プライバシーポリシー

Last updated: September 30, 2026

This Privacy Policy explains how Ethylowheel ("we", "us", or "our") collects, uses, stores, and shares certain personal information when you use:

• the EthyloKey website and online store, including services powered by Shopify; and
• the EthyloKey mobile application for iOS and Android (the "App").

The processing activities related to the online store and those related to the EthyloKey App are separate. Certain technologies and processing activities used on our website, including certain Shopify features, are not present in the EthyloKey App.

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, you can contact us at contact@ethylokey.com, by phone at +33 6 70 44 96 20, or by mail at Ethylowheel, 3 Bd Thomas Gobert, 91120 Palaiseau, France.

1. EthyloKey Mobile App

Information Processed by the App

The EthyloKey App accompanies the EthyloKey device and allows users to display the categories communicated by the device, maintain a history, log drinks and meals, generate certain estimates, use a reaction-time test, and organize party sessions.

When you create and use an account, we may process the following categories of information:

• Account information: email address, technical account identifier, account creation date, and login dates.
• Profile information: first name, country selected by you, driving profile, language, sex, App version, onboarding motivation, and dates associated with certain consents, preferences, or acceptance of terms.
• EthyloKey measurements: date and time, the category communicated by the device (green, amber, or red), device serial number, firmware version, battery level, App version, and whether the result originated from a real device or demo mode.
• Technical sensor data: technical information produced by the EthyloKey device, which may include humidity, temperature, air-quality information, volatile organic compounds, ethanol-related sensor signals, sensor resistance, and internal raw or compensated indices. These data may be used to provide the service, diagnose technical operation, and improve calibration and technical performance.
• Drink and meal declarations: drinks you log, including time, volume and alcohol strength, as well as meals you declare.
• Estimates: information required to provide the estimation feature, which may include the beginning of a session, last drink declared, number of drinks and meals, country and driving profile selected, sex, estimated peak, estimated timing, and estimated return-to-zero time.
• Reaction tests: date and time, type of test, median and best reaction times, and number of rounds.
• Party sessions: party name, start and end dates, and the association of certain measurements with a party session.
• EthyloKey device information: serial number, color, firmware version, date of first pairing, and last-seen date.
• Subscription information: technical account identifier used for subscription management and subscription status.

Information That Remains on Your Device

Certain information is intentionally stored only on your device and is not transmitted to our servers:

• the weight you enter in the App;
• first names of guests added to a party session;
• photos you choose for those guests;
• the association between a named guest and a measurement performed during a party session.

Guest photos are stored within the App's private local storage and are deleted when the relevant party session is deleted. Local App data is also removed when the App is uninstalled, subject to the operation of your device's operating system and any device-level backups.

If you add another person's first name or photograph to the App, you are responsible for ensuring that you are permitted to use that information.

What the App Does Not Collect or Use

The EthyloKey App:

• does not contain advertising SDKs;
• does not display targeted advertising;
• does not sell or share your App data for advertising purposes;
• does not use advertising identifiers to track you;
• does not currently contain third-party analytics or audience-measurement SDKs;
• does not collect your geographic location;
• does not access your contacts;
• does not access your microphone;
• does not access Apple Health data or equivalent health-platform data;
• does not access your credit card number or other banking credentials.

Device Permissions

The App may request certain permissions only when required for a specific feature:

• Bluetooth: to communicate with your EthyloKey device;
• Camera: if you choose to take a photograph of a party participant;
• Photo library: if you choose an existing photo for a party participant;
• Notifications: to schedule local reminders or notifications on your device.

Camera, photo-library, and notification access are optional. Photos used for party participants remain on your device.

How We Use App Information

We process information necessary for your account, synchronization, and App functionality in order to provide the services you request and perform our contract with you.

We may process certain technical device and sensor information to maintain security, diagnose technical issues, ensure proper operation, and improve the technical performance and calibration of EthyloKey. Where this processing is based on our legitimate interests, those interests include maintaining and improving the technical quality and reliability of our products and services.

Where required by applicable law, marketing communications are sent on the basis of your consent. You may withdraw that consent at any time.

We may also process certain information when necessary to comply with our legal obligations, prevent fraud, secure our systems, resolve disputes, or protect our legal rights.

About Estimates Displayed in the App

Values generated by the estimation feature are calculated from information declared by the user and a mathematical model. They are theoretical estimates and are not measurements performed by EthyloKey.

The EthyloKey device communicates a category to the App — green, amber, or red — and does not provide a measured blood alcohol concentration in g/L.

The EthyloKey App is a prevention and information tool. It is not a medical device, does not replace an approved breathalyser, and does not determine whether a person is fit to drive.

Service Providers Used by the App

We use a limited number of technical service providers to operate the App:

• Supabase: authentication, database hosting, synchronization, and technical infrastructure for account and App functionality;
• RevenueCat: technical management of subscriptions. RevenueCat receives a technical account identifier and subscription-status information. We do not provide RevenueCat with your EthyloKey measurements, first name, or email address for this purpose;
• Apple and, where applicable, Google: App distribution and management of purchases and subscriptions made through their platforms.

Payments made through the App Store or another distribution platform are processed directly by the relevant platform. We do not receive or store your full payment-card details.

Account and Data Deletion

You may delete your EthyloKey account directly from the App through your profile settings.

Deleting your account results in the deletion of App data associated with that account from our active database, except where we are legally required to retain certain information or where limited retention is necessary to establish, exercise, or defend legal claims.

Deleting your EthyloKey account does not necessarily cancel a subscription purchased through Apple or another platform. Subscriptions must be managed or cancelled through the relevant platform account settings.

2. Website and Shopify Store

Our website and online store are operated using Shopify services. The processing activities described in this section concern the website and online store, and not the EthyloKey mobile App, unless expressly stated otherwise.

Information Collected Through the Store

Depending on how you interact with our website and online store, we or Shopify may process information including:

• your name, email address, telephone number, billing address, and shipping address;
• information relating to your orders, purchases, returns, refunds, exchanges, and transactions;
• information necessary to process payments;
• information you provide when contacting customer support;
• technical information relating to your device, browser, network connection, IP address, and interaction with the website;
• your communication and marketing preferences.

How Store Information Is Used

This information may be used to:

• process and deliver orders;
• manage payments, returns, refunds, and exchanges;
• manage our relationship with you and respond to your requests;
• secure our store and prevent fraud;
• comply with legal, accounting, and tax obligations;
• send commercial communications where permitted by applicable law;
• measure and improve the operation of our website;
• personalize, where permitted, certain marketing communications or advertising experiences related to the online store.

Any advertising, personalization, analytics, or tracking activities related to Shopify or the website do not mean that the EthyloKey App contains advertising trackers or advertising technology. The two environments are separate.

Relationship With Shopify

Our online store is hosted by Shopify. Shopify collects and processes certain personal information relating to your access to and use of the store in order to provide and improve its services.

Shopify may also process certain information as an independent controller for its own products and features. You can learn more in the Shopify Consumer Privacy Policy and through the Shopify Privacy Portal.

3. Marketing Communications

Where you have agreed to receive marketing communications, we may use your contact details to provide information about our products, services, and company news.

You may unsubscribe at any time using the unsubscribe link included in our emails or by contacting us at contact@ethylokey.com.

Opting out of marketing communications does not prevent us from sending non-promotional communications necessary to manage your account, subscription, order, or customer-support requests.

4. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected.

Information associated with your EthyloKey App account is generally retained for the lifetime of your account and deleted when the account is deleted, except where we are required to retain certain information by law or where limited retention is necessary to resolve disputes or protect our legal rights.

Information related to purchases and transactions made through our online store may be retained for the periods required by applicable accounting, tax, consumer-protection, and other legal obligations.

Contact information used solely for marketing purposes is retained until you withdraw your consent or for such other period as permitted by applicable law.

5. International Data Transfers

Some of our technical service providers may process personal information in countries outside the country in which you live, including outside the European Economic Area.

Where personal information subject to the GDPR is transferred to a country that has not been recognized as providing an adequate level of protection, we rely, where required, on recognized safeguards such as the European Commission's Standard Contractual Clauses or another valid transfer mechanism.

6. Security

We use appropriate technical and organizational measures designed to protect personal information against unauthorized access, loss, alteration, disclosure, or destruction.

No information system or transmission method can be guaranteed to be completely secure. You are also responsible for protecting access to your email account, mobile device, and other accounts you use in connection with our services.

7. Your Privacy Rights

Depending on where you live and subject to applicable law, you may have some or all of the following rights:

• the right to access personal information we hold about you;
• the right to request correction of inaccurate personal information;
• the right to request deletion of personal information;
• the right to request restriction of certain processing;
• the right to object to certain processing activities;
• the right to data portability where applicable;
• the right to withdraw consent at any time where processing is based on consent.

You can exercise these rights by contacting us at contact@ethylokey.com.

We may need to verify your identity before responding to certain requests, as permitted or required by applicable law.

If you believe that your personal information has not been handled in accordance with applicable law, you may lodge a complaint with the competent data protection authority. In France, the relevant authority is the Commission Nationale de l'Informatique et des Libertés (CNIL): www.cnil.fr.

8. Children's Data

The EthyloKey App is intended for adults and is not intended for persons under 18 years of age.

We do not knowingly seek to collect personal information through the App from persons under the age of 18. If you believe that a minor has provided personal information to us, please contact us at contact@ethylokey.com so that we can review the situation.

9. Third-Party Websites and Services

Our website or App may contain links to services operated by third parties. When you leave our services, any processing performed by those third parties is governed by their own privacy policies and terms.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our services, practices, technology, legal requirements, or other operational reasons.

The date at the top of this page indicates when this Privacy Policy was last updated. Where required by applicable law, we will provide appropriate notice of material changes.

11. Contact and Data Controller

For the processing activities described in this Privacy Policy for which we determine the purposes and means of processing, the data controller is:

Ethylowheel
3 Bd Thomas Gobert
91120 Palaiseau
France

Email: contact@ethylokey.com

If you have any questions about our privacy practices, this Privacy Policy, or your personal information, please contact us at contact@ethylokey.com.