MACROUP PRIVACY POLICY

Fathonic LLC (hereinafter “MacroUp” or the “Provider”) operates the website macroup.app (hereinafter the “Website”) and MacroUp, a food and calorie diary app for iPhone and iPad (hereinafter the “App”).

This Privacy Policy explains which personal data of MacroUp users is processed, for what purposes, and to what extent. It applies to all processing of personal data carried out by MacroUp, including in the App and on the Website.

1. Controller

The controller within the meaning of the EU General Data Protection Regulation (GDPR), meaning the entity responsible for collecting, processing, and using users' personal data, is:

Fathonic LLC 30 N Gould St # R, Sheridan, Wyoming 82801-6317, United States Registered in the State of Wyoming, USA. Email for personal data enquiries: support@macroup.app

2. Encryption

All data exchanged by the App with our server and third-party providers is transmitted in encrypted form (HTTPS). A secure connection to the Website is indicated in the browser's address bar by an address beginning with “https://”. Encryption protects transmitted data from being read by third parties.

3. Collection, processing, and use of personal data

3.1. Personal data

“Personal data” within the meaning of the GDPR is any information relating to an identified or identifiable natural person. An identifiable person is someone who can be identified, directly or indirectly, in particular by a name, identification number, location data, online identifier, or factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity. MacroUp processes personal data (for example, nutrition data in the App) only in accordance with applicable data protection law. The nature, scope, and purposes of its collection, processing, and use are described below.

3.2. Data when visiting the Website

The website macroup.app does not collect visitor data: it has no cookies, visitor counters, advertising pixels, or forms. Like any web server, the Website's hosting provider sees the IP address and technical request data solely to deliver the page and protect the Website against misuse (legitimate interest, Article 6(1)(f) GDPR).

3.3. Using the App without an account

The App can be used without an account. In this case, the user's records are stored locally on their device. MacroUp cannot link this data to a specific user or restore it itself if the device is lost. If the App's data is included in an iPhone backup in iCloud or on a computer, it may be restored from that backup using Apple's tools.

3.4. Sign in with Apple

The user can connect a MacroUp account using their Apple ID. MacroUp does not request the user's name or email address from Apple. Our server stores a protected hash of the user's Apple identifier and sign-in session data. The account is used to link the subscription and synchronize the diary between devices once that feature is enabled. To restore the diary, the user must sign in to the same MacroUp account through Apple; “Restore Purchases” restores subscription entitlements and does not itself restore the diary.

Processing is carried out to perform the contract (Article 6(1)(b) GDPR). The account can be deleted in the App; on deletion, we delete the account record and revoke Sign in with Apple access. More about Sign in with Apple: https://support.apple.com/HT210318

3.5. Data entered by the user

In the App, the user can provide profile information, including the following body and health data:

— sex; — year of birth; — height; — current and target weight; — activity level; — goal (weight loss, maintenance, or gain) and desired rate of weight change; — the distribution of protein, fat, and carbohydrates in their diet.

The user also keeps a diary: meals, calories and nutrients, portions, meal photos, weight and body measurement history, water intake, custom foods, and reminders.

This data is used to calculate personal calorie and nutrient targets and to maintain the diary. Sex, year of birth, height, and weight are needed to calculate the target.

Without an account, the diary is stored on the device. When account synchronization is used, the following is sent to our server: the profile (sex, year of birth, height, current and target weight, activity, and goal); meal dates and entries with their ingredients, portions, and nutrients; weight, measurement, and water history; daily targets; custom foods and favorites; nutrition settings; manually entered activity calories; and the user's chosen addition to the calorie target. The data is linked to the account identifier and used to merge and restore the diary on the user's devices. When the account is first connected, the existing local diary is transferred to it and merged with its cloud history without adding the same records again.

Meal photos are not sent to synchronization storage or restored from the account on another device. They remain on the device on which they were saved. Sending photos for recognition is separate processing described in section 4.2. Original Apple Health records and samples are not sent for synchronization. Permissions, language, units of measurement, and reminders remain device settings.

When the user signs out, the account's diary and photos remain on that device but are hidden until the user signs in to the same account. A separate diary is opened for use without an account or with another account. Synchronized data is stored until the user deletes the corresponding entries, diary data, or account, or disables synchronization.

Weight, body, and nutrition data may fall within special categories of personal data (health data, Article 9(1) GDPR). MacroUp processes it on the basis of the user's explicit consent (Article 6(1)(a) and Article 9(2)(a) GDPR), which the user gives by entering this data in the App after reading this Policy. The user consents to the transfer and cloud storage of this data for synchronization by taking the action of signing in to their account with Apple after reading this Policy. Synchronization starts automatically after sign-in unless the user has previously disabled it. The user can withdraw consent to synchronization in account settings using “Disable sync”, or delete their data or account as described in section 8.

3.6. Data recorded automatically by the App

When using features that operate through our server, MacroUp processes:

— a random App installation identifier; — the IP address; — the time of the request.

The installation identifier is used to limit the number of requests and prevent misuse and is stored on the server for approximately one day. Processing is based on MacroUp's legitimate interest in the secure and reliable operation of the service (Article 6(1)(f) GDPR).

3.7. Contractual relationships and payment

If a contract between the user and MacroUp is entered into or amended, MacroUp processes the user's personal data on the basis of Article 6(1)(b) GDPR to the extent necessary to perform the contract.

The user can subscribe to MacroUp Premium through an in-app purchase in the Apple App Store. A free trial may be offered for the annual subscription. Apple processes payment; MacroUp does not receive bank card details. Apple's privacy policy: https://www.apple.com/privacy/

MacroUp uses Adapty to manage subscriptions. Adapty receives purchase information and subscription status, an anonymous profile identifier, technical device information (model, iOS version, language, time zone, and identifier for vendors, IDFV), the IP address, Apple Search Ads installation data (section 7.3), identifiers from the analytics services in section 7 to link subscription events, and, if the user answered these questions on first launch, sex and age group. Adapty sends subscription events (start, renewal, cancellation, and refund) to the analytics service Amplitude.

4. Transfer of data to third parties

MacroUp treats users' personal data confidentially and in accordance with data protection law and this Policy. Unless otherwise provided by law or contract, MacroUp processes data in third countries, or arranges for it to be processed there, only where the special requirements of Articles 44 et seq. GDPR are met, in particular on the basis of a European Commission adequacy decision or standard contractual clauses approved by the European Commission (Articles 45 and 46 GDPR).

Nevertheless, in certain circumstances, authorities in a third country may gain access to users' data for monitoring and supervision purposes, and effective remedies and data subject rights may not be enforceable in this respect.

The following providers and data are concerned:

4.1. Apple Health

The user can connect the App to Apple Health. Following permission in iOS, the App can read the following from Apple Health:

— active energy; — exercise time; — step count; — walking and running distance; — workouts (type, start time, duration, and calories burned).

The App does not write data to Apple Health. Apple Health data is not sent to our server, AI service providers, or analytics services. Access can be changed or disabled in iOS settings. Apple's privacy policy: https://www.apple.com/privacy/

4.2. AI service providers

MacroUp uses external AI service providers to operate the App's AI features. Data entered by the user for these features is sent to the provider solely to generate the requested result. MacroUp does not transfer this data to other recipients for this purpose or use it to train its own AI models.

These providers process data outside the European Economic Area, and the safeguards described at the beginning of section 4 apply to the transfer. A user who wants to know which providers are currently used can request this information at the address in section 1.

4.3. Adapty

Subscription management service; the data is described in section 3.7.

4.4. Analytics services

Amplitude and Firebase (Google); the data is described in section 7.

4.5. Diary storage and synchronization

The MacroUp server and synchronization database are hosted by Cloudflare (Cloudflare, Inc.). The data listed in section 3.5 and the account identifier are sent for storage in Cloudflare D1. Photos are not sent to this database. Access to the diary requires a verified session for the corresponding account; the connection is protected by HTTPS. This feature does not use diary data for advertising or AI training.

When the cloud diary is deleted, its data is removed immediately from the live database once the server receives the request, and automatically from the provider's backup history within 30 days. This period applies to MacroUp cloud storage; iPhone backups are managed using Apple's tools.

MacroUp uses Apple DeviceCheck to protect the free-entry limit without storing a device identifier for this check.

5. Communication and support

The user can contact support from the App. The email prepared by the App contains the enquiry text, the selected problem category, the App version, the iOS version, and the device model. Diary entries and photos are not attached to the email automatically. When the email is sent, MacroUp also receives the sender's email address.

This data is used only to respond to the enquiry. Processing is based on the user's consent (Article 6(1)(a) GDPR). The data is deleted once the enquiry has been handled, unless retention is required by law.

6. Use by children

The App is intended only for people aged 18 and over. People under 18 may not use the App, including with parental consent. If MacroUp learns that personal data of a person under 18 has been collected, MacroUp will promptly take steps to delete it. Parents who believe their child has provided us with personal data can contact MacroUp at the address in section 1.

7. Analytics and attribution tools

On the basis of the user's consent within the meaning of Article 6(1)(a) GDPR, MacroUp uses analytics tools to understand how the App is used, identify errors, and improve features.

Analytics services do not receive photos, voice, food names, barcodes, weight, health measurements, nutrients, or free text. Events are linked to a random identifier that does not contain a name, email address, or Apple ID. MacroUp does not request access to the device's advertising identifier (IDFA).

7.1. Amplitude

Amplitude receives App usage events: launches and sessions, first-launch steps, subscription screen displays, stages of food recognition, search, and saving, and the opening of summaries. Events are sent with the event time, random identifier, App and iOS versions, device model, language, and country from the regional settings. Collection of the IP address, city, and region is disabled. Amplitude's privacy policy: https://amplitude.com/privacy

7.2. Firebase

MacroUp uses Firebase services provided by Google Ireland Limited: Google Analytics for Firebase (usage statistics), Crashlytics (crash reports), and Performance Monitoring (execution times for individual operations). Firebase receives events and crash reports, a random identifier, and device and App version information. Firebase data is not used for advertising. Google's privacy policy: https://policies.google.com/privacy

7.3. Apple Search Ads

MacroUp uses Apple Search Ads, Apple's advertising program in the App Store. To determine whether an installation came from Apple Search Ads advertising, the App sends Adapty the installation information provided by Apple. The user can view and restrict the data Apple uses to display advertising in iOS settings. More information: https://searchads.apple.com/privacy

The user can withdraw consent to analytics by writing to the address in section 1. Deleting data in the App (section 8) also disables analytics on that device.

8. Data deletion

MacroUp retains the user's personal data for the duration of their use of the App.

“Delete Data” in the App's settings erases the diary and photos, profile, weight, measurement, and water history, custom foods, reminders, cached Apple Health data, widget data, and random identifiers from the device. iPhone backups may contain copies of this data. Deleting data in the App does not cancel the subscription or delete records in Apple Health.

If an account with synchronization is connected, “Delete Data” also deletes its cloud diary. This operation requires a server connection; local deletion begins after the server confirms it. The account and subscription are retained. Other devices with this account clear the previous diary and local photos on their next successful connection to the server; changes remaining in the old upload queue do not restore the deleted diary.

“Disable sync” in account settings deletes the cloud copy of the diary and stops further synchronization for that account on all devices. The local diary and photos, account, and subscription are retained. A server connection is required to confirm deletion. Other devices learn about the opt-out when they next connect; their local diaries are retained. Synchronization remains off after restarting the App and signing in again until the user selects “Enable sync”. When synchronization is enabled again, the local diary is uploaded to the cloud again. The period for removal from backup history is stated in section 4.5.

“Delete Account” is a separate action: it deletes the account, its cloud diary, and the local diary and photos for that account on the current device, and revokes Sign in with Apple access. Deleting the account does not cancel the App Store subscription. It cannot physically erase data from another device until that device connects or the user deletes the local data on it.

Deletion of individual entries is synchronized when a connection is available. A deleted entry is not restored from an old queue on another device. Until confirmed by the server, an entry deleted offline may remain visible on other devices. Device and server backups are handled separately from the active diary.

Data sent to analytics and subscription management services (Amplitude, Firebase, Adapty) is deleted at the user's request to the address in section 1.

9. User rights

The user has the following rights. These rights, other than the right in section 9.9, are exercised by contacting MacroUp at the address in section 1.

9.1. Right of access (Article 15 GDPR)

The user may at any time obtain, free of charge, information about their personal data held by MacroUp, its sources and recipients, the purposes of processing, and the intended retention period, including a copy of the personal data being processed.

9.2. Right to rectification (Article 16 GDPR)

The user may request, without undue delay, that inaccurate personal data be corrected or incomplete personal data be completed.

9.3. Right to withdraw consent (Article 7(3) GDPR)

The user may withdraw consent to processing at any time with effect for the future, without giving reasons.

9.4. Right to erasure (Article 17 GDPR)

Where the conditions in Article 17 GDPR are met, the user may request erasure of their personal data. The right to erasure depends, in particular, on whether MacroUp needs this data to comply with legal obligations.

9.5. Right to restriction of processing (Article 18 GDPR)

Where the conditions in Article 18 GDPR are met, the user may request restriction of the processing of their personal data.

9.6. Right to data portability (Article 20 GDPR)

The user may receive the personal data they have provided in a structured, commonly used, and machine-readable format, or transfer it to another controller, if processing is based on consent or a contract and is carried out by automated means.

9.7. Right to object (Article 21 GDPR)

The user may object at any time to the processing of their personal data where processing is based on Article 6(1)(e) or (f) GDPR. The personal data will no longer be processed unless compelling legitimate grounds override the user's interests, rights, and freedoms.

9.8. Right not to be subject to automated decision-making (Article 22 GDPR)

The user has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

9.9. Right to lodge a complaint (Article 77 GDPR)

The user may lodge a complaint with a supervisory authority, in particular in the EU or EEA Member State of their habitual residence, place of work, or the alleged infringement. In France, the supervisory authority is CNIL (https://www.cnil.fr). List of EU supervisory authorities: https://edpb.europa.eu/about-edpb/about-edpb/members_en. Users in the United Kingdom may contact the Information Commissioner's Office: https://ico.org.uk/make-a-complaint/

If the matter concerns MacroUp's processing of personal data, MacroUp asks the user to first write to the address in section 1 so that it can be resolved directly.

10. Version and updates to the Policy

This Privacy Policy is valid in the version dated 8 October 2026. Development of the Website or App, or changes in legal requirements, may make it necessary to amend this Policy. The current version can be viewed and printed at any time at https://macroup.app/privacy