Privacy Policy

SIA HEMM ("HEMM", "we", "us", or "our") is committed to protecting your personal data and privacy. This Privacy Policy explains how we collect, process, store, and protect your information when you use the HEMM mobile application (the "App") and its artificial intelligence features ("HEMM AI").

 

1. Data Controller & Contact Information

Under the EU General Data Protection Regulation (GDPR) and applicable data protection laws, the data controller responsible for your personal data is:

• Legal Entity: SIA HEMM

• Registration Number: 40203680928

• Registered Address: Vienības prospekts 43, Jūrmala, Latvia

• Privacy & Support Contact: health@hemm.app

• Data Protection Officer (DPO): danila@hemm.app

 

2. General Wellness Disclaimer (Not a Medical Device)

The App and HEMM AI features are designed exclusively as wellness, educational, and informational tools. 

The App is NOT a medical device, and it does not provide medical advice, clinical diagnosis, or treatment recommendations. Outputs generated by HEMM AI are produced by proprietary algorithmic scripts and are provided for general reference only. Never use the App to replace professional medical advice or to postpone seeking a clinical evaluation from a licensed healthcare provider.

 

3. Personal Data We Collect

We collect the following categories of data directly from you when you interact with the App:

• Account & Registration Data: First name, surname, date of birth (DOB), gender, and phone number.

• Lifestyle & Personalization Profile: Answers to lifestyle and daily habit questions used to personalize your account experience.

• Special Category (Health & Image) Data: Questionnaire inputs regarding symptoms, severity, and conditions related to hemorrhoids, as well as uploaded photos submitted for AI assessment. Under GDPR Article 9, this is treated as sensitive health data.

• Technical & Analytics Data: Device parameters (model, OS version), crash reports, app performance logs, IP address, and technical session identifiers.

 

4. How We Process Your Data & Legal Bases (GDPR)​

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5. AI Image & Health Data Processing

• In-House Processing Infrastructure: All photo uploads and health data inputs are processed using our own proprietary software scripts hosted on secure Amazon Web Services (AWS) cloud infrastructure located within the European Union (EEA). We do not send, share, or disclose your uploaded photos to third-party AI vendors or API providers.

• Explicit Consent Required: Accessing HEMM AI assessment functionality requires your explicit consent prior to processing sensitive health information or images.

• Optional Model Improvement: Using photos to train and refine our internal algorithms is strictly optional. We will only use your images for training if you explicitly toggle the in-app opt-in agreement. If you do not opt-in, photos are processed solely to display your immediate results within the app and are not used for algorithm training.

• No Sale or Public Display: We never sell, rent, or publicly display your photos or health data.

 

6. In-App Account Deletion & Data Retention

In-App Deletion Mechanism (Apple App Store Guideline 5.1.1 Compliant)

You can initiate complete deletion of your account and personal data at any time directly within the App:

• Open the App and navigate to HEMM Settings.

• Select Security.

• Tap Delete all my personal data.

Data Removal Timeframe

Once requested via the in-app path (or by emailing health@hemm.app), your profile, associated lifestyle data, questionnaire records, and uploaded photos will be permanently deleted or anonymized from our active production databases and servers within 30 days.

 

7. Data Storage, Security & Third-Party Sharing

• Cloud Hosting & Location: Your data is stored securely on AWS servers located within the European Economic Area (EEA), enforcing encryption at rest (AES-256) and in transit (TLS 1.3).

• Analytics & Technical Processors: We utilize standard application analytics and crash monitoring services strictly to maintain software stability. These services process technical telemetry data under Data Processing Agreements (DPAs) and cannot identify you personally.

• No Cross-App Tracking: The App does not engage in cross-app tracking, does not access Apple Advertising Identifiers (IDFA), and does not sell personal data to third-party ad networks.

 

8. Your GDPR Rights

If you reside within the European Economic Area (EEA), you possess the following rights regarding your personal data under the GDPR:

• Right to Access & Portability: Request access to or a structured export of your personal data.

• Right to Rectification: Request correction of inaccurate personal data.

• Right to Erasure ('Right to be Forgotten'): Request immediate or scheduled deletion of your data.

• Right to Withdraw Consent: Revoke consent for processing health data or optional AI photo training at any time without impacting past lawful processing.

• Right to Lodge a Complaint: File a complaint with a supervisory authority (in Latvia: Datu valsts inspekcija / Data State Inspectorate).

To exercise any of these rights, use the in-app controls or contact us at health@hemm.app.

 

9. Age Eligibility

The App is intended strictly for individuals who are 18 years of age or older. We do not knowingly collect personal data from minors. If we learn that we have collected personal data from a minor without proper legal authorization, we will delete it promptly.

 

10. Contact Us

For privacy inquiries, rights requests, or questions regarding this Privacy Policy, please contact:

• Company: SIA HEMM

• Address: Vienības prospekts 43, Jūrmala, Latvia

• Email: health@hemm.app

• Data Protection Officer: danila@hemm.app