Privacy Policy

UAB Dony Media ("we," "our," or "us") operates the Pul Ai mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

By using Pul Ai, you agree to the collection and use of information in accordance with this Privacy Policy.

IMPORTANT MEDICAL DISCLAIMER

Pul Ai is NOT a Medical Device

This App is designed for general wellness and fitness purposes only and is NOT intended to:

Diagnose, treat, cure, or prevent any disease or medical condition
Replace professional medical advice, diagnosis, or treatment
Be used as a substitute for traditional medical monitoring equipment
Provide medical-grade accuracy for clinical decision-making

The measurements provided by this App are estimates only and should not be relied upon for medical purposes.

Medical Warnings

NOT FDA Approved: This App has not been evaluated or approved by the U.S. Food and Drug Administration (FDA) or any other medical regulatory authority.
Not for Emergency Use: This App is not intended for use in medical emergencies. If you experience a medical emergency, call emergency services immediately.
Consult Healthcare Professionals: Always consult with a qualified healthcare provider before making any medical decisions based on information from this App.
Known Limitations: Camera-based measurements can be affected by factors including but not limited to: lighting conditions, skin tone, movement, device quality, and user technique.
Pre-existing Conditions: If you have any pre-existing medical conditions, particularly cardiovascular conditions, diabetes, or respiratory conditions, consult your healthcare provider before using this App.
Pregnancy: Pregnant individuals should consult their healthcare provider before using this App for health monitoring.

BY USING THIS APP, YOU ACKNOWLEDGE AND AGREE THAT:

You will not use this App as a substitute for professional medical advice
You understand the measurements are estimates and may not be accurate
You will seek immediate medical attention if you experience any concerning symptoms
You release UAB Dony Media from any liability related to medical decisions made based on App data

Information We Collect

1. Camera Access

To measure your pulse, blood oxygen levels, and other health metrics, the App requires access to your device's camera. The camera is used to:

2. Health Data

3. User Profile Information

4. Device Information

5. Optional Information

How We Use Your Information

Health Tracking

App Functionality

App Improvement

Legal Compliance

Advertising and Marketing

Data Storage and Security

Local Storage

All health data is stored locally on your device. We employ industry-standard security measures to protect your information:

iCloud Sync (Optional)

Data Retention

Data Sharing and Disclosure

We do not sell, trade, or rent your personal health information to third parties.

Third-Party Services

Legal Requirements

Your Rights and Choices

Access and Control

Camera Permissions

Notification Permissions

Note: When you uninstall the App, all local data will be removed from your device. Deleted data cannot be recovered unless you have an iCloud backup.

Advertising and Tracking Preferences

When you first open the App, you will see Apple's App Tracking Transparency prompt asking for permission to track your activity across other companies' apps and websites for advertising purposes.

Children's Privacy

Pul Ai is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will delete such information.

International Users and GDPR Compliance

UAB Dony Media is based in Lithuania (European Union). If you are using the App from outside the EU:

EU Users (GDPR Rights)

Note: Since all data is stored locally on your device, you can erase all data by uninstalling the App.

Legal Basis for Processing

Data Transfers

Your health data is stored locally on your device. If you enable iCloud sync, data may be transferred to Apple servers, which may be located outside the EU. These transfers are protected by Apple's data protection measures and standard contractual clauses.

When you use the App, some non-health data (analytics and advertising attribution data) may be transferred to service providers located outside the EU, specifically to the United States:

Important: Your health measurements and medical data are NEVER transferred to these third-party services. Only technical and usage data (device type, app version, installation source) is shared for analytics and advertising purposes.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by:

Your continued use of the App after changes constitute acceptance of the updated Privacy Policy.

Security Measures

We implement appropriate technical and organizational measures to protect your data:

Technical Measures

Organizational Measures

Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW:

UAB Dony Media shall not be liable for any damages arising from:

Inaccurate measurements or estimates
Medical decisions made based on App data
Reliance on the App in place of professional medical care
Technical malfunctions or errors
Loss of data due to device failure
Any health outcomes related to App use

USE OF THIS APP IS ENTIRELY AT YOUR OWN RISK.

Third-Party Links

The App may contain links to third-party websites or services that are not owned or controlled by UAB Dony Media. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

If you have any questions about this Privacy Policy or our data practices, please contact us:

For GDPR-related inquiries or to exercise your rights, please contact our data protection officer at: [DPO email if applicable]

Privacy Policy for Pul Ai

Introduction