Privacy Policy

Effective date: April 2, 2026

“You” means any individual or legal entity that accesses or uses the Service. If an individual accesses or uses the Service on behalf of a company or other organization, “You” also includes that company or organization.

“Company,” “we,” “us,” or “our” means WellyPal.

“Application” means the WellyPal software application provided by the Company, which You may download onto an electronic device.

“Service” means the Application.

“Device” means any device capable of accessing the Service, such as a computer, mobile phone, or tablet.

Under the General Data Protection Regulation (GDPR), You may also be referred to as the “Data Subject” or “User,” as You are the individual using the Service whose Personal Data is being processed. For purposes of the GDPR, WellyPal acts as the Data Controller, meaning the legal entity that alone, or jointly with others, determines the purposes and means of processing Personal Data.

When you use the Service, we may collect the following categories of data. Under applicable privacy laws and regulations, certain categories of such data may be considered health data, sensitive personal information, or information related to your physical condition.

Account and Profile Information

To create, manage, and maintain your account, we may collect the following information:

Email address

Avatar, nickname, and username

Login method information, such as sign-in via Apple, Google, or other third-party authentication services

Unique user ID (automatically generated by the system)

Subscription status and related subscription information

Any other personal information you voluntarily provide or submit

Health and Nutrition Data

To provide calorie estimation, nutrition tracking, goal management, and personalized health management features, we may collect the following health and nutrition-related information:

Weight

Target weight

Height

Age, date of birth, or birth year

Gender

Body Mass Index (BMI)

Activity level

Physical condition

Dietary logs and food-related data, including food information submitted via photo, voice, text, or manual input

Water intake records

Exercise records

Weight records

Body photos

Nutrition goals, weight goals, hydration goals, exercise goals, and other health-related goals

Dietary preferences, dietary restrictions, and allergy-related information

Health data synchronized with your authorization, such as data from Apple Health

Any other health, nutrition, or lifestyle-related information you voluntarily provide through the application

You may choose the scope of health data you provide. However, if you do not provide certain essential data required for core functionalities (such as dietary records, weight data, or related images), some features of the Service may not function properly or may not provide accurate and complete results.

User Content and AI Interaction Data

During your use of the Service, we may collect the following content that you submit or generate:

Photos uploaded for calorie analysis, food recognition, or nutrition analysis

Dietary, hydration, exercise, and weight tracking records

Body photos

Information you input during interactions with AI Coach

Information inferred during conversations based on data you have provided, for the purpose of ensuring continuity and personalization of responses

Feedback, comments, or complaints you submit

Communication content provided when contacting customer support

Any text, images, voice inputs, or other content you voluntarily submit

Usage Data and Device Data

To ensure, maintain, optimize, and improve the Service, we may automatically collect information related to your device, network environment, and usage behavior, including:

Time zone

System language

Country/region

Device type

Device unique identifiers

IP address

Browser type and version

Mobile network carrier information

Operating system name, version, and build number

Hardware model

Screen size, resolution, and density

Application name, version, and build version

Advertising identifiers such as IDFA, IDFV, or other device identifiers

Device mute status (related to reminder functionality)

Timestamps, activity logs, page visit records, session duration, and click behavior

Feature usage data

Performance data, crash reports, diagnostic data, and other technical log information

We call all the data listed above your "personal data".

We may collect your Personal Data through the following methods:

Information You Provide Directly

We collect information that you voluntarily provide when you:

Create an account

Complete your profile

Upload an avatar

Set a nickname or username

Upload photos

Log dietary, hydration, exercise, body, or weight data

Set health goals

Submit feedback or complaints

Subscribe to services

Interact with AI Coach

Contact customer support

Automatically Collected Information

When you use the Service, we may automatically collect certain information through the application, your device, or related technologies, including:

Device information

Device identifiers

IP address

Browser and system information

Page visit records

Session duration

Click behavior

Feature usage

Performance data

Crash logs

Analytics data

Diagnostic data

Access time and usage patterns

Information from Third-Party Platforms or Services

With your authorization, we may receive relevant information from third-party platforms or services, including:

Health data provided by Apple Health

Identity information from Apple login, Google login, or other third-party authentication services

Subscription and transaction status information from payment platforms, app stores, or subscription services

Data provided by other third-party services that you explicitly authorize

Information Collected via Permissions

When you use features such as taking photos, uploading images, or voice input, we may access your camera, photo library, microphone, or other device permissions with your authorization. You may withdraw such permissions at any time through your device settings. However, doing so may affect the availability of certain features.

Customer Support and Communication Information

When you contact us via email, in-app feedback, customer support channels, review platforms, or other communication methods, we may collect your communication records and related information for purposes such as:

Customer support

Security review

Service optimization

Dispute resolution

Troubleshooting

System-Generated or Inferred Information

To provide personalized services, continuity of records, and AI-powered functionality, we may generate certain analytical results, labels, or inferred information based on your provided data, historical records, and interactions with AI Coach, in order to better understand your needs and improve your experience.

We collect and process your Personal Data primarily for the following purposes:

To Provide and Operate the Service

Including but not limited to:

Creating, identifying, and managing your WellyPal account

Assigning and maintaining a unique user ID to associate your records, settings, and service status

Displaying and managing your profile information, such as avatar, nickname, username, and account details

Providing core application functionalities

Enabling tracking of diet, hydration, exercise, and weight

Providing calorie estimation, nutritional analysis, BMI calculations, and health goal management

Recording and displaying body changes, weight trends, and historical data

Supporting AI Coach interactions and related intelligent features

Managing subscription status, membership benefits, and account types

To Provide Personalized Analysis and Recommendations

We may use your data to generate insights and recommendations tailored to your needs, goals, and actual conditions, including:

Generating personalized analysis based on age, gender, height, weight, BMI, activity level, and physical condition

Providing personalized recommendations based on dietary, hydration, exercise, and weight records

Configuring initial settings and recommendations based on health goals, dietary preferences, restrictions, and allergy information

Delivering continuous responses, insights, and reminders through AI Coach

To Maintain, Improve, and Optimize the Service

We may use relevant data to:

Ensure proper operation of the Service

Analyze product usage, user preferences, and feature performance

Improve food recognition, nutritional analysis, recommendations, and reminders

Optimize interface design, device compatibility, and user experience across different screen conditions

Provide localized experiences, time calculations, reminders, and service adaptation based on system language, region, and time zone

Conduct internal research, analytics, testing, A/B testing, and product iteration

To Ensure Security and Prevent Misuse

We may use relevant data to:

Detect, prevent, and address fraud, abuse, violations, or harmful activities

Conduct security reviews, risk control, and anomaly monitoring

Troubleshoot technical issues and protect service integrity

Maintain the safety, stability, and appropriate use of AI functionalities

To Provide Customer Support

We may use your data to:

Respond to inquiries, feedback, complaints, or support requests

Assist in resolving account, login, subscription, payment, or functionality issues

Improve support quality and service experience based on communication records

To Manage Subscriptions and Related Transactions

We may use relevant data to manage your subscription status, membership benefits, order records, payment confirmations, cancellations, renewals, and related service processes.

To Communicate with You

We may use your contact information to send service-related notifications, including:

Account and security notifications

Service updates

Policy changes

Feature instructions, reminders, or support responses

Where permitted by applicable law and with your consent, we may also send promotional offers and marketing communications.

To Measure Marketing Effectiveness and Attribution

Where applicable and subject to your consent or as permitted by law, we may use advertising identifiers or similar identifiers (such as IDFA, IDFV, or other device identifiers) to measure marketing effectiveness, perform attribution analysis, understand user acquisition channels, and improve marketing campaigns.

To Comply with Legal Obligations and Protect Rights

We may use or disclose your Personal Data where required by law, regulatory requirements, legal processes, or where necessary to protect our legitimate rights, the rights of users, or third parties. This may include account information, usage logs, device data, customer support records, and other relevant data.

To provide a better user experience, the App may request access to certain system permissions. The relevant permissions are described below:

Camera permission: used to take photos and support recognition features. We will not access your camera without your authorization.

Storage permission: used to access local images, photos, and files. We will not access, delete, or modify any image files without your authorization.

Photo permission: used for image access required by recognition features. We will not access, delete, or modify any image files without your authorization.

Microphone Permission:Used to receive your voice input so we can provide voice recognition, generate records, and support related features. We will not access your microphone or record your voice without your permission. You can turn off this permission at any time in your device settings.

Media permission: used to access local media files such as images and photos.

Notification permission: used to send you service notifications, feature reminders, subscription status updates, campaign messages, or other Service-related communications. You may disable this permission at any time in your device settings.

Apple Health authorization: used, with your explicit authorization, to read or write health data relevant to the Service through Apple Health, such as weight, step count, energy burned, or other health data you authorize, so that we can provide health logging, analysis, and personalized features. We access such data only within the scope you authorize, and you may revoke that authorization at any time through Apple Health or your device settings.

IDFA/AAID: we may collect Apple’s Identifier for Advertisers (IDFA) and Google Advertising ID (AAID) to provide a more personalized advertising experience and to measure advertising performance, thereby improving the overall user experience.

AI coach

Coach chat. The AI Coach chat supports you on your wellness journey, it will answer your questions and help you learn more about living a healthier lifestyle. AI Coach may be sending daily check-ins, troubleshooting issues that you may face, and providing recommendations for next actions.

Coach and certain other AI-powered features within the Service rely on a third-party AI service provided by Google LLC, including Gemini-related services.

How We Use AI Coach Data

We use the personal data you submit through AI Coach—including food preferences, health-related information, meal logs, water intake records, exercise logs, weight records, goals, photos, voice inputs, text messages, and other information you choose to provide—to process your request, generate relevant and personalized responses, and provide AI-powered features within the Service.

Authorized members of our team may access, review, and process communications with AI Coach where reasonably necessary for customer support, product improvement, quality assurance, safety review, abuse prevention, troubleshooting, and to help ensure that AI Coach functions properly.

We may also use content you provide through AI Coach—including conversations, images, voice inputs, and related health and usage data—for internal research, analytics, safety review, abuse prevention, debugging, service improvement, and feature optimization, as permitted by applicable law.

While communicating with AI coach, do not provide any information that may directly identify you or any other people.

Your personal data is not used to train any third-party AI models.

Storage of AI Coach Conversations

Conversations and related content shared with AI Coach may be stored on infrastructure provided by Amazon Web Services (AWS), including servers located in the United States, until you delete the content, request deletion, or delete your account, whichever occurs first, unless we are required or permitted to retain certain data for legal compliance, security, fraud prevention, dispute resolution, backup, or other legitimate internal business purposes.

Deletion of AI Coach Conversations

You may request deletion of your AI Coach conversations and related content at any time by contacting us at support@wellypal.com.

We retain your Personal Data for as long as your account is active or as needed for the purposes of processing.

Impact of account deactivation/requests to erase personal data: You can deactivate your account at any time in the App settings or by sending a request to support@wellypal.com.

We will process your request within one month. In some cases, it may take up to 90 days to completely erase your personal data from our backup systems. If you choose to deactivate your account, Wellypal will delete your personal data, and it will not be recoverable should you later create another account.

Limitations: Even after your account is deleted or after processing your personal data erasure request, we may need to retain certain personal data and other information. This is required or permitted by applicable law, like the GDPR, and may include situations like:

complying with legal obligations;

managing and handling legal claims;

archiving for public interest, scientific or historical research, or statistical purposes.

Depending on the laws applicable in your jurisdiction, you may have certain rights regarding your Personal Data. These rights may include the right to know what categories of Personal Data we collect, the purposes for which we use it, and whether we disclose it to third parties.

Subject to applicable law, you may have the right to request access to the Personal Data we hold about you, request deletion of your Personal Data, request correction of inaccurate Personal Data, and object to or restrict certain types of processing. You may also have the right to opt out of certain uses or disclosures of your Personal Data, including processing activities that may be regarded as a “sale,” “sharing,” or targeted advertising under applicable privacy laws.

Where required by applicable law, and upon receipt of a verifiable request, we will provide the information required by law within the time period prescribed by applicable law. We will not discriminate against you for exercising any privacy rights granted to you under applicable law.

To exercise any rights available to you, you may contact us using the contact details provided below or use any privacy controls or request tools we make available through the Service. If you choose to opt out of certain processing activities, including personalized advertising where applicable, your choice may apply only to the specific browser, device, or service environment through which the request is submitted.

Some laws may also require us to explain how the Service responds to “Do Not Track” signals or similar browser-based privacy preferences. Unless otherwise stated, the Service does not currently respond to Do Not Track signals. However, you may be able to adjust your browser or device settings to limit certain tracking activities.

If applicable law grants additional rights to minors or registered users in relation to content they have posted through an online service, eligible users may contact us to request removal of such content or information. Please note that we may not be able to guarantee complete or comprehensive removal in all circumstances, including where retention is required or permitted by law.

We understand the importance of keeping your personal information safe and secure, and we take the following measures to protect it:

We encrypt your personal data when it is being transmitted and when it is at rest.

We perform regular system vulnerability scanning and penetration testing to identify and address potential security risks.

We protect the integrity of your data to prevent unauthorized access, use, or disclosure.

We have implemented organizational and legal measures to ensure that your data is protected, including access controls and employee training.

We conduct regular data protection impact assessments to ensure that our security measures are up-to-date and effective.

However, it's important to note that no method of transmission over the Internet or electronic storage can be guaranteed to be 100% secure. While we use commercially acceptable means to protect your personal data, we can not guarantee its absolute security.

We may share your personal data with third parties only as described in this Privacy Policy and only where necessary to provide the Service, comply with legal obligations, protect rights or safety, or where your consent or another valid legal basis applies. Where required, we obtain your permission before personal data is transmitted to a third-party AI service. This permission may be obtained through an in-context notice, consent screen, feature-specific authorization, or other affirmative action in the App, and does not require a separate mandatory pop-up reminder each time you use the feature.

We may disclose or share the information we process about you, including your personal data, in the following circumstances:

Affiliates

We may share your personal data with companies that are part of the same corporate group as us, including our subsidiaries and other affiliated entities (“Affiliates”). These Affiliates may act as our data processors and may process personal data on our behalf for purposes such as technical support, infrastructure management, analytics, and related operational services. Where applicable, such Affiliates are subject to appropriate contractual safeguards.

Service Providers, Contractors, and Business Partners.

We may disclose your personal data to third-party contractors, service providers, vendors, and business partners that support our business and help us provide the Service. These may include, for example, cloud hosting providers, email delivery providers, analytics providers, customer support tools, and subscription or payment-related service providers. We require service providers that process personal data on our behalf to do so under contractual confidentiality and data protection obligations, as applicable.

Third-Party AI Service Providers.

We may disclose certain personal data to Google LLC (USA), including in connection with Gemini-related services, which serves as our third-party AI service provider and/or data processor for AI chat functionality, content generation, abuse prevention, safety review, and related AI-powered features. Depending on the feature you choose to use, the data shared may include text prompts, uploaded photos, voice input, food logs, water intake records, exercise records, weight records, goals, other health-related information you choose to provide, and limited account, device, or technical information reasonably necessary to provide, secure, and maintain the relevant feature.

Analytics and Advertising Partners.

We may disclose your personal data to third-party analytics providers and advertising partners, or otherwise allow them to collect or access certain personal data, where permitted by applicable law. However, we do not use health-related data you provide through the Service—including Apple Health data, meal logs, water intake records, exercise records, weight records, body photos, or health-related AI Coach content—for third-party advertising, cross-context behavioral advertising, or interest-based advertising purposes.

Payment Processors.

We may disclose your personal data, including payment-related information where necessary, to payment processors and payment gateway providers that help us process transactions and manage subscription purchases. These providers may act as independent data controllers with respect to the payment information they process, in accordance with their own privacy policies.

Apple Health.

If you grant express permission on your device, we may read data from and/or write data to Apple Health. If you choose to enable this feature, we will only access or transfer the Apple Health data you authorize, and only for the purpose of providing the relevant Service features. The specific categories of Apple Health data involved will be presented to you within Apple Health. You may withdraw our access to read or write Apple Health data at any time through Apple Health or your device settings. We encourage you to review Apple’s privacy information before enabling this feature.

Business Transfers.

We may disclose your personal data in connection with an actual or proposed merger, acquisition, divestiture, restructuring, reorganization, financing, sale of assets, bankruptcy, dissolution, liquidation, or other corporate transaction involving us, our Affiliates, or any part of our business. In such circumstances, your personal data may be transferred as part of the relevant transaction, subject to applicable law.

Legal Compliance and Protection.

We may access, preserve, use, and disclose your personal data where we have a good faith belief that doing so is necessary to: comply with applicable law, regulation, legal process, or governmental request; enforce our Terms or other policies; detect, investigate, prevent, or address fraud, illegal activity, security issues, or technical problems; or protect the rights, property, safety, and security of us, our users, or others, including in situations involving potential death or imminent bodily harm.

When you use our Services, we and our service providers, vendors, and partners, including third parties, may use cookies (a small text file placed on your computer or mobile device to identify your computer and web browser) and other similar technologies to collect or receive certain information about you and/or your use of our Services.

However, it’s not only cookies that can be used in this way. Functions performed by a cookie can be achieved by other means, too. This Section, therefore, also applies to any similar technology that stores or accesses information on your device. This could include, for example, HTML5 local storage, local shared objects, beacons, pixels, and plug-ins.

We also use third-party analytics tools to help us measure traffic and usage trends of our Services, as well as for other purposes. Such analytics tools collect information via third-party SDKs incorporated into the App, which includes information about features of the App you visit or use, your actions in the App, and information about your subscription. Such information may be used to provide content, advertising, or functionality. Third parties may also use such information for their own purposes. For the avoidance of doubt, we do not use health data for advertising purposes.

Interest-based Advertising. We may partner with ad networks and other ad-serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your use of the App over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

Your Choices. Most browsers and devices are configured to accept cookies and similar tracking technologies automatically. You may be able to set your browser and device options so as to limit such technologies. You can visit the Digital Advertising Alliance (“DAA”) Webchoices tool at www.aboutads.info to learn more about this interest-based advertising and how to opt out of this kind of advertising by companies participating in the DAA self-regulatory program, and http://www.aboutads.info/appchoices for information on the DAA’s mobile app opt-out program. You can also opt out of receiving interest-based ads from members of the Network Advertising Initiative (“NAI”) by visiting the NAI consumer opt-out page at http://optout.networkadvertising.org/?c=1#!/. Opting out of receiving interest-based ads does not mean that you will no longer receive ads from us, but rather that the ads will not be tailored to your perceived interests.

Google Analytics. We use Google Analytics. To check how Google uses your personal data when you use or interact with our Services, visit “How Google uses information from sites or apps that use our services“. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

For users in the European Economic Area, United Kingdom, and United States. You can manage the collection and processing of Personal Data via cookies, SDKs, and other tracking technologies by contacting us at support@wellypal.com.

You may find that some parts of the App may not function properly if you have refused cookies or similar tracking technologies, and you should be aware that disabling cookies or similar tracking technologies may prevent you from accessing some of our content. Your choices are typically device and browser specific.

For more details on our use of tracking technologies, please see our Cookie Notice.

If you are using our Services, you may receive electronic communications from us (e.g., by posting in-app notices, via push notifications or emails). We send some of these communications to you, such as those related to your subscriptions, technical and security notices, and updates to the Privacy Policy and Terms of Use, where necessary to perform our contract with you to provide the App or otherwise based on our legitimate interest in contacting you.

Marketing & Promotional Emails. If required by law, we will ask for your consent to send you promotional and marketing emails, in-app communications, and push notifications about new products, features, or offers related to our Services. Promotional and marketing communications from us may include information about our Services as well as special offers from our trusted partners that we believe may be relevant to you. Please note, however, that we never share your personal data with third parties for their own direct marketing purposes without your consent.

If you wish to stop receiving our promotional and marketing emails, you can do so by following the “Unsubscribe” links in any marketing email sent to you.

Push Notifications. If you wish to stop receiving push notifications, you can do so through your mobile device settings by tapping “Settings” -> “Notifications” -> Choose WellyPal – > press the toggle to allow or forbid push notifications from the App.

General contact details. If you have any questions about this Privacy Policy, please contact us via email at support@wellypal.com.

The date this Privacy Policy was last reviewed is indicated at the top of the page. The Company may modify or update this Privacy Policy from time to time. Some changes do not require your consent or notification: for example, when we make changes for the sake of transparency, when we add a new purpose of processing that is compatible with the existing purposes, or a new processing activity that falls under the users’ reasonable expectations. However, if the changes made may pose risk to your rights and freedoms (for example, by including a new purpose of processing that is not compatible with the existing purposes of processing, a new legal basis, or a new category of personal data to be collected or a new data subject, all of which are not reasonably expected by the users), we will ask for your consent to those changes separately from this Privacy Policy. If you did not receive a request for your consent to the changes or refused to give consent, those changes will not apply to you. This can negatively affect some of our Services provided to you if those Services inevitably require consent to the changes.