Privacy Policy

⚠ DRAFT — legal review required. This text is a working placeholder and must be replaced with counsel-approved wording before launch.

Who is responsible for your information

OptoCeutics ApS, Nørrebrogade 45C, 2200 København N, Denmark is the data controller for EVY INSIGHT. That means we decide what is collected and why, and we answer for it. You can write to us at that address, or reply to any email we send you.

Where your information is kept

In the European Union. EVY INSIGHT runs on servers in the EU, and your answers stay there — encrypted on the way and at rest, with access limited to the small EVY INSIGHT team who need it to run the service. We do not move your information out of the EU. If you live in the United States, that means your information is held in Europe under European rules, which are stricter than most of what US law requires.

What we collect, and nothing beyond it

These are the same categories our App Store and Google Play listings declare, so the two say the same thing:

Email address — how you sign in, how the weekly check-in reaches you, and how we reply to you.

User ID — the identifier your account is given in our records, so that answers, and the record we build from them, can be joined up over the six weeks.

Your check-in answers, about the person you care for

This is health information, and it gets the extra care that the law requires for it.

Usage data and product interaction — which parts of EVY INSIGHT you open, which check-ins you start, pause and finish, and when. We use it to see whether the weekly rhythm is working and to make the service easier to live with.

How long you play the sound

EVY INSIGHT has a page that plays a tone through your browser. When you play it we keep the day, how many minutes of sound you actually heard, and whether it ran to the end. No audio is recorded and none is sent anywhere — the sound is made on your own device and stays there; what we keep is the length. We keep it for one reason: so that the page can show your own listening back to you. It is not joined to your check-in answers, nobody is graded on it, and it is deleted along with everything else when you ask us to delete your information.

When your EVY LIGHT was on, if you connect it

Connecting your lamp is optional and you can do it at any time, or never. If you do, we read from the lamp's own cloud service when it ran and for how long — the start time and length of each session, and nothing else. We do not receive sound, light, images, voice, or anything the lamp senses about the room, because the lamp does not report any of that. We keep it for one reason: so the page can show your own lamp use back to you. It is not joined to your check-in answers, nobody is graded on it, and no part of it is a measure of anyone's health.

Your time zone, if you connect your lamp

To put an evening on the right day we need to know which day your evening is. Your browser tells us the name of your time zone — "Europe/Copenhagen", "America/New_York" — and we store that name. It says which region keeps your clock, not where you are: it is not GPS, not an address, not a postcode, and it does not change as you move about. Without it a session at half past midnight would land on the wrong day.

What we do not collect

No GPS or precise location, and no address — the time zone name described above is the only location-shaped thing we hold, and only if you connect your lamp. No contacts. No advertising identifiers. Nothing from other apps on your phone. Nothing from any device in your home except your EVY LIGHT, and from it only the session times described above — never sound, images or anything it senses. There are no advertising or analytics trackers on the check-in pages.

Crash data — when something goes wrong we record the error, the moment it happened and basic technical facts about the device and its software version, so that we can find the fault and fix it. Some of this reaches us through the app store's own crash reporting.

Why we are allowed to hold it

Your email address, user ID and account exist so that we can provide the service you asked for. Your check-in answers are held on the basis of the agreement you gave when you joined, which you can take back at any time. How long you play the sound is held for the same reason as your account: it is part of the service you asked for, because showing your own listening back to you is the whole point of keeping it. Your lamp's session times and your time zone are held on the same footing, and only from the moment you choose to connect a lamp: they exist so the page can show you your own lamp use, and if you would rather we did not hold them, disconnect the lamp or ask us and we will delete them. Usage data and crash data are held because we have a legitimate interest in keeping EVY INSIGHT working and secure — and if you would rather we did not, tell us and we will look at your case.

Who else sees it

Only you and the EVY INSIGHT team, plus the companies that help us run the service under a written contract: hosting in the EU, the secure health-data platform your answers are stored in, email delivery, and the app stores' crash reporting. They may act only on our instructions. Your information is never sold, never used for advertising, and never handed to anyone for their own purposes. There are no third-party tracking pixels or advertising tools on the check-in pages. We would disclose something only if the law obliged us to.

Where your answers are stored

Your check-in answers are kept in a specialist platform built for health information, which we use as the secure store behind EVY INSIGHT — the same kind of system used for medical research, chosen because it is built to protect this sort of information rather than because you are part of a study. You are not. Your record there is held under a reference number we generate, not your email address or your name, and it holds only the check-in answers described above. If you ever do agree to take part in research, that is a separate agreement you sign separately, and we would tell you plainly at the time.

We do not use your answers for research

Joining EVY INSIGHT is not joining a study, and we have not asked you for anything beyond the two documents you agreed to. If that ever changes we will ask you separately, in plain words, and the asking will be a real question with "no" as an ordinary answer — not a box already ticked, and not a condition of anything. Nothing about EVY INSIGHT, your EVY LIGHT warranty, refunds or support depends on it. If you have separately signed a research agreement with us, that agreement — not this policy — governs what may be done with your answers for research, and you can withdraw it at any time.

How long we keep your lamp's session times

Two clocks, both running whether or not you ever ask. The detailed per-session list is deleted 90 days after each session. The day-by-day totals the page draws — one line per day, how long in total and how many sessions — are deleted after 24 months. Neither clock waits for you to request anything, and both apply to a lamp you have since disconnected. If you ask us to delete your information, all of it goes then, without waiting for either clock.

How long we keep it

Your record stays while your account is open, because it is the record you came for. When you close your account or ask us to delete your answers, a member of our team actions the deletion — we do it by hand rather than automatically, because it cannot be undone, and we will have it done within one month of your asking. We delete your answers and everything that identifies you, unless the law requires us to keep something specific — in which case we keep only that, and only for as long as we must. We keep a dated record that the deletion was asked for and carried out, with nothing in it that points back to you. Your answers are also held in the secure health-data platform described above, which has no automatic deletion; we remove them there by hand as part of the same request. De-identified information, which can no longer be traced to you, may remain.

Your rights

You can ask for a copy of what we hold, have it corrected, have it deleted, take it elsewhere in a portable form, object to how we use it, or take back an agreement you gave — taking it back does not undo what was lawfully done beforehand. Write to us and we will answer within one month.

If you live in the United States

The rights above are yours too, whichever state you live in — we do not run two standards. Several states also give you the right to know what is collected and who it goes to, to have it corrected or deleted, to receive a portable copy, and to opt out of the sale or sharing of your information and of profiling. We do not sell your information and we do not share it for advertising, so there is nothing there to opt out of, but you may ask us to confirm that in writing. We will never charge you a different price or give you a worse service for exercising any of these rights. Write to the address above.

If we get it wrong

In the EU you can complain to the Danish Data Protection Agency (Datatilsynet, datatilsynet.dk). In the United States you can complain to your state Attorney General. Either way, we would rather you told us first.

Children

EVY INSIGHT is for adults. We do not knowingly collect information about anyone under 18 through it.

Changes to this policy

If we change how your information is used in a way that matters to you, we will email you before it takes effect, and the version shown with this page will change with it.