Privacy Policy

Effective Date: July 4, 2026

1. Introduction

SOFTPRIME SOLUTIONS CONCEPT S.R.L. ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, process, and safeguard your information when you use the "Easy Cals" mobile application (the "App").

2. Data Controller

SOFTPRIME SOLUTIONS CONCEPT S.R.L., a company registered in Romania, is the Data Controller responsible for your personal data under the General Data Protection Regulation (GDPR).

3. Information We Collect

We collect the following types of information to provide and improve our services:

  • Account Data: When you sign in using Apple or Google authentication, we collect your email address, name, and an authentication token.
  • Health and Biometric Data: To calculate your daily macronutrient and caloric targets, we collect physical attributes such as height, weight, age, biological sex, activity level, and dietary goals.
  • Dietary and Usage Data: Information you log into the App, including food entries, meal descriptions, and custom nutritional data.
  • Device and Advertising Identifiers: Device identifiers, including the Identifier for Vendor (IDFV) and — only if you grant tracking permission — the Advertising Identifier (IDFA), together with your IP address and app events such as account registration, free-trial starts, and subscription purchases. This data is used solely to measure the effectiveness of our own advertising campaigns (see Section 6).
  • Technical Data: Basic server request logs including IP addresses and user-agent strings necessary for the operation and security of our servers.

4. How We Use Your Information

Your data is used strictly for the following purposes:

  • Providing the core functionalities of the App (macro calculations and food tracking).
  • Processing text or queries via third-party artificial intelligence to identify foods and estimate nutritional content.
  • Authenticating your account and maintaining your session security.
  • Managing your subscription and free-trial status.
  • Measuring and improving the performance of our own advertising campaigns (advertising attribution), based on your consent where required.
  • Sending account-related or technical support emails. We do not use your email address for marketing or promotional purposes.

5. Third-Party Data Sharing and Subprocessors

We do not sell your personal data. We share necessary data with the following third-party service providers solely to operate the App and to measure our own advertising:

  • Hosting Provider: Our backend systems and databases are hosted securely on Linode (Akamai). Your data is stored on their servers.
  • Authentication Providers: Apple and Google process your login credentials.
  • Payment Processor: All subscription payments are processed entirely by Apple. We do not collect, process, or store your credit card or billing information.
  • Subscription Management (RevenueCat): We use RevenueCat to manage subscriptions and free trials. RevenueCat processes your purchase history, subscription status, email address, and device identifiers on our behalf.
  • Advertising Attribution (AppsFlyer): We use AppsFlyer, a mobile measurement service, to understand which of our advertising campaigns lead to app installs and subscriptions. AppsFlyer processes device identifiers (IDFV; IDFA only with your tracking permission), IP address, and app events such as installs, registrations, trial starts, and purchases.
  • Advertising Platforms (TikTok): Attribution data (device identifiers and subscription events) may be shared, via AppsFlyer, with advertising platforms on which we run our own campaigns — currently TikTok — so they can measure and optimize the delivery of our ads. We never share your health data, food logs, name, or email address with advertising platforms.
  • AI Providers: To analyze food inputs, meal descriptions are sent to third-party AI services via OpenRouter (including models from OpenAI and Google). Note: We do not send your name, email, or account identifiers to these AI models. Only the specific food query or prompt is transmitted.
  • Food Databases: Anonymous queries are made to the USDA FoodData Central (FDC) and Open Food Facts to retrieve nutritional data.

6. Advertising Measurement and Your Choices

To keep the App available, we advertise it on platforms such as TikTok and measure how well those campaigns perform. On iOS, this involves Apple's App Tracking Transparency (ATT) framework:

  • Your permission is asked first. The App will request permission before accessing your Advertising Identifier (IDFA). If you decline, the IDFA is never accessed, and campaign measurement relies only on privacy-preserving, aggregate mechanisms provided by Apple (SKAdNetwork), which do not identify you individually.
  • What is shared: Only device identifiers and subscription-related events (install, registration, trial start, purchase, including product and price) are used for advertising measurement. Your health data, biometric data, food logs, name, and email address are never shared with advertising partners.
  • Changing your choice: You can grant or revoke tracking permission at any time in iOS Settings > Privacy & Security > Tracking.

7. Data Retention and Deletion

We retain your personal data only for as long as your account is active.

  • Account Deletion: You can delete your account and all associated data at any time directly within the App's settings menu.
  • Upon requesting account deletion, your biometric data, dietary logs, and account identifiers are permanently removed from our active Linode database.

8. Your Rights (GDPR)

As a resident of the European Economic Area (EEA), or under applicable global privacy laws, you have the right to:

  • Access the personal data we hold about you.
  • Request correction of inaccurate personal data.
  • Request erasure of your personal data ("Right to be Forgotten").
  • Object to or restrict the processing of your personal data.
  • Request the transfer of your personal data to another party (Data Portability).
  • Withdraw consent at any time where processing is based on consent, including tracking for advertising measurement (see Section 6).

To exercise any of these rights, contact us at the email address provided below.

9. International Data Transfers

Because we utilize third-party services (such as OpenRouter for AI processing, RevenueCat for subscription management, and AppsFlyer and TikTok for advertising measurement), some data may be processed on servers located outside the European Economic Area (EEA), including in the United States. We rely on legally approved transfer mechanisms, such as Standard Contractual Clauses (SCCs), to ensure your data remains protected.

10. Children's Privacy

The App is restricted to users who are 18 years of age or older. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have collected personal data from a minor, we will take immediate steps to delete that information from our servers.

11. Security

We implement industry-standard security measures, including encrypting all data in transit using HTTPS and securing our backend server infrastructure, to protect your personal information from unauthorized access, alteration, or disclosure.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy within the App and updating the "Effective Date" at the top of this document.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how your data is handled, please contact us at:

SOFTPRIME SOLUTIONS CONCEPT S.R.L.
Email: [email protected]