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Draft for review. Effective date, company name and contact address to be filled in before release. Lines marked "For the lawyer" are open questions and come out before release.

Celorbix privacy policy

Celorbix helps you log what you eat by speaking, typing, scanning a barcode or taking a photo, estimates its nutrition, tracks your health numbers next to it, and offers a coach, groups and professionals. This policy says what we collect, why, who else handles it, where it is kept, and the choices you have.

The short version

What we collect

What you log and set

About you

Apple Health, Oura and WHOOP

Apple Health. If you connect it, Celorbix reads your steps, energy burned, exercise, sleep, heart rate, heart rate variability, blood oxygen, breathing rate and weight to show them next to what you eat. It reads them on your phone. They do not leave it unless you choose: Celorbix AI sends steps, sleep, resting heart rate and weight, and a professional you share with receives the kinds you pick. If you allow it, Celorbix also saves what you log (meals, water, weight and readings) to Apple Health. You can turn access off at any time in the Health app → Sharing → Apps → Celorbix.

Oura and WHOOP. If you link one of these accounts, you sign in on its own page and Celorbix never sees your password. Your phone then reads your readiness or recovery score, sleep score, overnight heart rate variability and, for WHOOP, strain, directly from that service, and keeps them and the access tokens on your phone only. Our server helps with the sign-in and passes the tokens to your phone without keeping them. All we store is that you linked the account, what it allows, which wording you agreed to, and when you linked and disconnected it. You can disconnect at any time in Settings → Connected apps, and choose to delete what came in. Oura and WHOOP handle your data under their own privacy policies.

The rest

We do not collect your contacts, advertising identifiers or anything from other apps.

Celorbix AI: the coach

Without Celorbix AI, the coach's answers come from your phone and nothing is sent. Celorbix AI is off until you turn it on, in the coach or on the coach's terms; signing those terms does not turn it on. You can turn it off at any time. We record each choice.

Each question. With it on, each question and the last few messages go to our server and on to Groq, the company that runs the model, with a summary of you: your birth year and sex; the conditions you ticked and your diabetes type; your allergies and how you eat; your goal in your own words, your aims, targets and what you track; the country you eat in; today's meals; the past week's calories; your blood sugar and how it rose after meals; today's water and steps; last night's sleep; your resting heart rate; your weight; and your streak.

Your plan. Making a plan from your month sends the same way: a month of your days, with each meal's foods, time and calories; carbs, protein, sugar, fibre and glycemic load; your eating windows and fasts; steps, sleep, resting heart rate and weight, including from Apple Health if you connected it; blood sugar readings with their times; your daily energy check; your goal, aims and targets; the conditions you ticked with your answers to their questions; your allergies and how you eat; whether fasting is safe for you and why not; your birth year, sex and height.

Your name, email and photos are not sent. Our server does not store or log what it passes on, though it does check that your yes is on record. A question suggesting you may harm yourself is never sent to the AI: you get a line to call instead. Groq's terms say it does not train on this data.

The coach's terms, if you sign them, are kept with your account: the version, the name you typed, a hash of the text and when you signed.

For the lawyer: Groq's data retention. Whether our account has zero data retention on, and a data processing agreement, is not confirmed (D146). Is what is said here about Groq enough for GDPR Art. 13 and Art. 9(2)(a), and for App Store guideline 5.1.2(i) on third-party AI? Is the coach's plan "profiling" under Art. 22?

Professionals

In India, the United States and Mexico you can connect with a dietitian, doctor or trainer whose credentials we have checked. Not in France yet. If you connect with one:

If you join as a professional, we keep your profile, your library of plans, the credentials you give and the documents proving them, and show checked ones to people looking for you (never the number). A professional's own care of you is their responsibility and subject to the rules of their profession.

For the lawyer: who is the controller of what a professional reads (we, or they, or jointly), and whether a data processing agreement with each professional is needed. India's DPDP Act, HIPAA's reach in the US, and Mexico's LFPDPPP as they apply to this. France stays closed until this review is done (D147).

Community groups

For the lawyer: moderation records and EU DSA Art. 17; India's IT Rules 2021 (grievance deadlines); whether holding self-harm posts and showing them to staff needs anything further said here.

The website

For the lawyer: the website's sign-in doesn't take a separate yes to these terms beyond a line on the first screen. Is that enough? Is a notice about these two strictly necessary cookies enough under the ePrivacy rules if the EU opens?

Why we use it

We do not sell your data, we do not use it for advertising, and we do not use your diary to train models.

Who else handles it

WhoWhat forWhat they get
Google Cloud (Mumbai, India)Runs our server and databaseWhat our server holds
GroqCelorbix AI; speech your phone can't recognise; a second look at group posts if that is on The summary and the month described above, your question and its messages; the recording; the post's text
Google (Gemini, on a paid plan)Reading photos and nutrition labels; retouching a meal's photo; estimating a food in none of our lists; finding a swap for a dish; sorting feedback and drafting a reply for our team The photo; the words of that food; the dish's name and your country; the words of your feedback, as described above. On this plan Google does not use prompts and responses to improve its products, and logs them for a limited time for policy and legal reasons.
AppleSign-in, purchases, Apple Health on your phone, crash reports, speech where your phone can't recognise it aloneWhat each of those needs; Apple's own policy applies
Google, Facebook, MicrosoftSign-in, if you choose themWhat signing in needs; their own policies apply
Our email delivery serviceSign-up and password codes, if you sign up with an emailYour email address and that message
Oura, WHOOPLinked accounts, if you link oneYour sign-in on their own page; your phone reads from them
A professional you connect withYour careThe kinds of data you chose, and your messages

For the lawyer: feedback (D198). Someone can write anything in it, health details included, though a word list keeps the obvious ones from the AI. Is telling them on the screen they send it from, and here, enough, with no separate yes?

For the lawyer: a data processing agreement with each processor above, in particular Groq and Google. Confirm the Gemini wording against Google's current terms, and whether photos count as health data.

Where it is kept and for how long

For the lawyer: people in France and the EU have their data held in India. Transfers under GDPR Chapter V need a basis (standard contractual clauses and a transfer assessment); France's rules on hosting health data (HDS) may apply; an EU representative under Art. 27 may be needed.

For the lawyer: backups (D181). Is 35 days acceptable for data someone has erased (GDPR Art. 17, India's DPDP Act), and is this wording enough? Older dumps taken by hand are on a laptop in the US, and two old disk copies are in Mumbai: this sentence isn't true of them until they are deleted. Restoring a backup doesn't yet remove deleted accounts again by itself, as the last line of this list says it does (CLOUDSECOPS G13).

Your choices and rights

If you are in India

You have the rights given by the Digital Personal Data Protection Act, 2023, including access, correction, erasure and grievance redressal. Contact our grievance officer at the address below.

If you are in the European Union (including France) or the United Kingdom

Under the GDPR you may access your data, have it corrected or erased, restrict or object to its use, receive it in a portable form, and withdraw any consent at any time without affecting what was done before. You may also complain to your data protection authority (in France, the CNIL).

We use your data to provide the service you asked for (contract), to keep the service safe and working (legitimate interests), and to meet legal duties. We use your health data, including what you log where it reveals your health, only with your explicit consent, which you can withdraw in the app.

For the lawyer: confirm these legal bases, and whether a food diary as a whole is Art. 9 health data, in which case consent must be taken at sign-up (today it is taken for Celorbix AI, reminders, marketing, linked accounts and sharing, not for the diary itself). A data protection impact assessment, and a DPO, are likely needed for health data at scale. Age of consent is not at issue while the app is 18+.

If you are in the United States or Mexico

For the lawyer: US state consumer-health laws (Washington's My Health My Data Act and others) may require their own notice and consent; California's CCPA/CPRA rights. Mexico's LFPDPPP (aviso de privacidad, ARCO rights). A Spanish and a French version of this policy may be required.

Health information

Celorbix gives nutrition estimates and general guidance, not medical advice. The numbers are estimates from recipes, labels and published values and can be wrong. Talk to a doctor or dietitian about your diet and health. In an emergency, call your local emergency number.

Children

Celorbix is for adults 18 and over, and we do not knowingly collect children's data.

Contact

[Company name], [postal address]. Grievance officer: [name], [email]. Data protection contact: [name], [email].

We will post changes to this policy here and tell you in the app if they are significant.