Privacy Policy

Privacy Policy Consillium Mobile Application Effective Date: 13 January 2026 Last Updated: 13 January 2026 This Privacy Policy ("Policy") explains how the Consillium mobile application ("Application") collects, uses, stores, and protects personal data of users. The Application complies with: the Law of the Republic of Kazakhstan "On Personal Data and Their Protection", and applicable international data protection standards, including the General Data Protection Regulation (GDPR) principles where applicable. By using the Application, you confirm that you have read, understood, and agreed to this Privacy Policy. 1. Personal Data We Collect The Application collects only the data necessary to provide its functionality. All data are provided voluntarily by the user. 1.1 Categories of Data Contact Information Email address Basic Profile Data Age Body Metrics Height and weight Health-Related Information (Sensitive Data) Medical test results and other health-related information entered by the user manually AI Interaction Data User messages and interactions with the AI assistant related to health topics Usage and Technical Data App activity (opened features, session duration, interaction logs) This data is used in aggregated or anonymized form where possible 2. How We Use Personal Data Personal data are used strictly for the following purposes: generating an individual health-related score using an internal analytical model; providing non-medical, informational insights related to general health and lifestyle; improving app performance, usability, and reliability; ensuring security, fraud prevention, and system integrity; responding to user inquiries and support requests. 3. Legal Basis for Processing We process personal data based on: explicit user consent, provided during registration and before entering health-related data; legal obligations under applicable laws; legitimate interests, limited to maintaining and improving the Application without overriding user rights. Sensitive health data are processed only after explicit user consent and can be deleted at any time by the user. 4. Health Data & App Store Compliance In accordance with Apple App Store Review Guidelines: Health-related data are used solely to provide features visible and relevant to the user. Health data are never shared with third parties, advertisers, or data brokers. Health data are not used for medical diagnosis, treatment, or emergency purposes. The Application does not claim to be a medical device and does not replace professional medical advice. 5. Data Storage, Security, and Third Parties All personal data are protected using encryption, access controls, and secure infrastructure. Access to data is restricted to authorized personnel only. We may use trusted third-party service providers (e.g., cloud hosting, analytics) strictly for technical processing. These providers act under contractual obligations and meet security standards consistent with Apple requirements and applicable law. Only the minimum required data are shared with such providers. Cross-border data transfers, if applicable, are performed in compliance with legal requirements and appropriate safeguards. 6. Data Retention We retain personal data only for as long as necessary to fulfill the purposes described in this Policy or until the user deletes their account. Users may request full deletion of their account and all associated personal data at any time. 📧 Data deletion requests can be sent to: __________________________ 7. User Rights Users have the right to: access their personal data; correct or update inaccurate information; delete their personal data and account; withdraw consent to data processing; object to certain types of processing where permitted by law; submit a complaint to the relevant data protection authority. These rights can be exercised without discrimination or loss of core app functionality (except where data are required to provide features). 8. Medical Disclaimer Consillium is not a medical application and does not provide medical advice, diagnosis, or treatment. All insights and recommendations are informational only and should not be used as a substitute for consultation with a qualified healthcare professional. Always seek professional medical advice for health-related decisions. 9. Contact Information (Data Controller) For questions related to privacy or data protection, please contact: PulseAI Ltd., BIN 260140900354, a company registered in the Republic of Kazakhstan. __________________ 10. Changes to This Policy We may update this Privacy Policy from time to time. Any changes will be published within the Application and will take effect immediately upon publication.