Last Updated: October 26, 2026
Version 1.2
Mirri Diabetes LLC (“Mirri,” “we,” “us,” or “our”) provides Mirri Cloud. Mirri Cloud is two things that work together:
This Privacy Policy explains what information Mirri Cloud handles, what we can and cannot see, and the choices you have. Please read it together with the Mirri Cloud Terms of Service, the Mirri Cloud Consumer Health Data Privacy Policy and, if you use MIRRI One, the MIRRI One Privacy Policy. This Privacy Policy replaces all earlier versions.
Mirri Cloud is offered to individuals for research and data analysis: reading, arranging, and analyzing their own data and data that other people choose to share with them. Clinical use is not offered yet.
Mirri is not a HIPAA covered entity or business associate. Mirri Cloud is not offered to, and may not be used by, a HIPAA covered entity or business associate in any way that would cause Mirri to create, receive, maintain, or transmit protected health information on its behalf. Mirri Cloud is offered as a non-HIPAA service.
We handle information in accordance with this Policy and applicable privacy laws, including the Federal Trade Commission’s Health Breach Notification Rule; the Washington My Health My Data Act; the Nevada Consumer Health Data Privacy Law; the Connecticut Data Privacy Act; the Indiana Consumer Data Protection Act; the California Consumer Privacy Act (as amended by the California Privacy Rights Act); and similar state laws, where they apply.
Sealed on your phone. MIRRI One seals each entry — for example a glucose reading, an insulin dose, a meal, or a workout — on your phone before it is uploaded. Our servers store the sealed entry and are designed to hold no key that can open it, and Mirri Cloud is designed so that our staff and our service providers have no such key either. No health information leaves your device except in sealed form; what our servers read is the routing information listed here and nothing else.
Opened only on devices you approve. Your record’s keys stay on your devices. Copies of them are stored only in forms that your devices or your Recovery Code can open. A web browser that opens Mirri Cloud makes its own key, which is designed never to leave that browser, and it can read a record (shown in the apps as your data) only after a phone that holds the record’s keys approves it (by scanning the code the browser shows); the same is true of any other device you add. A new phone needs your Recovery Code, which only you hold. Mirri Cloud is designed so that entries are opened on your phone or in your browser, never on our servers, and so that we never hold your Recovery Code or any key that opens your data. On iPhone, MIRRI One also saves your Recovery Code in your iCloud Keychain, if iCloud Keychain is on, unless you turn that off on the Recovery Code screen, so a new iPhone on the same Apple Account can open your data without you typing it, and anyone who can sign in to your Apple Account on a device that knows your passcode could use it. If you remove a lost phone, it is signed out of Mirri Cloud and our servers refuse its requests, and the phone you remove it with changes the record’s data key so that the lost phone cannot open entries made afterwards; it does not undo what was already on that phone. Your phones are designed to refuse a key from our servers that does not match what they already hold.
What our servers can read. To store and deliver sealed entries, our servers need some information in readable form, which we call “routing information.” For each entry it is: the record the entry belongs to; a slot number, one of sixteen numbered slots that every record has, which your phone assigns to your kinds of information at random when it creates your record and keeps only in sealed form, so that the number does not tell us what kind of information the slot holds; the two-week period the entry falls in; its size, rounded up to one of five fixed sizes; the version of your record’s keys it was sealed under; the device that wrote it; and when our servers received it. Everything else about an entry — what you recorded, its kind, the time it happened, your time zone, and whether it changes or deletes an earlier entry — is sealed with the entry. Routing information is designed so that our servers cannot tell what you recorded, which kinds of information you record, when within a two-week period the things you recorded happened, or what you later changed or deleted.
What our servers can still see. Our servers can still see: which account holds which record, and that account’s email address; the devices that can read a record, with their public keys and a platform word such as “iPhone,” “Android,” or “Browser”; who follows which record, and since when; how many entries each record receives and when they arrive, and how many arrive in each slot, which can show a pattern of use, because one slot (usually your sensor’s readings) is busier than the others; the slot number and padded size of each entry; when your record’s keys change or a Follower’s sealed keys are replaced, which happens when you change or end a Follower’s access; which two-week periods have entries; the deletion, account-closure, and consent records described in Section 9; and the security log of who read which record and when, described in Section 4(g). Apple and Google, which deliver our wake-ups to MIRRI One, can see when each wake-up is sent to a device and that it is for MIRRI One. MIRRI One seals your cycle and other reproductive-health information on your phone like every other kind, and Mirri Cloud stores it only in that sealed form; because the slot number is assigned at random for each record, our servers cannot tell which entries are cycle entries.
Background refresh pings. MIRRI One has a “Background refresh pings” switch for Mirri Cloud, which is off unless you turn it on (the switch is shown only when MIRRI One’s glucose features are on). While it is on, your phone marks its glucose uploads, and our servers use those marks to send a silent wake-up to your Followers’ phones at your sensor’s cadence, which your phone declares, so that their view stays fresh, and to ask a Live Activity that shows your readings to redraw. Our servers then learn which slot paces the wake-ups and the cadence your phone declares, never a value. When you turn the switch off, your phone marks no upload and declares no cadence, and our servers pace no wake-ups for your record.
Limits. This protection depends on MIRRI One and the Mirri Cloud website working as designed. No method of encryption, transmission, or storage is completely secure, and we do not guarantee that our security measures cannot be circumvented or that security will never fail.
a. Account information. Your email address and, if you give one, a display name for your account. You log in by entering your email address and a one-time code that we send to it; if there is no account for that address, the code creates one, and we do not ask for your phone number. Your Mirri Cloud account is the same account you use for Mirri Cloud in MIRRI One. Our sign-in system also keeps a log of sign-in events and the sessions you have open, which can include your email address, IP address, and app or browser details.
b. Record details. MIRRI One keeps your record’s name only in sealed form: in the sealed list of your record’s slots, which only your own devices can open, and sealed separately to each Follower’s device. Our servers store it in those sealed forms, which are designed so that our servers cannot read it.
c. Sealed entries. Nothing is uploaded until you tap “Agree and turn on” on MIRRI One’s “Turn on Mirri Cloud” screen (described in Section 7 of the Mirri Cloud Consumer Health Data Privacy Policy). From then on, MIRRI One keeps your record in Mirri Cloud: it seals the kinds of health information it syncs and uploads them in the sealed form described in Section 3, whether or not anyone follows your record yet. You choose which kinds each Follower may read. The kinds of information a record can hold are listed in the Mirri Cloud Consumer Health Data Privacy Policy. MIRRI One does not send your notes, your photos, or your conversations with Iris to Mirri Cloud. It seals your cycle and other reproductive-health information on your phone like every other kind and uploads it in that sealed form; a Follower receives it only if you turn on the Cycle category for that Follower, which is off by default and asks for its own confirmation.
d. Devices and keys. For each phone, tablet, or browser that can read a record: its platform, shown only as a word such as “iPhone,” “Android,” or “Browser”; its public key; and when it was last seen. Your record’s keys are stored only in the sealed forms described in Section 3.
e. Followers and invitations. Who follows which record, and since when; the name you give each online connection, which is kept only in sealed form that our servers cannot read (a Follower’s own nickname for it stays on their device); for each Follower, sixteen sealed keys, one for each slot of the record, which look alike to us whether or not they open anything, so that we cannot tell which kinds of information you chose to show them; a sealed copy of what you granted each Follower, which only your own devices can open; when each Follower was confirmed and when their access ended; and when each Follower’s device last opened the record. Every Follower’s devices receive every sealed entry of the record, and can open only the slots you chose for them. A link you send to someone who is not with you is an invitation: it can be used only once and expires within 24 hours, and we store its code only in scrambled (hashed) form.
f. Notification tokens. If you use MIRRI One, we store your device’s Apple or Google push token, with when it was registered and when notices were delivered, and, if background refresh pings are on, the cadence your phone declares for them. Our notices carry no health information: they only wake MIRRI One to sync, tell it to fetch and open new entries itself, or ask it to redraw what it already shows. On a Follower’s phone, MIRRI One can also show reminders and Lock Screen widgets about the followed person’s recent doses, such as when a prebolus time has passed; that phone makes them from the entries it opened, and our servers do not send them.
g. Security records and technical information. Our servers keep a security and privacy log of events such as a Follower’s reads of a record (which record, when, and how many entries, never which days), refused requests, device approvals and removals, deletions, and changes our staff make to key tables. It is designed to contain no health content, and an account can read its own recent events. When a request is refused, a shortened form of the IP address it came from (the network, not the device) is recorded in that log. We use IP addresses only for rate limiting and security, and we keep them only in the shortened or scrambled forms described here. Our hosting provider also keeps short-lived technical logs of requests to our servers, which can include IP addresses and browser or app details; we count those logs as Section 4(l) describes. Our servers are designed not to write the contents of requests and responses to logs.
h. Information kept in your browser. The Mirri Cloud website keeps some information in your own browser: your browser’s key and sign-in session, which by default stay until you choose to forget the browser, with a fresh sign-in every 90 days or at another interval you choose between 30 and 180 days; in guest mode, for a shared or borrowed computer, the key and session are kept only for that tab and are removed when you close it, sign out, or leave it unused for 12 hours (or a period you choose between 5 minutes and 24 hours); your birth year, which stays there and is not sent to us; and a few settings, such as the theme. Keys that open entries are held only in memory while a page is open. The Mirri Cloud website’s own code does not set cookies; see Section 7 for a security cookie Cloudflare may use.
i. Offline Sharing. When you receive by Offline Sharing, the days arrive through your browser’s camera from the QR code on the sharer’s phone screen and are opened in that browser tab’s memory. Nothing about Offline Sharing is sent to us, and the days are gone when you end the Offline Sharing, reload the page, or close the tab.
j. Consent records. That you turned Mirri Cloud on, accepted a version of these documents, or accepted a Follower relationship, with the version, your platform, the time, and, for a Follower relationship, which one it was. They contain no health information.
k. Requests you make. Deletion, account-closure, and privacy requests, with their times.
l. Operating counts. To check that Mirri Cloud is working and stays within its hosting plan, our servers keep a small set of service-wide numbers. For each day, they keep these totals and no others: how much storage the database uses, how many accounts exist, how many requests our server functions answered and how many of those failed, how many requests were refused, whether our scheduled jobs failed and how long the slowest took, how many alert emails we sent, and how many days remain before our domain name must be renewed. While a check finds a problem, they also keep the check’s name, a count, and when the problem started and ended. These numbers are kept for the service as a whole, never for an account, record, or device, and none of them contains a health value, an email address, or an IP address. We work out the request totals by counting our hosting provider’s technical request logs (Section 4(g)) by server function and response; we read nothing else from those logs. When few people use Mirri Cloud, a day’s total can come close to one person’s activity that day. We therefore handle these totals as deidentified data, as the Washington My Health My Data Act (RCW 19.373.010), Nevada law (NRS Chapter 603A), the Connecticut Data Privacy Act (Conn. Gen. Stat. § 42-515), and the California Consumer Privacy Act (Cal. Civ. Code § 1798.140) use that term: we keep them only in this service-wide form, we take reasonable measures so that they cannot be associated with any person, we commit publicly here not to try to reidentify anyone from them, and the service providers that process them for us (Section 7) may use them only to provide services to us. Our staff see them in alert emails, which Resend delivers to us, and in our internal operations dashboard, which reads them from Mirri Cloud through a single connection that logs every read.
We use information to: provide Mirri Cloud; sign you in; keep records in sync between your devices; deliver sealed entries to the devices and Followers you approve; send the notices described in Section 4(f); secure Mirri Cloud and investigate misuse; check that Mirri Cloud is working and within its hosting plan, and alert our staff when it is not (Section 4(l)); carry out deletion and other requests; and comply with law.
We do not use your information for advertising or data mining, and we do not sell it. We cannot use the content of your entries for any purpose, because we cannot open them, and we do not use routing information to draw conclusions about anyone’s health.
People you share with are chosen by you and are not vetted, controlled, or supervised by Mirri. What they do with information they have opened is their responsibility under the Mirri Cloud Terms of Service.
We use a small number of service providers to run Mirri Cloud. They process information on our behalf under contracts that require them to protect it at least as well as this Policy does and to use it only to provide services to us. We do not share personal information with third parties for their own marketing.
We do not sell personal information or health information, and we do not share it for cross-context behavioral advertising, as those terms are defined by applicable law. The Mirri Cloud website’s own code includes no analytics, advertising, or session-recording tools, and it loads no scripts or fonts from other companies. Cloudflare adds a small script to the pages it delivers to check for automated traffic; the website’s security settings stop it from running. We honor the Global Privacy Control and other recognized opt-out preference signals where required by law. We do not allow third parties to collect personal information about your online activities over time and across different websites or online services through Mirri Cloud, and because Mirri Cloud does no such tracking there is nothing for a browser’s “Do Not Track” signal to stop. We do not collect, use, or sell personal information from Mirri Cloud to train large language models.
We keep information only as long as needed to provide Mirri Cloud and as required for legal, security, and record-keeping purposes.
Starting over. If you lose every device that can open your record and your Recovery Code, no one can open your entries, including us. Start Over in MIRRI One then deletes the unreadable entries, keys, devices, and Follower access at once, and your record begins again on your phone.
Records from before this version. Our servers cannot move entries into the new sealed form, because they cannot open them, so on October 24, 2026 we removed every entry, sharing key, and wake-up record Mirri Cloud held, and cleared the readable record names, keeping accounts, records, devices, and Followers. The first time you open the version of MIRRI One that seals routing information, your phone re-uploads your record from the history it holds, in the sealed form described in Section 3, and shares again with each Follower the categories you had chosen; a Follower whose choices your phone cannot carry across is marked for you to share with again. Until your phone has shared again with a Follower, our servers keep the list of kinds you had allowed that Follower under the earlier version, readable only to your account, so that your phone can carry it across, and they remove it when your phone shares again. Your Followers’ phones refill their short-term copies on their next sync. Our hosting provider’s routine backups from before that date, which hold the earlier routing information, expire within 30 days of it.
How to delete. In MIRRI One, open the Menu, then Mirri Cloud, then Settings, then Delete & close account. Or go to cloud.mirridiabetes.com/delete-my-data and sign in with a code sent to your email address. The deletion page stays available even if we pause the rest of the Mirri Cloud website.
What deletion cannot do. Deletion cannot recall information that a Follower has already opened on their own device, including the short-term copy MIRRI One keeps for a person someone follows, or anything a Follower or the recipient of Offline Sharing has saved, written down, or photographed.
We use administrative, technical, and physical safeguards designed to protect information, including sealing entries on your phone so that our servers cannot open them; keeping health tables out of reach of the database’s public interface; access controls on every table; limits on how often each account can call each function; a log of changes our staff make to key tables; and keeping the contents of requests out of our logs. These safeguards are designed to protect information but are not a guarantee; no application, server, or transmission method is 100% secure, and we do not warrant that our safeguards will prevent every incident.
If a breach of the security of health information occurs — including any acquisition, access, use, or disclosure of information without authorization — we will notify affected individuals and applicable authorities (including the Federal Trade Commission, prominent media where required, and applicable state authorities such as the Indiana Attorney General), without unreasonable delay and no later than 60 days after discovery, as required by law, including the FTC Health Breach Notification Rule and applicable state breach-notification and consumer-health-privacy laws. Our notice will describe, to the extent required, what happened and when, the categories of information involved, steps you can take, what we are doing in response, and how to contact us.
Your choices. In MIRRI One you can turn Mirri Cloud on, choose your Followers and what each of them may read, end a Follower’s access, turn background refresh pings on or off, remove a device, delete a record, and close your account. On the Mirri Cloud website you can stop following a record, use guest mode, forget the browser, and delete your data.
Your rights. Depending on where you live, you may have the right to: confirm whether we process your information and access it; correct it; delete it; obtain a portable copy; withdraw consent to the processing of your health information; opt out of any sale, sharing for targeted advertising, or certain profiling; limit the use of sensitive personal information; and appeal a decision we make about your request. We do not discriminate against you for exercising these rights.
Entries we cannot open. Because Mirri Cloud is designed so that we cannot open your entries, we cannot give you a readable copy of them. You can read them on your own approved devices, in MIRRI One and on the Mirri Cloud website, and we can give you the other information we hold about you, including the list of third parties described in the U.S. State Health Privacy Notice.
How to exercise them. Contact us at support@mirridiabetes.com, or delete your data as described in Section 9. We will confirm receipt within 10 days and respond within 45 days (extendable once by an additional 45 days with notice). We take reasonable steps to verify your identity before acting, and we accept requests from authorized agents with proof of authorization. If we deny your request, you may appeal by replying to our decision or contacting support@mirridiabetes.com; if your appeal is denied, you may contact your state Attorney General.
State privacy rights. Residents of Washington, Nevada, Connecticut, California, Virginia, Texas, Indiana, and other states should also read our U.S. State Health Privacy Notice, which gives additional disclosures and rights for health information in those and other states, and which we apply to everyone in the United States.
Mirri Cloud is not directed to children under 13, and a person under 13 may not create a Mirri Cloud account or record. MIRRI One and the Mirri Cloud website ask for your birth year before you sign in or give an email address, and keep that year on your device (on the website, in your browser; it is not sent to us): if you are 13 to 17, they ask you to confirm that a parent or guardian knows you are using Mirri Cloud and agrees before you continue, and if you are under 13, they do not let you sign in, no account or record is made, and nothing is uploaded. Mirri Cloud does not create or hold records that a parent or guardian keeps for a child.
If you are under 18 (or the age of majority where you live), use Mirri Cloud only with the permission of your parent or legal guardian. Plans for Mirri Cloud are offered to adults; if you are under 18, your parent or guardian buys any plan for you through the Apple App Store or Google Play. We do not knowingly collect personal information from a child under 13; if we learn that we have, we will delete it. If you believe a child’s information has reached Mirri Cloud, contact us at support@mirridiabetes.com and we will address it.
We treat the health information in Mirri Cloud, and the routing information and record details that relate to it, as “consumer health data” under laws such as the Washington My Health My Data Act and similar state laws. We do not sell consumer health data, we do not use it for advertising, and we do not use geofencing. For the full disclosures, see the Mirri Cloud Consumer Health Data Privacy Policy, which we link from our homepage and from the Mirri Cloud website.
Mirri Cloud is a tool for research and data analysis by the people who use it. Mirri does not use the information in Mirri Cloud for its own research. If Mirri ever invites you to share your record for a study, it will ask for your separate, explicit permission first. If you share your record with a researcher, they are a Follower like any other: you choose what they may read, and you can end their access at any time. Their research is theirs, not Mirri’s, and Mirri does not oversee it.
Mirri Cloud is intended for use in the United States, and we operate it and store information in the United States. We do not offer Mirri Cloud to individuals in the European Economic Area or the United Kingdom. If you use Mirri Cloud from outside the United States, you understand that information will be processed in the United States.
We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date and, for material changes, provide notice as required by law (for example, in MIRRI One, on the Mirri Cloud website, or by email). If a change materially affects how we collect, use, or share health information, we will obtain any consent required by law before it applies to you.
Legal process and government requests. We disclose information only when valid legal process (such as a subpoena, court order, or search warrant) requires it, or when the law otherwise requires us to. We cannot produce the contents of your entries, because Mirri Cloud is designed so that we hold no key that opens them. Our servers are designed not to hold which kinds of information you record, when within a two-week period the things you recorded happened, your time zone, or what you changed or deleted, so we cannot produce those either; what we could be required to produce is limited to the information our servers can read, described in Sections 3 and 4. We review every request for scope and validity, we object to requests that are overbroad or that seek more than the law requires, and we provide only what the request lawfully requires. Unless we are legally prohibited from doing so, we tell you about a request for your information before we respond, so that you can object. We do not voluntarily disclose information to any government body, and we treat requests concerning reproductive or sexual health exactly as we treat every other request; Cycle and other reproductive-health information is held, like every other kind, only in sealed form that we cannot open, and our servers cannot tell which entries are cycle entries, so we have no readable reproductive-health information to produce. We keep a record of each request we receive and how we answered it.
If you have questions about this Privacy Policy or our privacy practices, or to exercise your rights, contact us at:
Mirri Diabetes LLC
300 Main St., Ste. 900
Lafayette, IN 47901, United States