Privacy Policy

Effective Date: May 19, 2026  ·  Version: 1.0  ·  Last Updated: May 19, 2026

Table of Contents

  1. Introduction
  2. Data Controller
  3. Personal Data Collected
  4. Purpose and Legal Basis
  5. Third-Party Services and Subprocessors
  6. International Data Transfers
  7. Data Retention
  8. Your GDPR Rights
  9. Data Security
  10. Changes to Privacy Policy
  11. Contact Information

1. Introduction

Welcome to eatamame, the food education app that lets you photograph or describe your meals and receive an AI-powered health score to guide you toward healthier eating habits.

Protecting your personal data is our top priority. This Privacy Policy informs you about what data we collect, why we collect it, how we use it, and your rights under the General Data Protection Regulation (GDPR – EU Regulation 2016/679) and the Italian Privacy Code (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

Our core privacy principles:

  • Privacy by Design: Analytics services are disabled by default
  • Explicit Consent: We always ask permission before collecting non-essential data
  • Data Minimization: We only collect data strictly necessary for the service
  • Transparency: We clearly explain what we do with your data
  • Guaranteed Rights: You can access, modify, export, or delete your data at any time

2. Data Controller

eatamame

Email: team@eatamame.com

For any request regarding the processing of your personal data or to exercise your GDPR rights, you can contact us at the address above.

3. Personal Data Collected

eatamame collects different categories of personal data, depending on the features you use and the consents you have provided.

3.1 Authentication Data

Always Collected

Legal Basis: Art. 6(1)(b) GDPR – Contract performance

When you create an eatamame account via Google Sign-in or Apple Sign-in, we collect:

  • Email: Required to identify your account
  • Full Name: First and last name provided by the authentication provider
  • Firebase UID: Unique identifier generated by Firebase Authentication
  • Login Method: Google or Apple
  • Registration Date: Account creation timestamp

This data is essential to create and manage your account, allow you to access the app, and sync your meal history across devices.

3.2 Meal Data

Always Collected

Legal Basis: Art. 6(1)(b) GDPR – Contract performance

When you use eatamame to log a meal, we collect:

  • Meal Description: Text describing your meal (ingredients, quantities)
  • Meal Type: Breakfast, lunch, dinner, or snack
  • AI Analysis Result: Health score (1–10), nutritional estimates, badges, tips, and analysis text
  • Timestamp: Date and time of the meal
  • Food Preference: Your dietary preference (no preference, vegetarian, vegan)

Where it's stored: Firebase Firestore (server: europe-west1 – Belgium)

Important – Health Data (Art. 9 GDPR): Meal data may reveal information about your dietary habits, food intolerances, or health conditions and may constitute special category data. This data is processed exclusively on the basis of your explicit consent and is never shared with third parties for commercial purposes or used for profiling.

3.3 Temporary Media Files

Processed and Immediately Deleted

Legal Basis: Art. 6(1)(b) GDPR – Contract performance

When you use the photo or audio input features, we temporarily process meal photos and audio recordings.

  1. The file is uploaded to Firebase Storage in a temporary path
  2. Our backend Cloud Function reads the file and sends it to Google Gemini AI for analysis
  3. The file is permanently deleted immediately after analysis
  4. Only the resulting text description is retained — no photo or audio is ever stored

3.4 AI Usage Counters

Always Collected

Legal Basis: Art. 6(1)(b) GDPR – Contract performance

To ensure fair and sustainable use of the AI service, we maintain daily, weekly, and monthly AI request counts per user. This data is used to enforce fair usage limits and prevent abuse.

3.5 Onboarding Profile Data

Voluntarily Provided

Legal Basis: Art. 6(1)(a) GDPR – Explicit consent; Art. 9(2)(a) GDPR – for health-related data

During onboarding, we may ask you to share information to personalize your experience. All fields are answered voluntarily: age range, gender, occupation, food goals, main struggles, healthy eating frequency, food choice confidence, and more.

Important – Health Data (Art. 9 GDPR): Some fields may relate to physical or psychological well-being and fall under Article 9 GDPR. This data is not shared with third parties for commercial purposes and not used for individual profiling.

3.6 Analytics

Consent Required

Legal Basis: Art. 6(1)(a) GDPR – Explicit consent

If you accept analytics consent, we collect anonymous usage data via PostHog: screen views, user actions, device info, and timestamps — using a randomly generated anonymous identifier that cannot be traced back to you.

What we DON'T collect:

  • ❌ Email or username
  • ❌ Firebase UID or account identifier
  • ❌ IP Address
  • ❌ Content of your meals or photos
Server:
Europe – PostHog EU Cloud (Frankfurt, Germany)
Retention:
7 years
How to revoke:
Settings → Privacy → Disable "App Analytics"

3.7 Error Monitoring

Consent Required

Legal Basis: Art. 6(1)(a) GDPR – Explicit consent

If you accept error monitoring consent, we collect technical information about crashes via Sentry: stack traces, device info, and breadcrumbs. We do NOT collect IP addresses, email, meal content, or session recordings.

Server:
Germany (EU)
Retention:
90 days from the error
How to revoke:
Settings → Privacy → Disable "Error Monitoring"

3.8 Email Marketing

Consent Required

Legal Basis: Art. 6(1)(a) GDPR – Explicit consent

If you join our waitlist or accept marketing emails, we subscribe your email to our newsletter via Loops.so (email, name, subscription date and status).

Server:
USA (Standard Contractual Clauses – SCC)
Retention:
Until consent revocation or account deletion
How to revoke:
Click "Unsubscribe" in any email, or Settings → Privacy

4. Purpose and Legal Basis

Pursuant to Art. 13 GDPR, below we summarize the processing purposes and related legal bases:

DataPurposeLegal BasisMandatory?
Email, Name, UIDAuthentication and account managementArt. 6(1)(b) – Contract✅ Yes
Meal data (descriptions, scores)Meal tracking service provisionArt. 6(1)(b) + Art. 9(2)(a)✅ Yes
Temporary media (photos, audio)AI analysis – deleted immediatelyArt. 6(1)(b) – Contract❌ Optional
AI usage countersFair use enforcementArt. 6(1)(b) – Contract✅ Yes
Onboarding profileApp personalizationArt. 6(1)(a) + Art. 9(2)(a)❌ No
Analytics (PostHog)App improvement and UXArt. 6(1)(a) – Consent❌ No
Error Tracking (Sentry)App stability and bug fixingArt. 6(1)(a) – Consent❌ No
Email Marketing (Loops)Newsletter and promotionsArt. 6(1)(a) – Consent❌ No

5. Third-Party Services and Subprocessors

eatamame uses the following third-party services to process your personal data:

Firebase / Google Cloud Platform

Services:
Authentication, Firestore, Cloud Functions, Firebase Storage, App Check
Location:
Europe (europe-west1 – Belgium)
Data:
Email, name, UID, meal data, temporary media files
Legal Basis:
Art. 6(1)(b) GDPR – Contract

Google Gemini AI

Service:
AI-powered meal analysis and audio transcription
Model:
Gemini 2.5 Flash Lite
Data:
Meal text/photo/audio — not retained by Google beyond the API call
Legal Basis:
Art. 6(1)(b) + Art. 9(2)(a) GDPR

PostHog (Analytics)

Location:
Europe (Frankfurt, Germany – EU Cloud)
Data:
App events, anonymous_id, device info
Legal Basis:
Art. 6(1)(a) GDPR – Consent
Consent Required:
Yes ("App Analytics")

Sentry (Error Tracking)

Location:
Germany (EU)
Data:
Stack traces, device info, breadcrumbs
Legal Basis:
Art. 6(1)(a) GDPR – Consent
Consent Required:
Yes ("Error Monitoring")

Loops.so (Email Marketing)

Location:
USA (Standard Contractual Clauses)
Data:
Email, name, subscription status
Legal Basis:
Art. 6(1)(a) GDPR – Consent
Consent Required:
Yes

RevenueCat (Subscription Management)

Location:
USA (Standard Contractual Clauses)
Data:
Firebase UID, transaction data, subscription status
Legal Basis:
Art. 6(1)(b) GDPR – Contract
Consent Required:
No

6. International Data Transfers

Some subprocessors are located in the United States. We ensure all international data transfers comply with Chapter V of the GDPR (Art. 44–49).

Data Stored in EU

  • ✅ Firebase (europe-west1 – Belgium)
  • ✅ PostHog (Frankfurt, Germany)
  • ✅ Sentry (Germany)

Transfers to USA

Services: Loops.so, RevenueCat, Google Gemini API

Legal Mechanism: Standard Contractual Clauses (SCC) – Commission Decision 2021/914/EU

7. Data Retention

We retain your personal data only for as long as necessary, in accordance with Art. 5(1)(e) GDPR.

Data TypeRetention Period
Account and authenticationUntil account deletion
Meal data (descriptions, scores)Until account deletion
Temporary media (photos, audio)Deleted immediately after AI processing (seconds)
AI usage countersUntil account deletion
Onboarding profile dataUntil account deletion
Analytics (PostHog)7 years
Error logs (Sentry)90 days from the error
Email marketing (Loops)Until consent revocation or account deletion
Transaction data (RevenueCat)12 months after account deletion

Automatic Deletion on Account Deletion

When you delete your eatamame account, all data is deleted immediately:

  • ✅ Firebase Auth account deleted
  • ✅ All Firestore data deleted (meals, profile, settings, usage counters)
  • ✅ Any residual Firebase Storage files deleted
  • ✅ Loops contact deleted
  • ✅ RevenueCat customer deleted or anonymized
  • ✅ PostHog / Sentry: no deletion required (completely anonymous data)

8. Your GDPR Rights

In accordance with Articles 15–22 of the GDPR, you have the following rights:

Right of Access (Art. 15)

Obtain a copy of all personal data we hold about you. Contact us at team@eatamame.com — we will respond within 30 days.

Right to Data Portability (Art. 20)

Receive your data in a structured, machine-readable format. Go to Settings → Export Data in the app.

Right to Erasure (Art. 17)

Request deletion of all personal data. Go to Settings → Delete Account. All data will be permanently deleted immediately.

Right to Object (Art. 21)

Object to processing for analytics or marketing. Go to Settings → Privacy and disable the relevant consents. Effect is immediate.

Right to Rectification (Art. 16)

Correct inaccurate data. Edit meals directly in the app, or contact us at team@eatamame.com for other data.

Right to Restriction (Art. 18)

Request restriction of processing in certain circumstances. Contact us at team@eatamame.com.

Right to Withdraw Consent (Art. 7)

Withdraw consent at any time without affecting prior processing. Go to Settings → Privacy.

Right to Lodge a Complaint

If you believe we have violated the GDPR, you can lodge a complaint with the Italian Data Protection Authority (Garante):

Piazza Venezia, 11 – 00187 Rome, Italy  ·  garante@gpdp.it  ·  garanteprivacy.it

9. Data Security

We adopt appropriate technical and organizational measures in accordance with Art. 32 GDPR.

Technical Measures

  • ✅ TLS 1.3 for all communications
  • ✅ Encryption at rest (AES-256)
  • ✅ JWT tokens for authentication
  • ✅ OAuth 2.0 (no passwords stored)
  • ✅ Firestore Security Rules
  • ✅ Firebase App Check

Organizational Measures

  • ✅ Data access limited to authorized personnel
  • ✅ DPAs signed with all subprocessors
  • ✅ Incident Response Plan in place
Data Breach Notification: In case of a breach, we commit to notify the supervisory authority within 72 hours (Art. 33 GDPR) and affected users without undue delay if high risk is involved (Art. 34 GDPR).

10. Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time to reflect regulatory changes, new features, or improvements in data protection.

  • For substantial changes (new subprocessors, new processing purposes): email and in-app notification with 30 days' notice
  • For minor changes (editorial corrections, clarifications): only the "Last Updated" date will be updated

11. Contact Information

For any question, request, or complaint regarding the processing of your personal data:

Email: team@eatamame.com

We commit to respond within 30 days of receiving the request (Art. 12.3 GDPR).

© 2026 eatamame. All rights reserved.  ·  Version 1.0  ·  Published May 19, 2026