Privacy Policy

1. Introduction

Anfold is a food-and-training journal and assistant that uses AI to help you track meals, workouts, and notes on how you feel. This Privacy Policy explains which personal data we process when you use the Anfold app, for what purposes and on what legal basis, who receives it, how long we keep it, and what rights you have under the EU General Data Protection Regulation (GDPR). Much of what you log in Anfold is health data; section 5 explains how we handle it. Section 14 covers our website, anfold.app.

2. Controller and Contact

The controller responsible for processing your personal data is Avocado Technologies UG (haftungsbeschränkt), Caroline-Michaelis-Str. 15, 10115 Berlin, Germany. Email: [email protected].

We haven't appointed a data protection officer.

3. Data We Process

Depending on how you use Anfold, we process the following personal data:

• Account Data: Your name and email address, and your password, which our sign-in service stores only in protected (hashed) form. If you sign in with Apple or Google, we receive an identifier and the name and email address that Apple or Google shares with us (with Apple, possibly a relay address). We also store your user ID, language, and time zone.
• Profile Data: Birthday, gender, height, weight, activity level, nutrition and exercise goals, country, and units, and, if you add them, your city, dietary preferences, a short description of yourself, notes, and a profile photo.
• Health Details: If you add them: allergies and intolerances, medical conditions, and medications.
• Entries and Conversations: What you log and create in Anfold: meals, ingredients, and drinks, workouts, notes and check-ins about how you feel, photos you add, your messages to the assistant, entries saved in your Library, meal plans, and the analyses and replies the AI generates for you.
• Purchase and Fuel Data: Your subscription status, your purchases (product, date, store, and transaction IDs), and your fuel balance and usage. We don't receive your card or bank details: Apple or Google handles payment.
• Device and Technical Data: Device model, operating system and version, app version, language and time zone settings, IP address, crash and error reports, and identifiers created by the services described in section 6, such as installation IDs and your push token.
• Usage Data: Which features you use and when. We only collect this for usage analytics if you agree to it (see section 4).
• Communication: The content of emails you send us, and our replies.
• Information Stored on Your Device: The app doesn't use cookies. To work, it stores information on your device, such as your sign-in session, settings, and cached data, and the services described in section 6 store identifiers there (for example, app installation IDs). We only store or read information on your device where this is strictly necessary to provide the app you've asked for (Sec. 25(2) No. 2 of the German Telecommunications Digital Services Data Protection Act, TDDDG), or with your consent (Sec. 25(1) TDDDG), as for usage analytics.

Your profile, your health details, and your entries about food, training, and how you feel can reveal information about your health. We treat all of them as health data, a special category of personal data under Art. 9 GDPR (see section 5).

4. Purposes and Legal Bases

We process your data for the following purposes, each on the legal basis stated:

• Your Account and the App: To create and run your account, sign you in, store and sync your profile and entries, calculate nutrition and training values, show your history, manage your fuel balance, and deliver app updates. Legal basis: performance of our contract with you (Art. 6(1)(b) GDPR) and, for health data, your explicit consent (Art. 9(2)(a) GDPR).
• AI Features: To turn your descriptions and photos into draft entries, create analyses and meal plans, and answer your questions in the assistant. For this, we send the content of your request, together with the parts of your profile and health details relevant to it, to our AI provider, OpenAI, which processes it only on our behalf under a signed data processing agreement (see section 6). Legal basis: Art. 6(1)(b) GDPR and your explicit consent (Art. 9(2)(a) GDPR).
• Purchases, Subscriptions, and Fuel: To process subscriptions and refills you buy through the App Store or Google Play, add the right amount of fuel, and keep records of purchases. Legal basis: Art. 6(1)(b) GDPR; for records we must keep under tax and commercial law, Art. 6(1)(c) GDPR.
• Push Notifications: To let you know, for example, that a draft entry or a meal plan is ready. We only send push notifications if you allow them on your device. They contain short notices, such as the title of an entry that's ready. Legal basis: your consent (Art. 6(1)(a) GDPR, Sec. 25(1) TDDDG), which you can withdraw at any time in your device settings.
• Crash and Error Reports: So that we can find and fix crashes and errors and keep the app stable and secure, the app sends crash and error reports with technical data to our crash-reporting providers, Google and Sentry (see section 6). Legal basis: our legitimate interest in a stable, secure, and working app (Art. 6(1)(f) GDPR); storing and reading the identifiers this needs on your device is strictly necessary for it (Sec. 25(2) No. 2 TDDDG).
• Usage Analytics: If you agree to it in the app, we use Google’s app analytics to understand, in aggregate, how Anfold's features are used, so we can improve them. Legal basis: your consent (Art. 6(1)(a) GDPR, Sec. 25(1) TDDDG). Without your consent, no data is collected for usage analytics. You can withdraw your consent at any time in the app's settings, with effect for the future.
• Quality and Accuracy: We keep records of AI requests and responses to investigate errors, answer your questions about a result, measure and improve the accuracy of Anfold's AI features, and check fuel charges. Legal basis: our legitimate interest in accurate, working AI features and correct billing (Art. 6(1)(f) GDPR) and, for health data, your explicit consent (Art. 9(2)(a) GDPR).
• Security and Misuse Prevention: To protect accounts and our systems, and to detect and prevent misuse, such as fraud or the abuse of fuel. Legal basis: our legitimate interest in a secure service (Art. 6(1)(f) GDPR).
• Support and Communication: To answer your emails, and to send you emails your account needs, such as the verification email when you sign up with an email address. Legal basis: Art. 6(1)(b) GDPR, and otherwise our legitimate interest in answering inquiries (Art. 6(1)(f) GDPR).
• Legal Obligations and Claims: To meet our legal obligations, such as keeping tax and accounting records or answering lawful requests from authorities (Art. 6(1)(c) GDPR), and to establish, exercise, or defend legal claims (Art. 6(1)(f) GDPR and, for health data, Art. 9(2)(f) GDPR).

5. Health Data

Anfold is built around information about your body, food, training, and wellbeing. Because this is health data, we only process it with your explicit consent (Art. 9(2)(a) GDPR). We ask for this consent in the app before you set up your profile. It covers processing your health data to provide Anfold as described in this Privacy Policy, including sending it to our AI provider, OpenAI, which processes it on our behalf under a signed data processing agreement, also in the USA (sections 6 and 7), and keeping records of AI requests for quality and accuracy (section 4).

You can withdraw your consent at any time, with effect for the future, in the app's settings or by emailing us. This doesn't affect the lawfulness of processing before the withdrawal. Because Anfold can't work without this data, you can no longer use Anfold after withdrawing your consent, and we then delete your health data. You can also delete your whole account at any time (section 8).

We never use your health data for advertising, and we don't sell it.

6. Recipients and Service Providers

We only share your data where this is needed for the purposes above. Most recipients are service providers that process data on our behalf and on our instructions, under a data processing agreement (Art. 28 GDPR). Where a provider acts on its own responsibility, we say so.

• Google: Google Ireland Limited (Ireland) and Google LLC (USA) run Anfold's infrastructure for us: the database, file storage for your photos, server functions, sign-in, crash reports, and, only with your consent, usage analytics. This covers all categories of data in section 3. Processing takes place in the EU and in the USA; some services, such as sign-in, run in the USA.
• OpenAI: OpenAI Ireland Ltd. (Ireland) processes the content of your AI requests for us: your descriptions, photos, and messages, together with the parts of your profile and health details relevant to the request (such as height, weight, age, goals, dietary preferences, allergies, medical conditions, and medications). We don't send your name or email address. We have signed OpenAI’s Data Processing Addendum (openai.com/policies/data-processing-addendum), a data processing agreement under Art. 28 GDPR. Under it, OpenAI acts as our processor: it may process your data only to provide its services to us and only on our documented instructions; everyone at OpenAI who processes it is bound to confidentiality; and OpenAI must protect it with appropriate technical and organizational security measures, tell us without undue delay about a data breach, impose comparable obligations on its own sub-processors, and return or delete the data when our contract ends. OpenAI processes this data in the USA, doesn't use it to train its models, and keeps it for up to 30 days to detect abuse, unless the law requires longer retention.
• Sentry: Functional Software, Inc. (USA) receives error reports and technical logs from the app, including device and app data, your IP address, and your Anfold user ID. The data is stored in Sentry's EU region in Germany; Sentry may process some data in the USA.
• RevenueCat: RevenueCat, Inc. (USA) manages subscriptions and purchases for us. It receives your Anfold user ID, purchase and subscription details from the store, and technical data such as platform and app version. The data is processed in the USA.
• Expo: 650 Industries, Inc. (Expo, USA) delivers app updates and forwards push notifications to Apple and Google. For this, it processes your push token and the notification, and, for updates, your operating system and a random token. The data is processed in the USA.
• Apple and Google: When you download Anfold, buy a subscription or refill, sign in with Apple or Google, or receive push notifications, Apple and Google process data on their own responsibility, under their own terms and privacy policies. For purchases, they handle payment and send us the purchase details we need.
• Email: Zoho Corporation B.V. (Netherlands) hosts our email. Emails are stored in Zoho's EU data centres; Zoho may access them from outside the EU for support, on the basis of the EU Standard Contractual Clauses.
• Our Website: Cloudflare, Inc. hosts and delivers our website (see section 14).
• Authorities and Advisers: Where we're legally required to, we disclose data to authorities. Where necessary, we share data with our tax advisers or lawyers, who are bound to confidentiality.

Anfold doesn't sell your data.

7. Transfers Outside the EU

Some of the providers in section 6 are based in the USA or process data there. For the USA, the European Commission has decided that companies certified under the EU-U.S. Data Privacy Framework ensure an adequate level of data protection (adequacy decision, Art. 45 GDPR). Google, Sentry, Expo, and Cloudflare are certified. For providers that aren't certified, such as OpenAI and RevenueCat, transfers are based on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). For OpenAI, its Data Processing Addendum requires this: OpenAI Ireland Ltd. passes your data to other OpenAI companies or to service providers outside the European Economic Area only under agreements containing these clauses, or where the European Commission has issued an adequacy decision. The European Commission publishes the text of the Standard Contractual Clauses (Implementing Decision (EU) 2021/914) at eur-lex.europa.eu.

8. How Long We Keep Your Data

We keep personal data only as long as we need it for the purposes in section 4, or as long as the law requires:

• Account, Profile, and Entries: As long as you have an Anfold account. You can delete individual entries at any time. When you delete your account in the app, we delete your account and the data linked to it, including your profile, health details, entries, photos, conversations, and plans; copies in backups are overwritten in the regular backup cycle.
• Records of AI Requests: Only as long as needed for the purposes in section 4 (quality, accuracy, and fuel charges), and no longer than your account exists.
• Crash and Error Reports: Up to 90 days.
• Usage Analytics: Up to 14 months, and only if you've agreed to usage analytics.
• Sign-in Data: Our sign-in service (Google, see section 6) keeps the IP addresses of sign-ins for a few weeks.
• AI Provider: OpenAI keeps request data for up to 30 days. Its Data Processing Addendum requires it to return or delete our data when our contract ends (see section 6).
• Purchase Records: Up to 10 years, as German tax and commercial law requires (Sec. 147 of the German Fiscal Code, AO, and Sec. 257 of the German Commercial Code, HGB).
• Emails: As long as needed to deal with your request; where tax or commercial law requires us to keep them, for the statutory period (generally 6 years, at most 10 years).
• Legal Claims: Data we need to establish, exercise, or defend legal claims, until the matter is concluded.

After that, we delete the data, or anonymize it so that it can no longer identify you, for example as aggregated usage statistics.

9. Your Rights

Under the GDPR, you have the right to:

• access the personal data we hold about you and get a copy of it (Art. 15 GDPR);
• have inaccurate data corrected and incomplete data completed (Art. 16 GDPR); you can change most of it yourself in the app;
• have your data deleted (Art. 17 GDPR); you can delete your account yourself in the app;
• have the processing of your data restricted (Art. 18 GDPR);
• receive the data you've provided to us in a structured, commonly used, machine-readable format, or have it sent to another provider (Art. 20 GDPR);
• withdraw any consent you've given at any time, with effect for the future (Art. 7(3) GDPR);
• object to processing based on our legitimate interests (Art. 21 GDPR; see below).

To exercise these rights, email us at [email protected]. We may first ask you to confirm your identity. We'll reply within one month, as the GDPR requires.

You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the EU member state where you live or work, or where you believe an infringement took place. The authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59–61, 10555 Berlin, Germany, datenschutz-berlin.de.

10. Automated Decisions

Anfold's AI evaluates your entries and profile to draft entries, estimate nutrition and training values, and make suggestions. This is a form of profiling (Art. 4(4) GDPR). It only produces suggestions and estimates that you review and can change. We don't make decisions about you based solely on automated processing that have legal effects on you or similarly significantly affect you (Art. 22 GDPR).

11. Do You Have to Provide Your Data?

No law requires you to provide personal data to us. To create an account, however, we need an email address and a password, or your sign-in with Apple or Google. To finish setting up, the app asks for your birthday, gender, height, weight, country, language, units, and activity level, because nutrition and training calculations depend on them; without them, you can't use Anfold. Everything else, such as health details, dietary preferences, a description of yourself, photos, or push notifications, is optional, but Anfold can only take into account what you tell it.

12. Data Security

We protect your data with appropriate technical and organizational measures against loss, misuse, and unauthorized access, alteration, or disclosure (Art. 32 GDPR), for example with encryption in transit and at rest, and with access restricted to the people who need it. However, no online service can guarantee complete security.

13. Children

Anfold isn't meant for anyone under 16, and you must be at least 16 to use it (see our Terms of Service). We don't knowingly process data of children under 16. If we learn that a child has given us personal data, we delete it.

14. Our Website (anfold.app)

This section applies when you visit our website, anfold.app. You can use the website without an account, and it doesn't ask you for personal information. The following processing takes place:

• Hosting and Content Delivery: The website is hosted and delivered by Cloudflare. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA, which processes data on our behalf as a processor under its data processing addendum. Data may be processed in the United States; Cloudflare is certified under the EU-U.S. Data Privacy Framework, and its data processing addendum includes the EU Standard Contractual Clauses. Cloudflare's privacy policy: cloudflare.com/privacypolicy.
• Server Logs: When you open a page, your browser automatically sends technical information that is needed to deliver it. Cloudflare processes this information, including your IP address, the date and time of the request, the page requested, the referring page, and your browser's user agent (browser type and version, operating system), to deliver the website, keep it secure, and detect and prevent abuse such as attacks or excessive automated requests. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is a secure, working website. Cloudflare keeps this information only as long as needed for these purposes, in line with its own retention practices. We don't use it to identify you.
• Web Analytics (only with your consent): If you agree to it, we use Cloudflare’s web analytics to understand, in aggregate, how the website is used: for example, how many pages are viewed, which sites link to us, and how quickly pages load. Only then does your browser load a small script from Cloudflare that sends information about the page view to Cloudflare, such as the page address (without query parameters), the referring page, your browser's user agent, and page-load timings. It doesn't set cookies or use your browser's local storage, doesn't create a profile of you, and doesn't use your IP address, user agent, or any other data to recognize you or to follow you over time or across websites. We only see aggregated statistics, such as page views, referring sites, country, browser, operating system, device type, and load times. The provider is Cloudflare, Inc. (see above), acting as our processor. The legal basis is your consent (Sec. 25(1) TDDDG, Art. 6(1)(a) GDPR). Without it, the script isn't loaded. Your browser stores your choice in its local storage, so that we don't ask again. You can withdraw your consent at any time, with effect for the future, using the “Privacy settings” link at the bottom of every page.
• Fonts and Images: The website's fonts and app store badges are stored on and served from our own domain. Your browser doesn't contact Google Fonts, Apple, or Google to display them. The links to the App Store and Google Play are plain links: those stores only receive data from you when you follow a link, and their own privacy policies apply from then on.
• Language Choice: The website's language comes from its address: English pages, and German pages under /de/. To decide whether to suggest the other language, the page checks your browser's preferred language on your device. If you pick a language in the language menu, or follow or close that suggestion, your browser saves your choice in its local storage, only so the website doesn't suggest the other language again. Saving your choice is strictly necessary for this function (Sec. 25(2) No. 2 TDDDG). Neither leaves your device or is sent to us. You can delete the saved choice at any time in your browser settings.
• No Cookies or Other Tracking: The website itself doesn't set cookies and doesn't use any other analytics, advertising, or tracking tools, or embedded third-party content. If Cloudflare's security features consider a request automated, Cloudflare may run a check and set a short-lived, strictly necessary security cookie (such as __cf_bm or cf_clearance).

Your rights described in section 9 also apply to data processed through the website.

15. Changes to This Privacy Policy

We update this Privacy Policy when our processing or the law changes. The current version is always available here, with its effective date at the top. If a change affects processing that is based on your consent, we'll ask for your consent again where this is required.