Privacy Policy

Capitalized terms used in this Policy have the meanings assigned below:

• Account — the unique profile created for You to access the Service.
• Application — the Pacali mobile application.
• Company / We / Us / Our — Pacali Inc., a German Sole Proprietorship, Am Hellweg 10, 32105 Bad Salzuflen, Germany.
• Health Data — information relating to Your physical characteristics, health, nutrition, goals, or activity. This constitutes sensitive personal data under applicable privacy laws.
• Personal Data — information that identifies or can reasonably be linked to an individual.
• Service — the Pacali mobile application, website (pacali.app), and related services.
• Usage Data — data collected automatically through use of the Service.
• User Content — photos, images, text, food entries, recipes, or other inputs You upload.
• You — the individual accessing or using the Service.

2.1 Personal Data You Provide: Account information (name, email, password, profile photo), contact information (email).

2.2 Health Data: Weight, height, age, gender, activity level, food logs, nutrition goals, dietary preferences, allergies, progress photos. We process this data only with your explicit, affirmative opt-in consent (GDPR Art. 9(2)(a)).

2.3 User Content: Food photos for calorie analysis, progress photos, text entries, food logs, recipes. We may use anonymized or aggregated food images to improve our AI models. Progress photos are never used for model training.

2.4 Usage Data: Device type, OS, app version, device identifiers, IP address, timestamps, features used, crash logs.

2.5 Cookies and Tracking Technologies: Cookies, web beacons, mobile advertising identifiers (IDFA, Android ID).

• 3.1 To provide and improve the Service: food identification, nutrition tracking, personalization, account management, security.
• 3.2 To improve AI and computer vision models: anonymized/aggregated food images only, not linked to identity.
• 3.3 Communications: service notifications, support responses, newsletters (with consent).
• 3.4 Marketing (optional): promotional emails with opt-out option.
• 3.5 Legal and compliance: fraud prevention, legal obligations, rights protection.
• 3.6 Business transfers: data may transfer in mergers/acquisitions.

• Consent: For Health Data (Art. 9(2)(a)) and marketing (Art. 6(1)(a)).
• Contract Performance: To provide the Service (Art. 6(1)(b)).
• Legitimate Interests: Improving/securing the Service (Art. 6(1)(f)).
• Legal Obligations: Compliance (Art. 6(1)(c)).

We do not sell Your Personal Data. We may share with:

• Service Providers: Cloud hosting (AWS, Google Cloud), analytics (Google Analytics), AI/ML services, customer support, payment processors.
• Business Transfers: During mergers/acquisitions.
• Legal Compliance: Law enforcement when legally required.
• With Your Consent: Third-party integrations you authorize.
• Aggregated/Anonymized Data: For analytics, research, and marketing.

You grant Pacali a worldwide, royalty-free, sublicensable license to use Your User Content to operate and improve the Service. We do not publicly display Your photos without explicit consent. Progress photos are never used for model training.

• Account Data: Retained while active; deleted within 30–90 days of account deletion.
• Health Data: Retained during active use; deletable via app settings.
• Usage Data: Up to 13 months for analytics.
• Backups: May persist in standard disaster recovery.

Data may be transferred internationally. For EEA/UK transfers, we rely on the EU-US Data Privacy Framework, Standard Contractual Clauses, or explicit consent.

GDPR rights: Access, Rectification, Erasure, Restriction, Data Portability, Withdraw Consent, Object, Lodge Complaint.

CCPA rights: Right to Know, Opt-Out of Sale (we don't sell data), Non-Discrimination.

Exercise via app settings or email akremagency@gmail.com. Response within 30 days (45 for CCPA).

You may request deletion of your Account, progress photos, food logs, and profile data. Some data may persist where legally required.

We use SSL/TLS encryption in transit and at rest, access controls, anonymization/ pseudonymization, regular security audits, and employee training to protect your data.

Service is not intended for users under 18. We do not knowingly collect data from children under 18. Contact akremagency@gmail.com if you have concerns.

Updates will be posted with a revised effective date. Material changes will be notified via the app or email.

Email: akremagency@gmail.com
Mailing Address: Alex Kem, Am Hellweg 10, 32105 Bad Salzuflen, Germany