Privacy Policy

This policy explains what the Dry Eye Specialists app collects about you, why, where it goes, how long we keep it, and what you can ask us to do about it. If anything in it is unclear, email us and ask.

If you came here only to remove your information, go straight to Deleting your information.

Who we are

Dry Eye Specialists is published by SynRo AB, a company registered in Sweden. SynRo AB built the app together with the Dry Eye Specialist Group, a network of nine independent optometry practices in New Zealand. SynRo AB is the company behind the app. It is not the company behind the group.

SynRo AB is the agency that collects your information and the agency that holds it. Under the Privacy Act 2020 an overseas company counts as a New Zealand agency for the information it collects while doing business here, so the Act applies to us and we follow it. We also apply the rules of the Health Information Privacy Code 2020 to the health information you give us.

• SynRo AB
• Torgny Segerstedts Allé 7, 756 44 Uppsala, Sweden
• Email: contact@synro.life

What this policy covers

It covers the Dry Eye Specialists app for iPhone and Android, published under the identifier life.synro.dryeyespecialists, and the account and analysis services behind it. The app also shows you short notices at the moment it asks for something, for example before it opens the camera. Those notices and this page are meant to be read together.

It does not cover the records your own optometry practice keeps about your care. Those records belong to the practice, are held under New Zealand law by the practice, and are separate from the app. See What your practice can and cannot see.

Dry Eye Specialists is a self care and wellness app. It is not a medical device. It does not diagnose or treat any condition, and it does not replace the care of your optometrist.

Giving us your information is your choice

No law requires you to give us any of this. Everything on this page is given voluntarily. If you would rather not, here is what stops working:

• Without an account you cannot save anything, sync between devices, or come back to your history later.
• Without a camera recording the app cannot produce a check result.
• Without your symptom answers the app cannot show you how things change over time.
• Without a clinic code the app stays on its free features unless you buy access.
• Without notification permission your reminders will not reach you.
• Without consent to personal data processing, which you can switch off under My Account, then Privacy and Data, the app cannot make recommendations for you or sync your devices.

Why we collect it

We collect information for these purposes and no others:

• To give you an account, to sign you in, and to reach you about your account.
• To produce the result of a camera check and return it to you.
• To show you how your symptoms, your routine and your check results change over time.
• To run your plan, your routines and your reminders.
• To apply a clinic code and give you the access it carries, or the access you bought.
• To find and fix faults, and to see which parts of the app work and which fail.
• To answer you when you write to us.
• To test and improve the analysis, but only with the recordings of people who chose to join the improvement programme described below.

We do not use your information for advertising, and we do not sell it.

What we collect

Your account

Your first name, last name, email address, the username you choose, the age band you pick from a list that starts at 18 to 24, and a profile photo if you add one. We also store your settings: your language, whether syncing across devices and cloud backup are on, your streaks, and the consent choices described further down.

You can sign in with an email address and password, or with your Google or Apple account. When you use Google or Apple we receive your name and email address from them. We never receive your Google or Apple password.

Your country and your time zone

When you create an account the app reads the country and the time zone your device is set to, and offers them back to you. The country you confirm is saved with your account, and your time zone is kept so that reminders arrive at a sensible hour.

The app does not use GPS and it never asks for location permission. Your country comes from the region your phone is set to, not from where you happen to be. Like every internet service, our servers can see the network address your device connects from, which gives a rough idea of the country. We do not use it to work out where you are.

Your symptom answers

The answers you give in the comfort and symptom questions inside the app, and the date you gave them.

Your plan, routines and reminders

Which treatments and routines are on your plan, including a plan you agree with your optometrist and enter yourself, the doses and courses you set, which routine sessions you start and finish and when, your streaks, and your reminder settings.

Your eye camera checks

The app has three camera checks, and they use the camera differently. We want you to know exactly what happens:

• The tear film check records a short video of one eye with the rear camera. While it records, the phone's own small light is on so that the camera can see the reflection it needs. On most phones it runs at a low level, around a tenth of what the phone can produce. On phones whose light cannot be turned down, it runs at the phone's normal level and the camera is set darker instead. You hold the phone roughly 10 to 12 cm from your eye.
• The tear volume check takes still photographs of the same area with the rear camera. The light stays off.
• The blink check records a short video with the front camera. The light stays off.

No sound is recorded. The microphone is switched off for every one of these recordings.

Each recording is sent over an encrypted connection to our analysis service. The service produces three estimates and sends them back: tear film break up time in seconds, tear meniscus height in millimetres, and blink completeness. Those values and the date of the check are saved to your account so the app can show you change over time. They are estimates produced by software for your own self care use. They are not a diagnosis and they are not a clinical reading taken by your optometrist.

Sent with each recording, because the analysis needs them:

• your account identifier, so the result comes back to you
• for the tear film check, a single still photograph of the eye region taken in ordinary room light while you were lining the shot up, and which eye the app believes it filmed
• your device model, operating system version and app version
• the time of the capture, your time zone, and an identifier for that capture
• camera readings from the moment of capture, such as the light level used, exposure range, zoom, image stabilisation mode, the brightness the camera metered, and whether the phone reported that it was getting warm

Your name and your email address are not sent with a recording.

If you choose Save to gallery after a check, a copy of that video or photograph is written to your own device photo library. That copy is yours and sits on your phone. We do not hold it and we cannot delete it for you.

Messages you send us

If you use Contact us inside the app, we receive the message you write. If you use Feedback, we receive your rating, the topic you pick, what you write, and the email address you type into that form. Please do not put anything in those boxes that you would rather we did not hold.

App analytics

The app sends us a small stream of events about how it is being used. These include which screens you open and whether a feature finished, which routine sessions you start and complete, which plan items you add and which doses and courses you set, which learn videos you open, when you redeem a clinic code and which practice that code belongs to, and a short summary of the pattern your recent checks fell into, written as coarse bands such as short or low rather than as the values themselves.

The events themselves carry a random analytics identifier created on your device, and they never carry your name or your email address. Be aware of the whole picture though: the app is signed in when it sends them, so our server can tell which account a batch came from. We do not treat these events as anonymous and neither should you.

This is on by default. You can turn it off at any time: My Account, then Privacy and Data, then Consent to Anonymous Data Collection. When you turn it off, the app stops sending events and clears anything it was still holding to send.

Push notifications

If you allow notifications, Apple or Google gives the app a push token for your device. We store it with your account so that reminders can reach your phone, and we remove it from your account when you sign out or delete your account. If you switch notifications off on your phone, the messages stop arriving.

Crash reports

If the app crashes, a report goes to Firebase Crashlytics, a Google service we use, so that we can find the fault. The report contains the technical detail of the crash, the device model, the operating system version and the app version. A short note of the error type also goes to our own server, as one of the analytics events above, which means it stops as well when you turn analytics off. We do not attach your name or your email address to a crash report.

Your clinic code

If you enter a clinic code, we record which practice in the Dry Eye Specialist Group the code belongs to, that you redeemed it, and when. The code links your account to that practice and unlocks the full app at no charge.

Purchases

Subscriptions and single checks are sold through the App Store and Google Play. The store takes the payment and tells the app what you are entitled to. We never see your card number. We store your entitlement, for example whether a subscription is active and how many checks remain.

Conversations with Clara

Clara is an optional AI assistant. When you use her, the messages you type and any product photograph you choose to attach are sent over an encrypted connection to the separate Dry Eye Specialists Clara service operated for SynRo AB. The AI runs on our hosted infrastructure.

The app can also send relevant context from your plan, routines, reminders and recent eye tests to help Clara answer in context. Your result-visibility choices are applied before test results are included. An account-linked identifier keeps your conversation separate from other people's conversations. Please avoid including names, contact details or other information that Clara does not need. Clara's answers are AI-generated information, not a diagnosis or a prescription.

Your chat history is saved on your device. The server holds the active conversation temporarily to generate replies and expires inactive sessions after 30 minutes. If you choose to let Clara remember you between conversations, the service stores a short summary of preferences, routines and previous discussions. This memory is optional and off until you choose it. Turning it off removes the stored summary; unused summaries expire after 365 days. You can reset Clara's memory in the app. Deleting your account also requests removal of Clara's stored memory.

Learn videos

Learn More videos are hosted on YouTube and played inside the app by Google's player. When a video loads, your device contacts Google directly, and Google receives that request and whatever its own policy describes, including your network address and device details. We never hold a copy of that. We do record that a video was opened, as one of the analytics events above.

What we do not collect

• GPS or any precise location.
• Sound. Every camera check records with the microphone off.
• Your contacts, calendar, messages from other apps or documents you have not chosen to share with Clara.
• Advertising identifiers. We do not track you across other apps or websites and we do not show advertising.

We do not sell your information, to anyone, for any purpose.

Health information

Your symptom answers, your check values, your plan and your routine records are information about your health. New Zealand's Health Information Privacy Code 2020 sets the rules for health information, and we apply those rules to this information. The app being sold as a wellness app does not change what the information is.

The rules that matter most to you are these: we collect only what we actually need, we keep it safe, we keep it no longer than we need it, and you may see it and correct it.

The improvement programme is optional

We are still developing the software that produces your check values, and doing that well needs real recordings. Keeping your recordings for that purpose is optional and it is off unless you turn it on.

The app asks you once, after you have seen a check result, whether you want to join. The question explains what it covers, and you may join or decline. You can change your mind at any time: My Account, then Privacy and Data, then Help improve eye testing. When you turn it off, we delete the recordings we were holding under the programme.

If you have joined, we keep the recordings from your camera checks and the values worked out from them, and we use them to test and improve how the analysis works. We do not use them for advertising and we do not sell them.

If you have not joined, your recordings are not used to improve the analysis. Your first check is uploaded and processed before the app asks the question, because we only ask once a result is on screen. A recording made before you join is not part of the programme.

A recording that is not part of the programme is deleted from the analysis service once the analysis has finished. Only the values it produced stay with your account.

We do not show your recordings outside SynRo. If we ever wanted to use one somewhere else, for example in a talk or a published study, we would ask your permission first.

Where your information is stored

Three systems of our own process your information, both operated for SynRo AB and both reached only over encrypted connections. A small amount also sits with the providers named further down, in particular crash reports and push tokens held by Google.

• The account service holds your account, your symptom answers, your plan and routine records, your check values, your consent choices, your purchase entitlement, the messages you send us and your analytics events. Behind it is a managed database service.
• The analysis service receives your camera recordings, produces the values and returns them.
• The DES Clara service processes your conversations and relevant app context and holds an optional memory summary. It is separate from the Clara service for DryEyeGuide.

Both sit outside New Zealand. See Information held outside New Zealand for what that means under the Privacy Act.

The analysis service is shared between two apps

SynRo AB publishes more than one eye care app, and the service that analyses camera recordings serves both of them.

Every recording sent from Dry Eye Specialists carries a tag identifying this app. Material from the two apps is told apart by that tag.

What that means for you:

• Your recordings and your results only ever come back to your own account in this app.
• Your information is never shown to a user of the other app and is never mixed into that app's results.
• When you ask us to delete your recordings, we use that tag together with your account identifier to find your material.

Who else sees your information

• Nobody at your practice. See the next section.
• Providers who work for us. Hosting, the managed database, the computers that run the analysis, crash reporting and push notifications through Google Firebase, and payments handled by Apple and Google. They act on our instructions and for our purposes, not their own.
• Google, when a learn video plays, because the video comes from YouTube straight to your device.
• Anyone the law requires. If we are legally required to give information, for example under a court order, we will. We will tell you where we are allowed to.

We do not sell your information and we do not share it for advertising.

What your practice can and cannot see

Entering a clinic code links your account to one practice in the Dry Eye Specialist Group and unlocks the full app.

In this version of the app, your practice does not receive your check values, your symptom answers, your plan or your routine records through the app. There is no clinic dashboard. Your practice can see any of it only if you choose to show it to them yourself, for example on your own screen during a visit.

Your practice keeps its own records of the care it gives you. Those records are held by the practice, under New Zealand law, separately from the app. Deleting your app account does not touch them. If you want to see or correct what your practice holds, ask the practice directly.

If we ever build a way for a practice to see your information through the app, we will ask your permission first, tell you exactly what the practice would see, and update this page before it happens.

How long we keep your information

We keep information only for as long as we need it for the purpose we collected it for. In practice that means while your account is open, and then only what the law makes us keep.

How we protect your information

• Everything the app sends to us travels over an encrypted connection.
• Access to the systems holding your information is limited to the SynRo staff who need it to do their work.
• Where a provider stores or processes information for us, we remain responsible for it, and we require the provider to protect it.

No system is perfectly safe. If something does go wrong, we act on it, and where the law requires it we tell you and the Privacy Commissioner. See If there is a privacy breach.

Information held outside New Zealand

SynRo AB is a Swedish company and holds your information on systems outside New Zealand.

Under the Privacy Act 2020 it makes no difference where an agency holds information. SynRo AB is answerable under the Act for the information it collects while doing business in New Zealand, wherever that information sits, and moving information between SynRo's own systems is not a disclosure to anybody else.

Where an outside provider stores or processes information for us, the Act treats that information as still held by us, so that is not a disclosure either. That does not reduce what we owe you. We stay responsible for what happens to your information. Providers act only on our instructions and not for their own purposes, and each works under a written agreement with us that requires protection of your information comparable to the protection the New Zealand Privacy Act requires.

If we ever needed to give your information to an organisation overseas that would use it for its own purposes, information privacy principle 12 and rule 12 of the Health Information Privacy Code would apply, and we would only do it on a ground the law allows. If that ground were your permission, we would tell you first, in plain words, that the organisation may not be required to protect your information in a way that gives comparable safeguards overall. We do not do this today.

Seeing and correcting your information

You have the right to ask us for the personal information we hold about you, and the right to ask us to correct it if it is wrong. These are principles 6 and 7 of the Privacy Act 2020, and rules 6 and 7 of the Health Information Privacy Code 2020.

Most of it is already visible in the app. For anything else, or for a full copy, email contact@synro.life from the address on your account with Privacy request in the subject line. We may need to check who you are before we answer, so that we do not hand your information to somebody else. The Privacy Act allows us up to 20 working days to decide on a request, and we aim to be quicker than that.

If we correct something and we have already given the earlier version to somebody else, we will tell them about the correction. If we decide not to make a correction you have asked for, you can ask us to attach a statement of the correction you wanted, and we will attach it.

SynRo AB is a Swedish company, so European data protection law reaches us as well, and it gives you rights to erasure, to a portable copy, to restrict or object to certain uses, and to withdraw a consent you have given. Use the same email address, and if you are in Europe you can also complain to the data protection authority in your own country.

Deleting your information

You can delete your information from inside the app, or by writing to us. You do not need the app to ask us.

In the app, go to My Account, then Privacy and Data, then Delete My Data. Three choices are offered, and they do different things:

• Delete my check in history removes your checks and the values worked out from them. Your account stays open.
• Delete my personal details removes your name, email address and photo, and closes your account.
• Delete everything removes your account and the data attached to it. You will be asked to type your email address to confirm, so that this cannot happen by accident.

By email, write to contact@synro.life from the address on your account, with the subject Delete my Dry Eye Specialists account. We check who you are, complete the deletion within 30 days, and confirm by email.

Two things deletion does not reach. It does not touch the records your own practice holds about your care, because those belong to the practice. It does not touch copies you saved to your own phone with Save to gallery. We may also keep purchase records where accounting and tax law requires it, and copies can remain in our routine backups until those backups are overwritten.

Full instructions are on the data deletion page for Dry Eye Specialists.

If there is a privacy breach

If information we hold is lost, taken, or seen, changed or destroyed by somebody who should not have, we assess whether it is likely to have caused serious harm, using the factors set out in the Privacy Act 2020. Health information and images of your eye weigh heavily in that assessment.

If it is a notifiable breach, we tell the Office of the Privacy Commissioner as soon as practicable, and we tell the people affected as soon as practicable unless the Act allows otherwise. Our notice will say what happened, what we are doing about it, what you can do, who to contact at SynRo, and that you can complain to the Privacy Commissioner. If we cannot reach people individually, we will give public notice instead.

Children and young people

Dry Eye Specialists is for adults. Our terms require you to be 18 or over, and the age list in the app starts at 18 to 24. The app is not designed for children and we do not knowingly collect information from anyone under 18. If you believe a child has given us information, email contact@synro.life and we will remove it.

Changes to this policy

We update this page when the app changes. The date at the top tells you when it last changed. If a change matters to you, for example if we ever begin sharing something with your practice, we will tell you inside the app before it takes effect.

Which law applies

New Zealand law governs this policy. The courts of New Zealand deal with any dispute about it.

Nothing on this page takes away any right you have under New Zealand consumer law, including the Consumer Guarantees Act 1993 and the Fair Trading Act 1986.

How to complain

Tell us first. Email contact@synro.life with Privacy complaint in the subject line, addressed to the Privacy Officer. We will look into it and reply.

If you are not satisfied with our answer, or we do not answer, you can complain to the Office of the Privacy Commissioner. The Commissioner is independent, and complaining is free. Details are at privacy.org.nz.

Contact us

SynRo AB
Torgny Segerstedts Allé 7
756 44 Uppsala
Sweden
Email: contact@synro.life

Privacy Officer. SynRo AB has appointed a privacy officer, as the Privacy Act 2020 requires. To reach the privacy officer about access, correction, deletion, a complaint or a possible breach, email contact@synro.life and put Privacy Officer in the subject line.

Our terms. The terms and conditions for Dry Eye Specialists sit alongside this policy.

Clinical partner. Dry Eye Specialist Group, fixdryeyes.co.nz. For the records your own practice keeps about your care, contact the practice directly.