Caloloop Privacy Policy — draft for legal review

Not ready for publication. Bracketed fields and operational statements require verification. Do not publish until the data inventory, data protection arrangements, retention, security and rights processes match this text and counsel has reviewed it for each market.

Effective date: [date]
Controller/operator: [legal name], [postal address]
Privacy contact: [email or form]
Data protection officer or representative, if applicable: [contact, or remove if not applicable]

1. Scope

This policy describes how [operator] (“we,” “us”) collects and uses personal information when you use the Caloloop app and related services. It also explains your choices and rights. Caloloop is a nutrition and wellness app; some information you provide or that we derive may be sensitive health data under applicable law.

2. Information we collect

Depending on the features you use, we may process:

• Account and sign-in information: name, email, account identifiers, authentication information and information supplied by your chosen sign-in provider, such as Apple or Google. Credentials are handled according to the applicable sign-in method.
• Profile and health-related information: birth year, gender selection, height, weight, activity level, goals and target dates, food allergies and health concerns, and preferences and units you provide.
• Tracking and content: food and meal entries, nutrients, water, weight history, exercise, created foods and meals, recipe interactions, scanned barcodes, food images and analysis results. Photos may contain incidental personal or sensitive information; avoid capturing people or unrelated details.
• Purchases and subscription information: app user identifiers, product, transaction and entitlement status, and information from Apple, Google and RevenueCat. App-store payment providers process payment details; [verify what, if any, payment information the operator receives].
• Technical and service information: information needed to operate, maintain and secure the Service, such as [verify actual IP address, device information, diagnostics, access logs, crash reports, cookies and identifiers].
• Communications: information you send to support or in a privacy request.

Some information is provided directly by you, some is received from service providers you choose, and some is generated from your entries. We may combine these categories to provide the features you request.

3. Why we use information

We use information to create and authenticate accounts; save and display records; calculate and update estimates, goals and summaries; scan and identify foods; deliver and administer subscriptions; answer requests; maintain and secure the Service; investigate misuse; and comply with applicable obligations. We also use it for [describe and verify any analytics, product improvement, marketing or additional purpose, including choices and applicable legal bases].

Calculations and food analysis use automated processing to produce estimates based on your inputs. They are not medical diagnoses or decisions with legal or similarly significant effects. [Verify whether any other automated decision-making or profiling requires a separate disclosure.] See our Terms of Service and Use for an overview of methods and limitations.

4. Legal bases where GDPR or similar law applies

We process ordinary personal data on the following bases, as applicable: performance of a contract to provide requested account and Service features; compliance with legal obligations; and our legitimate interests in securing, maintaining and administering the Service, balanced against your rights. Where we rely on consent, you may withdraw it at any time without affecting earlier lawful processing. [Counsel must verify each purpose and basis and document the balancing test where relevant.]

Health data may be special-category data. Where required, we will seek your explicit, specific consent before processing it for the purposes explained at collection, unless another valid legal condition applies. Consent is separate from acceptance of the terms and may be withdrawn through [working mechanism]. Withdrawing consent may prevent features that require the information from functioning. [Do not publish this paragraph as an operational commitment until the required consent, withdrawal and processing controls exist and have been verified.]

5. Sharing and service providers

We share information only as necessary for the purposes described here, subject to applicable law and agreements:

• Authentication: Apple and Google when you choose their sign-in services; they process information under their own policies.
• Subscriptions: Apple or Google for store billing and RevenueCat for subscription and entitlement management.
• Food image analysis: when you use image scanning, the image is sent to OpenRouter and a configured AI model provider, currently Google's Gemini model through OpenRouter, for food recognition. Review the current providers, their processing roles, retention and permitted uses before enabling the feature. [Add provider-specific notices and an explicit permission flow where required, including Apple's requirements.]
• Food databases: food names or barcodes may be sent to USDA FoodData Central and Open Food Facts to retrieve matching product or nutrition information. [Verify all transmitted fields and configurations.]
• Infrastructure and support: [identify hosting, database, email, logging and other processors, their roles and categories of information].
• Legal or safety requests: authorities, professional advisers or other parties where legally required or reasonably necessary to protect rights and safety, subject to applicable law.
• Business transfers: a prospective or actual purchaser or successor in connection with a business transaction, subject to appropriate safeguards and applicable law.

[Describe accurately any sale, sharing for cross-context behavioral advertising, advertising, analytics, model training, and associated opt-outs. Do not claim they never occur until all SDKs, providers and deployments are audited.]

6. International transfers

Your information may be processed in [countries or regions] by us or the providers listed above. Where required, we use an appropriate transfer mechanism, such as an adequacy decision or contractual safeguards, and carry out any required assessment. Contact us for information about the safeguards. [Complete only after confirming actual hosting, provider locations and transfer arrangements.]

7. Retention and deletion

We retain personal information for [specific periods or meaningful criteria by category], including account and health records, images, logs, support requests, backups and transaction records. We may retain limited information longer where required by law or reasonably necessary for security, fraud prevention, disputes or enforcement. [Confirm schedules, backup deletion cycles and provider retention.]

You may request account and associated data deletion through [working in-app path] or [working web deletion URL/contact]. We will verify requests where appropriate, explain any permitted retention, and complete them within the applicable legal period. [Implement and verify the entire deletion workflow, including associated images and service-provider data, before making this commitment.] Uninstalling the app does not by itself delete your account. Deleting an account does not automatically cancel an app-store subscription; cancel it through your store account.

8. Security

We use measures designed to protect personal information and review them as appropriate to the risks. No system can be guaranteed completely secure. [Describe only controls verified in the deployed environment, including transport, storage, access and incident management. Do not claim encryption at rest, universal encryption or third-party certifications without evidence.]

9. Your rights and choices

Depending on your location and subject to legal conditions, you may request access to, correction or deletion of your data; a copy or portability; restriction of processing; or object to certain processing. Where processing is based on consent, you may withdraw it. You may also have rights concerning automated decisions or marketing. Contact [privacy contact or request URL]; we may need to verify your identity. We respond within applicable legal time limits. You may complain to your local data protection authority, including the authority where you live, work or believe an infringement occurred.

You can manage device camera or photo permissions in device settings. Declining permissions may prevent scanning; it does not automatically delete information previously provided. [Describe verified settings or alternative paths.]

10. Children

The Service is intended for [approved age group]. We do not knowingly process children's information contrary to applicable law. [Describe age checks, parental consent and deletion procedures actually implemented for each market; align this with the terms and product behavior.]

11. Changes and contact

We may update this policy to reflect changes in the Service or legal requirements. We will provide notice or obtain consent where required. The effective date above identifies the current version.

For privacy questions or requests, contact [legal entity, postal address, privacy contact]. [Add DPO or representative details if required.]