CareTechr Healthcare Lda.
Rua Colegio Militar 12
2780-239 Oeiras, Lisboa
PortugalGeneral Contact:

[email protected]

Privacy / DPO Contact:
Prasant Saha
Email: [email protected]

2. Applicable Data Protection Laws

CareTechr processes personal data in accordance with applicable data protection laws, including the General Data Protection Regulation — Regulation (EU) 2016/679 (“GDPR”) — and Portuguese Law No. 58/2019 of 8 August, which implements the GDPR in Portugal.

CareTechr applies appropriate technical and organizational measures to protect personal data and to ensure that personal data is processed lawfully, fairly, transparently, and only for legitimate purposes.

3. Minimum Age Requirement

The CareTechr application and services are intended for users who are 18 years of age or older.
By using the CareTechr application or services, you confirm that you are at least 18 years old and that the information you provide is true, accurate, complete, and up to date.

4. Personal Data We Collect

Depending on how you use CareTechr services, we may collect and process the following categories of personal data.

4.1 Account and Identification Data

We may collect:

• First name and surname;
• Email address;
• Phone number;
• Username or user ID;
• Password or authentication credentials;
• Nationality;
• Date of birth;
• Age;
• Gender;
• Identification document details, where required;
• Tax identification number, where required;
• Profile photograph, where voluntarily provided.

4.2 Contact Data

• Postal address;
• Billing or correspondence address, where required.

PART 3

4.3 Health and Wellness Data

The CareTechr application may allow you to voluntarily enter, upload, or connect health and wellness information, including:

• Weight;
• Height;
• Ethnicity, where required for specific health-related calculations;
• Body measurements;
• Health parameter readings;
• Health risk indicators;
• Charts, reports, and trends generated from the data you provide;
• Data received from compatible Bluetooth medical or wellness devices.

Health and wellness data may be considered sensitive personal data. CareTechr processes such data only for the purposes described in this Privacy Policy and where a lawful basis exists, including your explicit consent where required by law.

4.4 Device and Technical Data

We may collect technical data necessary for the operation, security, and improvement of the application, including:

• Device type;
• Operating system;
• Application version;
• Device identifiers or app instance identifiers;
• Crash logs;
• Diagnostic data;
• Security logs;
• Connection information;
• Bluetooth connectivity status, where relevant.

4.5 Bluetooth Data

The CareTechr application may connect to compatible health or wellness devices using Bluetooth or Bluetooth Low Energy technology.
Bluetooth is used only to connect the application with supported external devices and to receive measurements from those devices.
CareTechr does not use Bluetooth for advertising, tracking, or unrelated purposes.
You may disable Bluetooth from your device settings at any time. If Bluetooth is disabled, some connected-device features may not work.

4.6 Location Permission

On some Android and iOS devices, location permission may be required by the operating system to scan for or connect to Bluetooth devices.
CareTechr does not use location permission to track your movements, monitor your physical location, or create location-based profiles.
Where location permission is requested, it is used only to support Bluetooth connectivity with compatible medical or wellness devices.
CareTechr does not sell location data and does not use location data for advertising.
You may disable location permission in your device settings. However, disabling location permission may affect Bluetooth device connectivity.

4.7 Payment Data

If paid services are offered, payments may be processed by third-party payment providers.
CareTechr does not store full payment card details unless expressly stated and legally permitted. Payment providers may process payment information according to their own privacy and security policies.

4.8 Communication and Support Data

If you contact us, we may process:

• Your name;
• Message content;
• Support request details;
• Communication history.

PART 4

5. How We Collect Personal Data

CareTechr may collect personal data when:

• You create an account;
• You enter information in the application;
• You connect a compatible Bluetooth device;
• You use CareTechr features;
• You contact us for support;
• You subscribe to communications;
• The application generates crash logs, diagnostic logs, or security logs;
• Third-party service providers process data on our behalf.

6. Why We Use Your Personal Data

CareTechr may process your personal data for the following purposes:

• To create and manage your account;
• To provide access to the CareTechr application and services;
• To authenticate users and protect accounts;
• To display health and wellness measurements, charts, reports, calculations, and trends;
• To connect the application with compatible Bluetooth health or wellness devices;
• To generate health-related indicators based on data entered by you or received from connected devices;
• To respond to support requests;
• To send service-related communications;
• To provide backup, recovery, and account management support;
• To improve app performance, reliability, usability, and security;
• To detect and prevent fraud, misuse, unauthorized access, or security incidents;
• To comply with legal, regulatory, tax, audit, or security obligations;
• To send marketing communications only where permitted by law and, where required, after receiving your consent.

7. Health Disclaimer

The CareTechr application is intended to support personal, educational, informational, wellness, and convenience purposes.
Unless expressly stated and supported by applicable regulatory approval or certification, the CareTechr application is not a medical device and does not diagnose, treat, cure, or prevent any disease or medical condition.
The application may display calculations, charts, reports, risk indicators, or health-related information based on data entered by you or received from compatible external devices. These outputs are not a substitute for professional medical advice, diagnosis, or treatment.
Always consult a qualified healthcare professional before making medical decisions or changing any medication, treatment, diet, or exercise plan.
If the application connects to external medical or wellness devices, the accuracy of measurements depends on the connected device, correct device usage, device calibration, and the device manufacturer’s specifications.
PART 5

8. Legal Basis for Processing Personal Data

Where GDPR applies, CareTechr processes personal data based on one or more of the following lawful bases:

• Performance of a contract, where processing is necessary to provide the application and services;
• Your consent, especially for sensitive health data, optional features, marketing communications, and permissions where required;
• Compliance with legal obligations;
• Legitimate interests, including app security, fraud prevention, service improvement, and customer support, provided that such interests are not overridden by your rights and freedoms;
• Establishment, exercise, or defense of legal claims.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

9. Mandatory and Optional Data

Some data is necessary to create an account and provide the core CareTechr services. If you do not provide required information, we may not be able to provide the relevant service.
Optional data, such as certain health profile details, Bluetooth device readings, or marketing consent, may be skipped or disabled. However, some features may not function correctly without the relevant data or permission.

10. Sharing of Personal Data

CareTechr does not sell your personal data.
CareTechr may share personal data only where necessary and lawful, including with:

• Employees, contractors, consultants, and support staff who require access to provide services;
• Cloud hosting providers;
• Technical infrastructure providers;
• Analytics, diagnostics, and crash-reporting providers, where used;
• Customer support providers, where used;
• Payment processors, where paid services are offered;
• Professional advisers, such as lawyers, auditors, accountants, or insurers;
• Regulators, courts, public authorities, or law enforcement authorities where required by law;
• A successor organization in connection with a merger, acquisition, restructuring, or sale of assets, provided appropriate safeguards are applied.

All service providers must process personal data only according to CareTechr’s instructions and must apply appropriate confidentiality, privacy, and security safeguards.

11. Third-Party SDKs and Services

The CareTechr application may use third-party SDKs or service providers for hosting, analytics, diagnostics, crash reporting, payment processing, push notifications, customer support, or app performance monitoring.
Any third-party service provider that processes personal data on behalf of CareTechr must apply appropriate privacy and security safeguards.
CareTechr will ensure that app store privacy disclosures reflect the actual data collected, used, shared, and retained by the application and any third-party SDKs used in the application.
PART 6

12. International Data Transfers

CareTechr is based in Portugal and primarily processes data within Portugal or the European Union.
Where personal data is transferred outside the European Economic Area, CareTechr will ensure that appropriate safeguards are in place, such as adequacy decisions, Standard Contractual Clauses, contractual protections, or other lawful transfer mechanisms required by applicable law.

13. Data Security

CareTechr applies appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, destruction, or unlawful processing.
These measures may include:

• HTTPS encryption in transit;
• Secure authentication;
• Access controls;
• Role-based access restrictions;
• Secure server infrastructure;
• Monitoring and logging;
• Data minimization;
• Backup and recovery controls;
• Staff confidentiality obligations;
• Regular review of security practices.

However, no internet-based service, mobile application, or cloud system can be guaranteed to be completely secure. CareTechr works to protect your information but cannot guarantee absolute security.

14. Data Retention

CareTechr keeps personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required by law, regulation, security, dispute resolution, or legitimate business needs.
In general:

• Account data is retained while your account is active;
• Health and wellness data is retained while your account is active or until you delete it, request deletion, or withdraw consent where applicable;
• Support communications may be retained for service quality, legal, and audit purposes;
• Security logs may be retained for a limited period to protect the application and users;
• Where you delete your account, CareTechr will delete or anonymize personal data within a reasonable period, unless retention is required by law or legitimate reasons.

CareTechr may retain certain data for up to twelve months after account deletion where necessary for backup, security, legal, audit, fraud-prevention, or dispute-resolution purposes. After this period, the data will be deleted or anonymized unless longer retention is legally required.
PART 7 (FINAL)

15. Account Deletion and Data Deletion

If you create an account in the CareTechr application, you may request deletion of your account and associated personal data.
You can request account deletion by:

• Using the account deletion option inside the CareTechr application, where available; or
• Sending an email to [email protected] or [email protected] with the subject line “Account Deletion Request”.

When you request account deletion, CareTechr will delete or anonymize your account data and associated personal data, unless certain data must be retained for legal, security, fraud prevention, regulatory, dispute-resolution, or legitimate business reasons.
If any data must be retained, CareTechr will limit the retained data to what is necessary and will keep it only for the required period.

16. Your Privacy Rights

Subject to applicable law, you may have the following rights:

• Right of access: to know whether we process your personal data and to receive a copy of it;
• Right of rectification: to correct inaccurate or incomplete personal data;
• Right of erasure: to request deletion of your personal data;
• Right to restriction: to request limitation of processing;
• Right to data portability: to receive your data in a structured, commonly used, machine-readable format;
• Right to object: to object to processing based on legitimate interests or direct marketing;
• Right to withdraw consent: where processing is based on consent;
• Right to lodge a complaint with a data protection authority.

To exercise your rights, you may contact us at:
[email protected]
[email protected]

17. Complaints to Supervisory Authority

If you believe your data protection rights have been violated, you may contact the Portuguese Data Protection Authority:
CNPD — Comissão Nacional de Proteção de Dados
Av. D. Carlos I, 134 – 1.º
1200-651 Lisboa
Portugal
Phone: +351 213 928 400

18. Marketing Communications

CareTechr may send marketing communications only where permitted by law and, where required, after receiving your consent.
You may unsubscribe from marketing communications at any time by using the unsubscribe link in the email or by contacting us.
Service-related messages, such as security notices, account notices, support responses, or important application updates, may still be sent where necessary.

19. App Store and Google Play Privacy Disclosures

CareTechr will provide privacy disclosures in Google Play Console and Apple App Store Connect that reflect the actual data collected, used, shared, and retained by the application.
Depending on the application version and enabled features, these disclosures may include:

• Contact information;
• Account information;
• Identifiers;
• Health and wellness data;
• User profile data;
• Device or app diagnostics;
• Usage data;
• Bluetooth-related access;
• Location permission used only for Bluetooth connectivity, where applicable.

CareTechr does not sell personal data and does not use personal data for third-party advertising tracking unless clearly disclosed and consented to where required by law.

20. Cookies and Website Technologies

When you visit the CareTechr website, we may use cookies or similar technologies to operate the website, improve performance, analyze usage, remember preferences, and support security.
Where required by law, we will request your consent before using non-essential cookies.
You may control or disable cookies through your browser settings. Disabling cookies may affect certain website features.

21. Changes to This Privacy Policy

CareTechr may update this Privacy Policy from time to time due to changes in law, application functionality, business practices, or regulatory requirements.
If material changes are made, CareTechr may notify users through the application, by email, or through another appropriate method.
The updated Privacy Policy will be effective from the date it is published.

22. Contact Us

For questions about this Privacy Policy, your personal data, account deletion, or your privacy rights, please contact:
CareTechr Healthcare Lda.
Rua Colegio Militar 12
2780-239 Oeiras, Lisboa
Portugal
General Email:
Privacy / DPO Contact:
Prasant Saha
Privacy Email:
[email protected]