Privacy Policy

QALORIE PRIVACY POLICY

Effective as of 28th of June 2021

1. INTRODUCTION

1.1 This Privacy Policy document governs the collection, use and storage of personal information about App visitors and users of the Qalorie Services. This document uses the same terminology and abbreviations as our Terms and Conditions.

1.2 The information on Users is divided into personally identifiable and non-personally identifiable information depending on whether information can identify the User as a specific person. Personally identifiable information shall be referred to as “personal data”.

1.3 The operator of the Qalorie App is Qalorie, Inc, 400 CALAF ST., PMB #1004, 00918 San Juan, Puerto Rico and we are responsible for compliance with the principles relating to processing of personal data. If you have any question or concern regarding your privacy, you can contact us at support@qalorie.com.

2. PERSONAL DATA THAT WE PROCESS

2.1 During your interaction with the App or with us directly we may process the following personal data:

▪ ▪ ▪ ▪ ▪

Name
E-mail address
Third-Party services ID
General biometrics
Other information which you choose to provide

We may collect personal data when you interact with the App, when you register and

2.2
customise an account, or when you contact us.

(A) NAME

2.3 When entering into contract for using our Services you have to provide your name. Qalorie will only use this information to create an account for you and to address you whenever we contact you.

2.4 Qalorie will collect your name when you contact us through email or through other communication media provided that such information is contained within a communication. We will use this information only for addressing you in our responses.

(B) EMAIL ADDRESS

2.5 We require your e-mail address when you register to use the Services, or you may provide it when you contact our support. We will only use your email address in accordance with this Privacy Policy, including the rules for the duration of the collection. We collect your email address to provide our Services, for our legitimate interest in marketing, or with your consent, depending on the purpose of collection. We will collect your email address in the following cases:

- When you register an account. We will collect your email address to create and facilitate an account for you and to send you notifications about your account, such as when we change our privacy policy, or if there is a data breach. We will also contact you if you submit your email address but do not complete the registration process to ask if you require any assistance in completing your registration. Account is necessary to access some of our Services and if you do not provide us with your email address for this purpose you will not be able to access these Services.

- When you contact us. We will collect your email address whenever you contact us through our email support@qalorie.com. Whenever we collect your email address this way, we will only use it in order to respond to your enquiry.

- When you subscribe to the newsletter. We will collect your email address when you subscribe to receive more information about Qalorie.

(C) THIRD-PARTY SERVICES ID

2.6 We will collect your Third-Party services ID when you choose to register an account through the available Third-Party services account options such as Google, Facebook, or Apple. When you choose to register with your Third-Party services account, we will collect your Third- Party services account ID to create an account for you and to connect your account password and email with the right ID. We do not collect your third-party service password. For example, when you choose to register through your Facebook account, you will be referred to the Facebook consent dialogue box, after which, if the consent is provided, we will collect your name, e-mail address, profile photo, and information which is publicly available on your profile in order to create and facilitate your account and user profile.

(D) GENERAL BIOMETRICS

2.7 In order to provide our Services we need to process Information about your gender, age, height, weight, pregnancy status, breastfeeding status, goal weight loss, amount of exercise you are getting, how fast do you want to lose the weight, and other lifestyle information. All this information is necessary to calculate the right calorie and exercise plan for you and is not used for any other purpose.

(E) OTHER INFORMATION

2.8 You may at some point choose to provide other information which is not required for the proper functioning of the Services. In all such cases we will use this information only for the purpose for which you disclosed it. If we are not sure as to why you are providing such information, we will contact you wherever possible. Otherwise, we will delete such information.

(F) GENERAL

2.9 Some Services will not be available to you if you do not provide the requested Information. We may keep records of any questions, complaints or compliments made by you and the response, if any. Whenever you contact us, we shall collect any information which you chose to provide. We shall store and use this information only for the purpose of responding to

your enquiries. Information contained within the enquiry, free from any personally identifiable information, will be stored on our servers for the purpose of improving our Services and providing the best customer support possible.

2.10 We do not sell or rent personal information to any third-party. We use collected information for our internal and marketing purposes, as necessary by the nature of the Services, and only in accordance with this Privacy Policy. In some instances, we are obliged to comply with court orders and government requests and provide Information or parts of it to authorised bodies.

2.11 We may disclose your personal information to our partners, agents and operators under confidentiality or similar agreements, including data processors who we believe reasonably need to come into contact with that information: (i) to provide Services per your request; (ii) to administer our business or the website; (iii) to provide customer support; (iv) to update account information; (v) to forward updates, announcements, and newsletters; (vi) to respond to your communications, and communicate with you about the website and other activities related to the Services; (vii) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of Qalorie’s business or operations (including without limitation in connection with bankruptcy or any similar proceedings); or (viii) as otherwise authorized by you.

2.12 We have implemented security procedures and measures in order to ensure appropriate protection of the information we process, against any misuse, unauthorised access, disclosure or modification.

2.13 We acknowledge that the safety of your information is one of the highest priorities and therefore only authorised processors have access to your information. Although we take all appropriate measures in respect to keeping your information secure, you understand that no data security measures in the world can offer 100% protection. If we ever find or suspect a personal data breach we will without delay after becoming aware of it, notify you if there is a high risk to your rights associated with the data breach.

2.14 The processing of the information is being performed automatically, without human intervention. However, whenever you contact us through email, the information within the email will be handled and processed by a real person in order to provide you with the answer to the email.

3. STORAGE AND TRANSFER OF INFORMATION

3.1 Information will be stored on secure servers hosted by MongoDB, Inc. 5th Floor, 229 West 43rd Street, 11236 New York – USA (MongoDB). Hosted servers are controlled and maintained in accordance with sufficient privacy safeguards. We may store or transfer information on Users to processors located outside of US, provided that such countries implement appropriate and suitable safeguards regarding the security of personal information.

3.2 Some services require the use of Third-Party solutions, or the App or e-mails may contain links to other external websites that do not fall under our domain. When you are redirected from our App to the third-party website you are no longer interacting with our App and we are not responsible for the privacy practices or the content of such external websites. Any information

that you provide through third-party websites will be handled and processed in accordance with their privacy policies and other applicable terms.

4. THIRD PARTY SERVICES, AND COOKIES

4.1 We use third-party service providers for some aspects of our services, such as managing emails, communication environment, providing customer support and similar. These service providers sometimes need your personal information in order to properly deliver functionality, but they may only collect and use it under our control.

4.2 We use third party services like Google Analytics and Google Cloud Platform provided by Google Inc. Cookies from such services, Android Advertising ID, Advertising Identifier for iOS and similar technologies are used to collect data for statistical reports. Services by Google collect anonymous statistical data about the App use. You can review Google’s privacy policy here: https://policies.google.com/technologies/partner-sites. Users may opt-out of certain features like Google Analytics through applicable device settings, such as the device advertising settings for mobile phones or visit the Network Advertising Initiative Opt-out Page for more details http://optout.networkadvertising.org/#/.

4.3 We may use third-party services provided by SendGrid, Inc for email communication. You can review their Privacy Policy here https://sendgrid.com/policies/privacy/.

5. INFORMATION RETENTION PERIOD

5.1 Information is stored on the servers only for the duration necessary for providing the Services and maintaining the integrity of our databases. If you register to use our Services, we will store your information for as long as you have an active account. As soon as you terminate your account we will remove all information we have collected about you unless we have appropriate legal grounds for continuing their processing.

6. CHANGES TO THE PRIVACY POLICY

6.1 We reserve the right to change our Privacy Policy at any time. The current version of our Privacy Policy is available through the website, indicating the effective date. You are encouraged to periodically check our Privacy Policy.

7. CONTACT INFORMATION

7.1 If you have any queries or concerns regarding our Privacy Policy and how the information is handled, or you wish to access, retrieve, amend, or update your Information feel free to contact us at support@qalorie.com.