Privacy Policy

The data controller responsible for your personal data is:

Reli Magnezi
Operating as WholeMealGuide
Email: support@wholemealguide.com

For any questions regarding data protection, you can contact us at the email address above.

We collect information that you voluntarily provide to us when you register and use the service. This includes:

• Account Information: Your email address and display name used for authentication.
• Meal Data: Meal descriptions, meal photos (if uploaded), and food preferences you provide for nutritional analysis.
• Demographic Data: Age and sex, used alongside your manual nutrient targets to personalize your daily reference values.
• Nutrient Focus: Your personalized nutrient focus settings (e.g., marking specific nutrients as below or above reference baselines) to customize algorithmic ingredient variations.
• Usage Data: Anonymous server-side logs (timestamps, request counts, error rates) used to maintain service stability. No tracking cookies or client-side analytics scripts are used.

Sources of Personal Information

• Directly from you: All account information, demographic data, nutrient focus settings, ingredient preferences, and meal descriptions or photos are provided by you when using the service.
• Authentication provider (Logto): Email address and basic profile data used for sign-in.
• Social sign-in providers (Google, Facebook, Apple): If you sign in via a social account, authentication is mediated through Logto. These providers share your email address and display name. We never receive your social account password.
• Payment processor (our authorized Merchant of Record): Subscription status only. We do not receive or store your payment card details.

We use the information we collect strictly to provide and improve our service. Below is a per-category breakdown of how each type of data is used:

• Account Information (email, display name): Authentication, account management, and customer support.
• Meal Data (meal descriptions, meal photos, preferences): Nutritional analysis and algorithmic ingredient variations via our AI engine.
• Demographic Data (age, sex): Personalizing daily reference values alongside your manual nutrient targets.
• Nutrient Focus: Customizing analysis insights to highlight nutrients you are focused on.
• Usage Data: Maintaining the security, stability, and performance of our infrastructure.

We process your personal data based on the following legal grounds:

• Contract Performance (Art. 6(1)(b)): Processing your account information, meal data, and meal analyses is necessary to provide the WholeMealGuide service you signed up for.
• Legitimate Interest (Art. 6(1)(f)): We process minimal usage data to maintain the security, stability, and performance of our infrastructure.
• Consent (Art. 6(1)(a)): Demographic data (age, sex) and nutrient focus settings are provided voluntarily and used solely to personalize your daily reference values and ingredient variations. You can remove this data at any time from your Account settings.

WholeMealGuide uses Google Gemini to analyze meals and generate nutritional estimates. When processing your meals, we take the following precautions:

• No PII Shared: No Personally Identifiable Information (such as your name, email address, or account details) is ever sent to the AI model.
• Anonymized Data Only: We only send anonymized demographic variables (age, sex), nutrient focus settings, and meal descriptions or photos to generate your analysis.
• AI-processed data is not stored by the AI provider and is not used to train their models.

Your data is stored on private, encrypted infrastructure hosted on Oracle Cloud Infrastructure (OCI). It is not used for profiling, advertising, or any purpose beyond providing the WholeMealGuide service.

Our servers are located in Frankfurt, Germany. By using our service, you acknowledge that your data will be transferred to, stored, and processed in Germany, subject to strict European data protection standards (GDPR).

We do not sell, share, rent, or trade your personal information to or with third parties. As defined by the California Privacy Rights Act (CPRA), we do not "sell" personal information and do not "share" personal information for cross-context behavioral advertising.

We have not sold or shared personal information in the preceding 12 months. WholeMealGuide does not use analytics tracking scripts, advertising networks, or any form of behavioral profiling. We do not use your meal data to serve targeted third-party advertisements.

Under the CPRA, certain categories of personal information are classified as "sensitive personal information." WholeMealGuide may collect the following sensitive personal information:

• Information that may reveal religious beliefs: Ingredient preferences such as kosher or halal, used solely to filter and personalize ingredient variations.

This sensitive personal information is used only for providing the core WholeMealGuide service and is never used for secondary purposes, profiling, or advertising. Because we use sensitive personal information only as necessary to provide the service you request, a "Limit the Use of My Sensitive Personal Information" link is not required per CPRA §1798.121(d).

You can view, modify, or remove all sensitive personal information at any time from your Account settings.

We only share your data in the following limited circumstances:

• Service Providers: With essential third-party services strictly for providing the WholeMealGuide service. Data sent to these providers is minimized and anonymized where possible.
• Legal Obligations: If required to do so by law or in response to valid requests by public authorities.

Sub-processors we use (GDPR Article 28):

• Google LLC (Gemini AI): Meal analysis and nutritional estimation. Only anonymized data is sent (no PII).
• Logto: Authentication and identity management. Processes your email and basic profile for sign-in.
• Social Sign-In Providers (Google, Facebook, Apple): If you sign in via a social account, authentication is mediated through Logto. They process your email and basic profile data during the authentication flow under their own privacy policies.
• Our Authorized Merchant of Record: Payment processing for Pro subscriptions. Handles billing information directly; we do not store payment card details.
• Oracle Cloud Infrastructure (OCI): Infrastructure hosting in Frankfurt, Germany (EU).

For EEA Residents (GDPR)

If you are a resident of the European Economic Area (EEA), you have specific rights regarding your personal data:

• The Right to Access (Art. 15): You can request copies of your personal data. You can use the Export My Data feature in your Account settings to download all your data instantly.
• The Right to Rectification (Art. 16): You can update or correct your personal information directly in your Account settings at any time.
• The Right to Erasure (Art. 17 — Right to be Forgotten): You can permanently delete your account and all associated data using the Delete Account feature in your Account settings. Deletion is immediate and irreversible.
• The Right to Data Portability (Art. 20): You can export your data in a structured, machine-readable JSON format using the Export My Data feature in your Account settings.
• The Right to Restrict Processing (Art. 18): You can request that we limit the processing of your personal data in certain circumstances.
• The Right to Object (Art. 21): You can object to the processing of your personal data based on our legitimate interests.
• The Right to Lodge a Complaint: You have the right to file a complaint with a supervisory authority if you believe your data protection rights have been violated. You may contact your local data protection authority in the EEA.

Many of these rights can be exercised directly through your Account settings. For any additional requests, please contact us at support@wholemealguide.com. We will respond to your request within 30 days.

For California Residents (CPRA)

If you are a California resident, the California Privacy Rights Act (CPRA) provides you with specific rights regarding your personal information:

• Right to Know (§1798.100): You have the right to know what personal information we collect, use, and disclose. Use the Export My Data feature in your Account settings to download all your data.
• Right to Delete (§1798.105): You can request deletion of your personal information. Use the Delete Account feature in your Account settings to permanently and immediately delete all your data.
• Right to Correct (§1798.106): You can request correction of inaccurate personal information. Update your data directly in your Account settings.
• Right to Opt-Out of Sale/Sharing (§1798.120): WholeMealGuide does not sell or share your personal information. No opt-out is needed because no sale or sharing occurs.
• Right to Limit Sensitive PI Use (§1798.121): We use sensitive personal information only to provide the core service you request. See Section 8 for details.
• Non-Discrimination (§1798.125): We will not deny you services, charge you different prices, provide a different quality of service, or otherwise discriminate against you for exercising any of your CPRA rights.

Verification Process

In-app requests (Export Data, Delete Account, data corrections) are verified through your authenticated session. For requests submitted via email, we verify your identity by confirming the request originates from your registered email address.

Authorized Agents

You may designate an authorized agent to submit privacy rights requests on your behalf. The authorized agent must provide written authorization from you and we may verify your identity directly. To submit an authorized agent request, contact support@wholemealguide.com.

Response Time

We will respond to verifiable consumer requests within 45 days of receipt. If additional time is needed, we will notify you of the extension and the reason, for up to an additional 45 days.

We retain your data as follows:

• Account data (email, display name): Retained until account deletion.
• Demographic data (age, sex) and manual nutrient targets: Retained until account deletion. You can remove individual data points at any time from your Account settings.
• Ingredient preferences and nutrient focus settings: Retained until account deletion. Modifiable at any time from your Account settings.
• Meal analyses and history: Retained until account deletion.
• Usage data (server logs): Retained for a maximum of 90 days, then automatically purged.
• Payment and subscription status: Retained until account deletion. Our authorized Merchant of Record may retain billing records per their own data retention policy.

Upon account deletion, all personal data is permanently removed from our systems immediately. This includes your profile, preferences, meal history, and any associated records.

If you have questions or comments about this policy, or wish to exercise your data rights, please contact us:

Email: support@wholemealguide.com

Mail: Reli Magnezi, Operating as WholeMealGuide, 2 Braun Arie St., Peth Tikva 4906336, Israel