PRIVACY POLICY

1. INFORMATION WE COLLECT

1.1 Personal Information

When you create an account, we collect:

• Email address (required for account creation and communication)
• Name (required for account creation)
• Password (encrypted using bcrypt with 12 rounds - never stored in plain text)
• Preferred language (English, Spanish, etc.)
• Device information (device name, IP address, user agent for security)
• Platform type (Android, iOS, or Web)
• Account verification status

1.2 Dietary and Nutrition Tracking Data

To provide our kidney-friendly nutrition tracking service, we collect:

• Daily nutrition intake records (calories, protein, sodium, potassium, phosphorus, etc.)
• Recipes and meals you create, edit, or consume
• Ingredients and their nutritional values
• Serving sizes and meal portions
• Dietary limit settings (minimum/maximum nutrient targets customized for kidney health)
• Custom ingredients you create
• Eating history organized by date
• Favorite recipes list
• Recipe notes, cooking instructions, and images
• Recipe categories you create

1.3 Subscription and Payment Data

We collect:

• Subscription plan type (1-month, 3-month, 6-month, or 12-month)
• Subscription status (active, expired, grace period)
• Purchase dates, renewal dates, and expiration dates
• Auto-renewal preferences
• BUX wallet balance and transaction history
• BUX package purchases (100, 250, 600, 1400, 4000 BUX)
• Payment platform (Google Play, Apple App Store)
• Original transaction IDs for purchase verification
• Purchase receipts (encrypted at application level)
• Free trial status

Payment processing is handled securely by:

• Google Play Billing (Android) - Privacy Policy: https://policies.google.com/privacy
• Apple App Store (iOS) - Privacy Policy: https://www.apple.com/legal/privacy/

We do NOT store your credit card numbers, CVV codes, or complete payment credentials. Payment data is processed securely by the respective payment platforms.

1.4 Usage and Technical Data

We automatically collect:

• Session data (login times, session duration, device fingerprint)
• IP addresses (normalized for security and fraud prevention)
• App feature usage (which features you use, when, and how often)
• API request logs (for troubleshooting and performance optimization)
• Error logs and crash reports (to fix bugs)
• Session cookies (for authentication only)

1.5 AI Feature Usage Data

When you use our AI-powered features, we process:

• Recipe text you input for cleaning and parsing
• Ingredients you ask to match against nutritional database
• Unstructured recipe text for language detection
• Requests for recipe image generation

This data is processed temporarily and is NOT used to train third-party AI models or shared for advertising.

1.6 Data We Do NOT Collect

We explicitly DO NOT collect:

• Third-party analytics or behavioral tracking (NO Google Analytics, Firebase Analytics, Facebook Pixel, Mixpanel, Amplitude, etc.)
• Location data, GPS coordinates, or geolocation
• Contacts, address book, or phone numbers
• Photos or media files from your device (except recipe images you explicitly upload)
• Biometric data (fingerprints, face ID, etc.)
• Health data from other apps or wearable devices
• Social media profiles, connections, or activity
• Browsing history outside the app
• Advertising IDs or cross-app tracking identifiers

2. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes ONLY:

2.1 Service Delivery

• To create, maintain, and secure your user account
• To provide nutritional tracking and meal planning features
• To store and sync your recipes, ingredients, and eating history across devices
• To calculate daily nutrient intake and compare against your dietary limits
• To manage your BUX wallet, subscriptions, and in-app purchases
• To enable AI features (recipe cleaning, ingredient matching, image generation)
• To provide access to the USDA nutritional database

2.2 Communication (Transactional Only)

• To send account verification emails (24-hour token expiry)
• To send password reset instructions (1-hour token expiry)
• To notify you about subscription renewals, expiration, and grace periods
• To send BUX wallet notifications:
  • Inactivity warnings (up to 14 days before wallet cleanup after 6 months of no subscription)
• To send critical security alerts (suspicious login attempts, device changes)
• To respond to support requests

We do NOT send marketing emails or promotional communications. All emails are transactional and necessary for service operation.

2.3 Security and Fraud Prevention

• To authenticate your identity using device fingerprinting
• To prevent unauthorized access and account takeover
• To detect and prevent fraudulent transactions and refund abuse
• To track suspicious activities and security incidents
• To enforce our Terms of Service and prevent abuse
• To implement platform locks (preventing subscription platform switching after first purchase)

2.4 Internal Service Improvement (No External Analytics)

• To analyze usage patterns internally (without third-party analytics tools)
• To identify and fix bugs and technical issues
• To optimize app performance and server response times
• To improve existing features based on usage data
• To troubleshoot customer support issues

2.5 Legal Compliance and Protection

• To comply with legal obligations (tax reporting, financial regulations)
• To respond to lawful requests from government authorities
• To enforce our legal rights and defend against legal claims
• To investigate violations of our Terms of Service

3. DATA SHARING AND DISCLOSURE

3.1 We NEVER Sell Your Data

We NEVER sell, rent, lease, or trade your personal information to third parties for any purpose, including marketing, advertising, or data brokerage.

3.2 Third-Party Service Providers (Data Processors)

We share limited data with the following trusted service providers who are contractually bound to protect your data:

All third-party processors:

• Are contractually obligated to protect your data
• Use data ONLY for the specified purposes
• Must comply with GDPR, CCPA, and applicable data protection laws
• Cannot share or sell your data to other parties

3.3 Legal Requirements and Law Enforcement

We may disclose your information ONLY when legally required:

• Compliance with court orders, subpoenas, or legal processes
• Investigation of fraud, security violations, or illegal activities
• Protection of our legal rights and property
• Emergency situations involving imminent harm or danger to persons

We will notify you of such requests unless prohibited by law.

3.4 Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets:

• Your data may be transferred to the acquiring entity
• We will notify you at least 30 days in advance via email
• You will have the right to delete your account before the transfer
• The new entity must honor this Privacy Policy

3.5 Aggregated and Anonymized Data

We may create anonymized, aggregated statistics (e.g., "50% of users track sodium intake") that cannot identify individuals. This data may be used for:

• Internal research and development
• Public reports or blog posts
• Service improvement

3.6 No Cross-Platform Data Sharing

We do NOT share your data:

• With social media platforms
• With advertising networks
• With data brokers or marketing companies
• For behavioral profiling or targeted advertising
• Across different apps or services

4. DATA RETENTION AND DELETION

4.1 Active Account Data

We retain your data as long as your account is active to provide continuous service.

4.2 Account Deletion

If you delete your account:

• Personal information (name, email, password) is permanently deleted within 30 days
• Dietary data (recipes, eating history) is permanently deleted within 30 days
• Subscription and payment records are permanently deleted within 30 days
• BUX wallet transaction history is permanently deleted within 30 days
• All sessions and authentication tokens are immediately invalidated
• Anonymized usage statistics may be retained indefinitely for service improvement

4.3 Session Data Retention

• Unverified sessions (before email verification): Automatically deleted after 1 hour
• Normal sessions: Expire after 30 days of inactivity
• Expired sessions: Automatically purged every 6 hours by scheduled cleanup job
• Maximum concurrent sessions: 10 per user (oldest sessions auto-deleted)

4.4 Verification and Security Tokens

• Email verification tokens: Expire and are deleted after 24 hours
• Password reset tokens: Expire and are deleted after 1 hour
• Expired tokens are automatically purged from the database

4.5 BUX Wallet and Subscription Data

• Active BUX transactions: Retained while account is active for wallet balance accuracy
• Subscription history: Retained while account is active; deleted when account is deleted
• Wallet inactivity cleanup: After 6 months without active subscription:
  • You will receive email warnings up to 14 days before cleanup
  • All remaining BUX balance will be zeroed after 6 months
  • Transaction history is preserved for records
• Expired subscriptions: Records retained for billing history
• Important: Without an active subscription (after grace period expires), you will not be able to use the app. Please renew your subscription to continue using the service.

4.6 Logs and Technical Data

• Application logs: Retained for 90 days (debugging and security monitoring)
• Security incident logs: Retained for 1 year
• Error logs and crash reports: Retained for 90 days
• Database backups: Retained for 90 days (disaster recovery)

4.7 Email Communication Records

• Transactional emails (sent): Logs retained for 30 days
• Support conversations: Retained for 2 years or until issue resolution

4.8 Legal Hold

If your data is subject to legal proceedings, investigations, or disputes, retention periods may be extended as required by law.

5. DATA SECURITY MEASURES

We implement industry-leading security practices to protect your data:

5.1 Encryption

• Passwords: Encrypted using bcrypt with 12 rounds (OWASP 2024 recommended standard)
• Data in Transit: All communications use HTTPS with TLS 1.2+ encryption
• Data at Rest: Database encryption enabled on our servers
• Session Cookies: Secured with HttpOnly, Secure, and SameSite=Strict flags
• Payment Receipts: Encrypted at application level before database storage
• Password Reset/Verification Tokens: Cryptographically secure random tokens (32-byte hex)

5.2 Authentication and Access Controls

• Session-Based Authentication: Secure cookie-based sessions (30-day expiry)
• Device Fingerprinting: SHA256 hash of device name + user agent for anomaly detection
• Multi-IP Tracking: Automatic whitelisting of trusted IPs with IPv4/IPv6 normalization
• Role-Based Access Control (RBAC): Separate permissions for users and admins
• Admin Security: Admin accounts require device fingerprint verification and additional two-factor authentication
• Internal API Key: 64-character hex key for service-to-service communication (constant-time comparison)
• Max Login Attempts: Rate limiting to prevent brute force attacks

5.3 Database Security

• Transaction Isolation: SERIALIZABLE isolation level for critical operations (wallet, subscriptions)
• Row-Level Locking: FOR UPDATE locks prevent race conditions during concurrent transactions
• SQL Injection Prevention: Prepared statements and parameterized queries exclusively
• Input Validation: Express-validator for all user inputs
• Idempotency Keys: Prevent duplicate purchases and transactions

5.4 Network Security

• DDoS Protection: Rate limiting on API endpoints
• IP Whitelisting: Trusted IPs automatically added to session records
• CORS Configuration: Restricted cross-origin requests
• Proxy Trust: Properly configured for reverse proxy environments
• TLS Enforcement: HTTPS required in production (HSTS headers)

5.5 Monitoring and Incident Response

• Security Incident Logging: Suspicious activities logged in security_incidents table
• Automated Session Cleanup: Every 6 hours to remove expired/stale sessions
• Refund Abuse Tracking: Automated detection of fraudulent refund patterns
• Constant-Time Comparison: For tokens and sensitive comparisons (prevents timing attacks)
• Fingerprint Mismatch Handling: Immediate session deletion on device mismatch
• Background Jobs: Scheduled tasks for subscription expiry checks and inactive wallet cleanup

5.6 Application Security

• Password Requirements: Minimum 8 characters with uppercase, lowercase, and numbers
• Email Normalization: Prevents duplicate accounts with email variations
• Platform Lock: Prevents subscription platform switching after first purchase
• Deduplication: Unique constraints and idempotency checks prevent duplicate operations
• Graceful Shutdown: Proper cleanup of connections and background jobs

5.7 Operational Security

• Regular Security Audits: Periodic vulnerability assessments
• Dependency Updates: Regular updates to address security vulnerabilities
• Error Handling: Sanitized error messages (no sensitive data exposure)
• Logging: Structured logging with sensitive data redaction
• Backup Security: Encrypted backups with restricted access

6. YOUR PRIVACY RIGHTS

Depending on your jurisdiction, you have the following rights:

6.1 Right to Access (GDPR Art. 15, CCPA, LGPD)

• Request a copy of all personal data we hold about you
• Receive data in a structured, machine-readable format (JSON or CSV)
• Understand how we collect, use, and share your data

6.2 Right to Rectification (GDPR Art. 16, CCPA, LGPD)

• Correct inaccurate or incomplete personal information
• Update your profile information directly in app settings
• Request correction of data you cannot edit yourself

6.3 Right to Erasure / "Right to be Forgotten" (GDPR Art. 17, CCPA, LGPD)

• Request deletion of your account and all associated personal data
• Data will be permanently deleted within 30 days
• Exceptions: Financial records retained for 7 years (legal requirement)

6.4 Right to Restriction (GDPR Art. 18)

• Request limitation of processing your data under certain conditions
• Temporary suspension of data processing while disputes are resolved

6.5 Right to Object (GDPR Art. 21)

• Object to processing based on legitimate interests
• Opt-out of direct marketing (we don't send marketing emails)

6.6 Right to Data Portability (GDPR Art. 20)

• Receive your data in JSON or CSV format
• Transfer your data to another service provider
• Available within 30 days of request

6.7 Right to Withdraw Consent (GDPR Art. 7(3))

• Withdraw consent for data processing at any time
• Note: Withdrawal may prevent access to certain features
• Does not affect the lawfulness of prior processing

6.8 Right to Opt-Out of Communications

• Unsubscribe from optional emails (currently none)
• Transactional emails (verification, security, billing) cannot be disabled while account is active

6.9 California Residents - CCPA/CPRA Rights

• Right to Know: Categories of personal information collected, sources, purposes, and third parties
• Right to Delete: Request deletion (with exceptions for legal obligations)
• Right to Opt-Out of Sale: We do NOT sell personal information (opt-out not applicable)
• Right to Non-Discrimination: No penalty for exercising CCPA rights
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit Use of Sensitive Personal Information: We minimize collection of sensitive data

6.10 European Union Residents - GDPR Rights

• Legal Basis for Processing:
  • Contract performance (providing the Service)
  • Legitimate interests (security, fraud prevention)
  • Legal obligations (tax, financial regulations)
  • Consent (where applicable)
• Right to Lodge a Complaint: Contact your local Data Protection Authority (DPA)
  • List of EU DPAs: https://edpb.europa.eu/about-edpb/board/members_en
• International Data Transfers: We use Standard Contractual Clauses (SCCs) approved by the European Commission

6.11 Canada (PIPEDA), Brazil (LGPD), Australia (Privacy Act), Singapore (PDPA)

• Similar rights to GDPR (access, correction, deletion, portability)
• Right to file complaint with respective privacy authorities
• Specific provisions for sensitive personal information

6.12 How to Exercise Your Rights

Email: ngthvinh150481@gmail.com
Subject Line: Privacy Rights Request - [Your Right, e.g., "Data Deletion"]
Include:

• Your full name and email address associated with your account
• Specific right you wish to exercise
• Any additional information to help us verify your identity

Response Time:

• GDPR (EU): Within 30 days (extendable to 60 days for complex requests)
• CCPA (California): Within 45 days (extendable to 90 days)
• Other jurisdictions: Within 30-45 days as required by local law

Identity Verification:
For security, we may request additional information to verify your identity before processing requests.

7. CHILDREN'S PRIVACY

Age Restriction: Our Service is intended ONLY for users aged 18 years or older (or age of majority in your jurisdiction).

No Knowingly Collected Data from Minors:
We do NOT knowingly collect, use, or disclose personal information from children under 18 years of age (or 16 in the EU).

If You Are a Parent or Guardian:
If you believe your child under 18 has provided personal information to us, please contact us immediately at ngthvinh150481@gmail.com with the subject line "Minor's Data Removal."

Immediate Deletion:
Upon verification, we will permanently delete the child's account and all associated data within 48 hours.

Compliance:

• COPPA (USA): Children under 13
• GDPR (EU): Children under 16
• Other jurisdictions: Age of consent as defined by local law

8. INTERNATIONAL DATA TRANSFERS

8.1 Server Location

Our servers and databases are hosted in the United States (Phoenix, Arizona).

8.2 Cross-Border Data Transfers

If you access our Service from outside the server location country, your personal data will be transferred internationally to our servers.

8.3 Safeguards for International Transfers

We ensure adequate protection through:

For EU Residents (GDPR Article 46):

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions by the European Commission (where applicable)
• Supplementary measures to ensure GDPR-level protection

For Other Jurisdictions:

• Appropriate contractual safeguards with service providers
• Encryption in transit and at rest
• Compliance with local data export laws

For UK Residents (UK GDPR):

• International Data Transfer Agreement (IDTA) or SCCs
• Adequacy regulations as determined by UK authorities

8.4 Payment Processor Transfers

Payment processors (Google, Apple) may transfer data to their respective countries:

• Google (USA)
• Apple (USA)

These transfers are governed by their respective privacy policies and data transfer mechanisms.

8.5 Your Consent

By using our Service, you consent to the transfer of your data as described above. You have the right to withdraw consent or object to transfers (may limit service availability).

9. COOKIES AND TRACKING TECHNOLOGIES

9.1 Cookies We Use

We use cookies ONLY for essential service functionality:

Essential Cookies (Cannot be Disabled):

• session_id: Maintains your login session
  • Type: HTTP-only, Secure, SameSite=Strict
  • Duration: 30 days (extends with activity)
  • Purpose: Authentication and security
  • Domain: .kidneydietfood.com (production)

Preference Cookies (Optional):

• preferred_language: Stores your language choice
  • Duration: 1 year
  • Purpose: Remember your language settings
  • Can be cleared via browser settings

9.2 We Do NOT Use

• Third-party tracking cookies (Google Analytics, Facebook Pixel, etc.)
• Advertising cookies or remarketing pixels
• Social media cookies or widgets
• Cross-site tracking cookies
• Affiliate tracking cookies
• Analytics cookies (we use internal logging only)

9.3 Local Storage

We use browser local storage (Android app uses DataStore) to:

• Cache user preferences (theme, language)
• Store session information
• Improve app performance

9.4 Cookie Management

Browser Settings:
You can manage or delete cookies through your browser:

• Chrome: Settings → Privacy and Security → Cookies
• Firefox: Settings → Privacy & Security → Cookies and Site Data
• Safari: Preferences → Privacy → Manage Website Data
• Edge: Settings → Privacy → Cookies

Android App: Clear app data via Settings → Apps → Kidney Diet Food → Storage → Clear Data

iOS App: Settings → Kidney Diet Food → Reset Data (or uninstall/reinstall)

9.5 Do Not Track (DNT)

We respect Do Not Track (DNT) browser signals. Since we don't use tracking technologies, DNT settings do not affect our Service.

10. THIRD-PARTY LINKS AND SERVICES

10.1 External Links

Our Service may contain links to third-party websites or resources (e.g., nutritional databases, support documentation).

We Are Not Responsible For:

• Privacy practices of third-party websites
• Content or accuracy of external sites
• Security of data you provide to third parties

Recommendation: Review the privacy policies of any third-party sites you visit.

10.2 Third-Party Services We Use

• Google Play Services (Android) - for in-app purchases
• Apple StoreKit (iOS) - for in-app purchases
• USDA FoodData Central API - public nutritional database (no personal data shared)
• Third-party AI services - for recipe cleaning, ingredient matching, and image generation (no personal data shared; only recipe content such as ingredient names, quantities, and recipe names is processed)

10.3 No Third-Party Advertising

We do NOT display third-party advertisements or use ad networks in our app.

11. DATA BREACH NOTIFICATION

11.1 Our Commitment

In the event of a data breach affecting your personal information, we will:

Immediate Actions (Within 72 Hours of Discovery):

• Contain and investigate the breach
• Assess the scope and impact on user data
• Implement measures to prevent further unauthorized access
• Notify relevant supervisory authorities (as required by GDPR, CCPA, etc.)

User Notification (Within 72 Hours):

• Email notification to all affected users
• Clear description of the breach (what data was affected)
• Potential consequences and risks
• Steps we are taking to address the breach
• Recommendations for users to protect themselves
• Contact information for questions

Regulatory Notification:

• GDPR (EU): Within 72 hours to supervisory authority
• CCPA (California): Without unreasonable delay
• Other jurisdictions: As required by applicable law

11.2 What We Monitor

• Unauthorized access attempts
• Unusual login patterns
• Database access anomalies
• Payment system irregularities
• Security incident logs

11.3 User Responsibilities

If you suspect unauthorized access to your account:

• Change your password immediately
• Review recent activity in your account
• Enable two-factor authentication (if available)
• Contact us at ngthvinh150481@gmail.com

12. CHANGES TO THIS PRIVACY POLICY

12.1 Updates

We may update this Privacy Policy periodically to reflect:

• Changes in our data practices
• New features or services
• Changes in applicable laws
• Feedback from users or regulators

12.2 Notification of Material Changes

For significant changes, we will notify you by:

• Email to your registered email address (at least 30 days before effective date)
• In-app notification or banner
• Prominent notice on our website
• Updated "Last Updated" date at the top of this policy

12.3 Continued Use Constitutes Acceptance

Continued use of the Service after changes become effective constitutes your acceptance of the updated Privacy Policy.

12.4 Right to Object

If you do not agree with changes, you may:

• Stop using the Service
• Delete your account before changes take effect
• Contact us with concerns at ngthvinh150481@gmail.com

12.5 Version History

Previous versions of this Privacy Policy will be archived and available upon request.

13. JURISDICTION-SPECIFIC PROVISIONS

13.1 European Union (GDPR)

• Legal Basis: Contract, consent, legitimate interest, legal obligation
• Data Protection Officer: Contact ngthvinh150481@gmail.com with subject "DPO - [Your Country]"
• Supervisory Authority: Right to lodge complaint with your local DPA
• Data Transfers: Standard Contractual Clauses (SCCs)
• Automated Decision-Making: We do NOT use automated decision-making or profiling

13.2 California, USA (CCPA/CPRA)

• Business Name: Kidney Diet Food
• Categories of Personal Information: See Section 1
• Business Purpose: See Section 2
• Categories Shared: Payment processors, email service, hosting (see Section 3)
• Sale of Personal Information: We do NOT sell personal information
• Sensitive Personal Information: We minimize collection and use
• Retention Period: See Section 4
• Contact: ngthvinh150481@gmail.com with subject "CCPA Request"

13.3 Canada (PIPEDA)

• Privacy Officer: ngthvinh150481@gmail.com
• Complaint Process: Contact Privacy Officer first, then Privacy Commissioner of Canada
• Commissioner Website: https://www.priv.gc.ca/
• Consent: Implied for service delivery, express for other purposes
• Accountability: We are responsible for data processed by third parties

13.4 Brazil (LGPD)

• Legal Basis: Consent, contract execution, legal obligation, legitimate interest
• Data Protection Officer (DPO): ngthvinh150481@gmail.com with subject "DPO Brazil"
• National Authority: ANPD (Autoridade Nacional de Proteção de Dados)
• ANPD Website: https://www.gov.br/anpd/
• Data Transfers: Adequate safeguards required

13.5 Australia (Privacy Act 1988)

• Australian Privacy Principles (APP) Compliance: Full compliance
• Overseas Disclosure: See Section 8 (International Data Transfers)
• Complaint Process: Contact us first, then Office of the Australian Information Commissioner (OAIC)
• OAIC Website: https://www.oaic.gov.au/

13.6 Singapore (PDPA)

• Data Protection Officer: ngthvinh150481@gmail.com with subject "DPO Singapore"
• Personal Data Protection Commission (PDPC): https://www.pdpc.gov.sg/
• Consent Requirements: Deemed consent for reasonable purposes, express for others
• Do Not Call (DNC) Registry: We do not conduct telemarketing

13.7 United Kingdom (UK GDPR)

• Legal Basis: Same as EU GDPR
• International Transfers: IDTA or SCCs
• ICO (Information Commissioner's Office): https://ico.org.uk/
• Right to Complain: Contact ICO if dissatisfied with our response

13.8 Other Jurisdictions

If your jurisdiction is not listed, you still have rights under our general privacy practices. Contact us at ngthvinh150481@gmail.com for jurisdiction-specific information.

14. CONTACT US

For any questions, concerns, or requests regarding this Privacy Policy or your personal data:

Response Time:

• General inquiries: Within 5 business days
• Data rights requests: Within 30-45 days (as required by law)
• Security concerns: Within 24 hours (priority handling)

15. APP STORE COMPLIANCE DECLARATIONS

15.1 Google Play Store - Data Safety Declaration

This app collects the following data types:

• Personal Info: Name, email address
• Health & Fitness: Nutrition and dietary tracking data (used only for app functionality)
• Financial Info: Purchase history, subscription status (processed by Google Play)
• App Activity: In-app actions and feature usage
• Device & Other IDs: Device identifiers for security purposes

Data Usage:

• Data is used ONLY for app functionality (not for advertising or analytics)
• Data is encrypted in transit using TLS
• Data is encrypted at rest
• You can request data deletion

Data Sharing:

• Data is NOT shared with third parties for advertising
• Data is NOT shared for analytics purposes

• Payment data is shared with Google Play Billing for purchase processing

15.2 Apple App Store - Privacy Nutrition Labels

Data Linked to You:

• Contact Info: Email address
• User Content: Recipes, meal plans, dietary data
• Purchases: In-app purchase history

Data Not Collected:

• Location data
• Browsing history
• Contacts
• Health data from Apple Health app

Data Used to Track You:

• None (we do NOT use tracking)

Data Practices:

• Data is used ONLY for app functionality

• Data is NOT used for third-party advertising
• Data is NOT used for analytics or marketing purposes

15.3 Medical Device and Health Claims Disclaimer

16. RESTRICTIONS AND PROHIBITED COUNTRIES

16.1 Countries Where Service May Be Unavailable

Due to legal, regulatory, or operational reasons, our Service may not be available in:

• Countries subject to comprehensive US sanctions (e.g., Cuba, Iran, North Korea, Syria, Crimea region)
• Countries where payment processors (Google Play, Apple) are unavailable
• Countries with restrictive data localization laws incompatible with our infrastructure

We will notify users if their country becomes restricted.

16.2 Compliance with Local Laws

Users are responsible for ensuring their use of the Service complies with local laws in their jurisdiction.

END OF PRIVACY POLICY