In order to use our application, we may ask you to enter your name, email, current weight and height, target weight, fitness level, and food preferences, and ask other onboarding questions. We also automatically collect from your device unique identifiers (such as IDFA and UUID) if you allow tracking on your device. We need this data to provide our services, analyze how our customers use the app, to serve ads.
For improving the app and attracting users, we use third party solutions. As a result, we may process data using solutions developed by Google, Apple, Amplitude, AppsFlyer. Therefore, some of the data is stored and processed on servers of such third parties. This enables us to (1) analyze different interactions (how often users make subscriptions, the average weight and height of our users, what are their food preferences; (2) serve ads (and are able to show them only to a particular group of users). Consequently, we, in particular, better understand in what of our features and content you see the most value and are able to focus on them to enhance your experience and increase the quality of our products.
Please read our Privacy Policy below to know more about what we do with data (Section 2), what data privacy rights are available to you (Section 5) and who will be the data controller (Section 12). If any questions will remain unanswered or you would like to exercise your privacy rights, please contact us at hello@salmo.app
Privacy Policy
This Privacy Policy explains what personal data is collected when you use our mobile applications, websites, and the services provided through them (together “App” or “Service”), how such personal data will be processed.
By using the service, you promise us that (i) you have read, understand and agree to this privacy policy, and (ii) you are over 16 years of age (or have had your parent or guardian read and agree to this privacy policy for you). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) delete your account and contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time, or by us if you purchased it directly from our websites; and (c) delete the App from your devices.
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states to the European Union and the European Economic Area.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
1. CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, when you create an account with us or send us an email). We also may receive data about you from third parties (for example, when you sign in via Apple). Finally, we collect data automatically (for example, your IP address).
1.1. Data you give us
You provide us information about yourself when you register for and/or use the Service. For example: name, age, gender, data on physical characteristics (including height and weight), fitness level, food preferences (including diet preferences; preferred number of meals, foods you do not like, or food allergies), email address.
1.2. Data provided by third parties
When you use sign in with Apple to register an account in the App, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the sign in with the Apple screen. Find more about signing with Apple here.
1.3. Data we collect automatically:
- Data about how you found us.
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad). - Usage data
We record how you interact with our Service. For example, we log your taps on certain areas of the interface, the features, and content you interact with, recipes you choose, the time and duration of your workouts, how often you use the App, how long you are in the App, your training program progress, and your subscription orders. We also record the ads in our App with which you interact (and the Internet links to which those ads lead). - Advertising IDs
We collect your Apple Identifier for Advertising (“IDFA”) or Universal Unique ID (“UUID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this). - Transaction data
When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.
2. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
2.1. To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
2.2. To customize your experience
We process your personal data, in particular, such as the time you can dedicate to cooking, your food preferences, allergies, or your location to adjust the content of the Service that would be tailored to your needs. For example, knowing your location enables the Service to suggest to you shops and markets where you can purchase the ingredients necessary for your meals.
2.3. To manage your account and provide you with customer support
We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.
2.4. To communicate with you regarding your use of our Service
We communicate with you, for example, by push notifications. These may include reminders and motivational messages encouraging you to follow your nutrition plan, or other information about the App. To opt out of receiving push notifications, you need to change the settings on your device.
2.5. To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and nutrition plans of the Services our users like more, what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing. For example, if we discover that users specifically like some products, we may develop and introduce new recipes using this product.
2.6. To send you marketing communications
We process your personal data for our marketing campaigns. We may add your email address to our marketing list, provided we receive consent or otherwise establish legal basis for sending you marketing communications. As a result, you will receive information about our products, such as for example, special offers. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.
We may also show you advertisements in our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device.
2.7. To personalize our ads
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products, for example, in your Facebook’s feed.
2.8. To process your payments
We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for our Service and we will be notified that the payment has been made and will provide you with confirmation. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
2.9. To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
2.10. To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (APPLIES ONLY TO EEA-BASED USERS)
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.
We process your personal data, in particular, under the following legal bases:
3.1. Your consent
We rely on this basis to send you marketing communications.
3.2. To perform our contract with you
Under this legal basis we:
- Provide our Service (in accordance with our Terms and Conditions of Use)
- Customize your experience
- Manage your account and provide you with customer support
- Communicate with you regarding your use of our Service
- Process your payments
3.3. For our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data
We rely on legitimate interests:
- To communicate with you regarding your use of our Service
This includes, for example, sending you push notifications reminding you about your nutrition goals. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. - To research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features). - To send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way. - To personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way. - To enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
3.4. To comply with legal obligations
4. WITH WHOM WE SHARE YOUR PERSONAL DATA
We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 2 of this Privacy Policy. The types of third parties we share information with include, in particular:
4.1. Service providers
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We share your personal information with the following types of service providers:
- cloud storage providers (Google, Apple)
- data analytics providers (Amplitude, AppsFlyer)
- marketing partners (in particular, social media networks, marketing agencies, email delivery services)
- payment processing providers
4.3. Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
4.4. Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You have the right to review, edit, or change the personal data that you had previously provided to us in the account section of the App. If you would like to receive a copy of data we process, please send us a data access request.
Deleting your personal data. You can request the erasure of your personal data, as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof. Additional information for EEA-based users. If you are based in the EEA, you have the following rights in addition to the above:
- The right to lodge a complaint with the supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work, or where the alleged infringement has taken place.
- The right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data as described above. The data will be made available to you in the .json file or another file format.
To exercise any of the available to you privacy rights, please send a request to hello@salmo.app
6. AGE LIMITATIONS
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at hello@salmo.app
7. INTERNATIONAL DATA TRANSFERS
We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.
8. CHANGES TO THIS PRIVACY POLICY
We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.
9. CALIFORNIA PRIVACY RIGHTS
This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.
For more details about the personal information we have collected, including the categories of sources, please see Section 1 above. We collect this information for purposes described in Section 2 of this Privacy Policy. We may also share your information with certain categories of third parties as indicated in Section 4.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at hello@salmo.app. We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.
Access rights under California’s Shine the Light
California also provides its residents with additional access rights. Under Shine the Light law, the residents may ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to hello@salmo.app, which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
10. DATA RETENTION
We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
11. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Except as otherwise stipulated in this Privacy Policy, this App does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
12. PERSONAL DATA CONTROLLER
Developer Tetiana Nikolin Tewill be the controller of your personal data.
13. CONTACT US
You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at hello@salmo.app.
Last updated: 16.06.22