PRIVACY POLICY

1. OVERVIEW

This Privacy Policy describes how FlowSelfie ("Application", "App", "we", "us", or "our"), developed by Etta LLC ("Service Provider"), collects, uses, stores, and protects information when you use our mobile application. This Policy applies to all users of the Application.

FlowSelfie is a medical device companion application designed for healthcare professionals. It connects to medical devices such as urine analyzers and other diagnostic devices to collect, process, and display analysis results.

2. INFORMATION WE COLLECT

We collect the following types of information through the Application:

2.1 Health and Device Data

2.2 Anonymous Research Data (Opt-In Only)

2.3 Support Chat Data

2.4 Device Licensing Data

2.5 Technical Data

3. HOW WE USE INFORMATION

4. DATA STORAGE AND SECURITY

4.1 Local Storage

• Health and Device Data: All medical device measurements and analysis results are stored locally on your device
• Encryption: Data is protected using device-level encryption
• Access Control: Data is accessible only through the Application on your device

4.2 Server Storage

• Anonymous Research Data: Stored on Etta LLC servers when voluntarily shared by the user. Contains no personally identifiable information
• Support Chat Data: Stored on Etta LLC servers for support processing
• Licensing Data: License codes stored on Etta LLC servers for verification purposes

4.3 Security Measures

• Server-side data is protected using industry-standard security practices
• Access to server-stored data is restricted to authorized personnel only
• All data transmission between the Application and servers uses encrypted connections

5. DATA TRANSMISSION

5.1 Data That IS Transmitted to Servers

• Anonymous Research Data: Only when the user has enabled research participation in settings AND explicitly taps the "Share" button. Data contains no patient or healthcare provider identification
• Support Chat Messages: When the user voluntarily sends a support message, including the name they entered and the message content
• License Codes: Sent to Etta LLC servers for device license verification
• Crash Reports: Anonymous crash data automatically sent to Firebase Crashlytics

5.2 Data That Is NOT Transmitted

6. MEDICAL DEVICE INTEGRATION

The Application connects to medical devices to collect and display analysis results:

6.1 Supported Devices

• Urine Analyzers: Chemical composition, concentration levels, and other analytical measurements
• Other Diagnostic Devices: Various diagnostic parameters depending on the connected device

6.2 Data Processing

• Collection: Data is received from connected medical devices via Bluetooth or other supported protocols
• Processing: All data is processed locally within the Application
• Storage: Results are stored locally on the device
• Transmission: No device data is transmitted to external servers unless the user participates in voluntary research sharing

7. ANONYMOUS RESEARCH DATA COLLECTION

7.1 What Research Data Includes

• Anonymous medical measurements from connected devices
• Patient demographic data (such as age) entered by the healthcare provider

7.2 What Research Data Does NOT Include

• Patient names, identifiers, or any personally identifiable information
• Healthcare provider names, identifiers, or any personally identifiable information
• Device serial numbers or other hardware identifiers linked to individuals
• Location data or IP addresses associated with measurements

7.3 Purpose

Research data is used solely for scientific research into the effectiveness and accuracy of medical diagnostic devices. This research helps improve the quality of medical diagnostics.

7.4 Data Handling

• Research data is sent to Etta LLC servers for research purposes only
• Data is not shared with any third parties
• Data is stored in anonymized form and cannot be traced back to individual patients or healthcare providers

8. SUPPORT CHAT

The Application includes a support chat feature for communicating with Etta LLC support team:

• User-Initiated: The user voluntarily enters their name and writes messages
• Data Transmitted: User-entered name and message content are sent to Etta LLC servers
• Purpose: Providing technical support and resolving user issues
• Sharing: Support chat data is not shared with third parties

9. DEVICE LICENSING

The Application uses a licensing system to verify connected medical devices:

• License Codes: Sent to Etta LLC servers to verify device authorization
• No Personal Data: License verification does not include any personal or health information
• Purpose: Ensuring only authorized devices are used with the Application

10. THIRD-PARTY SERVICES

The Application uses the following third-party service for technical functionality:

• Firebase Crashlytics: Anonymous crash reporting to help identify and fix application issues

Note: Firebase Crashlytics collects anonymous technical data (crash reports, device information) but does not have access to any personal or health data.

11. USER RIGHTS AND CONTROL

11.1 Data Ownership

• Users retain full ownership of all health and device data stored on their device
• All locally stored data remains under the user's complete control
• Users can access, modify, or delete their local data at any time

11.2 Research Participation Control

• Users can enable or disable research participation at any time in settings
• Disabling research participation immediately stops any future data sharing
• Previously shared anonymous research data cannot be retrieved or deleted as it contains no identifying information

11.3 Permission Management

• Users can disable medical device connections at any time
• Users can control all data sharing features through the Application settings

11.4 Data Deletion

• Users can delete local data through the Application
• All local data is automatically deleted when the Application is uninstalled
• Users can request deletion of support chat data by contacting INFO@ETTAGROUP.RU

12. DATA RETENTION

• Local Data: Retained as long as the Application is installed. Automatically deleted upon uninstallation
• Anonymous Research Data: Retained on Etta LLC servers indefinitely for ongoing research purposes. This data contains no personally identifiable information
• Support Chat Data: Retained on Etta LLC servers for the duration necessary to resolve support inquiries and for quality assurance purposes
• Licensing Data: Retained on Etta LLC servers for the duration of the device license validity
• Crash Reports: Retained by Firebase Crashlytics according to Google's data retention policies

13. CHILDREN'S PRIVACY

The Application is designed exclusively for adult healthcare professionals (18+). We do not knowingly collect personal information from children under 18. The Application is not intended for use by minors. If you believe a minor has accessed the Application or provided personal information, please contact us immediately at INFO@ETTAGROUP.RU.

14. INTERNATIONAL DATA TRANSFERS

Health and device data is stored locally on the user's device, and no international transfer of this data occurs. When data is transmitted to Etta LLC servers (anonymous research data, support chat, licensing), it may be processed in the jurisdiction where Etta LLC servers are located. Anonymous crash report data may be processed by Firebase Crashlytics in accordance with Google's data processing terms.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Material changes will be communicated through:

• In-app notifications
• Updated "Last Updated" date

Continued use of the Application after changes constitutes acceptance of the updated Privacy Policy.

16. CONTACT INFORMATION

For questions about this Privacy Policy or our data practices, contact us:

17. CONSENT AND ACCEPTANCE

By downloading, installing, or using the Application, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. You consent to:

• The collection and local processing of medical device data as described
• The integration with medical devices (with your explicit permission)
• The local storage of all health and device data on your device
• The collection of anonymous crash reports via Firebase Crashlytics
• The transmission of license codes for device verification

For optional features requiring additional consent:

• Research Data Sharing: Requires separate opt-in through Application settings and explicit action (tapping "Share") for each data submission
• Support Chat: Data is transmitted only when the user voluntarily initiates a support conversation