Privacy Policy
for Sense Baseline.

Welcome to Emteq Ltd. (“Emteq Labs”, “we”, “us”, “our”).

This Privacy Policy explains how we collect, use, and protect your personal data when you take part in Sense Baseline, our 7-day assessment using OCOsense smart glasses and the Sense application (the “App”). Sense Baseline provides insights into your eating behaviour and dietary patterns using sensor-based technology and data analysis.

This Privacy Policy applies to:

• the OCOsense smart glasses
• the Sense application
• the 7-day Sense Baseline assessment
• any related interactions with us

It does not apply to our general website.

Emteq Ltd is the data controller responsible for your personal data.

Address: Sussex Innovation Centre, Brighton BN1 9SB, United Kingdom
Email: privacy@emteqlabs.com

This Privacy Policy applies to individuals who:

• sign up for and participate in Sense Baseline
• use the OCOsense glasses and App
• interact with us in relation to the service

Sense Baseline is intended for adults only (18+).

We collect the following types of personal data:

5.1 Account and registration data

• Full name
• Email address
• Phone number
• Country and city
• Date of birth or age-related data
• Device and operating system information
• Glasses-related information (e.g. prescription, fit, IPD, sizing photos)
• Trial availability and preferences
• User-provided goals and dietary objectives

5.2 Behavioural and dietary data (sensor-derived)

Using OCOsense, we collect derived behavioural metrics, including:

• Chewing rate and number of chews
• Number of bites
• Time between bites
• Meal duration and timing
• Head movement patterns related to eating
• Eating pace

We may also generate dietary estimates such as:

• calorie estimates
• macronutrient breakdown
• ingredient-level insights

These are inferred insights, not direct measurements.

5.3 Technical data

• App usage data
• Device type and model
• Operating system
• Access timestamps

5.4 What we do NOT collect

We use your personal data for the following purposes:

6.1 To provide Sense Baseline

• deliver real-time feedback
• generate daily insights
• produce your end-of-week report
• maintain your account after the trial

Legal basis: Contract

6.2 To improve the product

• improve algorithms and insights
• test and develop new features
• ensure performance and reliability

Legal basis: Legitimate interests

6.3 Scientific research and product development

We use data that does not directly identify you (for example, anonymised or aggregated data) to:

• better understand eating behaviour
• improve our models and services
• develop new products and features
• conduct and publish research

This data may be shared with research or commercial partners and may be included in scientific publications.

Legal basis: Legitimate interests

6.4 Customer support

• respond to queries
• troubleshoot issues
• manage your participation

Legal basis: Contract / Legitimate interests

6.5 Marketing (optional)

If you opt in, we may send:

• product updates
• insights and content
• offers and invitations

You can opt out at any time. We do not use behavioural or sensor data for marketing.

Legal basis: Consent

We process your personal data under the following legal bases:

• Contract: to provide Sense Baseline and related services
• Legitimate interests: to improve and develop our products and services
• Consent: for marketing communications and where required for certain types of data
• Legal obligation: where required by applicable law

Some of the data we process may be considered health-related data. Where required, we rely on your explicit consent to process this data.

We do not sell your personal data.

We may share data with:

8.1 Service providers

Including cloud infrastructure providers (e.g. AWS) and customer support tools. These providers process data only on our instructions.

8.2 Research and development partners

We may share data that does not directly identify you (such as anonymised or aggregated data) with research institutions and commercial partners.

8.3 Legal or regulatory authorities

Where required by law.

Your data is stored and processed in the United Kingdom. Where data is transferred outside the UK, we ensure appropriate safeguards are in place in accordance with applicable data protection laws.

We retain personal data as follows:

• Account data: up to 10 years after your last interaction
• Behavioural and sensor-derived data: retained for service provision and improvement, and may later be anonymised or aggregated
• Marketing data: until you withdraw consent
• Data that no longer identifies you: may be retained indefinitely

You have the right to:

• access your personal data
• correct inaccurate data
• request deletion
• object to processing
• request restriction of processing in certain circumstances
• withdraw consent (where applicable)

To exercise your rights, contact privacy@emteqlabs.com.

You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).

We use appropriate technical and organisational measures to protect your data, including:

• secure cloud infrastructure
• restricted access controls
• encryption where appropriate

We may update this Privacy Policy from time to time. We will notify you of significant changes where appropriate.