CGMSIM Privacy Policy

Who we are

CGMSIM is a free type 1 diabetes simulator for learning and practice, available at cgmsim.com and as the CGMSIM mobile app on Google Play and the App Store. CGMSIM is developed and operated by Lorenzo Sandini, Lappeenranta, Finland ("CGMSIM", "we", "us").

This policy explains what personal data CGMSIM collects, how we use, store, share and protect it, and how you can delete it. It applies to the website, the web app and the mobile apps. Questions: info@cgmsim.com.

Information we collect

What we collect depends on how you sign in and which features you use.

• Email and password. Your email address and a securely hashed password.
• Sign in with Apple. Your Apple user identifier, and the name and email address Apple shares with us (this may be an Apple private relay address).
• Sign in with Google. See "Google user data" below.
• Using CGMSIM. The settings and parameters you enter for your virtual patient and simulations.

CGMSIM no longer retrieves physical activity data (such as steps or heart rate) from Fitbit, Google Fit or Google Health. We do not collect payment information, precise location, contacts or advertising identifiers.

Google user data

If you sign in with Google, CGMSIM accesses only the following Google user data, and only for the purpose stated:

• Basic profile (scopes openid, email, profile): your Google account identifier, name, email address and profile picture. We use these to create your CGMSIM account, sign you in and contact you about your account.
• Google Health settings, read-only (scope googlehealth.settings.readonly, shown to you as "See your Google Health settings"): your legacy Fitbit user ID, a 6-character identifier. We use it only to find and reconnect the CGMSIM account you originally created with Fitbit.

Users who first registered with a Fitbit account now sign in with the Google account their Fitbit was moved to. The legacy Fitbit user ID is the identifier of those existing CGMSIM accounts. We read it once at sign-in to link you to your account. We do not read any health, fitness, activity, sleep or body data from Google Health or any other Google service.

CGMSIM's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

How we use information

We use your information only to provide and improve CGMSIM's user-facing features:

• create and manage your account, and sign you in
• link legacy Fitbit-registered users to their existing accounts
• run your simulations
• send essential account and service messages (we do not send promotional or marketing email)
• keep the service secure and fix problems

We never use Google user data, or any other personal data, for:

• advertising of any kind, including targeted, personalized, retargeted or interest-based advertising
• selling, or providing it to data brokers or information resellers
• determining creditworthiness or for lending purposes
• building databases or profiles unrelated to your use of CGMSIM

CGMSIM does not use Google Workspace APIs or any Google user data to develop, improve or train generalized or non-personalized AI or machine-learning models.

Sharing and disclosure

We do not sell, rent or trade personal data, and we do not transfer or disclose Google user data to third parties except as described here.

• Hosting. CGMSIM runs on servers rented from Oracle Cloud Infrastructure, which stores data on our behalf and may not use it for its own purposes.
• Legal requirements. We may disclose information if required by law, or to protect the rights and safety of users or others.
• Change of ownership. If CGMSIM is merged, acquired or transferred, personal data may move with it. Google user data will only be transferred with your explicit prior consent.

Security

We use administrative and technical safeguards to protect the confidentiality of your data:

• all traffic to CGMSIM is encrypted in transit with HTTPS (TLS)
• passwords are stored only as salted hashes, never in plain text
• OAuth tokens and connected-service credentials are stored encrypted
• access to servers and databases is limited to the CGMSIM administrators and protected by key-based authentication
• we do not request Google OAuth refresh tokens beyond what sign-in requires, and we do not write Google user data to application logs

No system is perfectly secure. If a breach affects your personal data, we will notify you and the competent authorities as required by law.

Data retention and deletion

We keep your personal data only while your account is active, or as long as needed to provide the service.

• Delete your account at any time in the app: Settings → CGMSIM Settings, log in, open the main menu and choose "Delete Account". Step-by-step help: cgmsim.com/auth/delete-user.
• What is deleted. Your profile, sign-in identifiers (including your Google account identifier and legacy Fitbit user ID), stored tokens and credentials, and your simulation data are deleted immediately and permanently from our active systems.
• Backups. Residual copies in backups are overwritten within 30 days.
• Revoking Google access. You can remove CGMSIM's access at any time at myaccount.google.com/permissions. This stops any further access; to also delete the data we already hold, delete your account or email us.
• Inactive or orphaned data. If you cannot sign in, email info@cgmsim.com from your account's address and we will delete your data within 30 days.

Your rights (GDPR)

CGMSIM is operated from Finland and follows the EU General Data Protection Regulation. We process your data to perform our agreement with you (providing your account and the simulator), and on our legitimate interest in keeping the service secure.

You have the right to access, correct, export or delete your personal data, and to object to or restrict its processing. Email info@cgmsim.com and we will respond within one month. You can also lodge a complaint with the Finnish Data Protection Ombudsman (tietosuoja.fi) or your local supervisory authority.

CGMSIM is an educational tool, not a medical device, and is not intended for children under 16.

Changes to this policy

The date at the top shows when this policy was last updated. If we change how CGMSIM accesses, uses, stores or shares your data, in particular Google user data, we will notify you by email or in the app before the change takes effect and, where required, ask for your consent again.

Contact

Lorenzo Sandini, CGMSIM, Lappeenranta, Finland — info@cgmsim.com