1. Introduction and Scope #

This Privacy Policy explains how FlashSoft OÜ, a private limited company (osaühing) incorporated under the laws of the Republic of Estonia ("Company", "we", "us" or "our"), processes information in connection with the mobile application Fasting Tracker (the "App").

For the purposes of the EU General Data Protection Regulation (GDPR) and the UK GDPR, the Company is the controller of Personal Data processed through the App, except where a Third-Party Service or an App Store Provider acts as an independent controller, as described in this Privacy Policy.

This Privacy Policy applies only to the App. It does not apply to any Third-Party Services, websites or apps, even if they are accessible through the App.

By downloading, installing, accessing or using the App, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the App and must delete it from your Device.

This Privacy Policy forms part of, and should be read together with, our End User License Agreement (Terms of Use) available at https://flashsoftapps.com/fasting-tracker-eula.html.

2. Definitions #

• "Personal Data" means any information relating to an identified or identifiable natural person.
• "Processing" means any operation performed on Personal Data, such as collection, storage, use, disclosure or deletion.
• "Device" means the smartphone, tablet or other device on which the App is installed.
• "Third-Party Services" means services, software development kits (SDKs), platforms and content provided by persons other than the Company.
• "App Store Provider" means Apple Inc. (App Store) or Google LLC (Google Play), as applicable.

3. Information We Collect #

3.1 Information You Provide to Us #

We do not require you to create an account or to provide your name, email address or other contact details to use the core features of the App, unless stated otherwise below.

If you contact us, for example by email, we process the information you choose to provide, such as your email address, name and the content of your message, in order to respond to you.

Content You Submit to AI Features. When you use AI-powered features, the text, images, audio or other content you submit ("Input") is transmitted to our AI service provider(s) listed in Section 4 to generate a response ("Output"). Do not submit sensitive Personal Data, confidential information, or Personal Data of other people through AI features. Input and Output are processed by the provider in accordance with its own terms and privacy policy.

Content Processed on Our Servers. Where a feature requires server-side processing, the content you submit (meal photos you submit for a calorie estimate, and the messages and profile you send to the AI coach) is transmitted to servers operated on our behalf by Hostpro Lab LLC (Ukraine) and is processed only to provide that feature. Such content is deleted within seven (7) days after processing, unless a longer period is required by law or you choose to store it in the App.

Sync via Your iCloud Account. If you are signed in to iCloud, the App may use Apple's iCloud service to sync your settings, profile, fasting, weight and water history, fasting notes and moods, AI coach conversation history and nutrition diary (without meal photos) across your own Devices. This information is stored in your private iCloud account, governed by Apple's privacy policy, and is not transmitted to our servers and not accessible to us. You can control this at any time in your Device's iCloud settings, including by disabling iCloud for the App or deleting the data from iCloud.

Profile You Enter. During onboarding and later in the App, you may enter information about yourself, such as your sex, age, height, current and goal body weight, activity level and goals, and you may log fasts, meals, water, weight, notes and moods. This information is stored on your Device and, if enabled, in your own iCloud account. Once, when you complete onboarding, your age, sex and body mass index are sent to Apphud as attributes of your app user identifier, which we use to analyze subscription performance by user group.

AI Coach and Your Health Profile. When you send a message to the AI coach or request weekly tips, the App sends your message to our server together with a profile built from the information in the App, so that answers can be specific to you: sex, age, height, current, starting and goal body weight, body mass index, goal and activity level, fasting plan, current fasting or eating phase and the time spent and left in it, fasting streak and statistics for the last seven days, daily calorie and protein targets, the calories, protein and number of meals logged today, water goal and water logged today, unit system and your local time. The profile does not include your name, email address, notes or photos. Our server forwards the message and the profile to OpenAI, as described in Section 4, and does not store them. OpenAI stores AI coach conversations for at least thirty (30) days so that the coach can continue the conversation, and may retain requests for up to thirty (30) days for abuse monitoring. This information concerns your health and is a special category of Personal Data. If you are located in the EEA, the UK or Switzerland, we process it on the basis of your explicit consent (Art. 9(2)(a) GDPR), which you give by choosing to use the AI coach after being informed in this Privacy Policy, and which you can withdraw at any time by no longer using the AI coach. If you do not want this information to be processed, do not use the AI coach.

3.2 Information Collected Automatically #

When you use the App, certain information is collected automatically by the App and by the Third-Party Services integrated into it, including:

• Device information: Device model, manufacturer, operating system and version, language, time zone, screen parameters, and technical information about the Device such as memory and storage.
• Identifiers: app instance identifiers, installation identifiers, app user identifiers, the vendor identifier (IDFV) on iOS, the app set ID on Android and, only where you have permitted access, the advertising identifier (IDFA on iOS or Android Advertising ID on Android).
• Usage data: the date and time of your use of the App, first launch, sessions, screens viewed, features used, taps and other in-app events.
• Diagnostic data: crash reports, error logs, performance data and related technical information.
• Approximate location: country, region and city derived from your IP address. We do not collect your precise GPS location unless stated in Section 3.4.
• Purchase information: information about Subscriptions and in-app purchases, such as product identifier, transaction identifier, purchase date, renewal status, price and currency, and trial status.
• Advertising data: information about advertisements shown to you and your interactions with them.

3.3 Information from App Store Providers #

When you make a purchase in the App, the App Store Provider processes your payment and provides us, directly or through Apphud, with transaction information necessary to validate and manage the purchase. We do not receive or store your payment card details, billing address or App Store Provider account password.

3.4 Device Permissions #

The App may request permission to access certain features of your Device. You decide whether to grant each permission and can change your decision at any time in your Device settings. If you decline or revoke a permission, some features of the App may not be available or may not work properly, and the Company is not responsible for any resulting limitation.

Camera. The App may request access to your Device camera to photograph your meals for an AI calorie estimate and scan product barcodes. Camera access is used only when you actively use the related feature. Unless stated otherwise in this Privacy Policy, images and video captured through the App are processed on your Device and are not transmitted to us. You can grant or revoke camera access at any time in your Device settings.

Photo Library. The App may request access to your photo library to choose a meal photo for an AI calorie estimate. The App accesses only the photos and videos you select or, where applicable, the items you allow in your Device settings. Unless stated otherwise in this Privacy Policy, selected media is processed on your Device and is not transmitted to us. The App may save content you create to your photo library when you instruct it to do so.

Notifications. The App may ask for permission to send you notifications, such as reminders and information about features or offers. You can disable notifications at any time in your Device settings.

Apple Health (iOS). With your permission, the App may read the following data from Apple Health: steps and body weight, and may write the following data that you log in the App to Apple Health: water intake and body weight. Data read from Apple Health is used to show your daily activity and keep your weight history up to date. Body weight read from Apple Health is added to the weight history in the App; like the rest of your App data, this history may be synced through your own iCloud account and may be included in the profile sent with AI coach requests, as described in Section 3.1. Data read from Apple Health is not shared with the analytics and advertising Third-Party Services listed in Section 4, is not used for advertising, marketing or data mining, and is not sold. You choose which data types to share on the iOS permission screen and can change your choice at any time in the Health app or in Settings > Privacy & Security > Health. If you are located in the EEA, the UK or Switzerland, this processing is based on your explicit consent (Art. 9(2)(a) GDPR), which you give and can withdraw through the iOS Health permissions.

3.5 Information We Do Not Intentionally Collect #

Unless expressly stated in this Privacy Policy, we do not intentionally collect your name, postal address, phone number, precise location, contacts, photos, files, or any special categories of Personal Data (such as data concerning health, biometric data, racial or ethnic origin, political opinions, religious beliefs or sexual orientation). Please do not send us such information.

4. Third-Party Services We Use #

The App uses the Third-Party Services listed below. These providers collect and process information directly from your Device in accordance with their own privacy policies. Some of them process data on our behalf as processors, and some act as independent controllers. We do not control, and are not responsible for, the data practices of Third-Party Services. We encourage you to read their privacy policies.

Apphud. We use Apphud, provided by Apphud Inc. (USA), to manage Subscriptions and in-app purchases, validate purchase receipts, restore purchases and analyze subscription performance. Apphud processes purchase and transaction history, device identifiers (such as IDFV, and IDFA or Android Advertising ID where you have permitted access), an app user identifier, country, language, locale, time zone, IP address, device model, operating system version, app version and the date of your last activity in the App. Apphud does not receive your payment card details. Apphud's privacy policy is available at https://legal.apphud.com/privacy.

Firebase Analytics. We use Google Analytics for Firebase, provided by Google, to understand how the App is used and to improve it. Firebase Analytics automatically collects an app instance identifier, the advertising identifier where you have permitted access, device model, operating system and app version, language, country and approximate region, first launch, session information, screens viewed, and in-app events and purchases. Your approximate location is derived from your IP address; according to Google, IP addresses are not logged or stored in Google Analytics. More information is available at https://firebase.google.com/support/privacy and in Google's Privacy Policy at https://policies.google.com/privacy.

Firebase Crashlytics. We use Firebase Crashlytics, provided by Google, to receive crash reports and diagnose errors. When the App crashes or experiences an error, Crashlytics may collect a crash installation identifier, a Firebase installation ID, crash stack traces and logs, device model, processor architecture, memory and disk space, operating system name and version, app version, device state (such as orientation and jailbreak or root status) and timestamps. According to Google, this data is retained for ninety (90) days. More information is available at https://firebase.google.com/support/privacy.

Amplitude. We use Amplitude, provided by Amplitude, Inc. (USA), for product analytics, to understand how users interact with the App and to improve its features, onboarding and purchase flows. Amplitude may collect a device identifier, an app user identifier, the advertising identifier where you have permitted access, in-app events and interactions, session data, device model, operating system and app version, mobile carrier, language, and country, region and city derived from your IP address. Amplitude's privacy notice is available at https://amplitude.com/privacy.

Google AdMob. We use Google AdMob, provided by Google, to display advertisements in the App. AdMob may collect your IP address (which may be used to estimate the general location of your Device), your advertising identifier (IDFA on iOS or Android Advertising ID on Android) where you have permitted access, an app set ID, information about your interactions with advertisements and the App (such as app launches, taps and video views), diagnostic and performance data, and Device and operating system information. This data is used by Google to deliver, measure and personalize advertisements and to prevent fraud and abuse. Learn how Google uses this information at https://policies.google.com/technologies/partner-sites.

Firebase Remote Config. We use Firebase Remote Config, provided by Google, to deliver configuration values to the App, such as settings for features and in-app screens, without requiring an App update. Remote Config uses a Firebase installation ID to select the configuration values returned to your Device. According to Google, Firebase installation IDs are retained until we request their deletion and are then removed from Google's systems within 180 days. More information is available at https://firebase.google.com/support/privacy.

AppsFlyer. We use AppsFlyer, provided by AppsFlyer Ltd. (Israel), for mobile attribution and marketing analytics: to understand which campaign or channel led you to install the App, to measure the performance of our marketing and to detect advertising fraud. AppsFlyer may collect your IP address (which may indicate your general location), user agent, the advertising identifier (IDFA on iOS or Android Advertising ID on Android) where you have permitted access, device type, operating system version and system language, and engagement data such as clicks, impressions, installations and in-app events. AppsFlyer's services privacy policy is available at https://www.appsflyer.com/legal/services-privacy-policy/.

Meta (Facebook SDK). We use the Facebook SDK, provided by Meta Platforms, Inc. (USA) and, for users in the EEA and Switzerland, Meta Platforms Ireland Limited, to record app events, such as installations, launches and in-app purchases, in order to measure and optimize our advertising campaigns on Meta platforms. The SDK may collect the advertising identifier (IDFA) where you have permitted access, app event data, Device information, your IP address and diagnostic data about the SDK. Meta may combine this information with other information it holds and uses it in accordance with its Privacy Policy, available at https://www.facebook.com/privacy/policy/, and the Meta Business Tools Terms.

OpenAI. AI features of the App are provided using the OpenAI API, provided by OpenAI Ireland Ltd (Ireland) and OpenAI OpCo, LLC (USA). The App sends your requests to our server, which forwards them to OpenAI. OpenAI processes the content you submit and the generated responses on our behalf to provide the feature. According to OpenAI, data sent to its API is not used to train its models, and it may be retained for up to thirty (30) days for abuse monitoring, unless longer retention is required by law. More information is available at https://openai.com/enterprise-privacy/ and in OpenAI's Privacy Policy at https://openai.com/policies/privacy-policy/.

Open Food Facts. When you scan a product barcode, the App requests the product's name, nutrition facts and ingredients from Open Food Facts, an open food database operated by a non-profit association in France. The request contains the barcode number and the name and version of the App, and Open Food Facts receives the IP address of your Device. Open Food Facts processes this information as an independent controller in accordance with its privacy policy, available at https://world.openfoodfacts.org/privacy.

USDA FoodData Central. If Open Food Facts has no data for a scanned barcode, the App searches FoodData Central, a food database of the U.S. Department of Agriculture, through the api.data.gov service. The request contains the barcode number, and the service receives the IP address of your Device. More information is available at https://data.gov/privacy-policy/.

Hostpro. Our server, which receives requests from server-based features of the App and forwards them to our AI service provider, is hosted by Hostpro Lab LLC in Ukraine, which processes this data on our behalf. More information is available at https://hostpro.ua/en/tos/.

Apple and Google. Purchases and Subscriptions are processed by the App Store Provider through which you downloaded the App: Apple Inc. (https://www.apple.com/legal/privacy/) or Google LLC (https://policies.google.com/privacy). The App Store Provider acts as an independent controller of your account and payment information. We do not receive or store your payment card details, billing address or App Store account password.

5. How We Use Information #

We and our Third-Party Services use the information described in this Privacy Policy for the following purposes:

• to provide, operate and maintain the App and its features;
• to process, validate, manage and restore Subscriptions and in-app purchases;
• to monitor the stability and performance of the App and to diagnose and fix errors and crashes;
• to analyze how the App is used and to develop, test and improve the App, its features, content and user experience;
• to measure the effectiveness of our marketing and promotional activities;
• to display advertisements, including personalized advertisements where you have given consent or where otherwise permitted by law, and to measure their performance;
• to provide AI-powered features by transmitting your Input to our AI service provider(s) and returning the Output to you;
• to sync your settings and content across your own Devices through your iCloud account;
• to personalize AI coach answers and weekly tips using the health and fitness profile described in Section 3.1;
• to detect, prevent and address fraud, abuse, security incidents and technical issues;
• to respond to your requests and communicate with you;
• to comply with legal obligations and to establish, exercise or defend legal claims;
• for any other purpose with your consent.

6. Legal Bases for Processing (EEA, UK and Switzerland) #

If you are located in the European Economic Area, the United Kingdom or Switzerland, we rely on the following legal bases:

• Performance of a contract (Art. 6(1)(b) GDPR): to provide the App and to process and manage your Subscriptions and purchases.
• Legitimate interests (Art. 6(1)(f) GDPR): to keep the App secure and stable, to diagnose errors, to analyze and improve the App, to prevent fraud, and to establish, exercise or defend legal claims. Our legitimate interests are not overridden by your interests or fundamental rights, taking into account the pseudonymous nature of most of the data.
• Consent (Art. 6(1)(a) GDPR): where required by applicable law, including for personalized advertising, for access to the advertising identifier and for storing or accessing information on your Device. You may withdraw your consent at any time as described in Section 13. Withdrawal does not affect the lawfulness of processing before withdrawal.
• Legal obligation (Art. 6(1)(c) GDPR): where processing is necessary to comply with the law, such as accounting and tax obligations.

7. Advertising and Tracking #

The free version of the App may display advertisements provided by Google AdMob. Advertisements are provided by third parties, and the Company does not control their content.

Consent in the EEA, UK and Switzerland. Where required by law, the App displays a consent message, provided through a consent management solution certified by Google, before personalized advertising is used. If you do not consent, you may still see non-personalized or limited advertisements, which are based on contextual information such as the App content and your general location.

App Tracking Transparency (iOS). On iOS, the App will request your permission before accessing your Device's advertising identifier (IDFA) for tracking purposes. If you decline, the IDFA is not made available to the App or to Third-Party Services.

How to limit personalized advertising:

• iOS: Settings > Privacy & Security > Tracking — disable "Allow Apps to Request to Track" or disable tracking for the App.
• Android: Settings > Google > Ads (or Settings > Privacy > Ads) — delete your advertising ID or opt out of ads personalization.
• Within the App: where available, use the privacy or consent settings to review or change your choices.

Limiting personalized advertising does not remove advertisements from the App; you may continue to see non-personalized advertisements.

8. How We Share Information #

We do not sell your Personal Data for money. We may share information only as follows:

• Third-Party Services listed in Section 4, which process data to provide their services to us or as independent controllers.
• App Store Providers, which process purchases and Subscriptions.
• Legal requirements: where we believe in good faith that disclosure is required by law, regulation, legal process or a governmental request, or is necessary to protect the rights, property or safety of the Company, our users or others.
• Business transfers: in connection with a merger, acquisition, reorganization, financing, sale of assets or similar transaction, in which case information may be transferred to the acquirer or successor.
• With your consent or at your direction.
• Aggregated or de-identified information that cannot reasonably be used to identify you may be shared for any lawful purpose.

9. International Data Transfers #

The Company is established in the European Union. Our Third-Party Services are located in, or transfer data to, countries outside the European Economic Area, including the United States, which may not provide the same level of data protection as your country. Where required, such transfers are based on the European Commission's adequacy decisions (including the EU-U.S. Data Privacy Framework, for certified recipients), Standard Contractual Clauses approved by the European Commission, or other lawful transfer mechanisms. By using the App, you acknowledge that your information will be transferred to and processed in such countries.

10. Data Retention #

We retain Personal Data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Information processed by Third-Party Services is retained in accordance with their retention policies, as summarized in Section 4. Correspondence with us is retained for as long as needed to handle your request and for a reasonable period afterwards to defend potential claims. When information is no longer needed, it is deleted or anonymized.

11. Data Security #

We and our Third-Party Services use technical and organizational measures designed to protect information against unauthorized access, loss, misuse or alteration, including encryption in transit. However, no method of transmission over the internet or of electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your Device secure, including using a passcode, installing operating system updates and not using the App on a jailbroken or rooted Device. Where required by applicable law, we will notify you and/or the competent authorities of a personal data breach.

12. Your Rights #

12.1 EEA, UK and Switzerland #

Subject to the conditions and exceptions set out in applicable law, you have the right to:

• request access to your Personal Data;
• request rectification of inaccurate Personal Data;
• request erasure of your Personal Data;
• request restriction of processing;
• receive your Personal Data in a portable format;
• object to processing based on legitimate interests, including profiling;
• withdraw your consent at any time;
• lodge a complaint with a supervisory authority. The lead supervisory authority for the Company is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), https://www.aki.ee. You may also contact the authority in your country of residence.

12.2 United States #

Depending on your state of residence (for example, California, Virginia, Colorado, Connecticut, Utah, Texas or Oregon), you may have the right to know what Personal Data we process, to access and receive a copy of it, to correct it, to delete it, and to opt out of "targeted advertising", "sale" or "sharing" of Personal Data as defined by applicable state law. We do not sell Personal Data for money. The use of advertising and analytics Third-Party Services may be considered "sharing" or "targeted advertising" under some state laws; you can opt out as described in Section 7 and Section 13. We will not discriminate against you for exercising your rights. You may designate an authorized agent to make a request on your behalf, subject to verification.

12.3 How to Exercise Your Rights #

To exercise your rights, contact us at contact@flashsoftapps.com. We may need to verify your identity before responding. We respond within the time limits required by applicable law.

Most information processed through the App is pseudonymous and linked to Device or app identifiers rather than to your name or email address. To help us locate your data, please include in your request the App name, your Device platform and, if available, the identifiers shown in the App's settings or the transaction ID of your purchase. If we cannot reasonably identify the data relating to you, we may be unable to fulfill your request, as permitted by applicable law. Some requests may also be exercised directly with the relevant Third-Party Service or App Store Provider.

13. Your Choices and Controls #

• Device permissions: manage or revoke permissions at any time in your Device settings.
• Advertising identifier and tracking: control as described in Section 7.
• Consent choices: where the App displays a consent message, you may review or change your choices in the App's settings, where available.
• Subscriptions: manage or cancel through your App Store Provider account settings.
• Stop all collection: you can stop all collection of information by the App at any time by uninstalling the App from your Device.

14. Children's Privacy #

The App is not directed to children under the age of 13, or under the higher minimum age required for consent to data processing in your country (for example, 16 in some EEA countries). We do not knowingly collect Personal Data from such children. If you are a parent or guardian and believe that your child has provided Personal Data through the App, contact us at contact@flashsoftapps.com, and we will take steps to delete such information. Parents and guardians are responsible for supervising their children's use of Devices and apps.

15. Third-Party Links and Content #

The App may contain links to, or content from, third-party websites, apps and services, including advertisements. We are not responsible for the content, privacy practices or security of any third party. Your interactions with third parties are governed by their own terms and privacy policies.

16. Changes to This Privacy Policy #

We may update this Privacy Policy from time to time at our sole discretion. The updated version will be published at https://flashsoftapps.com/fasting-tracker-privacy-policy.html and will be effective from the "Last Updated" date shown above. Where required by applicable law, we will inform you of material changes through the App or by other appropriate means. Your continued use of the App after the "Last Updated" date means that you acknowledge the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

17. Language #

This Privacy Policy is written in English. If it is translated into another language, the English version prevails in the event of any inconsistency, to the extent permitted by applicable law.

18. Contact Us #

If you have any questions about this Privacy Policy or our data practices, contact us:

• Company: FlashSoft OÜ
• Email: contact@flashsoftapps.com
• Website: https://flashsoftapps.com