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Legal notice

In accordance with applicable regulations, you will find below information relating to the publication and hosting of the EasyDiabby website.

Last updated: June 8, 2026

01

Site publisher

EDDA – Évaluation Diététique Diabétique Assistance
Simplified Joint-Stock Company (SAS)
Registered office:
535 Route des Lucioles
Les Aqueducs – Batiment 3 Sophia-Antipolis
06560 Valbonne
France
Legal representative:
Sébastien SAPPA
SIREN:
100 062 033 R.C.S. Grasse
Document version:
1.0
Effective date:
September 2026
Hosting Provider
The site is hosted by 772424, with its registered office at: Chemin Petit Cabri - Le Tholonet - 13100 Aix-en-Provence.
Website: https://www.772424.com
02

LEGAL NOTICE

Article 1 – Publisher
The Diabassist application is published by the company EDDA (Évaluation Diététique Diabétique Assistance), a *Société par Actions Simplifiée* (SAS) registered in France.
The publication director is:
Sébastien SAPPA
Registered office address:
535 Route des Lucioles
Les Aqueducs – Bâtiment 3 Sophia-Antipolis
06560 Valbonne
France
Email address:
contact@diabassit.com
Website:
www.diabassist.com

Article 2 – Hosting
The application is distributed via the Apple App Store and Google Play platforms.
The technical services required for the application's operation may be hosted by specialized service providers that comply with European data security requirements.
03

GENERAL TERMS OF USE

Article 1 – Purpose
These General Terms of Use define the rules for using the Diabassist application.
Any use of the application implies unreserved acceptance of these General Terms of Use.

Article 2 – Application Overview
Diabassist is a nutritional support application designed primarily for individuals living with diabetes or those wishing to better understand the impact of their diet on their blood sugar balance.
Key features of the application include:
an estimate of carbohydrates, proteins, fats, and calories based on a photograph of a meal, using artificial intelligence;
a blood glucose tracking log;
a table of glycemic indices (GI) and glycemic loads (GL);
a library of low-glycemic-index recipes;
educational tools to support therapeutic patient education.
The features offered are intended for informational and educational purposes.

Article 3 – Target Audience
The application is intended for any adult wishing to better understand their diet.
Minors may only use the application under the supervision of a parent or legal guardian.

Article 4 – Nature of Information Provided
Information provided by Diabassist is for reference purposes only.
Results calculated by artificial intelligence are estimates and may contain errors.
The company EDDA does not guarantee the absolute accuracy of nutritional analyses or the perfect identification of foods in a photograph.
The user acknowledges that the results should be interpreted with caution.
Article 5 – Not a medical device
Diabassist is not a medical device within the meaning of European regulations.
The application does not provide:
any medical diagnosis;
any medical prescription;
any personalized therapeutic recommendation;
any treatment adjustment.
It never replaces a medical consultation.

Article 6 – Medical warning
Information provided by Diabassist must never be used as the sole basis for decisions regarding:
insulin injection;
treatment modification;
dosage adjustment;
hypoglycemia correction;
emergency decisions.
In case of doubt, the user must consult a healthcare professional.
In the event of feeling unwell, severe hypoglycemia, or significant hyperglycemia, standard medical recommendations must be followed, disregarding the application's estimates.

Article 7 – Account creation
Certain features require the creation of a user account.
The user guarantees the accuracy of the information provided.
The user is responsible for the confidentiality of their login credentials.

Article 8 – Proper Use
The user agrees to:
use the application for its intended purpose;
not attempt to circumvent security measures;
not copy or reproduce the content;
not interfere with the operation of the application.
Any fraudulent use may result in the immediate suspension of the account.

Article 9 – Availability
EDDA makes every effort to ensure continuous access to the service.
However, the application may be temporarily unavailable due to:
maintenance;
updates;
technical issues;
force majeure.
No compensation may be claimed on these grounds.

Article 10 – Application Updates
EDDA reserves the right to add, modify, or remove features in order to improve the application, fix errors, or comply with regulatory changes, without entitling the user to any compensation.

04

GENERAL TERMS AND CONDITIONS OF SALE

Diabassit Application
Version 1.0 – Effective: September 2026
Article 1 – Purpose
These General Terms and Conditions of Sale (GTCS) govern the subscription, payment, and usage terms for subscriptions offered within the Diabassit application, published by the company EDDA – Évaluation Diététique Diabétique Assistance.
Any subscription constitutes unreserved acceptance of these GTCS.

Article 2 – Description of Services
The Diabassit subscription provides access to the application's premium features, including:
AI-assisted nutritional analysis based on meal photographs;
blood glucose monitoring;
therapeutic education tools;
a glycemic index (GI) and glycemic load (GL) chart;
low-glycemic-index recipes;
future features reserved for subscribers.
EDDA reserves the right to modify features in order to improve the service.

Article 3 – Pricing
Prices are displayed prior to subscription on the Apple App Store and Google Play.
Rates are quoted inclusive of all applicable taxes.
EDDA may change its rates at any time. New rates apply only to subscriptions purchased after the new rates come into effect or upon renewal, in accordance with the payment platform's rules.

Article 4 – Payment Terms
Payments are processed exclusively via:
Apple App Store;
Google Play Store.
The user's banking information is never collected, stored, or processed by EDDA.
Payments are subject to the general terms and conditions of the respective platforms.
Article 5 – Subscription Duration
The subscription is entered into for a period of one (1) month.
It renews automatically unless the user cancels it via their Apple or Google account.

Article 6 – Cancellation
The user may stop the automatic renewal of their subscription at any time via their Apple App Store or Google Play account settings.
Cancellation takes effect at the end of the subscription period that has already been paid for.
No refunds are issued for a period that has already begun, unless otherwise stipulated by Apple or Google Play policies.
Deleting the Diabassit account does not automatically cancel the subscription.

Article 7 – Right of withdrawal
In accordance with the Consumer Code, the right of withdrawal applicable to digital content may no longer be exercised once the provision of the service has begun with the user's express consent and in accordance with the conditions stipulated by law.
Refund requests are processed in accordance with Apple App Store or Google Play procedures.

Article 8 – Service availability
EDDA strives to ensure continuous access to the application.
However, interruptions may occur due to maintenance, security, technical upgrades, or force majeure.
Such interruptions do not entitle the user to any compensation.

Article 9 – Limitation of liability
Diabassit is an information and therapeutic education tool.
The application is not a medical device and does not replace a healthcare professional.
Results generated by artificial intelligence are estimates that may contain errors.
Consequently, EDDA shall not be held liable for:
nutritional analysis errors;
misidentification of a food item;
inaccurate estimates of carbohydrates, proteins, fats, calories, glycemic indices, or glycemic loads;
medical decisions made solely on the basis of information provided by the application;
damage resulting from use that does not comply with these General Terms and Conditions of Sale.
The user remains solely responsible for decisions made regarding their health and treatment.

Article 10 – Intellectual Property
All elements comprising the Diabassit application (name, logo, interface, databases, text, recipes, illustrations, software, algorithms, and content) are protected by intellectual property laws.
Any reproduction, distribution, extraction, adaptation, or use without the prior written authorization of EDDA is prohibited.

Article 11 – Account Suspension or Termination
EDDA may suspend or terminate access to an account in the event of:
fraud;
attempted hacking;
non-compliance with these General Terms and Conditions of Sale (GTCS) or General Terms and Conditions of Use (GTCU);
use that compromises the security or operation of the application.

Article 12 – Force Majeure
EDDA shall not be held liable if an unforeseeable, unavoidable, and external event temporarily or permanently prevents the performance of the service.

Article 13 – Governing Law
These GTCS are governed by French law.
In the absence of an amicable agreement, any dispute shall be brought before the competent courts in accordance with the rules applicable to consumers.

Article 14 – Customer Service
For any questions regarding a subscription or these GTCS, the user may contact EDDA at the email address specified in the application's legal notice.

05

PRIVACY POLICY

Diabassit Application
Version 1.0 – Effective date: September 2026
Article 1. Preamble
The company EDDA – Évaluation Diététique Diabétique Assistance attaches great importance to the protection of its users' personal data.
The purpose of this Privacy Policy is to inform users of the Diabassit application about how their data is processed, in accordance with Regulation (EU) 2016/679 (GDPR) and applicable French legislation.

Article 2. Data Controller
The data controller is:
EDDA – Évaluation Diététique Diabétique Assistance (SAS)
Registered office:
535 Route des Lucioles
Les Aqueducs – Bâtiment 3 Sophia-Antipolis
06560 Valbonne
France
Legal representative:
Sébastien SAPPA
Email address:
contact@diabassit.com
Article 3. Data Collected
Depending on the features used, Diabassit may process the following categories of data:
email address (account creation or management);
user ID;
usage preferences;
meal photographs submitted for analysis;
nutritional analysis results;
blood glucose levels entered by the user;
dietary tracking data;
technical information necessary for the application's operation.
Diabassit does not aim to collect more personal data than is strictly necessary for the operation of its services.

Article 4. Health Data
Blood glucose levels, dietary information, and other data entered by the user may constitute health-related data within the meaning of the GDPR.
By default, this data is stored locally on the user's phone or tablet.
The company EDDA does not have access to this data and does not use it for commercial purposes.
If the application is deleted, or the device is lost or replaced, locally stored data may be permanently lost.
The user is responsible for backing up their information.

Article 5. Purposes of Processing
The data is used solely to:
provide the application's features;
display nutritional analyses;
record blood glucose levels;
offer personalized tracking within the application;
ensure the proper functioning and security of the service;
respond to user requests;
comply with applicable legal obligations.
The data is not used to create advertising profiles.

Article 6. Artificial Intelligence
Meal photographs are analyzed by an artificial intelligence system to estimate carbohydrate, protein, fat, and calorie content.
The results are estimates and may contain errors.
They are provided solely for informational and therapeutic education purposes.
They do not replace professional medical advice.

Article 7. Data Recipients
Personal data is shared only with the individuals or service providers strictly necessary for the application's operation.
Subscription payments are processed exclusively via the Apple App Store and Google Play, in accordance with their respective privacy policies.

Article 8. Data Retention Period
Data stored solely on the user's device remains available for as long as the user retains it.
Data required for managing the contractual relationship or for legal obligations is retained for the periods prescribed by applicable regulations.

Article 9. Security
EDDA implements reasonable technical and organizational measures to protect processed data against loss, destruction, unauthorized access, or disclosure.
However, no computer system can guarantee absolute security.

Article 10. User Rights
In accordance with the GDPR, each user has, among others, the following rights:
right of access;
right to rectification;
right to erasure;
right to restriction of processing;
right to object;
right to data portability, where applicable.
Requests may be sent to the email address provided in the legal notice.
A response will be provided within the timeframes prescribed by regulations.

Article 11. Cookies and Trackers
The application does not use cookies in the sense usually applicable to websites.
However, certain technical identifiers essential for the operation of Apple or Google platforms may be used in accordance with their respective policies.

Article 12. Modifications
This Privacy Policy may be modified to reflect legal, regulatory, or technical changes.
The version currently in force is the one published within the application.

Article 13. Contact
For any questions regarding personal data protection or to exercise your rights, you may contact:
EDDA – Évaluation Diététique Diabétique Assistance
Email address: contact@diabassit.com
Postal address:
535 Route des Lucioles
Les Aqueducs – Bâtiment 3 Sophia-Antipolis
06560 Valbonne
France

Article 14. Supervisory Authority
If you believe that your rights are not being respected, you may lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), without prejudice to any other administrative or judicial remedy provided by law.

06

Health Data Management Policy

Diabassit Application
Version 1.0 – Effective date: September 2026
Article 1 – Purpose
This policy describes how Diabassit processes information that may be considered health-related data.
It supplements the General Terms of Use, the General Terms of Sale, and the Privacy Policy.

Article 2 – Nature of the data concerned
Depending on how the application is used, the following information may be processed:
blood glucose levels entered by the user;
photographs of meals submitted for analysis;
nutritional estimates (carbohydrates, proteins, fats, calories);
food diary;
nutritional preferences specified by the user.
This information may be considered health-related data within the meaning of the General Data Protection Regulation (GDPR).

Article 3 – Purpose
This data is used exclusively to:
provide the application's features;
help the user better understand the nutritional impact of their diet;
offer therapeutic education tools;
improve the user experience.
The data is not used to establish a medical diagnosis or to make automated medical decisions.

Article 4 – Local storage
Personal tracking data (blood glucose levels, food diary, and information recorded by the user) is stored locally on the user's device.
The company EDDA does not host this data on its servers.
Consequently:
EDDA cannot view the user's blood glucose levels;
EDDA cannot restore the data in the event of loss or a change of device;
deleting the application may result in the permanent loss of local data.
It is the user's responsibility to take any measures they deem appropriate to safeguard their information.

Article 5 – Analysis of photographs
When the user chooses to analyze a meal, the photograph is transmitted to an artificial intelligence service operated by a provider selected by EDDA—currently OpenAI.
This transmission is strictly limited to performing the requested analysis.
The results are sent back to the application to display a nutritional estimate.

Article 6 – Limitations of analyses
Automatically generated results may vary depending on numerous factors, including:
the quality of the photograph;
lighting;
the camera angle;
food presentation;
the recipes used;
the portions actually consumed.
The displayed values ​​should be considered estimates.

Article 7 – No automated medical decision-making
Diabassit does not make any automated medical decisions.
The application does not calculate insulin doses, does not alter any treatment, and never replaces the advice of a healthcare professional.
The results provided must not be used as the sole basis for a therapeutic decision.

Article 8 – Confidentiality
EDDA implements appropriate security measures to protect the personal data it processes.
However, the user is responsible for protecting their device (passcode, biometrics, updates, etc.) in order to safeguard the confidentiality of information stored locally.

Article 9 – Data Deletion
Users may delete information stored in the application using the features provided for this purpose.
Deletion is permanent and cannot be undone.

Article 10 – Updates
This policy may be modified to reflect regulatory, technical, or functional changes to the application.
Any new version will be communicated to users via the application or the Diabassit website.

07

Artificial Intelligence Usage Policy

Diabassist Application
Version 1.0

Article 1 – Purpose
The purpose of this Policy is to inform users about the use of artificial intelligence (AI) within the Diabassist application and to govern its use.
Diabassist uses artificial intelligence technologies to assist users in estimating the nutritional characteristics of their meals.
The AI ​​serves as an assistive tool and never replaces human judgment or the advice of a healthcare professional.

Article 2 – Operation
The user can take a photo of a meal or upload a photo.
This photo is transmitted to an artificial intelligence service provided by OpenAI or any other equivalent service provider selected by EDDA.
The artificial intelligence analyzes, in particular:
the foods present;
the visible portions;
the probable composition of the meal;
estimated macronutrients;
estimated calories.
The result is then transmitted to the Diabassist application.

Article 3 – Limitations of artificial intelligence
Artificial intelligence relies on probabilistic models.
Consequently, it may:
fail to correctly recognize a food item;
confuse similar food items;
underestimate or overestimate quantities;
provide inaccurate nutritional values;
fail to detect certain ingredients that are not visible.
The estimates may differ from actual nutritional values.
Article 4 – Recommended Use
The results should be considered estimates intended to help the user understand their diet.
They do not constitute certified medical information.
They do not replace:
a food scale;
official nutritional labeling;
personalized dietary advice;
a medical consultation.

Article 5 – Therapeutic Decisions
The user agrees never to rely exclusively on the results provided by the application to:
determine an insulin dose;
modify a medical treatment;
correct hypoglycemia;
correct hyperglycemia;
make an urgent medical decision.
Any therapeutic decision must be made in consultation with a healthcare professional.

Article 6 – Photographs
The user warrants that the photographs submitted belong to them or that they hold the necessary authorizations.
They agree not to transmit content that is unlawful, offensive, or infringes upon the rights of third parties.

Article 7 – Availability
The artificial intelligence analysis service relies on external technical providers.
In the event of temporary unavailability of these services, EDDA cannot guarantee the immediate performance of analyses.

Article 8. Retention Period
Data stored solely on the user's device remains available for as long as the user retains it.
Data necessary for managing the contractual relationship or for legal obligations is retained for the periods prescribed by applicable regulations.

Article 9. Security
EDDA implements reasonable technical and organizational measures to protect processed data against loss, destruction, unauthorized access, or disclosure.
However, no computer system can guarantee absolute security.

Article 10. User Rights
In accordance with the GDPR, each user has, among others, the following rights:
right of access;
right to rectification;
right to erasure;
right to restriction of processing;
right to object;
right to data portability, where applicable.
Requests may be sent to the email address provided in the legal notice.
A response will be provided within the timeframes prescribed by regulations.

Article 11. Cookies and Trackers
The application does not use cookies in the sense usually applicable to websites.
However, certain technical identifiers essential for the operation of Apple or Google platforms may be used in accordance with their respective policies.

Article 12. Modifications
This Privacy Policy may be modified to reflect legal, regulatory, or technical changes.
The version currently in effect is the one published within the application.

Article 13. Contact
For any questions regarding personal data protection or to exercise your rights, you may contact:
EDDA – Évaluation Diététique Diabétique Assistance
Email address: contact@diabassit.com
Postal address:
535 Route des Lucioles
Les Aqueducs – Bâtiment 3 Sophia-Antipolis
06560 Valbonne
France

Article 14. Supervisory Authority
If you believe that your rights are not being respected, you may lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), without prejudice to any other administrative or judicial remedy provided by law.

08

Health Data Management Policy

Diabassit Application
Version 1.0 – Effective date: September 2026
Article 1 – Purpose
This policy describes how Diabassit processes information that may be considered health-related data.
It supplements the General Terms of Use, the General Terms of Sale, and the Privacy Policy.

Article 2 – Nature of the data concerned
Depending on how the application is used, the following information may be processed:
blood glucose levels entered by the user;
photographs of meals submitted for analysis;
nutritional estimates (carbohydrates, proteins, fats, calories);
food diary;
nutritional preferences specified by the user.
This information may be considered health-related data within the meaning of the General Data Protection Regulation (GDPR).

Article 3 – Purpose
This data is used exclusively to:
provide the application's features;
help the user better understand the nutritional impact of their diet;
offer therapeutic education tools;
improve the user experience.
The data is not used to establish a medical diagnosis or to make automated medical decisions.
Article 4 – Local storage
Personal tracking data (blood glucose levels, food diary, and user-recorded information) is stored locally on the user's device.
EDDA does not host this data on its servers.
Consequently:
EDDA cannot access the user's blood glucose levels;
EDDA cannot restore data in the event of data loss or a change of device;
deleting the application may result in the permanent loss of local data.
It is the user's responsibility to take any measures they deem appropriate to safeguard their information.

Article 5 – Photograph analysis
When the user chooses to analyze a meal, the photograph is transmitted to an artificial intelligence service operated by a provider selected by EDDA—currently OpenAI.
This transmission is strictly limited to performing the requested analysis.
The results are sent back to the application to display a nutritional estimate.

Article 6 – Analysis limitations
Automatically generated results may vary depending on numerous factors, including:
photograph quality;
lighting;
shooting angle;
food presentation;
recipes used;
actual portions consumed.
The displayed values ​​should be considered estimates.

Article 7 – No Automated Medical Decision-Making
Diabassit does not make any automated medical decisions.
The application does not calculate insulin doses, does not alter any treatment, and never replaces the advice of a healthcare professional.
The results provided must not be used as the sole basis for a therapeutic decision.

Article 8 – Confidentiality
EDDA implements appropriate security measures to protect the personal data it processes.
However, the user is responsible for protecting their device (passcode, biometrics, updates, etc.) in order to safeguard the confidentiality of information stored locally.

Article 9 – Data Deletion
Users may delete information recorded in the application using the features provided for this purpose.
Deletion is permanent and cannot be undone.

Article 10 – Updates
This policy may be modified to reflect regulatory, technical, or functional changes to the application.
Any new version will be communicated to users via the application or the Diabassit website.

09

Artificial Intelligence Usage Policy

Diabassist Application
Version 1.0

Article 1 – Purpose
The purpose of this Charter is to inform users about the use of artificial intelligence (AI) within the Diabassist application and to govern its use.
Diabassist uses artificial intelligence technologies to assist users in estimating the nutritional characteristics of their meals.
The AI ​​serves as an assistive tool and never replaces human judgment or the advice of a healthcare professional.

Article 2 – How it works
The user can take a photo of a meal or upload a photo.
This photo is transmitted to an artificial intelligence service provided by OpenAI or any other equivalent service provider selected by EDDA.
The artificial intelligence analyzes, in particular:
the foods present;
the visible portions;
the probable composition of the meal;
estimated macronutrients;
estimated calories.
The result is then transmitted to the Diabassist application.

Article 3 – Limitations of artificial intelligence
Artificial intelligence relies on probabilistic models.
Consequently, it may:
fail to correctly recognize a food item;
confuse similar food items;
underestimate or overestimate quantities;
provide inaccurate nutritional values;
fail to detect certain ingredients that are not visible.
The estimates may differ from actual nutritional values.

Article 4 – Recommended use
The results should be considered estimates intended to help the user understand their diet.
They do not constitute certified medical information.
They do not replace:
a food scale;
official nutritional labeling;
personalized dietary advice;
a medical consultation.

Article 5 – Therapeutic decisions
The user agrees never to rely exclusively on the results provided by the application to:
determine an insulin dose;
modify a medical treatment;
correct hypoglycemia;
correct hyperglycemia;
make an urgent medical decision.
Any therapeutic decision must be made in consultation with a healthcare professional.

Article 6 – Photographs
The user warrants that the photographs submitted belong to them or that they hold the necessary authorizations.
The user agrees not to transmit content that is unlawful, offensive, or infringes upon the rights of third parties.

Article 7 – Availability
The artificial intelligence analysis service relies on external technical providers.
In the event of temporary unavailability of these services, EDDA cannot guarantee immediate analysis.

Article 8 – Model updates
EDDA may, at any time, change the artificial intelligence provider, the models used, or the analysis parameters in order to improve the service's performance, security, or reliability.
Such changes do not constitute a substantial modification of these terms and conditions.

Article 9 – No Guarantee
EDDA does not guarantee:
absolute accuracy of the results;
perfect food recognition;
exhaustive nutritional precision;
continuous availability of the service.
Results must always be interpreted with discernment.

Article 10 – Acceptance
By using the artificial intelligence analysis features, the user acknowledges having read these provisions and accepts the limitations inherent in this technology.

10

CLAUSE REGARDING NON-SUBSTITUTION FOR MEDICAL ADVICE

Important Notice
Diabassit is an app for nutritional support and therapeutic education. It is not a medical device and does not provide diagnoses, treatments, or medical advice.
Analyses performed using artificial intelligence are estimates that may contain errors. They must never be used as the sole basis for adjusting treatment, modifying insulin dosages, making therapeutic decisions, or managing medical emergencies.
In the event of doubt, unusual symptoms, hypoglycemia, hyperglycemia, or any situation requiring medical advice, consult a healthcare professional or appropriate emergency services immediately.
11

ACCOUNT DELETION POLICY

Diabassist App
Version 1.0

Article 1 – Purpose
This policy outlines the procedure for deleting a Diabassist user account.
It complies with the requirements of the Apple App Store and Google Play, as well as the principles of the General Data Protection Regulation (GDPR).

Article 2 – Right to Deletion
Users may request the permanent deletion of their Diabassist account at any time, without needing to provide a reason.
Account deletion is free of charge.

Article 3 – Deletion Procedure
Requests may be made:
directly within the app via the "Settings > My Account > Delete My Account" section;
or by sending a request to contact@diabassist.com.
For security reasons, EDDA may request information to verify the requester's identity.

Article 4 – Consequences of Deletion
Account deletion results in:
the deletion of information linked to the user account;
the inability to access services requiring authentication;
the loss of account-related preferences.
Data stored solely on the user's device may be deleted depending on the choices made during the procedure or upon uninstallation of the app.
Article 5 – Subscription
Deleting the account does not automatically cancel the subscription.
As subscriptions are managed by the Apple App Store or Google Play, the user must also cancel their subscription via their Apple or Google account.
The user retains access to paid features until the end of the subscription period that has already been paid for.

Article 6 – Timeframes
EDDA undertakes to process deletion requests as soon as possible and, barring exceptional circumstances, within a maximum of one (1) month of receiving a complete request, in accordance with the GDPR.

Article 7 – Legal obligations
Certain information may be retained for the period strictly necessary to comply with legal, accounting, or tax obligations, or to defend EDDA’s rights.
This information will not be used for any other purpose.

Article 8 – Incomplete or abusive requests
EDDA may request additional information if the request does not allow the requester to be identified with certainty.
Requests that are manifestly abusive or repetitive may be handled in accordance with GDPR provisions.

Article 9 – Contact
Any questions regarding account deletion may be addressed to:
EDDA – Évaluation Diététique Diabétique Assistance
535 Route des Lucioles
Les Aqueducs – Bâtiment 3 Sophia-antipolis
06560 Valbonne
France
Email address: contact@diabassist.com

Article 10 – Updates
This policy may be modified to reflect regulatory, technical, or functional changes to the application.
The version currently in force is the one published within the application and on the website www.diabassit.com.

12

DATA SECURITY POLICY

Diabassist Application
Version 1.0

Article 1 – Purpose
This Security Policy outlines the technical and organizational measures implemented by the company EDDA (Évaluation Diététique Diabétique Assistance) to protect data processed through the use of the Diabassist application.
This policy supplements the General Terms of Use, the General Terms of Sale, and the Privacy Policy.

Article 2 – General Principles
EDDA commits to implementing appropriate security measures to ensure:
data confidentiality;
information integrity;
service availability;
protection against unauthorized access;
protection against accidental data loss.
However, no computer system can guarantee absolute security.

Article 3 – Account Security
Each user is responsible for the confidentiality of their login credentials.
Users agree to:
choose a strong password;
never share their credentials with third parties;
immediately report any unauthorized use of their account.
EDDA shall not be held liable for unauthorized access resulting from user negligence.

Article 4 – Local Data Storage
Personal tracking data, such as blood glucose readings and food logs, is stored locally on the user's device.
EDDA does not retain a copy of this data on its servers.
Users are advised to protect their device using a passcode, biometric authentication, or another appropriate security mechanism.

Article 5 – Transmission of photographs
When a user requests a nutritional analysis, the photograph of the meal is securely transmitted to the artificial intelligence service provider used by EDDA.
This transmission is limited to the performance of the requested analysis.

Article 6 – Securing communications
Communications between the application, payment services, and services required for the application's operation utilize secure communication protocols to reduce the risk of data interception or alteration.

Article 7 – Service providers
EDDA carefully selects the service providers involved in the operation of the application.
When service providers process data on behalf of EDDA, ​​they must provide appropriate guarantees regarding security and data protection.

Article 8 – Incident management
In the event of a security incident likely to affect personal data processed by EDDA, ​​the company will implement the necessary measures to:
identify the source of the incident;
limit its consequences;
restore service functionality as quickly as possible;
comply with legal notification obligations where applicable.

Article 9 – User responsibility
The user contributes to the security of their data by:
keeping their device up to date;
installing application updates;
using strong passwords;
avoiding use of the application on compromised devices or devices unlocked in an insecure manner.

Article 10 – Continuous improvement
This policy may be updated to reflect technological or regulatory changes or cybersecurity best practices.
The version currently in effect is the one published within the application and on the website www.diabassit.com.

13

CONSUMER MEDIATION

Diabassist Application
Version 1.0

Article 1 – Purpose
In accordance with the provisions of the Consumer Code, any consumer has the right to use a consumer mediation service free of charge for the amicable resolution of a dispute with the company EDDA.
Before referring the matter to the mediator, the user is requested to submit a written complaint to customer service.

Article 2 – Preliminary Complaint
Any complaint must be sent to:
EDDA – Évaluation Diététique Diabétique Assistance
535 Route des Lucioles
Les Aqueducs – Bâtiment 3 Sophia-Antipolis
06560 Valbonne
France
Email:
contact@diabassist.com
EDDA will endeavor to provide a response within a reasonable timeframe.

Article 3 – Consumer Mediator
Failing an amicable agreement, the consumer may refer the matter to a consumer mediator free of charge, in accordance with applicable legal provisions.
The name and contact details of the mediator will be provided following their official appointment by EDDA.

Article 4 – European Platform
Consumers residing in a European Union Member State may also utilize the avenues of redress provided for by applicable regulations.
Article 5 – Applicable Law
These conditions are governed by French law.
Any dispute shall be submitted to the competent courts in accordance with the protective rules applicable to consumers.
14

INTELLECTUAL PROPERTY

Article 1 – Property Rights
The Diabassist application—including its name, visual identity, logo, graphical interface, text, illustrations, recipes, databases, software code, algorithms, and all content provided—is protected by intellectual property laws.
These remain the exclusive property of the company EDDA.

Article 2 – License of Use
The user is granted a personal, limited, non-exclusive, non-assignable, and non-transferable right to use the application in accordance with these terms.
No intellectual property rights are transferred to the user.

Article 3 – Prohibitions
Except with the prior written authorization of EDDA, ​​it is prohibited to:
copy or reproduce all or part of the application;
modify the content;
decompile or attempt to decompile the application, except as permitted by law;
extract a substantial part of the databases;
resell or redistribute the services offered by Diabassist.
Any violation may result in civil and criminal proceedings.
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APPLE APP STORE AND GOOGLE PLAY SPECIFIC TERMS

Subscriptions are sold via the Apple App Store and Google Play.
Terms regarding payment, renewal, cancellation, and—where applicable—refunds are subject to the policies of the platform used by the user.
In the event of a conflict between these General Terms and Conditions of Sale and the terms imposed by Apple or Google regarding subscription management, the mandatory provisions of the relevant platform shall prevail for matters falling within its responsibility.
EDDA does not have access to users' banking information and cannot intervene in the management of payments processed by Apple or Google.
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NON-MEDICAL DEVICE CLAUSE

Diabassist is an information and therapeutic education tool.
The application is not a medical device within the meaning of Regulation (EU) 2017/745 on medical devices.
It does not provide diagnoses, prescribe treatments, or replace a healthcare professional.
The results provided by the application are estimates intended to help the user understand their diet.
They must never be used as the sole basis for making medical or therapeutic decisions.
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ANNEX I DATA RETENTION POLICY

Diabassist Application
Version 1.0

Article 1 – Principle
The company EDDA applies the data minimization principle set out in the General Data Protection Regulation (GDPR).
Only data strictly necessary for the application's operation is processed.

Article 2 – User account
Account-related information (email address, username, and information required for subscription management and support) is retained for the duration of the account's existence.
Upon account deletion, this data is deleted or anonymized, subject to legal retention obligations.

Article 3 – Health data
Blood glucose readings, the food diary, and tracking information are stored locally on the user's device.
EDDA does not store this data on its servers.

Article 4 – Photographs
Photographs submitted for analysis are sent to the artificial intelligence service provider solely to perform the requested analysis.
They are not used by EDDA to create a database of food photographs or to train its own models.

Article 5 – Payment data
As payments are handled exclusively by the Apple App Store and Google Play, EDDA does not store any banking data.

Article 6 – Technical logs
Certain technical information may be retained temporarily to ensure security, maintenance, and incident resolution.
Article 7 – Request for deletion
Any person may request the deletion of their account in accordance with the Account Deletion Policy.
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ANNEX II EXERCISE OF GDPR RIGHTS

Any person may exercise the following rights:
right of access;
right to rectification;
right to erasure;
right to restriction of processing;
right to object;
right to data portability, where applicable.
Requests may be sent to:
contact@diabassit.com
A response will be provided within the timeframe stipulated by the GDPR.
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ANNEX III IMPORTANT NOTICE

Diabassist is a therapeutic education tool designed to help users better understand their diet.
The application is not a medical device.
Results generated by artificial intelligence are estimates.
They may contain errors.
They never replace:
medical advice;
treatment;
a ​​consultation;
a prescription;
a diagnosis.
The glycemic index and glycemic load chart is for informational purposes only, as the carbohydrate content of a given food can vary depending on its ripeness, processing, and cooking method.
If you have any concerns about your health, consult a healthcare professional.
In the event of a medical emergency, contact the appropriate emergency services immediately.