Privacy Policy and Disclosure Notice

February 24, 2026

1. DATA COLLECTED AND PURPOSES

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 & Nutrition Data (Special Category): height, weight, age, gender, activity level, goals, foods logged, nutrition values, and related inputs; (c) Visual Data: photos you upload for food analysis; (d) AI Interaction Data: prompts/messages you send in AI chat and relevant nutrition context required to generate responses; (e) Usage & Device Data: device model, operating system, IP address, locale, and app usage logs; (f) 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.

2. DATA SHARING AND INTERNATIONAL TRANSFERS

(a) AI Processing: AI chat prompts/messages, uploaded food photos, and related nutrition inputs may be processed by one or more providers: OpenAI (ChatGPT), Anthropic (Claude), and Google (Gemini); (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.

3. USER RIGHTS (KVKK Art. 11 & GDPR)

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).

4. DATA SECURITY

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.

5. CHILDREN'S PRIVACY

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.

6. DATA RETENTION

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.

7. FUTURE ADVERTISING (NOT ACTIVE)

We do not display in-app ads or share your data for ad targeting at this time. 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 your data for advertising purposes.

8. AI CONSENT FLOW

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. 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 3.

9. CONTACT US

Data Controller: ZeroCal Software. Email: [email protected]. For KVKK inquiries, you may also apply in writing to our registered address.