solutions we use. However, we undertake to delete any such backups within a reasonable period of time.

Security

User data is held on secure servers hosted by Amazon Web Services, in the European Union. All data sent or received from our servers is transferred using the Secure Socket Layer (SSL) protocol, which encrypts the data in transit. However, the nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organizational measures) to protect your personal data.

Removal of data

If you want us to remove your data, please email us at privacy@foodmarble.com from your registered email address and tell us that you would like your data to be deleted.

Retrieving your data

Similarly, if you'd like to get a copy of all your data, email us at privacy@foodmarble.com with your registered email address.

Contact Details

Full Company Name: FoodMarble Digestive Health Ltd.

Contact email: healthcare@foodmarble.com

Postal Address: FoodMarble, Guinness Enterprise Centre, Dublin 8, D08 T1WY, Ireland

Document Info

Created on: 19th April 2020

Updated: 12th February 2025

Version: 1.3