Privacy policy

General information

Shen.AI OÜ (“Shen.AI”, “us”, “our” or “we”) protects the privacy rights of our users (“you”). This Privacy Policy (“Policy”) lays out the general rules for processing the data you provide or we collect when you use BP Diary and its website at bdiary.app (“Services”).

Information relating to an identified or identifiable person is personal data. We process personal data in accordance with the General Data Protection Regulation (GDPR), applicable Estonian data protection law and other applicable data protection laws. Additional information or consent requests for a particular feature explain any rules specific to that feature.

BP Diary can use the camera of your device to analyze your face. The Face data section describes what face data we collect and how we use, share, store, retain and delete it.

Who is processing your personal data?

Shen.AI OÜ is the data controller responsible for the Services.

Address: Lõõtsa tn 8a, 11415 Tallinn, Estonia

Privacy requests: data@shen.ai

Data Protection Officer: dpo@shen.ai

Why are we processing your data?

Your data is processed for the following purposes:

Providing the diary, measurements, calibration, reports and other features you request.
Maintaining and protecting the Services, diagnosing problems and understanding how the Services are used.
Responding to your questions and requests, fulfilling our legal obligations and establishing, exercising or defending legal claims.
With your face scan consent, improving the accuracy and reliability of Shen.AI camera measurements using the facial image described in Face data.
Where you separately agree, conducting other non-medical research to develop and improve Shen.AI measurement technology.
Where you agree, measuring whether our advertising leads to app use and completed calibration.

Participation in that separate research is voluntary. Declining it does not prevent you from using the diary or measurement features. BP Diary does not show advertising or sponsored health recommendations inside the app.

What data are we processing and how do we collect it?

Your diary, profile and account

BP Diary processes the blood pressure and pulse readings you record, their dates and sources, your notes and related calibration information. You may also provide optional profile information, including your name, age, sex, ethnicity, country, body measurements, lifestyle and relevant medical history or laboratory results.

You can use the diary without an account, with your diary and profile stored on your device. Signing in enables cloud synchronization of your diary, profile and preferences. Account information includes your email address, account identifiers and information supplied by your chosen sign-in service. Signing out or uninstalling the app does not delete your cloud account.

Reports and exports contain the information you select. When you share them, the recipients or applications you choose receive that information. Previously shared copies cannot be recalled. Measurement reminders are scheduled on your device. Website calculators process the values you enter in your browser.

Camera measurements

Shen.AI technology analyzes facial skin signals to estimate blood pressure, heart rate and other physiological measurements. The purpose of this analysis is to obtain health measurements, not to identify you. Physiological analysis takes place on the device; the SDK also communicates with Shen.AI services for authorization, analysis, calibration and technical operation. The Face data section describes the face data involved in full.

Cuff photographs

When you photograph or select an image of a cuff display, its encoded image is passed to the Shen.AI service for recognition. This service is Shen.AI’s own technology, not a third party. You review the recognized numbers before saving them. The diary stores the confirmed readings rather than the cuff photograph.

Participation in non-medical research

Research aims to develop Shen.AI technology for measuring cardiovascular parameters. Where you choose to participate, the separate research explanation identifies the data involved and how it will be used. This may include physiological signals, camera-derived information, cuff measurements and relevant profile information. Apart from the facial image covered by your face scan consent, research participation requires separate consent; permission to use your camera does not by itself authorize research.

Automatically collected information

The Services also process technical and usage information, such as device and browser details, app versions, interactions, timestamps, identifiers, approximate location derived from an IP address and diagnostic records. Some of this information may be associated with your account.

We use PostHog for app and website analytics and Sentry for diagnostics. Cookies and similar storage also support sign-in, local data and preferences. The applicable notice and choices distinguish optional analytics from processing needed to provide the Services. Where consent is required, it must be obtained before the processing concerned begins.

Optional Google Ads measurement

With your permission, we use Google Analytics for Firebase to measure whether our advertising leads to app use and completed calibration. Firebase records installation and app activity, such as first openings, session starts and time spent in the app. We also send a completion event when calibration finishes. Google uses these events for reporting and to improve campaign performance. We do not supply Google with diary readings, face images, profile information or account identifiers through this integration.

The collected information includes app installation identifiers, app and operating system versions, device details, event times and, when permitted, advertising identifiers. Information about the ad or store referral that led to installation may also be available. Google uses IP addresses to estimate approximate location. We disable advertising personalization for this integration and do not use it to build remarketing audiences. See how Google uses advertising data.

On Android, the app asks whether you allow advertising measurement. On iOS, Apple’s tracking permission request is the advertising measurement choice; BP Diary does not show a second advertising consent request. Advertising measurement stays disabled until you agree. You can decline and continue using every feature of BP Diary.

You can withdraw your choice in the app’s Settings. Withdrawal stops new collection and clears advertising measurement data still stored locally by Firebase. It cannot recall events already received by Google. Changing Apple’s tracking permission to disallow tracking also stops advertising measurement when BP Diary next checks that permission.

Face data

This section covers all face data BP Diary handles: what it is, how we use it, who can access it, where it is stored and when it is deleted.

What face data we collect

A face scan uses the front camera of your device. During a scan, BP Diary processes the following face data:

Live video. The camera video is analyzed in real time on your device. It is never stored and never leaves your device.
Face position. The area of the video where your face is located is computed on your device only to read the skin signals. It is never stored and never leaves your device.
Facial image. One very low-resolution still image of your face per scan, in which you cannot be recognized.

The following data leaves your device in connection with a face scan:

Blood-flow signals read from your skin and the resulting health measurements, such as blood pressure and heart rate estimates. These are numerical data, not images, and cannot be used to recreate your face. They are sent to Shen.AI servers and processed to produce your estimates.
One very low-resolution facial image per scan, sent to Shen.AI servers.

No other face data leaves your device.

Before your first face scan, BP Diary explains what is sent and to whom, and asks for your explicit consent. The scan does not access the camera and no face data is sent until you agree. If you do not agree, no face scan takes place, and you can still keep your diary by typing readings or photographing your cuff display.

You can withdraw your consent at any time in the app’s Settings or by writing to data@shen.ai. Your saved readings stay, no further facial image is sent, and BP Diary asks again before another face scan.

How we use face data

Live video and face position are used only to calculate your measurements and show your results in the app.
Facial images are used only to improve the accuracy and reliability of Shen.AI camera measurements. This work is non-medical and is carried out by Shen.AI alone.
We do not use face data to identify you, to authenticate you or to verify your identity, and no biometric template is created. We do not use face data for advertising or marketing or to build user profiles. We never sell face data.

We do not share, transfer or sell face data to any third party. This includes advertising platforms, analytics and diagnostic providers, data brokers and any external artificial intelligence or machine learning provider. Facial images are accessible only to authorized Shen.AI personnel who work on the measurement technology and are bound by confidentiality obligations.

Storage of face data

Live video and face position exist only temporarily in the memory of your device during a scan. Facial images are stored in encrypted form on secure servers located in the European Economic Area and used only by Shen.AI. Face data is never transferred outside the European Economic Area.

Retention and deletion of face data

Live video and face position are not retained. They are discarded as soon as the scan ends.
Facial images are retained until you ask us to delete them. You can do that at any time, with or without an account, by writing to data@shen.ai. They are then permanently deleted from our servers and from every dataset that contains them.

Legal basis for personal data processing

We process face data, health information and optional ethnicity on the basis of explicit consent under Articles 6(1)(a) and 9(2)(a) GDPR. Separate choices cover participation in research and optional Google Ads measurement.

We process ordinary personal data necessary to provide the Services you request under Article 6(1)(b). Proportionate security, maintenance and essential diagnostics rely on our legitimate interests under Article 6(1)(f), subject to your rights. Optional analytics relies on consent where required. Processing required by law relies on Article 6(1)(c).

Providing data is voluntary, but some information is necessary for the feature you request. Withdrawing consent necessary for that feature may make it unavailable. The Services do not make decisions about you that produce legal or similarly significant effects solely through automated processing.

Who may access your data?

Within Shen.AI, access is limited to personnel who need the information for their work. Our service providers process information needed to operate the Services, including Cloudflare for hosting and cloud storage, the analytics and diagnostic providers named above, and Apple or Google when you use their sign-in services. If you agree to optional advertising measurement, Google also receives the data described above. Data may also be disclosed where required by law or necessary to address legal claims.

None of these recipients receives face data. We do not sell your personal data and we do not share it with third parties for their own marketing.

All analysis of face data, cuff photographs and health data in BP Diary is performed by Shen.AI’s own technology. We do not send your data to any external artificial intelligence or machine learning provider.

Providers may process data outside the European Economic Area. Where international-transfer rules apply, appropriate safeguards are required, such as an adequacy decision or standard contractual clauses. Contact data@shen.ai for information about the safeguards applicable to your data and how to obtain a copy.

How long do we store your personal data?

We keep diary and account information for the period you use the Services, until you delete the records or your account. Your diary history does not expire simply because readings become old. Local records remain until you delete them or clear the app’s storage.

Face data is retained as described in Face data. Other information is retained for the period needed for its purpose, including resolving a support request, investigating a technical or security incident, or completing the research described when you consent. Backup copies follow the applicable backup retention cycle. Legal obligations or the establishment, exercise or defence of legal claims may require limited information to be retained longer.

When information is no longer needed and there is no lawful reason to retain it, it must be erased or anonymized. Withdrawal does not affect the lawfulness of processing carried out before it.

Information about your rights

Under applicable law, you may request access, correction, erasure, restriction or portability of your personal data. You may object to processing based on legitimate interests and withdraw consent at any time.

You can delete readings, clear your diary or delete your account through the app’s Settings. To request account and data deletion without using the app, email data@shen.ai with the subject “BP Diary account and data deletion”. Where possible, use the email address associated with your account. We may ask for information needed to verify your identity; you do not need to send your health readings with the request.

Send other privacy requests to data@shen.ai. You may also complain to the Estonian Data Protection Inspectorate at info@aki.ee, or another competent data protection authority.

Age restriction and changes to this Policy

The Services are for adults aged 18 or older. If we learn that we have inadvertently collected personal data from a younger user, we will take reasonable measures to erase it.

We may update this Policy when the Services or data-processing arrangements change. Changes will be communicated through the website and, where appropriate, directly to you. Where a new use requires consent, we will request it before that use begins.