FamilyDose Privacy Policy
Beta version. This document has not been reviewed by a lawyer.
Version 2.1
Date: 2026-10-18
What changed in this version
- Growth: the chart shows the WHO reference curves beside the child's own measurements, for information only, not a diagnosis.
- The operator is now Primelink Digital Online Seller, a sole establishment licensed in Dubai.
- The policy covers every region where FamilyDose is offered at launch, with a section for each region whose law needs its own words.
- Where your data is stored (Japan, Tokyo) and which service providers in the United States process it, by name and purpose.
- The legal bases: explicit consent for health information, a separate consent for storage in Japan and processing by the named service providers, and the contract for your account.
- The full list of service providers, the same list as our Subprocessors page and our app store privacy answers.
- How to use each right, how fast we answer, how we tell you about a breach, and which authority you can complain to.
- Telegram alerts and the temperature chart's outside chart library are no longer used and were removed.
- We added Cloudflare Turnstile, which checks that sign-ins come from people, not bots.
- The Admin of a shared household now chooses its new Admin before leaving or deleting their account. If nobody can be chosen, the household is deleted; it is kept for 30 days, then deleted for good.
1. Who we are
FamilyDose is operated by Primelink Digital Online Seller, a sole establishment licensed by the Department of Economy and Tourism, Dubai, licence no. 1603034, P.O. Box 48800, Dubai, United Arab Emirates. Contact: support@familydose.app. In this policy "we", "us" and "our" mean Primelink Digital Online Seller.
We decide why and how your personal data is used, so we are the controller (in some laws the "data fiduciary", "business" or "regulated entity") for the data in FamilyDose.
- Privacy questions and requests: privacy@familydose.app. This mailbox is read by our privacy officer, who is responsible for the protection of personal information.
- Support: support@familydose.app
FamilyDose is offered in the Gulf, the rest of the Middle East and North Africa, Asia (not mainland China), Africa, Latin America, the United States and Canada (Not offered yet: Canada opens when the app is in French). It is not yet offered in the European Union, the United Kingdom or mainland China.
2. What FamilyDose is and is not
FamilyDose is a record-keeping and reminder tool that holds family health information. It is not a clinical service and it is not a medical device. It does not diagnose, treat, prescribe, advise, or tell anyone what or how much to give. Reminders follow the schedule the user sets and can be delayed or fail.
What you see in FamilyDose is what you or someone in your household entered. Always check the record before giving a dose. FamilyDose is not an emergency service. For any question about a medicine, a dose or a symptom: Ask your doctor or pharmacist.
3. Words we use
- Household: a shared space in FamilyDose for the records of one or more people.
- Member: an adult with a FamilyDose account who has joined a household.
- Admin: the member who owns the household.
- Full access and Restricted: the two access levels a member can have besides Admin.
- Patient: a person whose records are kept in a household. A patient can be a child, an adult you care for, or you. Patients do not have accounts.
- Care card link: a web link that shows chosen parts of a patient's record to anyone who has the link.
- Service provider: a company that runs part of FamilyDose for us and processes data only to provide its service to us.
4. Who this policy covers
Account holders are adults (see section 13 for the minimum age where you live). Children and other patients never have an account and never sign in. Everything about a patient is entered by adults in the household.
FamilyDose holds health information, including health information about children. We treat all of it as sensitive.
These documents go with this policy:
- the Consumer Health Data Privacy Policy, about health data only, for users in US states with consumer health data laws and for everyone who wants the health data details in one place;
- the Subprocessors page, with the same service provider list as section 9;
- Your data rights, the step-by-step guide to section 12;
- the notice for parents and the notice for children.
5. What we collect
We collect only what you or your household enter, what your device sends so the app can work, and the technical records listed below.
Your account
- Email address, first and last name.
- A password, stored by our sign-in provider in a one-way scrambled form, or your Apple identity if you use Sign in with Apple. With Sign in with Apple we also keep a token from Apple, which we ask Apple to revoke when you delete your account.
- Your date of birth, used to check that you meet the minimum age where you live. Only you can see it in the app.
- A record of the age check, with the time, the method and the minimum age that applied.
- The country you live in, as you chose it, with the time you chose it and each earlier answer, and your phone's region setting beside it. We do not read your location and we do not use your IP address for this. We use the country to apply the rules of that country (which documents, consents and minimum age apply, and whether FamilyDose is open there).
- A record of each consent you gave or withdrew, with its version, the exact text shown, the language, the time, the app version and the platform (see section 7).
- A record that you agreed to the Beta Participation Agreement, while FamilyDose is in a closed beta.
- Your preferences, such as units, time format, language and your colour and relationship label in each household.
- When you sign up, a check of whether your email address matches another FamilyDose account, to catch duplicate accounts made by mistake.
Patient profiles, including children
For each patient: name, and if you add them, date and time of birth, sex, relationship to you, blood type, allergies, known conditions, diet notes, emergency contacts, insurance details and photos of the insurance card.
Medicines and doses
- Medicines: name, dose, route, category, schedule, notes, any diagnosis you choose to enter, stock counts, and whether a medicine is paused or finished.
- A history of changes made to each medicine: what changed, when, and which member changed it.
- Doses: when a dose was marked given, skipped or snoozed, and which member logged it. This includes as-needed doses.
Symptoms and temperatures
Temperature readings, severity, tags and notes.
Vaccinations
Vaccine name, dose number, date and time given, next due date, lot number, doctor and clinic. The vaccination booklet holds only what you enter. Official schedules are shown only as a labelled reference for information.
Growth
Height and weight, the date, and any note. The app draws them as a chart of the child's own measurements, with the WHO reference curves (the 2nd, 50th and 98th percentile lines) beside them. The reference curves are for information only, not a diagnosis. The curves are drawn on your phone; nothing about the child is sent to the WHO.
Appointments
Title or reason, date and time, doctor or provider, location and notes.
Documents and photos
Files you upload for a patient, such as photos and PDFs of prescriptions, vaccination records, medical records, insurance, identification or school documents. We store the file, its name, the type you choose, when it was uploaded and who uploaded it.
Scans
- A camera scan of a prescription label is read on your phone. The image stays on the phone for that reading.
- If you turn on "Closer reading" (its own consent), a prescription photo can be sent to OpenAI in the United States for a closer reading. It is sent with storage for training switched off.
- For every scan we store the text that was read and the details picked out of it, such as the patient's name, date of birth and medicines, so you can review them. Nothing from a scan is saved as a medicine or vaccination until you confirm it.
- A photo sent for a closer reading is stored in your household's private file storage. Today it stays there until the household or the account that scanned it is deleted. [CONFIRM: whether the uploaded scan file is removed once the scan is confirmed or discarded by the publication date]
Care cards
What you choose to put on a patient's care card: allergies and what to do about them, conditions, medicines, diet, blood type, emergency contacts, insurance details and, if you add one, the insurance card image. For each care card link: the sections it shows, its end date, how many times it was opened and when it was last opened.
Household and caregiver data
Household name, members, each member's role and access level, which patients each member can see, and who entered or changed each record.
Other people's details
- Invited people: the email address of anyone you invite to your household, before they have an account. We send them an invitation email.
- Emergency contacts: name, phone number and relationship.
- Doctors and clinics named in vaccination and appointment records.
Please add another person's details only when you have a reason to.
Notification settings
For each household you belong to: which channels are on (push, email), which kinds of notification you get, your quiet hours, and a second delivery email address if you add one.
Notifications contain health information. A reminder or alert can include a patient's first name, a medicine name and dose, or a temperature. It can appear on your lock screen or in your inbox. You can hide medicine names in push notifications and in emails: Settings, Notifications.
Push tokens and device sessions
For each phone or tablet you sign in on: the device type, the name given to the device (which often includes a person's name), a session identifier, when it was last active, and the push token that lets us send notifications to it.
Usage events
Records of which features are used and when, for example that a dose or a symptom was logged, or which fields of a scan you corrected. Each event carries your user ID and household ID. It does not contain what you entered. Usage events are stored in our own database, not with an analytics company.
You can turn usage events off at any time: Settings, Data and privacy, Share usage data. When it is off, the server refuses to record usage events for you. [CONFIRM with counsel: whether this switch must be off by default in some regions]
Crash and error reports
If the app or a server function fails, a report goes to Sentry in the United States: the error, the device type, the system and app version, and a scrubbed message. Names, email addresses, medicine words and IP addresses are removed before the report is sent.
Support messages
Messages you send to support@familydose.app or privacy@familydose.app, feedback you send from the app, and a record of any privacy request and how it was handled.
IP addresses and server logs
When your phone or browser connects, our service providers record technical details such as IP address, time and the request made. Supabase does this for sign-in and app requests. Vercel does this for familydose.app, including each time anyone opens a care card link. Our server functions also log account IDs when something fails. Logs are written to carry IDs and counts, not names.
Website product news list
If you join the list on familydose.app, we store the email address you enter and use it only to write to you about FamilyDose.
Kept only on your phone
Some settings stay on your phone, such as which household you last opened. If you turn on Face ID or Touch ID sign-in, a sign-in token is kept in the phone's keychain. Reminders the phone schedules for itself stay on the phone. Text in a photo is first read on the phone by Google ML Kit; the photo is not sent to Google.
What we do not collect
We do not collect your location (the country above is the one you choose), your address book, or advertising identifiers. We do not import data from Apple Health or Health Connect. We do not buy data about you from anyone. We do not use third-party analytics or advertising networks.
6. Why we use your data
| Purpose | What we use |
|---|---|
| Keep your household's shared record | Account, household, patient and health records |
| Send the reminders and alerts you and your household set | Schedules, dose records, notification settings, push tokens, email addresses |
| Read a scan for you to review | Scan images and text |
| Show a care card to people you choose | The sections you chose |
| Check the minimum age and apply the rules of your country | Date of birth, the country you chose |
| Keep accounts secure | Device sessions, sign-in records, server logs |
| Fix faults | Crash and error reports, server logs |
| Understand which features are used | Usage events, if the switch is on |
| Answer you | Support messages and privacy requests |
| Send product news | Your email address, only if you opt in |
| Meet our legal duties | Consent records, age records, privacy request records |
We do not sell your data. We do not use it for advertising. We do not build profiles of you or of any patient for marketing or for automated decisions about you. We do not use health data for anything other than the records and reminders your family sets.
7. Our legal bases and your consents
| What | Legal basis |
|---|---|
| Your account, your household and the service you asked for | Our contract with you (the Terms of Service) |
| Health information about you and the people you add | Your explicit consent, given separately from the Terms and recorded |
| A child's health information | The explicit consent of the child's parent or legal guardian, given for each child and recorded |
| Storage in Japan and processing in the United States by the named service providers | Your separate consent to the transfer, recorded |
| Security, fault fixing and records the law requires us to keep | What is needed to provide the service you asked for, and our legal duties [CONFIRM with counsel: the basis for security logs and crash reports in each region] |
| Usage events, product news emails | Your choice: a switch you can turn off at any time |
The app asks for each consent separately, with its own unticked control, records the version and the exact text you saw, and lets you withdraw it in Settings with immediate effect. We never bundle the health data consent or the transfer consent into the Terms.
| # | Consent | When it is asked | How to withdraw |
|---|---|---|---|
| 1 | Terms of Service and Privacy Policy, with the age check | At sign-up, and again when either document changes | Settings, Data and privacy, Withdraw consent. The account cannot run without it, so withdrawing means exporting your data if you wish and deleting the account. |
| 2 | Health information: explicit consent to keep the health information you enter about yourself and the people you look after | At sign-up, before any health information is stored | Settings, Data and privacy. FamilyDose then cannot keep these records. |
| 3 | Transfer: storage in Japan (Tokyo) by Supabase on Amazon Web Services, and processing in the United States by the service providers in section 9 | At sign-up | Settings, Data and privacy. FamilyDose cannot be used without it, because it has no other place to keep records. |
| 4 | Parent or legal guardian consent for each child | Before a child's health information is stored. Only the Admin or a Full access adult can give it. | Settings, Data and privacy, Privacy and consents |
| 5 | Caregiver confirmation that they act on the parent's behalf | Once, for members who are not the parent or guardian | Settings, Data and privacy, Privacy and consents |
| 6 | Closer reading: a prescription photo is sent to OpenAI in the United States | Before the first photo is sent | Settings, Data and privacy, Closer reading with OpenAI |
| 7 | Messages by email, which can contain medicine names | When you turn on email notifications | Settings, Data and privacy, Privacy and consents, or Settings, Notifications |
| 8 | Care card link: a confirmation each time a link is shared | Each time you create or share a link | Revoke the link from the patient's care card |
| 9 | Product news and tips | A separate opt-in, off by default | Settings, Data and privacy, Privacy and consents, and the unsubscribe link in each email |
Withdrawing a consent does not undo what was lawfully done before you withdrew it.
8. Who can see your data
People in your household
Members see the patients they have been given access to. The Admin sets each member's access level and can switch a member's access to a patient off. A parent or guardian can see who entered each record.
People you give a link or file to
Anyone who has a care card link can open it without signing in and see the sections you chose, until the link's end date or until you revoke it. The page is not listed in search engines, but it is not locked: anyone who has the link can open it. A PDF or an export you share can be read by whoever receives it, and we cannot recall it. Sharing a care card link is your own choice.
Our staff
Authorised staff, working from the United Arab Emirates, can view household records, including health information, through an internal admin dashboard. Staff must sign in with a second factor to use it. We use this access only to answer a support or privacy request, to investigate a fault or a security problem, or where the law requires it. Staff actions that change or delete data are recorded. [CONFIRM: number of people with staff access at publication]
Authorities
We disclose data to a court, a regulator or the police only where a law we are subject to requires it, and we disclose no more than required. Where the law allows, we tell you first.
9. Service providers, where your data is stored and transfers
We use the service providers listed here to run FamilyDose. They process data only to provide their service to us.
Where your data is stored
Your data is stored in Japan (Tokyo) by Supabase on Amazon Web Services (AWS region ap-northeast-1). This is the database, sign-in records, stored files and backups. Supabase Inc. is a company in the United States.
Transfers
Your data leaves the country you live in. It is stored in Japan, and some of it is processed in the United States by the providers below, for email, push notifications, error reports, the website and shared care cards, medicine name suggestions and, only with your consent, the closer reading of a prescription photo. Our staff view it from the United Arab Emirates. Data travels over encrypted connections.
We rely on your separate transfer consent (consent 3 in section 7), and on our agreements with the providers. [CONFIRM: that a data processing agreement is accepted or signed with Supabase, Resend, Expo, Sentry, OpenAI, Vercel and Zoho; Apple acts under its own developer terms]
The service providers
| Service provider | What it does for us | What it receives | When | Where |
|---|---|---|---|---|
| Supabase (on Amazon Web Services) | Database, sign-in, file storage, server functions | Everything the app stores: account (name, email, date of birth), household and members, people cared for, medicines, doses, symptoms, temperatures, growth, appointments, notes, files and photos, consent records, settings, usage events | Always | Japan (Tokyo, AWS ap-northeast-1) |
| Resend | Sends email | The recipient's email address and the email's words: invitations, sign-in codes, dose and missed-dose emails (a medicine name unless you hide medicine names in email), support replies | When an email is sent | United States |
| Expo push service, then Apple Push Notification service | Delivers push notifications | The phone's push token and the notification's words (a medicine name unless you hide medicine names in push) | When a push is sent | United States (Expo); Apple worldwide |
| Apple | Sign in with Apple, App Store and in-app purchases, TestFlight | Your Apple sign-in identifier and the email Apple shares; purchase records; crash and usage data only if you share it with developers in iOS settings | Sign-in, purchase | Apple, worldwide |
| Sentry (Functional Software Inc.) | Crash and error reports, app and server | The error, the device and app version, a scrubbed message; no names, emails, medicine words or IP address | When something fails | United States |
| OpenAI | Reads a prescription photo more closely, only after you turn on "Closer reading" (its own consent) | The prescription photo, not stored by OpenAI for training | Only with that consent, only that photo | United States |
| US National Library of Medicine (Clinical Tables, RxTerms) | Medicine name suggestions while you type | The letters typed into the medicine name box; no account, person or household data | While you type a name | United States |
| Vercel | Hosts the website (familydose.app), the shared care card pages and our admin dashboard | When a care card link is opened: the card the family chose to share (name, allergies, conditions, medicines, emergency contacts, insurance front photo if added); website visits (standard request logs) | When a link is opened or the site is visited | United States and edge locations |
| Zoho Mail | Our support and privacy mailboxes | Whatever you write to support@familydose.app or privacy@familydose.app | When you write | Zoho region of the mailbox [CONFIRM: the Zoho data centre, from the Zoho account settings] |
| Healthchecks.io | Watches that the reminder job runs | A ping with no user data | Every run | European Union |
| Cloudflare Turnstile (Cloudflare, Inc.) | Checks that a sign-in, sign-up, email code or password reset comes from a person, not a bot | Your IP address, browser or app signals and a check token; never your email, password, name or any health data | Each sign-in, sign-up, code or reset | United States and Cloudflare's worldwide network |
| Firebase Cloud Messaging (Google) | Delivers push notifications on Android, once the Android app is available | The Android push token and the notification words (medicine names hidden if you choose) | When a notification is sent to an Android phone | Google, worldwide |
We do not use advertising networks, third-party analytics or data brokers. We do not sell data and we do not share it for advertising.
If FamilyDose is ever transferred to another operator, we will tell you before your data moves and you will be able to delete your account first.
10. How long we keep it
| Data | How long |
|---|---|
| Household records (patients, medicines, doses, symptoms, vaccinations, growth, appointments, documents, care cards) | As long as the household exists. We do not delete health records because of age. |
| A dose, as-needed dose or symptom you delete | Hidden at once, permanently deleted after 30 days |
| A medicine you delete | Hidden, and kept with its dose history while the patient's record exists |
| A patient the Admin removes from the household | Hidden from everyone and from any link. Kept until the Admin restores the patient or the data is permanently deleted. |
| A household the Admin deletes | Kept for 30 days so it can be restored, then permanently deleted. Its stored files are removed shortly after. |
| A shared household whose Admin deletes their account when no other member can be the Admin | Deleted with the account. It is kept for 30 days, then permanently deleted. Its stored files are removed shortly after. |
| Your account | Until you delete it. Deletion is immediate and permanent. |
| The country you chose, your age check and your consent records | Until you delete your account. Whether some must be kept longer to prove consent is a question for our lawyer [CONFIRM] |
| Scans nobody finished reviewing | 30 days |
| Photos sent for a closer reading | Until the household or the scanning account is deleted [CONFIRM: see section 5, Scans] |
| Usage events | 12 months |
| Email delivery records (delivered, bounced, marked as spam) | 12 months |
| Queued alert emails | 30 days after sending |
| Records that an alert was already sent | 3 days |
| Database backups | 7 days. Deleted data leaves the backups within 7 days. |
| Staff audit records, privacy request records, support messages | No fixed period yet [CONFIRM: retention period] |
| Crash reports at Sentry | [CONFIRM: Sentry retention on the current plan] |
| Content at OpenAI | Each request is sent with storage switched off. OpenAI may keep content for up to 30 days in its abuse-monitoring logs. |
| Server logs at Supabase and Vercel | [CONFIRM: log retention on the current plans] |
| Emails at Resend, push records at Expo and Apple | Set by each provider [CONFIRM each] |
What happens when you delete your account
You can delete your account in the app: Settings, Data and privacy, Delete account. It is immediate and permanent. Without the app, see section 12.
- Always deleted: your name, email address, sign-in details, devices and push tokens, notification settings, any second email address, invitations sent to your address, your consent and age records, the country you chose, and your feedback.
- If you are the only member of a household: the whole household is deleted with your account, including every patient, all history and every stored file.
- If the household is shared: the household stays for the other members. Entries you made stay in its history, shown without your name. [CONFIRM: the label shown in the app; the current code shows "Household member"]
- Your own patient profile: the delete screen offers to delete your own profile and its records too. If you leave it, it stays with the household, no longer linked to you.
- If you are the Admin of a shared household: before you leave the household or delete your account, you choose its new Admin. Only a member with their own sign-in who meets the minimum age for their region can be chosen. The new Admin gets a notice and does not need to accept. If no member can be chosen, the household is deleted when you leave or delete your account. It is kept for 30 days, then deleted for good. The app warns you first and offers to download your data.
- Sign in with Apple: we ask Apple to revoke the token. If Apple cannot be reached at that moment, your account is still deleted and our copy of the token is deleted.
- Kept without your identity: usage events and email delivery records, until their 12 months end, and staff audit and privacy request records.
- Backups: roll off after 7 days.
11. Security
- Data is encrypted when it travels between your phone and our servers, and when it is stored by our service providers.
- Every table in the database is limited to the members of the household it belongs to, and the limits are enforced on the server.
- Stored files are private and are opened through short-lived links.
- Staff access needs a second factor.
- You can see where you are signed in and sign a device out: Settings, Sign-in and security, Where you're signed in.
No system is free of risk. Care card links and files you share are outside these controls once you share them.
If there is a breach
If a security breach affects your personal data, we tell the people affected and the authorities, as each law that applies requires, without undue delay. We tell you what happened, what data was involved, what we have done and what you can do. For users in the United States, we follow the FTC Health Breach Notification Rule: we notify affected people, the Federal Trade Commission and, where the rule requires, the media, without unreasonable delay and no later than 60 calendar days after we discover the breach. We keep a record of every incident.
12. Your rights and how to use them
Wherever you live, you can:
- access your data and get a copy;
- correct it;
- delete it;
- export it in a file other software can read;
- withdraw any consent, as easily as you gave it;
- complain to us, and to the data protection authority where you live (section 14).
Some laws give more rights, such as to restrict or object to processing, to know who your data is shared with, or to name someone to act for you if you die or cannot act. Ask us and we will apply them where they apply to you.
How to use them
- In the app: Settings, Data and privacy. You can export your data (Export my data, an Excel file; Readable summary, a PDF), turn usage events and closer reading off, withdraw consents (Privacy and consents, Withdraw consent) and delete your account (Delete account). Most things happen at once.
- By email: write to privacy@familydose.app, from the email address of your FamilyDose account if you have one. Please do not put health details in the email.
- Without the app: if you no longer have the app, you can ask for your account to be deleted on the web at https://familydose.app/support#delete-account. You email privacy@familydose.app from the account's email address; we confirm the request with you and delete the account within 30 days.
People without an account, such as a patient in someone else's household, can also write to privacy@familydose.app. We check that a request comes from you or from someone allowed to act for you, and we never ask for your password. The step-by-step guide is Your data rights.
How fast we answer
We answer within 30 days. Where a law sets a shorter time, we meet it: for example, in Brazil we answer a request for confirmation or a full copy within 15 days where the LGPD requires it. Where a law allows a longer time, such as 45 days under US state laws, we still aim for 30 days and tell you if we need more time and why. We do not charge for a request. Using your rights never changes the service you get.
If we refuse a request, we tell you why and how to ask us to look again (an appeal). If you are still unhappy, you can complain to the authority where you live.
13. Children
FamilyDose is for adults. It is not directed to children, and children do not have accounts or sign in.
The account holder must be at least 18, or older where the law of the country you live in says so:
| Where you live | Minimum age of the account holder |
|---|---|
| Everywhere FamilyDose is offered, unless listed below | 18 |
| South Korea, Algeria, Canada (Not offered yet) | 19 |
| Thailand | 20 |
| Kuwait, Bahrain | 21 |
The app checks your age from your date of birth and refuses sign-up below the minimum, without keeping what you typed. If we learn that an account holder is under the minimum age, we delete the account.
A child's information is added only by the child's parent or legal guardian, or by an adult acting for them with their permission, and only after the parent or legal guardian has given their own consent for that child (consent 4 in section 7). We collect a child's information from the adult, not from the child. We do not show advertising, we do not profile children, and we do not sell or share a child's information for marketing. A child's information is seen outside the household only if an adult in the household shares it, for example through a care card link.
More detail: the notice for parents and the notice for children.
14. Authorities
You can complain to the data protection authority where you live. You do not have to contact us first, although we would like the chance to put things right.
| Where you live | Authority |
|---|---|
| United Arab Emirates | UAE Data Office (Federal Decree-Law No. 45 of 2021, the PDPL). For health data under Federal Law No. 2 of 2019 on the use of information and communications technology in health fields: the Ministry of Health and Prevention and the health authority of your emirate |
| Saudi Arabia | Saudi Data and AI Authority (SDAIA) |
| Qatar | National Cyber Security Agency, Compliance and Data Protection Department |
| Kuwait | Communication and Information Technology Regulatory Authority (CITRA) |
| Bahrain | Personal Data Protection Authority |
| Oman | Ministry of Transport, Communications and Information Technology |
| Egypt | Personal Data Protection Center |
| Jordan | Personal Data Protection Council |
| Morocco | National Commission for the Control of Personal Data Protection (CNDP) |
| Tunisia | National Authority for the Protection of Personal Data (INPDP) |
| Algeria | National Authority for the Protection of Personal Data (ANPDP) |
| Japan | Personal Information Protection Commission |
| India | Data Protection Board of India |
| South Korea | Personal Information Protection Commission (PIPC) |
| Singapore | Personal Data Protection Commission |
| Malaysia | Personal Data Protection Commissioner |
| Thailand | Personal Data Protection Committee |
| Philippines | National Privacy Commission |
| Hong Kong | Office of the Privacy Commissioner for Personal Data |
| Vietnam | Ministry of Public Security (Department of Cybersecurity and High-Tech Crime Prevention) |
| Nigeria | Nigeria Data Protection Commission |
| Kenya | Office of the Data Protection Commissioner |
| South Africa | Information Regulator |
| Ghana | Data Protection Commission |
| Brazil | National Data Protection Authority (ANPD) |
| Mexico | Secretariat of Anti-Corruption and Good Government |
| Argentina | Agency for Access to Public Information (AAIP) |
| Colombia | Superintendence of Industry and Commerce (SIC) |
| Peru | National Authority for Personal Data Protection (Ministry of Justice and Human Rights) |
| Chile | Personal Data Protection Agency (from 1 December 2026) |
| United States | Your state attorney general, and the Federal Trade Commission |
| Canada (Not offered yet) | Office of the Privacy Commissioner of Canada |
| Quebec (Not offered yet) | Commission d'accès à l'information du Québec, and the Office of the Privacy Commissioner of Canada |
| Anywhere else | The data protection authority where you live |
15. Regional sections
These sections add to the rest of this policy for people who live in these places. If a section and the rest of the policy differ, the section wins for those people.
United States: consumer health data
Some US states, including Washington (My Health My Data Act), Nevada and Connecticut, have laws about consumer health data. Our Consumer Health Data Privacy Policy covers them: what health data we collect, why, where it comes from, who receives it, and how to use your rights. We ask for your consent before we collect consumer health data, and for a separate consent before we share it with anyone other than the service providers who process it for us. We do not sell consumer health data. A breach is handled as section 11 describes.
FamilyDose is not directed to children under 13 and does not knowingly collect personal information from them. A child's information is entered by the parent or legal guardian, who gives consent first.
Brazil (LGPD)
The controller is Primelink Digital Online Seller (section 1). Our data protection officer (encarregado) is our privacy officer at privacy@familydose.app. We process health data only with your specific and highlighted consent, for the purposes in section 6, and a child's data only with the specific and highlighted consent of a parent or legal guardian, in the child's best interest. Your rights include confirmation that we process your data, access, correction, anonymisation, blocking or deletion of unnecessary data, portability, deletion of data processed with consent, information about who we share data with, information about the possibility of refusing consent and its consequences, and withdrawal of consent. Your data is transferred to Japan and the United States as section 9 describes, with your specific consent and under our agreements with the providers. [CONFIRM: that the ANPD standard contractual clauses are in place with Supabase and the US providers] You can complain to the ANPD.
India (DPDP Act 2023)
We are the data fiduciary for your personal data. This notice lists, item by item, the personal data we process (section 5) and why (section 6). You give consent for each purpose separately and you can withdraw it at any time, as easily as you gave it (section 7); the consequence of withdrawing is described next to each consent. You have the rights to access a summary of your data and of who it is shared with, to correction, completion, updating and erasure, to grievance redressal, and to nominate a person to use your rights if you die or cannot act. Our grievance contact is our privacy officer at privacy@familydose.app; we answer within 30 days. If you are not satisfied, you can complain to the Data Protection Board of India. A child's data (anyone under 18) is entered only by the parent or legal guardian after their own consent; we do not track children's behaviour or target advertising at them. You can ask for this notice in English or in any language listed in the Eighth Schedule to the Constitution of India.
South Korea (PIPA)
We ask for a separate consent to keep health information (sensitive information) and a separate consent to the overseas transfer. The overseas transfer items:
| Item | Detail |
|---|---|
| Personal information transferred | Account (name, email, date of birth), household and members, the people you care for, medicines, doses, symptoms, temperatures, growth, appointments, notes, files and photos, consent records, settings and usage events; for each US provider, only what section 9 lists for it |
| Countries | Japan (storage). The United States (the providers in section 9). The United Arab Emirates (our staff). |
| When and how | When you use FamilyDose, over encrypted connections |
| Recipients | Supabase Inc. on Amazon Web Services (Japan); in the United States: Resend, Expo, Apple, Sentry (Functional Software Inc.), OpenAI (only with closer reading on), the US National Library of Medicine, Vercel and Cloudflare (bot check at sign-in). Contact: [CONFIRM: each recipient's privacy contact address] |
| Purpose | To store your records and run the service: email, push notifications, error reports, medicine name suggestions, the website and shared care cards, and the closer reading of a prescription photo |
| Retention | Until you delete the data or your account, and as section 10 describes for each provider |
| How to refuse, and what happens | You can refuse or withdraw the transfer consent in the app (Settings, Data and privacy) or by email. FamilyDose cannot be used without it, because it has no other place to keep records. |
You can complain to the PIPC. [CONFIRM with counsel: whether a domestic representative is needed]
Quebec (Law 25)
Not offered yet. FamilyDose is not yet offered in Canada; it opens there when the app is in French. This section applies from then.
The person in charge of the protection of personal information is our privacy officer, who can be reached at privacy@familydose.app. Your information is communicated outside Quebec, to Japan and the United States (section 9). [CONFIRM: the privacy impact assessment for communication outside Quebec is completed before launch in Quebec] You can ask to have your information corrected or deleted, to get a copy in a structured, commonly used technological format, and to withdraw consent. You can complain to the Commission d'accès à l'information. A French version is available.
United Arab Emirates
We are a Dubai establishment. The UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) applies to your personal data, and the UAE Data Office is the authority. Health information has its own law, Federal Law No. 2 of 2019 on the use of information and communications technology in health fields, which limits keeping health data outside the UAE except in permitted cases. We collect health information only with your explicit consent, given separately and recorded, and your data is stored in Japan with your separate transfer consent. We are preparing a copy of UAE users' data kept in the UAE. Until it is in place, your data is stored as section 9 describes. [CONFIRM with counsel: which exception under Ministerial Decision No. 51 of 2021 applies, and whether a UAE copy is required]
Japan
Your data is stored in Japan. We, the operator, are in the United Arab Emirates, and some data is processed in the United States (section 9). The UAE has a federal personal data protection law supervised by the UAE Data Office. The United States has no single federal privacy law; privacy is protected by federal and state laws and enforced by the FTC and state attorneys general. We take security measures for data handled outside Japan (section 11).
16. Changes to this policy
When this policy or the Terms change, the app asks you to read and accept the new version before you continue. We record which version you accepted and when. If you do not agree, you can export your data and delete your account from the same screen.
Earlier versions are available on request.
17. Contact
Privacy questions and data requests: privacy@familydose.app
Support: support@familydose.app
Primelink Digital Online Seller, a sole establishment licensed by the Department of Economy and Tourism, Dubai, licence no. 1603034, P.O. Box 48800, Dubai, United Arab Emirates.