Legal

Privacy Policy

Last updated: January 2025  ·  Effective: January 2025

1. Who we are

This Privacy Policy applies to services provided by Lumio Holdings Limited ("Lumio", "we", "us"), a company incorporated in the Abu Dhabi Global Market (ADGM), acting as data controller, and Kwelio Labs FZ LLC ("Kwelio Labs"), incorporated in Dubai Media City, acting as data processor.

Together, these entities operate the Kwelio platform, including the Pop by Kwelio mobile application and the Kwelix insurer dashboard (collectively, the "Services").

2. What data we collect

We collect the following categories of personal data:

  • Identity data: Name, date of birth, nationality, Emirates ID or passport number (where required for verification)
  • Contact data: Email address, phone number
  • Health data: Medication names, dosage schedules, dose logs with timestamps and optional photos
  • Behavioural data: App usage patterns, adherence scores (KAS/KIS), notification interaction data
  • Technical data: Device identifiers, IP address, operating system, app version
  • Financial data: Payment information for supplement purchases (processed via Stripe — we do not store card details)

3. How we use your data

  • To operate the Pop by Kwelio app and track medication adherence
  • To calculate KAS and KIS adherence scores
  • To provide anonymised, aggregated adherence intelligence to health insurers via Kwelix
  • To administer the Lio Points loyalty programme
  • To process supplement purchases and manage subscriptions
  • To comply with legal and regulatory obligations

4. Legal basis for processing

We process your data on the following legal bases under UAE PDPL and ADGM DPR: explicit consent (for health data), contractual necessity (for service delivery), and legitimate interests (for security and fraud prevention).

5. Who we share data with

We share anonymised adherence scores with participating health insurers. We never share raw personal health data with insurers. We share data with the following categories of service providers: cloud infrastructure (Firebase / Google Cloud), payment processing (Stripe), analytics, and customer support tooling.

We do not sell personal data. Ever.

6. Data retention

We retain personal data for as long as your account is active, or as required by law. You may request deletion of your account and associated data at any time via the Pop by Kwelio app settings or by emailing privacy@kwelio.com.

7. Your rights

Under applicable law, you have the right to: access your personal data, correct inaccurate data, request deletion, restrict processing, data portability, and withdraw consent at any time.

To exercise any of these rights, contact: privacy@kwelio.com

8. Cookies

Our websites use essential cookies for session management and analytics. No advertising or third-party tracking cookies are used without consent.

9. Changes to this policy

We may update this policy from time to time. We will notify registered users of material changes via email or in-app notification.

10. Contact

Data Controller: Lumio Holdings Limited, ADGM, Abu Dhabi, UAE
Data Processor: Kwelio Labs FZ LLC, Dubai Media City, Dubai, UAE
Privacy enquiries: privacy@kwelio.com