Privacy Policy
Effective: pending (not yet in force). Applies to the Gramito app (closed beta and later releases) and this website. Information under Articles 13 and 14 of the GDPR (Regulation (EU) 2016/679).
1. Who is responsible
The controller of your personal data is devcore s. r. o., registered office Vysokoškolákov 8556/33B, 010 08 Žilina, Slovakia, Company ID (IČO) 57 304 807, entered in the commercial register: District Court Žilina, Section Sro, insert no. 89211/L. Contact for all privacy questions and for exercising your rights: [email protected]. We have not appointed a data protection officer; the contact above handles privacy matters.
2. Who the app is for
Gramito is intended for adults (18 and over). We do not knowingly process data of anyone under 18. If you believe a minor uses the app, write to us and we will delete the account.
3. What we process, why, on what basis, and for how long
| Data | Why | Legal basis | Kept |
|---|---|---|---|
| Account: name and e-mail from Sign in with Apple or Google, the provider's account id, session records (token, IP address, device/app description) | Sign in, keep you signed in (30 days) | Contract, Art. 6(1)(b) | Until you delete the account; a session ends after 30 days |
| Profile: sex, date of birth, height, weight, activity level, goal, target weight, pace, your own target overrides, language, units, time zone | Calculate your daily target and forecast | Your explicit consent to health data, Art. 9(2)(a) with Art. 6(1)(a) | Until you delete the account |
| Weight entries, diary entries (food, amounts, calories, protein, fat, carbs, meal type, notes), your own dishes and foods | The diary, progress and plan | Explicit consent to health data, Art. 9(2)(a) | Until you delete them or the account |
| Photos of meals (originals and small thumbnails) and photos you send in the assistant chat | Show the photo in the diary; recognition | Contract, Art. 6(1)(b); consent to AI processing, Art. 6(1)(a) | Diary photos until you delete the entry, the history or the account; chat photos with the chat messages |
| Assistant chat messages and meal descriptions | Answer you, recognise meals | Consent to AI processing, Art. 6(1)(a) (and Art. 9(2)(a) where they reveal health data) | Chat messages older than 90 days are deleted automatically; earlier if you delete them or the account |
| Your consents (health, AI, statistics): which, which text version, when granted or withdrawn | Prove and honour your choices | Legal obligation to demonstrate consent, Art. 7(1) and 6(1)(c); legitimate interest, Art. 6(1)(f) | Until you delete the account |
| AI usage records: which kind of AI call, when, token counts, whether a photo was included (no content) | Fair-use limits, cost control | Legitimate interest, Art. 6(1)(f) | Until you delete the account |
| Abuse-prevention identifier: a salted one-way hash of your sign-in provider and account id, with daily usage counters. No name, e-mail or user id | A deleted and re-created account must not get a fresh daily AI allowance | Legitimate interest, Art. 6(1)(f) | Deleted automatically 35 days after use, even if you delete your account |
| Support messages: your text, an optional reply address, app version and OS version. Not linked to your account | Answer you | Legitimate interest, Art. 6(1)(f) | 90 days |
| Support e-mails you write to us | Answer you | Legitimate interest, Art. 6(1)(f) | As long as needed to answer and document the request |
| Server logs: account id, event type, counts, error codes. No chat text, food text, e-mail or tokens. Our network provider also sees your IP address | Security, fixing faults | Legitimate interest, Art. 6(1)(f) | Server logs 14 days (rotated); the network provider keeps its own logs under its terms |
| Backups of the database (encrypted) | Recover from a failure | Legitimate interest, Art. 6(1)(f) | 14 daily and 8 weekly copies, then purged |
We do not collect your location, contacts or advertising identifiers. Meal reminders are scheduled on your phone; no push token is sent to our server at the moment. Dictation of a meal description uses the speech recognition built into your phone.
4. Health data and your consent
Weight, height, goal and food entries can reveal information about your health. We process them only with your separate, explicit consent (Art. 9(2)(a) GDPR), given during sign-up, not pre-ticked and not bundled with accepting these documents. You can withdraw it at any time in Profile › Settings › Privacy and consents. Withdrawal does not affect what was done before; without the consent the app cannot save new diary or weight data. Your existing data stays until you delete it.
5. AI processing
To recognise a meal and to power the assistant, the app sends data to an external AI provider: to be named before the public release. Before the first use the app asks for your consent and shows what is sent; nothing is sent without it.
- Sent: the meal photos you recognise or attach; meal descriptions and chat messages; your goal, weight and the day's food log, only when you ask the assistant about them.
- Purpose: only to answer you. According to the provider's API terms, data sent through the API is not used to train its models (we re-check this for the chosen provider before publication).
- Withdraw: Profile › Settings › Privacy and consents › AI recognition. Manual entry, search, barcode scan and favourites keep working without AI.
- Results are estimates, not medical advice. You are told that you are dealing with an AI.
6. Who else processes data
| Recipient | Role | What |
|---|---|---|
| Oracle Corporation (Oracle Cloud Infrastructure), data center eu-frankfurt-1, Germany | Processor: server and database hosting | All account data listed above |
| Cloudflare, Inc. | Processor: DNS, network proxy, firewall (DDoS and rate limiting), access control of our admin panel, object storage (R2, EU jurisdiction) for photos, thumbnails, temporary export files and encrypted backups, e-mail routing of the support address, hosting of this website | Traffic to our API including IP addresses; photos; exports; support e-mails |
| to be named before the public release | Processor (AI processing) | Photos, descriptions, chat messages, and on request goal, weight and day log |
| Apple Inc. / Google LLC | Sign-in providers (Sign in with Apple, Google sign-in); Apple also distributes the beta through TestFlight | Identity data you share on sign-in. They act under their own terms |
| Open Food Facts | Food database lookup by barcode | The barcode you scan (our server asks, not your phone; no account data) |
We do not sell personal data and do not use it for advertising or tracking. The app has no advertising or analytics SDKs.
7. Transfers outside your country
Some of the recipients above are located, or process data, outside the European Economic Area, including in the United States. Where this happens we rely on to be specified before the public release (for example the EU–US Data Privacy Framework or Standard Contractual Clauses). You can ask us for a copy of the safeguards.
8. Deleted data and backups
When you delete your account in the app, we delete your files from storage and your database records. Copies may remain in our encrypted backups until they are purged (14 daily and 8 weekly copies). The abuse-prevention identifier (section 3) is kept for 35 days. Deleting the account does not remove the Gramito entry from your Apple or Google account settings; you can also remove it there. Deleting the account does not cancel any store subscription; there are no payments in the beta.
9. Your rights
You have the right to: access your data (Art. 15); receive a copy in a machine-readable format (Art. 20: Profile › Account › Export data, a JSON file; the link works for one hour); correct it (Art. 16, edit in the app); delete it (Art. 17: Profile › Account › Delete account, or Delete food history); restrict processing (Art. 18); object to processing based on legitimate interest (Art. 21); and withdraw consent at any time (Art. 7(3)). To use a right the app does not cover, write to [email protected]. We may ask you to confirm your identity and we answer within one month.
You may complain to a supervisory authority. In Slovakia: Úrad na ochranu osobných údajov Slovenskej republiky (Office for Personal Data Protection of the Slovak Republic), Galvaniho 7/B, 821 04 Bratislava, dataprotection.gov.sk. You may also complain in the EU country where you live or work.
10. Automated decisions
We do not take decisions that have legal or similarly significant effects on you by automated means (Art. 22). AI estimates of calories and macronutrients, and the daily target calculated from your profile, are informational suggestions that you can change.
11. Security
Traffic is encrypted with HTTPS. There are no passwords: sign-in is Apple or Google only. Provider tokens are stored encrypted. Photos have random, unguessable addresses; data exports sit in a private bucket and are reachable only through a short-lived signed link, then deleted. Backups are encrypted. Requests are rate-limited, and the admin panel is behind an access gate. No system is perfectly secure; tell us at once if you suspect a problem. If a breach is likely to put you at high risk we tell you and the authority as the law requires.
12. Cookies and tracking
This website sets no cookies and loads no third-party scripts. The app does not track you across other apps or sites. (Our internal admin panel, not open to the public, uses a Cloudflare Access cookie for the administrators who sign in.)
13. Changes
We will post changes here and, for material changes, tell you in the app. The date at the top shows the current version.
14. Contact
devcore s. r. o., registered office Vysokoškolákov 8556/33B, 010 08 Žilina, Slovakia, Company ID (IČO) 57 304 807, entered in the commercial register: District Court Žilina, Section Sro, insert no. 89211/L. [email protected].