Kalorina d.o.o. (“we”, “us”, “our”, or the “Company”) respects your privacy and is committed to protecting your personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and other applicable EU laws.

This Privacy Policy explains how we collect, use, disclose, transfer, and protect your personal data when you use our Kayree AI mobile application (the “App” or “Service”). By using the Service, you agree to the practices described here. If you do not agree, please do not use the Service.

1. Who We Are (Data Controller)

Controller: Kalorina d.o.o., a company registered in Croatia (EU), with registered address Ulica Marina Drzica 27, Cepin, OIB 44007937841. Contact: support@kayree-ai.app

If we appoint a Data Protection Officer (DPO), we will update this section with their contact details. For EU users, you may also contact your national supervisory authority (in Croatia: Agencija za zaštitu osobnih podataka – AZOP).

2. Data We Collect

We collect the following categories of data:

Personal Data you provide:

• Account information: Name, email address, password (hashed).
• Profile data: Age, gender, height, weight, dietary preferences/goals (e.g., weight loss, maintenance), activity level.
• Health-related data (special category data under GDPR Article 9): Food/nutrition logs (meals, calories, macronutrients), calorie intake estimates, exercise/step data (if synced or entered), weight/body measurements over time, AI-generated insights (e.g., personalized recommendations, progress trends inferring health/diet patterns).

Usage Data (collected automatically):

• Device information: IP address, device type/model, OS version, unique device identifiers, browser type.
• App usage: Pages/features visited, time/date of access, session duration, interactions (e.g., logged meals).
• If using mobile: Mobile OS, carrier, location data only if you enable it for features (e.g., nearby food suggestions; we ask for consent).

Exercise Data: Step counts, exercise logs, and related metrics are processed primarily on-device using your phone’s sensors/APIs (e.g., Google Fit/Apple Health). We do not store raw exercise data on our servers unless you explicitly sync it for cross-device features or AI analysis (in which case we process it with your explicit consent). You can delete synced exercise data anytime in-app.

We do not collect sensitive data such as precise medical diagnoses, genetic data, or biometric scans unless you voluntarily provide it (and even then, we minimize processing).

3. How We Use Your Data (Purposes and Legal Bases)

We process your data only for specified, legitimate purposes. We rely on the following GDPR legal bases (Article 6 and, for health data, Article 9):

• Performance of a contract (Art. 6(1)(b) GDPR): To provide core Service features (e.g., account creation, calorie tracking, basic AI recommendations).
• Explicit consent (Art. 6(1)(a) + Art. 9(2)(a) GDPR): For processing health-related data (nutrition logs, AI insights on diet/health goals), marketing communications, and optional features (e.g., syncing exercise data to servers). You can withdraw consent anytime in-app without affecting prior processing.
• Legitimate interests (Art. 6(1)(f) GDPR): For Usage Data analytics to improve the App, fraud prevention, and security (balanced against your rights; you can object).
• Legal obligations (Art. 6(1)(c) GDPR): To comply with tax, accounting, or regulatory requirements.

Specific uses:

• Provide/maintain the Service (e.g., calculate calories, generate AI insights).
• Personalize experience (e.g., tailored nutrition advice based on your logs).
• Communicate updates, security notices, or support responses.
• Send promotional offers (only with opt-in consent).
• Aggregate/anonymize data for internal analysis (no longer personal data).
• Business transfers (e.g., merger).

We do not use your data for automated decisions with legal effects unless you explicitly consent.

4. Sharing Your Data

We share data only when necessary:

• Service providers (processors): Cloud hosting, analytics (e.g., anonymized), payment processors (under strict contracts per Art. 28 GDPR).
• In business transfers (e.g., merger).
• To public authorities if legally required.

No selling of personal data.

5. International Transfers

Data may be processed outside the EU/EEA (e.g., by cloud providers in the US). We use safeguards like EU Standard Contractual Clauses (SCCs) or adequacy decisions to ensure protection (Art. 44–50 GDPR). Details available on request.

6. Retention Periods

• Account/profile data: While your account is active + up to 1 year after deletion (for backups/legal reasons).
• Health/nutrition logs: Until you delete them or your account (you control this in-app).
• Usage Data: Up to 12 months for analytics; longer if needed for security/legal obligations.
• We delete or anonymize data when no longer needed.

7. Your GDPR Rights

As an EU/EEA resident, you have:

• Access (Art. 15): Request a copy of your data.
• Rectification (Art. 16): Correct inaccurate data.
• Erasure (“right to be forgotten”, Art. 17): Delete data (subject to legal exceptions).
• Restriction (Art. 18): Limit processing.
• Objection (Art. 21): Object to processing based on legitimate interests or for marketing.
• Portability (Art. 20): Receive data in structured format.
• Withdraw consent: Anytime (e.g., in-app settings for health data/marketing).

Exercise rights via in-app tools or email support@kayree-ai.app. We respond within 1 month (extendable). Free unless manifestly unfounded/excessive. You can complain to AZOP or your local authority.

8. Security

We use encryption (in transit/rest), access controls, regular audits, and other measures. No transmission/storage is 100% secure, but we aim for high standards.

9. Children’s Privacy

The Service is not directed at children under 16. We do not knowingly collect data from under-16s without parental consent (required under GDPR Art. 8 in many cases). If we learn of such data, we delete it.

10. Changes to This Policy

We may update this policy. Changes are posted here with the updated date. Significant changes (e.g., new health data uses) will be notified in-app or by email.

11. Contact Us

Questions? Email: support@kayree-ai.app

Thank you for trusting Kayree AI with your data. We prioritize your privacy and health goals.

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