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, the Kwelio app (to be listed on the App Store as POP by Kwelio Health) 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, scores (KAS and 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 your Kwelio Adherence Score (KAS) and Kwelio Intervention Score (KIS)
- To share your scores with your health insurance plan through Kwelix, if you join one through your insurer
- To train and improve Kwelio’s models, including the model that recognises medication in photos, using dose and label photos. This is a core purpose of the app. Where your health insurer requires it, we ask for your consent to this separately.
- 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 the UAE Federal Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), the ADGM Data Protection Regulations 2021 and, where it applies, the GDPR: explicit consent (for health data), contractual necessity (for service delivery), and legitimate interests (for security and fraud prevention).
5. Who we share data with
If you join a health insurance plan through your insurer, its care team sees your scores and whether you might need support. It never sees your photos or your daily dose logs, and it sees the reason for a missed dose only if you agree to be contacted by the care team. Taking part, or choosing not to, does not affect your cover, your premium, or how any claim is handled. We share data with the following categories of service providers: cloud infrastructure (Supabase and Amazon Web Services in Frankfurt, Germany, with encrypted backups in Ireland, for the Kwelio app and insurer programmes; Firebase / Google Cloud for the Pop by Kwelio app), 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. When you ask us to delete your account, we keep your data for 30 days in case you change your mind, then delete it, unless the law requires us to keep it longer. You may request deletion of your account and associated data at any time in the settings of the Pop by Kwelio app or the Kwelio app 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