Participant Consent Form

GLP-1 Companion data use for Research Purposes

Before you use GLP-1 Companion feature (the “Feature”), please read this Participant Consent Form carefully.

This form explains what data we may collect through this Feature, how we may use that data for research purposes, how long we may keep it, and your rights, including how to withdraw your consent and request deletion of your data.

Use of the Simple app is also governed by Simple’s Privacy Policy and Terms of Use. This Participant Consent Form is supplementary to those documents and covers only the use of your GLP-1 medication data for research and analytics purposes. The processing of your data necessary for delivering Feature’s core functionality is governed by those primary documents and does not require this additional consent.

1. About this Feature and research

The GLP-1 Companion feature allows users to track GLP-1 medication intake, view intake schedules, log and delete intake records, display a concentration graph, and receive push-notification dose reminders.

We wish to use the data collected through this Feature for internal research purposes, including to better understand medication adherence patterns, pharmacokinetic trends, feature engagement, and health outcomes associated with use of Simple.

As part of this, and subject to your consent, we may collect and process:

  • medication intake data that you log in the app (intake records, timestamps, dosage information, medication type);
  • pharmacokinetic concentration data derived from your logged intake;
  • onboarding data you provide during the GLP-1 setup flow (e.g., current medication, dosage tier, intake day preference);
  • related metadata such as but not limited to dates, timestamps, units, dose-reminder interaction data, and source of entry.

2. Data Controller

Simple.Life Apps Inc.

8 The Green, Ste A, Dover, County of Kent, 19901, Delaware, USA.
Email: support@simple.life

If you have questions about how your personal data is handled, you can contact our Data Protection Officer at: dpo@simple.life.

3. What data we process

If you consent, we will collect and process the categories of data that you provide us with through the Feature. This may include:

a. GLP-1 medication data

  • Medication name and type;
  • Dosage amount;
  • Intake date and time;
  • Preferred intake day of the week;
  • Pharmacokinetic concentration levels derived from logged intake.

b. Related account and research data

  • Your Simple account identifiers necessary to associate the health marker data with your account;
  • Feature usage and engagement data;
  • Other health and wellness data already associated with your use of Simple, where relevant for research and analytics and permitted by applicable law and your consents.

4. Purpose and legal basis for processing

Purpose

We process this data for the purpose of conducting internal research, which includes:

  • analyzing medication adherence patterns, dosing trends;
  • understanding how users engage with the Feature (onboarding completion, reminder effectiveness, graph usage);
  • evaluating and improving the Feature and other Simple services;
  • conducting internal scientific, statistical, and product research; and
  • generating aggregated and de-identified insights, reports, and publications.

Legal basis

The legal basis for processing your personal data is our legitimate interest in conducting the research, improvement of our services, and provision of a more reliable service to you (Article 6(1)(f) GDPR). The legal basis for processing your health and medication data for research and analytics purposes is your explicit consent (Article 9(2)(a) GDPR).

Where applicable U.S. state privacy laws require consent for the processing of health data or sensitive personal information for purposes beyond service delivery (including under the California Consumer Privacy Act as amended, the Washington My Health My Data Act, the Connecticut Data Privacy Act, and analogous state laws), your explicit consent provided under this form satisfies those requirements.

You may withdraw your consent at any time as described in Section 10 below.

5. Voluntary participation

Consenting to research use of your GLP-1 medication data is entirely voluntary. You may use the core functionality of the GLP-1 Companion feature (logging intake, viewing your schedule, receiving reminders, viewing the pharmacokinetic graph) without consenting to research use.

If you do not consent, your medication data will be processed only as necessary to deliver the Feature’s services to you, as described in Simple’s Privacy Policy and Terms of Use.

You may also withdraw your consent to research use at any time by contacting us at dpo@simple.life.

6. Who can access your data

Your personal data may be accessed only by authorized Simple personnel who need access for product operations, research, analytics, compliance, or support purposes.

Where possible, research outputs will be limited to aggregated and anonymized data. External collaborators, if any, will only receive anonymized or aggregated outputs unless an additional lawful basis and appropriate safeguards are in place.

We will not sell your personal data or share it with third parties for unrelated marketing purposes.

7. Where your data may be processed

Your data may be processed by Simple and its service providers in the jurisdictions where they operate, in accordance with applicable data protection laws and contractual safeguards.

Where personal data is transferred internationally, we will use appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, an adequacy decision, or other lawful transfer mechanisms recognized under applicable law.

8. How long we keep the data

We will keep your personal data collected through this Feature for as long as your account exists in order to provide you with the proper functionality. When you withdraw your consent to the use of your personal data collected through this Feature for research purposes, it will not be deleted (since it is still required for the proper Feature functionality), but we will add you to a suppression list to make sure we do not use your personal data for the mentioned research purposes.

After expiry of the applicable retention period, personal data will be securely deleted or irreversibly de-identified.

9. Withdrawal of consent and deletion of data

You may withdraw your consent at any time, without giving a reason, by:

  • changing your permissions in the app, where this functionality is available;
  • disconnecting Apple Health or another connected data source (for imported data); or
  • contacting dpo@simple.life and requesting withdrawal of consent and deletion of your GLP-1 medication data used for research.

If you withdraw consent, we will stop future processing of your GLP-1 medication data for research purposes from that point onward. Withdrawal will not affect the lawfulness of processing carried out before withdrawal.

If data has already been irreversibly de-identified or included in aggregated analyses that no longer identify you, we will not be able to remove it from those analytics outputs.

10. Your Rights

Under the GDPR (where applicable), you have the right to:

  • access the personal data we hold about you;
  • rectify inaccurate personal data;
  • request erasure of your personal data;
  • restrict processing of your personal data;
  • data portability; and
  • lodge a complaint with a supervisory authority.

Under applicable U.S. state privacy laws (where applicable), you may have additional rights, including:

  • the right to know what personal information is collected, used, and shared;
  • the right to delete personal information;
  • the right to opt out of the sale or sharing of personal information (we do not sell your data);
  • the right to correct inaccurate personal information; and
  • the right to non-discrimination for exercising your privacy rights.

To exercise any of these rights, please contact dpo@simple.life.

11. Consent statements

Please confirm the following:

  • I have read and understood this Participant Consent Form. I understand that the GLP-1 Companion feature is for informational and personal tracking purposes only, that Simple is not a medical device, and that Simple does not provide medical advice.
  • I explicitly consent to Simple using my GLP-1 medication intake data for research purposes, including analysis of medication adherence patterns, pharmacokinetic trends, user outcomes, product improvement, and aggregated/de-identified research reporting.
  • I understand that this consent is voluntary and that I may withdraw it at any time without affecting my ability to use the core GLP-1 Companion feature.