{"data":{"title":"Privacy Policy and Disclosure Notice","lastUpdated":"May 27, 2026","sections":[{"title":"1. DATA COLLECTED AND PURPOSES","content":"We process the following data to provide the Service: (a) Account Data: email, login identifiers (Apple/Google), and basic profile details you provide; (b) Health, Fitness & Nutrition Data: height, weight, age, gender, activity level, goals, foods logged, exercise logs, nutrition values, and related inputs; (c) Apple Health Data, if you choose to connect it: workouts, steps, walking and running distance, active energy, workout source, workout start/end time, and activity type; (d) Visual Data: photos you upload for food analysis; (e) AI Interaction Data: prompts/messages you send in AI chat and relevant nutrition context required to generate responses; (f) Usage & Device Data: device model, operating system, IP address, locale, and app usage logs; (g) Push Tokens (if enabled): to send app notifications. We use this data to operate the Service, personalize your experience, provide support, improve features, prevent fraud/abuse, and comply with legal obligations."},{"title":"2. DATA SHARING AND INTERNATIONAL TRANSFERS","content":"(a) AI Processing: AI chat prompts/messages, uploaded food photos, and related nutrition inputs may be processed by Google Gemini to provide requested AI features. Apple Health data is not sent to AI providers for food photo analysis or AI chat; (b) Subscriptions & Payments: Apple In-App Purchase and RevenueCat process subscription status and payments; (c) Sign-in Providers: Apple and Google provide authentication services; (d) Notifications: Expo services may process push tokens to deliver notifications; (e) Data Sources: We use Open Food Facts (ODbL) and USDA FoodData Central as nutrition references; (f) Service Providers: Hosting, security, analytics, and support vendors that act on our behalf; (g) Legal Requirements: We may disclose data if required by law or to protect rights. Your data may be transferred and processed outside your country. Where required, we use appropriate safeguards and/or obtain explicit consent for international transfers, including under KVKK and GDPR."},{"title":"3. APPLE HEALTH DATA","content":"Apple Health integration is optional and read-only in this version. If you connect Apple Health, Zerocal reads selected Apple Health data only after you grant permission in iOS. Zerocal uses workouts, steps, walking/running distance, and active energy to keep your exercise log, activity calories, and daily calorie balance up to date. Zerocal does not write data to Apple Health in this version. Zerocal does not store Apple Health data in iCloud. Zerocal does not use Apple Health data for advertising, tracking, marketing targeting, data broker sales, or third-party ad payloads. You can disable access at any time in the Apple Health app or iOS Settings."},{"title":"4. USER RIGHTS (KVKK Art. 11 & GDPR)","content":"You may contact us at any time to: (a) Request deletion of your data (\"Right to be Forgotten\"); (b) Obtain a copy of your data; (c) Request data in machine-readable format (JSON) for portability to another service; (d) Withdraw your consent to stop data processing. When you delete your account, we deactivate it and restrict access. We may retain or pseudonymize certain data as required by law or for legitimate purposes (e.g., security, fraud prevention, accounting)."},{"title":"5. DATA SECURITY","content":"We implement reasonable technical and organizational security measures to protect your data. No system is 100% secure. If a personal data breach occurs, we will notify you and authorities as required by applicable law."},{"title":"6. CHILDREN'S PRIVACY","content":"Zerocal is not intended for children. You must be at least 16 to use the Service. We do not knowingly collect data from children under 16. If we discover such data, we will delete it as soon as technically feasible."},{"title":"7. DATA RETENTION","content":"We retain personal data only as long as necessary to provide the Service and to meet legal, security, and compliance obligations. If you delete your account, access is restricted and some data may be retained in de-identified or pseudonymized form where permitted by law."},{"title":"8. FUTURE ADVERTISING (NOT ACTIVE)","content":"We do not display in-app ads or share your data for ad targeting at this time. Apple Health data is never used for advertising or tracking. If we introduce advertising in the future, we will update this Policy and, where required, obtain your consent or provide opt-out controls before using eligible non-HealthKit data for advertising purposes."},{"title":"9. AI CONSENT FLOW","content":"Before your first AI action (for example, sending an AI chat message or running photo analysis), we present an in-app consent prompt. If you do not consent, core app usage remains available, but AI processing actions are not performed. Apple Health data is not sent to AI providers. If consent is declined, we may ask again when you initiate a new AI action. You can always contact us to withdraw consent and request data deletion under Section 4."},{"title":"10. CONTACT US","content":"Data Controller: Zerocal Software. Email: privacy@zerocal.co. For KVKK inquiries, you may also apply in writing to our registered address."}]}}