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1. Data We Collect

Depending on the features you use, we may collect:

• Account & contact data — Email, user ID, authentication data, and information from third-party sign-in (e.g., Apple Sign In)
• Profile & health goals — Age/age range, gender (if provided), height, weight, weight goals, daily calorie targets, and nutrition information you enter
• Photos — Meal photos you take or upload for calorie estimation, profile photos (if added), and image metadata (e.g., capture date)
• Activity & movement data — Step count, distance (if supported), daily step goals, and activity data from device sensors or Apple Health (if you authorize)
• Usage logs — Meal history, logged calories, daily timeline, and in-app settings
• Usage & device data — In-app events (screens viewed, buttons tapped), device model, OS version, language, app version, and IP address (for security)

We do not provide a public user-generated content posting feature. Data you enter or upload to use features remains your personal data.

2. Sources of Data

• From you directly — When you sign up, complete your profile, take meal photos, or use features
• From your device — Step sensors, Apple HealthKit (if authorized), and device information
• Automatically — Through analytics, system logs, and infrastructure to operate the app

3. How We Use Data (Purposes & Legal Bases)

We use your data to:

• Provide core services — Account creation, calorie estimation from photos, step tracking, and health data display
• Improve the Services — Usage analytics, bug fixes, and calorie estimation accuracy improvements
• Security — Prevent abuse, attacks, and fraud
• Communication — Support, user assistance, and important service notices
• Legal compliance — As required by law

Legal bases may include necessity to provide the Services you request (contract), our legitimate interests (security/improvement), and/or consent where required (e.g., sensitive data or HealthKit connections).

4. Sensitive Data (Health Information)

Some health and nutrition data (e.g., weight, calorie targets, HealthKit data) may be considered sensitive under the PDPA.

We use such data only to provide health/nutrition features, apply appropriate safeguards, and request additional consent through in-app flows where required by law.

5. Sharing & Processors

We may share data with service providers acting as processors, including:

• Supabase — Database, authentication, and backend infrastructure
• Apple — App Store, payments (if subscriptions are offered), and Apple Sign In
• AI/ML providers — Processing meal photos for calorie estimation (only data necessary for the task)
• Analytics providers — App usage analysis to improve user experience

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

We may disclose data when required by law or to protect the rights, safety, and property of us and our users.

6. International Data Transfers

Your data may be stored or processed outside Thailand depending on our providers (e.g., Supabase, Apple, AI providers).

We apply appropriate measures, such as standard contractual clauses or measures required by the PDPA, to ensure lawful transfers.

7. Data Retention

• Account/profile data — Retained while your account is active or until you request deletion
• Meal photos and food logs — Retained as needed to provide the Service or until you delete them
• Analytics and system logs — Retained per provider defaults or as needed for security and improvement (typically up to 24 months)

When no longer necessary, we delete or anonymize the data.

8. Your Rights

Under the PDPA and applicable law, you may have the right to:

• Access and obtain a copy of your personal data
• Request correction of inaccurate or incomplete data
• Request deletion or destruction when no longer necessary
• Request restriction of processing in certain cases
• Object to processing in certain cases
• Request data portability where applicable
• Withdraw consent (where we rely on consent) without affecting prior processing

Exercise your rights by contacting support@calbuddy.live. We will respond within the timeframe required by law (typically within 30 days).

9. Security

We implement appropriate safeguards, including:

• Encryption in transit (TLS/HTTPS)
• Access controls and role-based permissions
• Security practices of infrastructure providers (e.g., Supabase)
• Regular system monitoring and updates

No method of transmission or storage is 100% secure. We cannot guarantee absolute security.

10. Cookies & Tracking Technologies

Our website may use cookies and similar technologies for essential functionality, preference storage, and usage analytics. See our Cookie Policy for details.

The mobile app may use device identifiers and in-app analytics as described in sections 1 and 5 of this Policy.

11. Children’s Privacy

The Services are intended for users aged 13 and above. We do not knowingly collect data from children under 13.

If you believe a child under 13 provided data to us, contact support@calbuddy.live to request deletion.

12. Updates to This Policy

We may update this Policy from time to time. We will notify you via the app, website, or other appropriate means and update the effective date above.

Continued use after the effective date constitutes acknowledgment of the updated Policy. For material changes, we will provide clear notice.

For terms of use, see our Terms of Service.