Privacy Policy

Data controller

The data controller is Bussolari Alessio, based at Via del Prete 121, 47841 Cattolica (RN), Italy. For data protection requests, email [email protected].

Personal data we process

• Account data: name, optional surname, email address, preferred language, and measurement unit.
• Authentication and security data: password stored only as a hash, session tokens and digests, IP address, user agent, and temporary password-reset or email-change codes.
• Photos and content: product or label images, profile photo, barcodes, optional notes, and analysis results.
• Health and dietary data, all optional: allergies, intolerances, food preferences, daily net-carb goal, portions, and consumption times.
• App activity: history, generated or saved recipes, shopping list, onboarding journey, insights, and notifications.
• Device and technical data: Firebase notification token, platform, app version, crashes, redacted logs, and performance data.
• Premium subscription purchase data: purchase store (Apple or Google), product and plan, transaction identifiers and receipts, status, trial, and expiry. We do not receive payment details.

Purposes and legal bases

• Performance of contract (GDPR Art. 6(1)(b)): create and manage the account; analyze food; provide results, history, recipes, goals, insights, and the shopping list; verify and manage the Premium subscription.
• Consent (GDPR Art. 6(1)(a)): enable push notifications and process optional information when consent is required. Consent may be withdrawn without affecting earlier processing.
• Explicit consent (GDPR Art. 9(2)(a)): process voluntarily selected allergies and intolerances to produce personalized warnings. Providing this data is optional and it can be removed from the profile.
• Legitimate interest (GDPR Art. 6(1)(f)): security, abuse prevention, error diagnosis, and reliability improvements using minimized and redacted data.
• Legal obligation (GDPR Art. 6(1)(c)): answer lawful authority requests and meet applicable obligations.

Allergies, intolerances, and dietary data

These data are used only to personalize warnings, suggestions, and progress. If you entered allergies or intolerances, the list is sent to Google Gemini, through OpenRouter, with each analysis, only to generate personalized warnings. They are not used for diagnosis, advertising, or commercial profiling. èKeto is not a medical device and its results do not replace professional advice.

Providers and recipients

We use providers that process only the data needed for their assigned purpose:

• Hetzner Online GmbH (Germany): application, database, and infrastructure hosting, on servers in the Falkenstein and Nuremberg data centers.
• Amazon Web Services EMEA SARL (Luxembourg): storage of photos and other files through S3 in the Frankfurt region (Germany), and of database backups in the Ireland region.
• OpenRouter, Inc. (United States), which forwards requests to the Google Gemini model of Google LLC (United States): for each analysis it receives the photo, the label text, optional notes and, for personalized warnings, the list of allergies, intolerances, and disliked foods you entered in your profile. For recipes it receives the name and ingredients of the analyzed product and, if you use the pantry, the items in it. We do not automatically include your name or email address in the data sent. However, the photos and notes you provide may contain personal data.
• Google LLC (United States), Firebase Cloud Messaging: device token and operational data needed to deliver push notifications.
• Plus Five Five, Inc., operating as Resend (United States): email address and transactional email content, such as OTP codes and security messages.
• Cloudflare, Inc. (United States): the network in front of the website and the API that protects them from attacks; it processes IP addresses and technical request data and protects access to the administration area.
• Apple Distribution International Ltd. (Ireland) for the App Store and Google Commerce Limited (Ireland) for Google Play: they sell the subscription and handle its payment and renewal as independent controllers under their own privacy policies; they tell us the subscription status.
• CloseYourIt: a monitoring service run by the controller itself on Hetzner servers in Germany; it receives crashes, redacted logs, and technical metrics for security and maintenance. Sending identifiable personal data is disabled.

International transfers

Our servers (Hetzner, Germany) and S3 storage (Germany and Ireland) are in the European Union. Some providers are in the United States or may also process data there: Google LLC (Gemini and Firebase), OpenRouter, Resend, Cloudflare, and Amazon Web Services. Google, Amazon Web Services, Cloudflare, and Resend are certified under the EU-U.S. Data Privacy Framework, recognised as adequate by the European Commission (GDPR Art. 45). For OpenRouter the transfer relies on the standard contractual clauses approved by the European Commission (GDPR Art. 46). Apple and Google, as stores, are independent controllers and apply their own safeguards. You can ask us for a copy of the safeguards by writing to [email protected].

Retention periods

• Account, analyses, recipes, preferences, consumption entries, shopping list, and subscription data: until account deletion, unless the law requires longer retention.
• Analysis photos: until account deletion when photo saving is enabled; deleted after processing when the user disables this option.
• Login sessions: tokens expire within 30 days at most and are invalidated on logout or account deletion.
• Password-reset and email-change codes: expire after 15 minutes.
• Push tokens: until logout, account deletion, or invalidation by the device or Firebase.
• CloseYourIt: logs are retained for 14 days after collection, error reports and diagnostic data for 30 days after collection; they are then deleted automatically.
• Application logs on our servers: at most 10 MB per container, overwritten progressively; containers of previous versions, with their logs, are deleted once more than 5 remain.
• Database backups: we create a full backup daily and retain the latest 7 full backups with the data needed for recovery. Backup objects are also subject to an expiry rule of 60 days from creation, applied asynchronously by the provider. Backups are used only for incident recovery and may contain data deleted from the application until they are removed.

Your rights

You may exercise access, rectification, erasure, restriction, portability, objection, and consent withdrawal under GDPR Articles 7 and 15-22 by emailing [email protected]. We will reply within the legal deadline. You can delete your account and related data directly in the app. You may also complain to the Italian Data Protection Authority at www.garanteprivacy.it.

Children's data

èKeto is intended for people aged 16 or older. We do not knowingly collect data from children under 16. A parent or guardian may email [email protected] to request deletion.

Automated analysis and artificial intelligence

Google Gemini processes images and context provided by the user to estimate ingredients, keto score, carbohydrates, warnings, alternatives, and recipes. Results may be wrong and do not produce legal or similarly significant effects. Users can correct an identification, run the analysis again, and contact us for clarification.

Security

We use HTTPS/TLS, irreversible password hashing, expiring and revocable tokens, secure app storage, request throttling, access controls, and redaction of credentials and personal data from logs. No system is risk-free, but we apply safeguards proportionate to the data processed.

No advertising or data sales

We do not sell personal data, display ads, use advertising IDs, or track users for advertising across third-party apps or websites.

Changes to this policy

We may update this policy when the service or applicable law changes. Material changes will be announced in the app, on the website, by email, or by push notification where appropriate.

Contact

Bussolari Alessio — Via del Prete 121, 47841 Cattolica (RN), Italy — [email protected].