1. Children and Minors

The Services are not intended for users under 18. We do not knowingly collect personal data from anyone under 18. If we learn that we collected personal data from a person under 18 without appropriate consent, we will delete it as required by law. This age restriction is designed to reduce risk under children's privacy laws and minor data rules in the United States, Canada, the EU, and the EEA.

2. Personal Data We Collect

Depending on how you use the Services, we may collect or process the following categories of personal data. In Canada, this may be considered personal information. In the EU/EEA, this may be considered personal data.

Some nutrition, wellness, fitness, body metric, dietary, advertising, location, payment, or preference information may be considered sensitive personal data, sensitive personal information, consumer health data, or special category data under certain laws. We process such information only as described in this Privacy Policy, as necessary to provide requested features, as required by law, or with consent where required.

• Account and contact information: name, email address, username, authentication identifiers, and account settings.
• Profile and preference information: nutrition goals, food preferences, dietary preferences, units of measurement, saved foods, saved meals, recipes, and app preferences.
• Nutrition, wellness, and fitness information: food logs, meals, recipes, calories, macronutrients, micronutrients, body weight, body measurements, activity-related entries, goals, progress notes, and similar wellness information you choose to provide.
• User Content: notes, manually entered food data, uploaded or submitted images, barcode searches, feedback, support messages, and other information you provide.
• Device and technical information: IP address, device type, operating system, browser type, app version, device identifiers, crash logs, diagnostics, logs, and security events.
• Usage information: screens or pages viewed, features used, search queries, scan or lookup activity, clicks, referring pages, timestamps, and interactions with notifications, ads, sponsored content, subscription screens, and payment flows.
• Advertising and measurement information: ad impressions, clicks, conversions, attribution events, advertising identifiers where permitted, cookie or SDK identifiers, device and browser signals, consent status, ad preferences, approximate location, frequency-capping data, fraud-prevention signals, and interactions with contextual, personalized, targeted, sponsored, affiliate, or promotional content, including information processed through Google advertising products where implemented.
• Approximate location information: general location inferred from IP address. We do not collect precise real-time geolocation unless we clearly disclose that feature and obtain consent where required.
• Payment and transaction information: subscription status, product purchased, plan type, billing period, transaction identifiers, renewal status, cancellation status, refund status, payment method type, country, currency, tax information, app store receipts, invoices, and payment-provider metadata. We do not intentionally collect or store full payment card numbers when payment is processed by a third-party processor, app store, or platform provider.
• Regional privacy request information: information needed to verify and respond to rights requests from users in the United States, Canada, the EU, EEA, and other jurisdictions.

3. How We Collect Personal Data

We collect personal data directly from you when you create an account, enter information, log meals, save recipes, contact us, submit feedback, purchase or subscribe to Paid Services, interact with ads or promotions, manage consent choices, or otherwise use the Services. We also collect information automatically through cookies, mobile SDKs, local storage, server logs, app telemetry, analytics tools, payment systems, ad measurement tools, app stores, and security systems. We may receive limited information from service providers, payment processors, app stores, advertising providers, analytics providers, authentication providers, and third-party food and nutrition data providers.

For Canadian users, we seek meaningful consent for the collection, use, and disclosure of personal information where required, and we identify purposes at or before collection. For EU/EEA users, we process personal data only where we have a legal basis, as described below.

4. Third-Party Food and Nutrition Data

The Services may retrieve, display, store, or process food and nutrition information from third-party sources, including Open Food Facts and USDA FoodData Central. When you search for, scan, save, or log a food item, we may process the query, barcode, selected item, source identifier, and related food metadata to provide the requested feature and maintain your logs. Third-party food data may be subject to source-specific licenses, attribution requirements, and accuracy limitations.

5. Cookies, SDKs, Analytics, Advertising, and Similar Technologies

We may use cookies, local storage, mobile SDKs, pixels, server logs, advertising identifiers, attribution tools, and similar technologies to keep you signed in, remember preferences, secure the Services, measure performance, diagnose issues, understand feature use, prevent fraud, provide analytics, show ads, measure ad delivery, limit ad frequency, attribute conversions, and personalize content or ads where permitted.

Some technologies are necessary for authentication, security, fraud prevention, subscription entitlement, payment processing, preference storage, and core Services functionality. Other technologies may support analytics, diagnostics, contextual advertising, personalized advertising, targeted advertising, ad measurement, attribution, affiliate tracking, frequency capping, and marketing. We expect to use Google advertising products, which may include Google Ads, Google AdMob, Google AdSense, Google Ad Manager, Google consent tools, or related Google advertising and measurement technologies depending on platform and implementation.

Where required by Canadian, EU, EEA, UK, Swiss, US state, or other applicable law, we will provide appropriate notice and obtain consent before using non-essential cookies, SDKs, advertising identifiers, local storage, pixels, or similar technologies, including for personalized or targeted advertising. Where legally permitted, we may show generic or contextual ads without using personal data for ad personalization. You may be able to adjust ad personalization, cookie, SDK, and tracking choices through in-app settings, device settings, browser settings, consent tools, platform controls, or other methods we make available.

6. Payments, Subscriptions, and App Store Purchases

If you purchase, subscribe to, renew, cancel, refund, or otherwise interact with Paid Services, payment and transaction information may be processed by Apple through the Apple App Store, Google through Google Play, Stripe for web or direct checkout transactions, and any other payment or subscription provider disclosed at or before purchase. These providers may act as independent controllers/businesses or processors/service providers depending on the transaction and applicable law.

We may receive and store limited payment-related information needed to provide Paid Services, verify entitlement, manage subscriptions, provide receipts or support, process refunds, handle disputes, comply with tax and accounting obligations, and prevent fraud. This may include product identifiers, transaction IDs, receipt metadata, subscription status, renewal status, cancellation status, refund status, billing country, tax information, account identifiers, entitlement records, payment failure notices, chargeback information, and support communications. We do not receive or store full card numbers when payments are handled by Apple, Google, Stripe, or other third-party payment providers.

7. Advertising, Sponsored Content, and Promotions

The Services may display or deliver contextual ads, personalized or targeted ads, sponsored content, sponsored listings, affiliate links, offers, surveys, promotions, cross-promotions, or marketing messages. We expect to use Google advertising products, which may include Google Ads, Google AdMob, Google AdSense, Google Ad Manager, or related Google advertising and measurement tools. Ads may be selected, delivered, limited, measured, reported, and improved using information such as app activity, viewed pages or screens, interactions, device information, approximate location, advertising identifiers where permitted, cookies, SDK signals, consent status, and other information permitted by law and your choices.

We may disclose limited personal data to advertising, analytics, attribution, measurement, affiliate, promotional, and sponsored-content partners, including Google advertising products where implemented, for contextual advertising, personalized advertising, targeted advertising, ad selection, ad delivery, ad measurement, conversion tracking, attribution, frequency capping, fraud prevention, reporting, and campaign performance analysis. Depending on applicable law, these activities may be considered targeted advertising, cross-context behavioral advertising, a sale, sharing, or processing for advertising purposes, and may require consent or provide opt-out rights.

We do not knowingly use sensitive nutrition, wellness, body metric, dietary, health-related, or payment information to target third-party ads unless we provide additional notice and obtain any legally required consent. As a baseline product rule, generic or contextual ads should not require use of sensitive nutrition or body-metric data for ad targeting. If this changes, the Privacy Policy, consent flows, and product controls must be updated before launch of that use.

8. How We Use Personal Data

We use personal data for the following purposes:

We do not use nutrition, wellness, body metric, or dietary information to provide medical diagnosis or treatment. We do not sell sensitive personal data or special category data as of this draft.

• create, authenticate, maintain, secure, and administer accounts;
• provide nutrition logging, food search, recipe, meal planning, goal tracking, progress, and related product features;
• personalize units, goals, saved foods, recipes, recommendations, ads, and app experience where permitted;
• retrieve, display, process, and manage third-party food and nutrition data;
• provide support, respond to inquiries, and send service-related communications;
• analyze performance, diagnose errors, prevent abuse, protect security, and maintain reliability;
• improve, test, and develop the Services, including aggregated or deidentified analytics where appropriate;
• process purchases, subscriptions, renewals, refunds, taxes, billing, payment disputes, entitlement verification, and fraud prevention;
• provide, measure, personalize, limit, and report advertising, sponsored content, affiliate offers, promotions, and marketing where permitted;
• comply with law, enforce terms, protect rights, respond to lawful requests, and resolve disputes;
• for any other purpose disclosed at the time of collection or with your consent where required.

9. Legal Bases for EU/EEA Processing

If you are located in the EU or EEA, our legal bases may include the following:

Where we rely on consent, you may withdraw consent at any time. Withdrawal does not affect processing that occurred before withdrawal. Where we rely on legitimate interests, you may object to processing where applicable law allows.

10. Canadian Consent and Purpose Limitation

For Canadian users, we collect, use, and disclose personal information for purposes a reasonable person would consider appropriate in the circumstances. We seek meaningful consent where required, including for material uses such as optional marketing, non-essential cookies or SDKs, personalized advertising, and sensitive wellness or body metric processing where applicable. You may withdraw consent subject to legal or contractual restrictions and reasonable notice. If you withdraw consent for information needed to provide core Services, certain features may not function.

11. How We Disclose Personal Data

We may disclose personal data to the following categories of recipients:

As of this draft, expected service providers and third-party platforms include Supabase for backend/database services, Vercel for hosting/deployment, Apple App Store, Google Play, Stripe, Google advertising products, Open Food Facts, and USDA FoodData Central. If additional vendors are added, such as analytics, crash reporting, email delivery, customer support, AI, or additional ad networks, this policy should be updated before launch or before the new processing begins where required.

• service providers and processors that support hosting, deployment, backend databases, storage, analytics, diagnostics, payments, subscriptions, tax, entitlement management, customer support, security, fraud prevention, and operational functions, including Supabase, Vercel, Apple, Google, Stripe, and similar providers where implemented;
• third-party food and nutrition data providers when necessary to retrieve or validate food data, subject to their API terms and technical requirements;
• app stores, payment processors, platform providers, banks, card networks, tax providers, and fraud-prevention providers if you use mobile apps or paid features;
• advertising networks, analytics providers, measurement partners, affiliate partners, promotional partners, sponsored-content partners, and Google advertising products where permitted by law and your choices;
• professional advisors, insurers, auditors, and legal representatives;
• government, law enforcement, courts, regulators, or others where required by law or necessary to protect rights, safety, and security;
• successors or potential successors in connection with a merger, acquisition, financing, restructuring, bankruptcy, or sale of assets;
• other parties with your consent or at your direction.

12. International Transfers

RN Simplicity, its service providers, and third-party infrastructure providers may process and store personal data in Canada, the United States, the EU/EEA, and other countries where we or our providers operate. For Canadian users, personal information may be transferred outside Canada for processing and may be accessible to courts, law enforcement, national security authorities, or regulators in those jurisdictions. For EU/EEA users, where personal data is transferred outside the EU/EEA to a country not recognized as providing an adequate level of protection, we will use appropriate safeguards where required, such as Standard Contractual Clauses, transfer impact assessments, supplementary measures, or another lawful transfer mechanism.

13. Retention

We keep personal data for as long as reasonably necessary to provide the Services, maintain your account, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, maintain security, administer subscriptions, process payments, keep records required for accounting or tax purposes, and support legitimate business purposes. Account data is generally retained while your account is active. Food logs, recipes, goals, and related entries are generally retained until you delete them, delete your account, or request deletion, subject to backups, legal obligations, payment records, fraud-prevention records, dispute records, and legitimate retention needs. Advertising, analytics, and payment metadata may be retained for shorter or longer periods depending on provider settings, legal requirements, consent choices, and fraud or audit needs.

14. Security

We use administrative, technical, and organizational measures designed to protect personal data against accidental loss, unauthorized access, disclosure, alteration, and destruction. These measures may include access controls, authentication, encryption in transit, logging, provider security controls, payment-provider tokenization, and vendor management. No website, application, payment system, advertising system, transmission, or storage method is completely secure. You are responsible for protecting your credentials and using secure devices and networks.

15. Your Choices

You may be able to access, update, correct, export, or delete certain information through your account settings. You may control some cookies, SDKs, ad personalization, tracking, notifications, marketing, and payment-related settings through the Services, your browser, your device, your app store account, payment provider settings, or a privacy request. You may request account deletion from your profile page or by contacting support@logviva.com. Deleting your account may delete or disable access to personal data associated with the account, subject to legal, payment, fraud-prevention, tax, security, backup, and dispute-resolution retention needs.

16. Privacy Rights by Region

United States: Depending on your US state of residence, you may have rights to access, correct, delete, port, or opt out of certain processing of personal data, including targeted advertising, sales, sharing, or profiling where applicable. Canada: If you are in Canada, you may request access to personal information we hold about you, request correction of inaccurate or incomplete information, withdraw consent where applicable, ask questions about our privacy practices, and challenge compliance with applicable Canadian privacy law. EU/EEA: If you are in the EU or EEA, you may have the right to request access, rectification, erasure, restriction of processing, data portability, objection to processing, withdrawal of consent, and complaint to a supervisory authority. These rights are subject to limits and exceptions under applicable law. We may ask for information to verify your identity and process your request.

17. Automated Decision-Making, Profiling, and AI

The Services may generate estimates, summaries, calculations, or suggestions based on information you provide and food database information. As of this draft, the Services are not intended to make automated decisions that produce legal or similarly significant effects. For EU/EEA users, if we introduce automated decision-making that produces legal or similarly significant effects, we will provide required notices and rights. If future AI functionality is added, this Privacy Policy should be updated before launch to describe the data used, purposes, legal bases, retention, opt-out or consent choices, and whether user content is used for model training.

18. Marketing and Communications

We may send service-related messages that are necessary for account, security, legal, payment, subscription, billing, or operational reasons. We may send marketing communications, promotional offers, sponsored messages, or product updates where permitted by law or with consent where required. You may opt out of marketing communications, but you may still receive service-related messages. Push notifications, email marketing, SMS, and similar channels may be subject to separate consent rules depending on your location.

19. Data Accuracy

We rely on you to provide accurate account, profile, payment support, food log, and wellness information. You may correct certain information in your account or request correction as described above. Food database information, ads, sponsored content, prices, offers, subscription features, and payment status information may change and may be inaccurate or unavailable at times.

20. Open Data, Attribution, and Deidentified Data

We may use open, public, aggregated, or deidentified information to operate and improve the Services. Deidentified or aggregated information is not intended to identify you. We may preserve source identifiers, attribution, and license information for third-party food data. We do not claim ownership of third-party open data merely by displaying or processing it through the Services.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by the "Last updated" date above. If we make material changes, we will provide notice as required by applicable law. For Canada, EU, and EEA users, if a change requires renewed consent or additional notice, we will provide it before applying the changed processing where required.

22. Contact Information

Controller/organization: RN Simplicity

Product: Logviva

Email: support@logviva.com

Privacy requests: support@logviva.com

Mailing address: [MAILING ADDRESS, IF APPLICABLE]

EU/EEA representative: [EU/EEA REPRESENTATIVE, IF REQUIRED]

Data Protection Officer: [DPO CONTACT, IF APPOINTED]

Canadian privacy contact: [CANADIAN PRIVACY CONTACT, IF DIFFERENT]