Last updated: 15 October 2026
This Privacy Policy describes the processing of information associated with the DOT Sensor Android application (the “App”), developed by GEMILABS UAB (“Gemilabs”, “we”, “us”). It explains the data involved in the App’s Bluetooth sensor functions and server communication, how it is used, and how to contact us about your privacy rights.
1. Developer and privacy contact
GEMILABS UAB is a company established in Lithuania, company registration number 304206431.
2. What DOT Sensor does
The App connects over Bluetooth to compatible sensor devices, including the BAS, BLS and HLS product families, to display their measurements and adjust supported settings. Some functions involve communicating with servers associated with the App. In particular, sensor telemetry is sent to a server, and sensor password changes can be synchronized with a server even if the change is initiated while the device is offline.
3. Categories of information processed
- Sensor readings and telemetry: information generated or reported by compatible sensors and transmitted by the App to its associated server. The content depends on the sensor type and its configuration.
- Sensor configuration information: settings managed through the App, including a new sensor password when a password change is requested. A sensor password is a credential used to configure the sensor; it should not automatically be treated as an App-account password.
- Local operational information: the App maintains an encrypted local queue of pending sensor password changes so that synchronization can be retried after connectivity is restored.
- Communications-related information: when the App connects to an online service, technical connection information (which may include network addresses and request metadata) may be processed as part of that communication.
Whether information relates to an identifiable person depends on the context in which a sensor is used and whether it can be linked to a person. You should treat sensor data and identifiers as potentially personal when they can reasonably be associated with a user or a device owner.
4. Purposes and legal grounds
Information is processed to provide the features requested through the App: establishing communication with sensors, displaying readings, configuring sensors, carrying out password changes and synchronizing sensor-related information with the server. Technical information may also be processed to maintain service integrity and security.
When this processing involves personal data, the applicable legal ground depends on the service relationship and the purpose of processing. This may include processing necessary to provide an agreed service (GDPR Article 6(1)(b)) or our legitimate interests in operating and protecting the service (GDPR Article 6(1)(f)), where the applicable conditions are met. You can contact us for information about the legal ground applicable to particular processing involving your data.
5. Bluetooth, local storage and security
Bluetooth is used to communicate with compatible sensors. When a user submits a new sensor password, the App saves it in a local encrypted retry queue before attempting to send it to the associated server. This queue uses Android Keystore and AES-GCM encryption. Pending synchronization can be retried while the App is active and through Android WorkManager background tasks. Android determines when background work is allowed to run.
The local encryption described above relates to the pending password queue. It does not, by itself, establish how every network transmission, server record or backup is protected. No claim of end-to-end encryption or a specific server-side encryption method is made in this policy.
6. Server communication and recipients
The App transmits sensor telemetry and sensor-password synchronization information to the server associated with the App. These are separate data flows. The App also checks the availability of newer versions through Google Play; this involves the Google Play environment on the user's device.
Information sent to the App’s server is processed as part of the associated sensor service. Where hosting, infrastructure or technical-support providers process personal data on our behalf, they are recipients in their respective service roles. Information about a specific provider or processing arrangement can be requested using the contact details above.
If a transfer of personal data outside the European Economic Area applies, it must comply with the relevant requirements of data protection law. You may request information about the relevant transfer and safeguards where applicable.
7. Storage periods and deletion
The retention of information depends on its purpose and the system in which it is held. The local encrypted retry queue is used for pending synchronization of sensor password changes. Data held on associated servers, if it is retained, is subject to the operational needs of the sensor-related service, troubleshooting or security needs, and any applicable legal obligations. Different categories of information may therefore have different retention periods.
Where personal data is involved, you may request its deletion by writing to info@gemilabs.com with the subject “DOT Sensor data deletion request”. Please provide enough information to locate the relevant records, such as an applicable sensor identifier or context, but do not include sensor passwords in your message. Requests are assessed under applicable data protection law. Some information may need to be retained where an applicable legal obligation or other lawful exception requires it.
Removing the App from an Android device and deleting information from a remote server are separate actions. Uninstalling the App should not be treated as a request to delete any server-side records.
8. Your rights
Where the GDPR applies, and to the extent the information relates to you, you may have the right to request access to, correction or deletion of your personal data, restriction of processing, data portability, or to object to processing. You may also have the right to withdraw consent where consent is the applicable legal basis. Exercising these rights is subject to the conditions and exceptions set out in applicable law.
To submit a privacy request, email info@gemilabs.com. You also have the right to lodge a complaint with a competent data protection supervisory authority, including the Lithuanian State Data Protection Inspectorate (VDAI).
9. Changes to this policy
We may revise this Privacy Policy to reflect changes to the App, related services or legal requirements. The updated version will be made available at its public web address, with a revised date displayed above.
10. Contact
For questions concerning DOT Sensor and the processing of your information, contact GEMILABS UAB at info@gemilabs.com.