Privacy Policy

Privacy Policy

Your POPS are personal;

so is your data.

Your POPS are personal; so is your data.

  1. Pop smart, Scroll safe.
    Privacy’s part of the plan.

  2. Pop smart,
    Scroll safe.
    Privacy’s part of the plan.

  3. Effective Date: 1 March 2025
    Last Updated: 23 February 2026

    This Privacy Policy sets forth how Kwelio collects, uses, discloses, and protects your personal information when you access and use the Kwelio website (the “Site”).

    The Policy complies with applicable data protection laws in the United Arab Emirates, including relevant provisions of the UAE Federal Law No. 2 of 2019 on Information Technology, as well as international standards for users subject to GDPR.

    Please read this document carefully before creating your account. By tapping “Sign Up” or “Create Account” you confirm that you have read, understood, and agree to both the Privacy Policy and the Terms and Conditions set out below.

    If you have any questions, please contact us at privacy@kwelio.com.

  4. Part A – Privacy policy

  5. A1. Who we are

  6. Kwelio is the brand under Lumio Holdings Limited, which includes all entities that collectively provide our products and services. Specifically:

    • Kwelio Food Supplements Trading LLC governs and manages our supplement products—this includes formulation, sale, and distribution.

    • Kwelio Labs FZ LLC is responsible for managing the website, technology platform (including the forthcoming app), customer support, and the overall supplement experience (packaging and delivery).

    The POP by Kwelio application (the “App”) is owned by Lumio Holdings Limited, incorporated in the Abu Dhabi Global Market (“ADGM”) with registration number 18866 (“Lumio”), and operated by Kwelio Labs FZ LLC, incorporated in Dubai Media City, United Arab Emirates (“Kwelio Labs”). Together they are referred to as “Kwelio”, “we”, “us”, or “our”.

    Lumio Holdings Limited is the data controller. Kwelio Labs FZ LLC acts as data processor on its behalf. Questions: privacy@kwelio.com | DPO: dpo@kwelio.com.

    Registered Address:
    Kwelio Labs FZ LLC
    G-01, L3, LOFT OFFICES 3
    Dubai Media City, Dubai, UAE

  8. A2. Cookies

  9. The App is a native mobile application. It does not use cookies or similar browser-based tracking technologies.

  11. A3. Applicable Data Protection Laws

  12. We comply with: UAE PDPL (Federal Decree-Law No. 45 of 2021); ADGM Data Protection Regulations 2021; EU GDPR (for EU/EEA users); and UK GDPR and Data Protection Act 2018 (for UK users). Where these differ, we apply the higher standard.

  14. A4. Information We Collect

  15. A4.1 Information you provide

    • Account credentials: email address and password.

    • Medication data: names, dosages, and scheduled intake times.

    • Pop logs: records of doses you mark as taken.

  17. A4.2 Automatically Collected

    • Device info: model, OS version, language, time zone.

    • City and time zone: for schedule accuracy. No precise GPS location is collected.

    • Usage and crash data: via Firebase Analytics and Crashlytics.

  19. A4.3 Health-Related Data

  20. Medication names, schedules, and adherence logs are health-related (sensitive) personal data. We rely on your explicit consent — given when you sign up — to process this data. We do not share it with advertisers or marketers.

  22. A5. How We Use Your Information

    • Account creation and management.

    • Displaying your schedule, calendar, Pop history, KAS, and Lio Points.

    • Sending dose reminders (where permitted by your device settings).

    • Diagnosing technical issues and improving the App.

    • Analysing anonymised aggregate usage to improve features.

    • Complying with legal obligations.

    Lawful bases: performance of contract (core features); explicit consent (health data); legitimate interests (crash reporting, security); legal obligation.

  25. A6. Third-Party SDKs

  26. The App uses the following SDKs which may collect technical data under their own privacy policies:


    1. Firebase Authentication

    2. Firebase Firestore

    3. Firebase Analytics

    4. Firebase Crashlytics

  28. A7. Account Deletion and Data Requests

  29. You can exercise your rights to delete your account or access your data directly within the App, via the App Data section in settings:

    • Delete Account: permanently deletes your account and all associated personal data within 30 days. Irreversible.

    • Request App Data: sends a copy of your personal data to your registered email address, fulfilling your right to data portability.

    To exercise any other right (access, rectification, restriction, objection, withdrawal of consent), email privacy@kwelio.com. We will respond within 30 days. Withdrawal of consent for health data will prevent use of the App’s core features.

    EU/EEA users may complain to their local supervisory authority. UK users may contact the ICO (ico.org.uk). ADGM users may contact the ADGM Registration Authority.

  31. A8. Data Sharing

  32. We do not sell your data or share it with advertisers. We share only with: Firebase/Google (as processor); between Lumio and Kwelio Labs; where required by law; in a business transfer (with notice); or with your explicit consent.

  34. A9. International Transfers, Retention and Security

  35. Data is stored in the UAE via Firebase, which may process data in other jurisdictions. We use appropriate safeguards (SCCs, UK IDTAs, ADGM/PDPL-compliant contractual protections). We retain data while your account is active and for up to 30 days after deletion. We use HTTPS/TLS, Firebase Authentication, and role-based access controls.

  37. A10. Children

  38. The App is not directed at children under 13. Contact privacy@kwelio.com to request deletion of any data submitted by a minor.

  40. Part B – Terms & Conditions

  41. B1. Acceptance

  42. By tapping “Sign Up” or “Create Account” you agree to be bound by these Terms and Conditions. If you do not agree, do not create an account.

  44. B2. About the App

  45. POP by Kwelio enables you to: log in with your email and password; add medications and intake schedules; log dose intake (“Pop”); view Pop history and a calendar of past adherence; view your KAS; earn Lio Points for consistent adherence; and view Today’s Schedule.

  47. B3. Medical Disclaimer

  48. THE APP IS NOT A MEDICAL DEVICE AND DOES NOT PROVIDE MEDICAL ADVICE. It is a personal tracking tool only. Always follow your healthcare provider’s instructions. In a medical emergency, call 998 (UAE) or your local emergency service immediately. Do not use the App to seek emergency help.

  50. B4. Eligibility

  51. You must be 18 or older to use the App independently. Users aged 13–17 require explicit parental or guardian consent. The App is not for children under 13.

  53. B5. Your Account

  54. You are responsible for keeping your password confidential, providing accurate registration information, and all activity under your account. Notify us at support@kwelio.com of any suspected unauthorised access.

  56. B6. Account Deletion and Data Requests

  57. You may delete your account or request your data at any time via the App Data section in the App settings:

    • Delete Account: permanently deletes your account and all associated personal data within 30 days. Irreversible.

    • Request App Data: sends a copy of your personal data to your registered email address.

    You may also email support@kwelio.com or privacy@kwelio.com to make either request.

  59. B7. Acceptable Use

  60. You must not violate any law; attempt unauthorised access to our systems; reverse engineer the App; upload harmful code; or infringe any third-party rights. We may suspend or terminate your account for any breach.

  62. B8. Intellectual Property

  63. All intellectual property in the App is owned by or licensed to Lumio Holdings Limited. Kwelio Labs FZ LLC operates the App under licence from Lumio. You receive only a limited, personal, non-exclusive, non-transferable, revocable licence for personal, non-commercial use.

  65. B9. KAS and Lio Points

  66. The KAS is calculated from your self-reported dose logs and is for personal information only — it is not a clinical assessment. Lio Points are virtual in-app credits with no monetary value, cannot be exchanged for cash, and may be modified or discontinued by Kwelio at any time.

  68. B10. Limitation of Liability

  69. TO THE MAXIMUM EXTENT PERMITTED BY LAW, KWELIO IS NOT LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING LOSS OF HEALTH OUTCOMES. KWELIO’S TOTAL LIABILITY SHALL NOT EXCEED THE GREATER OF THE AMOUNT PAID TO KWELIO IN THE PRECEDING 12 MONTHS OR AED 100.

  71. B11. Changes and Termination

  72. We may update the App or these Terms at any time, with notice of material changes. You may delete your account at any time via the App. We may terminate your access for breach of these Terms.

    We review and update this Privacy Policy periodically. Any material changes will be posted on the Site along with a revised effective date. Continued use of the App after changes constitutes acceptance of the revised Policy.

  74. B12. Governing Law

  75. This agreement is governed by the laws of the Abu Dhabi Global Market (ADGM). All disputes are subject to the exclusive jurisdiction of the ADGM Courts.

  77. B7. How you can reach us

  78. General: support@kwelio.com
    Legal: legal@kwelio.com
    Privacy: privacy@kwelio.com

    Lumio Holdings Limited
    ADGM Reg. No. 18866, Abu Dhabi Global Market, UAE

    Kwelio Labs FZ LLC
    Loft Offices 3, Office # G-01, Entrance A, Dubai Media City, Dubai, UAE