What we collect, why, and what you can do

The Glucose Never Lies Ltd

The Glucose Never Lies Ltd (GNL) is a UK private limited company, registered in England and Wales (Company No. 16733595). We run the diabetes education website at theglucoseneverlies.com, which includes the free Grace AI education assistant at theglucoseneverlies.com/gnl-grace/, the separate registered Grace app at app.theglucoseneverlies.com, a newsletter, a podcast, and a consultancy service.

We are the data controller under UK GDPR and the Data Protection Act 2018. That means we decide how and why your data is processed, and we are responsible for looking after it correctly.

We are registered with the UK Information Commissioner’s Office (ICO) as a data controller, registration number ZC057708.

Our data protection contact is John Pemberton, GNL Founder and Director. You can reach him at john@theglucoseneverlies.com for any data-related question, request, or concern. We aim to respond within five working days for general enquiries and within 30 days for formal subject access or erasure requests (as required by UK GDPR Article 12(3)).

The personal data we hold

Newsletter subscribers (via Brevo)

When you sign up to GNL email updates, we collect your name and email address. You are added to Brevo, our newsletter delivery platform. The newsletter checkbox is ticked by default when you create a Grace account; you can untick it at any point during registration, or unsubscribe at any time afterwards with one click. We never add you to a list without your knowledge.

Grace user accounts

When you register for Grace at app.theglucoseneverlies.com, we collect your email address, display name, and audience self-identification (person with diabetes, supporter, healthcare professional, researcher, or industry). If you choose to enter a date of birth, weight, or total daily insulin dose, those values are stored in your profile.

One thing worth being clear about: those profile values are never used to silently pre-fill clinical outputs. Every time you run an educational query, you select your own inputs fresh. GNL is an educational tool, not a personalised medical service; the distinction matters.

Grace’s AI responses are generated by Anthropic’s Claude model. Your query text passes through Anthropic’s API to generate a response. Under Anthropic’s standard commercial API terms that text is not used to train their models; Anthropic holds it for a limited period for safety and abuse monitoring, then deletes it.

Email correspondence

If you email us at any GNL address (john@, anj@, phillip@, dani@theglucoseneverlies.com), that correspondence is stored in Google Workspace. We archive rather than delete as we go, so an exchange can be traced if a question or dispute arises later; the retention table below sets the outer limit of six years.

Accounts and financial records

Invoices, receipts, and VAT records contain the names, addresses, and payment details of clients and suppliers. These are kept as required by UK law.

System and security logs

Our servers record standard access logs (IP address, request type, timestamp). These are used for security monitoring and incident investigation, not for user profiling.

Our lawful basis for each type of processing

Newsletter subscription: consent

We send the newsletter because you consented, either by subscribing directly or by leaving the default-ticked checkbox in place during Grace account registration. You can withdraw consent at any time; there is a one-click unsubscribe link at the bottom of every email we send.

Grace account and service delivery: contract

Creating a Grace account forms a service agreement between you and GNL. We process your account data because it is necessary to provide that service, including authenticating your access and routing educational outputs to the correct audience type.

Logs, security, and incident traceability: legitimate interests

We have a legitimate interest in keeping our systems secure and being able to investigate problems. Server logs and the archive-only email policy both serve that interest. We have weighed this against your privacy interests and concluded the processing is proportionate.

Grace conversation content: legitimate interests

We keep Grace conversations while Grace is in beta so that a safety concern or complaint raised after the fact can be investigated. We have weighed this against your privacy interests and concluded the processing is proportionate.

Accounts data: legal obligation

UK tax and company law requires us to keep financial records for six years. This is a statutory obligation, not a choice.

Retention periods

We keep data for as long as there is a clear reason to hold it and no longer.

Our data processors

We do not sell personal data. We do not use personal data for advertising or profiling outside the GNL educational service. We share data only with the processors listed below. Each one is either UK-based, EU-based, or operates under a UK GDPR-compatible transfer mechanism (Standard Contractual Clauses or the UK International Data Transfer Addendum, where applicable).

Your rights and how to use them

Unsubscribe from the newsletter

Every GNL email contains a one-click unsubscribe link in the footer. Clicking it removes you from the list immediately; no login or form is required. The newsletter checkbox is ticked by default when you register for Grace, so if you did not untick it at the time and would now like to opt out, use the link in any email you have received.

Delete your Grace account

Registered Grace users can delete their account at any time from within the app. Deletion removes all account data from our system. If you have trouble accessing the deletion option, email john@theglucoseneverlies.com and we will complete the deletion manually within five working days.

Subject access requests

You have the right to ask us for a copy of the personal data we hold about you. Email john@theglucoseneverlies.com with the subject line “Subject access request”. We will confirm receipt and provide the information within 30 days, as required by UK GDPR Article 12(3).

Correction and erasure

If any data we hold is wrong, email us and we will correct it. If you want us to delete data that we are not required by law to keep, email us and we will do so. We cannot delete data covered by statutory retention obligations (financial records, for example), but we will tell you clearly if that applies to any part of your request.

Other rights under UK GDPR

You also have the right to restrict processing, the right to data portability, and the right to object to processing based on legitimate interests. To exercise any of these, contact john@theglucoseneverlies.com. We will respond within 30 days.

Something gone wrong? We want to know

If you believe we have handled your personal data incorrectly, please email john@theglucoseneverlies.com first. Most issues can be resolved quickly and directly, and we take every concern seriously.

You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at any time, without needing to contact us first:

Website: ico.org.uk
Telephone: 0303 123 1113
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

The ICO is the supervisory authority for UK data protection law.

What runs on this site

GNL uses Google Analytics 4 (GA4) for anonymised traffic measurement. GA4 does not log or store your IP address, and we have enabled no advertising features, so nothing here is used for ad targeting or to build a profile of you. GA4 does set first-party cookies in your browser (named _ga and _ga_<id>) to tell one visit from another; you can block or delete them in your browser settings and the site will work normally. Because the website and the registered Grace app sit on two GNL domains, GA4 is configured to recognise a visit that moves between theglucoseneverlies.com and app.theglucoseneverlies.com as one visit rather than two. That linkage is between our own two properties only; we do not follow you across anyone else’s websites.

Three third-party services load on our pages and therefore see your IP address as a normal part of serving the request: Google Fonts (typefaces, from fonts.googleapis.com and fonts.gstatic.com), AddToAny (the share buttons, from static.addtoany.com), and Google Tag Manager (which delivers the GA4 code). None is an advertising tracker, and we pass none of them your account details, email address, or any health data. AddToAny learns about a share only if you actually click a share button.

Grace, our AI education assistant, has a home on this site at theglucoseneverlies.com/gnl-grace/, and the “Ask Grace” links on our guide pages point there. Beyond the site-wide analytics described above, that page sets no cookie of its own. It does keep one small thing in your browser while you are using it: when you tick the acknowledgements on the page’s consent notices, those ticks are held in your browser’s session storage, so that you are not asked the same question twice as you move around the page. That record holds the ticks and the version of the wording you were shown, and nothing else; it carries no name and no identifier, it is never sent to us, and your browser erases it the moment you close the tab. We also count, anonymously, which of the page’s tabs and device selectors get opened: the name of the tab or selector, and nothing else. That count carries no identifier either, so it tells us that the Explorers tab was opened, never who opened it; we use it to see which parts of the page earn their place and which do not. If you send Grace a message or run an explorer, your browser requests a short-lived access token that is held in memory only and disappears when you navigate away. We also keep a one-way hash of your IP address for up to one hour, purely as a counter that lets us rate-limit abuse and cap running costs; it is not used to identify you or to build a profile. We use no advertising cookies on that page and do not track your behaviour across other sites. Registered Grace accounts on the separate app at app.theglucoseneverlies.com are covered under “Grace user accounts” above.

Grace can also read her replies aloud. If you press the Listen button, the text of that reply is sent to ElevenLabs, our voice processor in the United States, which turns it into speech and sends the audio back to your browser to play. Only the text of the reply is sent: no name, no email address and no account identifier goes with it, and nothing is sent unless you press Listen.

If you use the microphone, the sound of your voice is handled by your browser, not by us. It becomes text in the message box, where you can read it and change it, and only that text reaches us, and only when you press send.

The microphone works differently from Listen, and ElevenLabs is not involved in it at all. When you press the microphone, your browser’s own speech recognition turns what you say into text; your browser will ask your permission the first time. Depending on which browser you use, it may do this on your device, or it may send the sound to the company that makes the browser, for example Google for Chrome or Apple for Safari. That step is between you and your browser’s maker, under their privacy policy rather than ours. We do not choose it, we cannot see it, and we cannot tell you how long they keep anything, because it never passes through us. What reaches us is the text alone, and only when you press send. If you would rather not use it, you can type instead, or use the dictation built into your own phone or computer, which is governed by your device’s settings rather than by this page.

What Grace does keep is the conversation itself. The messages you send and the replies Grace returns are stored on our server while Grace is in beta; a deletion schedule has not yet been switched on, and when it is, this notice will state it. We keep them for one reason: if a safety concern or a complaint is raised about something Grace said, we need to be able to look at what was actually said. A family member or a clinician may not connect a concern back to a Grace conversation until weeks or months later, which is why the record needs to reach back weeks or months rather than a few days. Our lawful basis is legitimate interests (UK GDPR Article 6(1)(f)): safety and quality assurance for an educational tool covering a clinical topic. We have weighed this against your privacy interests and concluded the processing is proportionate; the content is already held in order to deliver the service, it is not used for profiling, marketing, or model training, and the true position is stated here plainly rather than dressed as a schedule.

No third-party advertising trackers are used on any GNL page.

What we count, and why

We keep a small number of counts so that we can tell which of our guides and which parts of Grace are actually being used, and put our effort where it does the most good. Everything in the table below is set out in full in the sections above; this is the summary in one place.

None of it identifies you. None of these records carries a name, an email address, an account, a cookie or an identifier of any kind, so none of them can be traced back to you, and none can be used to tie two visits together. We do not use any of it for advertising, we do not sell it, and we do not share it.

All of these reach our own server in London and are stored there as counts, except your consent ticks, which never leave your browser at all. Beyond these, the only other measurement on the site is Google Analytics, described under “Cookies and tracking” above.

Your name never leaves your browser

Some guide pages end with a short quiz, and a passing score generates a certificate of completion. To put your name on that certificate, the quiz asks you to type a name and, optionally, a workplace.

Those values are handled entirely inside your own browser. They are used to draw the certificate on screen so that you can save or print it, and they are never sent to us: no name, no workplace and no answers reach a GNL server. Nothing is written to your browser’s storage either, so closing the tab clears it.

We do count how the quizzes are going, and we do it anonymously. When you finish a quiz, our server records three things: which guide it was, your score, and the mark it was out of. That is the whole record. It carries no name, no workplace, no answers, no account, no cookie, no IP address and no identifier of any kind, and it holds nothing that could be joined back to you or used to tie two attempts together. So we can see that a guide was attempted and how people did on it; we cannot see who took it. We use it for one purpose: to find out which guides are teaching well and which need rewriting. It is never used for advertising, never sold and never shared. Because the record identifies nobody, it is not personal data, and no data-protection rights attach to it; we are telling you because you should know what leaves the page, not because the law requires it. To stop the counter being flooded, our server also runs a brief rate-limit check on the way in, using a one-way hash of your IP address that is thrown away after a minute; that check is kept separate from the score record, and nothing from it is stored alongside it.

The certificate records completion of our educational material; it is not an accredited or regulated qualification.

The Learn with Grace private beta has ended

We ran a small invitation-only beta of an educational product called Learn with Grace at a private cohort URL. That beta closed on 2 June 2026. The cohort URL no longer serves it and now redirects to our public guides at theglucoseneverlies.com/gnl-guides/. We collect nothing through it any more.

The beta was deliberately light-touch. Everything it recorded about a tester (a pseudonymous handle, relationship to diabetes, condition track, device type, a self-rated knowledge score, optional placement-test answers, and per-module scores) was written to that person’s own browser storage and never sent to us; we never held a copy. It asked for no clinical detail, so it processed no special-category health data. If you took part and want to clear what may still sit on your own device, clear your browser’s site data for theglucoseneverlies.com.

The one thing that did reach us is free-text feedback testers chose to send. Those messages sit in our john@theglucoseneverlies.com inbox and are retained under the email-archive policy described above. If you sent us Learn with Grace feedback and would like it deleted, email john@theglucoseneverlies.com and we will remove it.

When this notice changes

We review this notice at least every quarter and update it when our data practices change. The effective date at the foot of this page shows when the current version came into force. If we make a material change, such as adding a new processor or a new category of data, we will notify registered Grace users by email before the change takes effect.

If you would like to read the more detailed internal data-protection policy (written for insurers and auditors rather than for users), email john@theglucoseneverlies.com and we will send a copy.

Recent changes