PRIVACY POLICY

Last updated: July 3, 2025

TechForce OÜ
Registry Code: 16238287
Registered Address: Sepapaja tn 6, Tallinn, Estonia 15551
Email: support@carbsyapp.com

1. INTRODUCTION

TechForce OÜ (“we,” “our,” or “us”) operates the Carbsy mobile application (the “Service”). This Privacy Policy explains how we collect, use, and protect your information when you use our Service.

We are committed to protecting your privacy and complying with applicable data protection laws, including the European Union General Data Protection Regulation (GDPR).

2. INFORMATION WE COLLECT

2.1 Personal Data We DO NOT Collect

We do not collect personally identifiable information such as:

• Names
• Email addresses
• Phone numbers
• Physical addresses
• User accounts or login credentials

2.2 Data We Do Collect

We collect the following types of non-personally identifiable information:

• Usage Data: Information about how you use the app, including features accessed and interaction patterns
• Device Information: Device type, operating system version, app version, and unique device identifiers (for analytics purposes only)
• Food and Nutrition Data: Information about meals you track, including photos, voice recordings, text descriptions, and calculated nutritional information
• Technical Data: App performance data, crash reports, and error logs for troubleshooting purposes

3. HOW WE USE YOUR INFORMATION

We use the collected information for the following purposes:

• To provide and maintain our Service
• To process your food tracking requests and provide nutritional analysis
• To improve app functionality and user experience
• To analyze usage patterns and optimize app performance
• To troubleshoot technical issues and provide customer support
• To comply with legal obligations

4. THIRD-PARTY DATA PROCESSING

4.1 OpenAI API

When you submit food photos, voice recordings, or text descriptions, this data is processed by OpenAI’s API services to provide nutritional analysis. Important details:

• Your data is sent to OpenAI servers for processing
• OpenAI does not use your data to train their AI models
• Data transmission is encrypted and secure
• We do not share personally identifiable information with OpenAI as we don’t collect it
• OpenAI’s data processing is governed by their privacy policy and data processing agreement

4.2 Analytics Services

We may use third-party analytics services to understand app usage and improve our Service. These services may collect device identifiers and usage data but cannot identify you personally.

5. DATA STORAGE AND SECURITY

We implement appropriate technical and organizational measures to protect your data:

• Data is encrypted in transit and at rest
• We use secure servers and follow industry best practices
• Access to data is limited to authorized personnel only
• We regularly review and update our security measures

6. DATA RETENTION

We retain your data only as long as necessary to provide our services and for legitimate business purposes:

• Food tracking data: Retained while you use the app and for up to 90 days after app deletion
• Analytics data: Retained for up to 24 months
• Technical logs: Retained for up to 12 months

7. YOUR RIGHTS UNDER GDPR

If you are in the European Economic Area, you have the following rights:

• Right of Access: You can request information about the data we process
• Right to Rectification: You can request correction of inaccurate data
• Right to Erasure: You can request deletion of your data
• Right to Restrict Processing: You can request limitation of data processing
• Right to Data Portability: You can request your data in a portable format
• Right to Object: You can object to data processing for legitimate interests

To exercise these rights, contact us at privacy@carbsyapp.com.

8. CHILDREN’S PRIVACY

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected such information, we will take steps to delete it.

9. INTERNATIONAL DATA TRANSFERS

Your data may be transferred to and processed in countries other than your own, including Estonia, the United States (OpenAI servers), and other countries where our service providers operate. We ensure appropriate safeguards are in place for such transfers in compliance with GDPR.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy in the app and updating the “Last updated” date. You are advised to review this Privacy Policy periodically.

11. CONTACT US

If you have any questions about this Privacy Policy or our data practices, please contact us:

TechForce OÜ
Email: privacy@carbsyapp.com
Subject: Privacy Policy Inquiry

12. LEGAL BASIS FOR PROCESSING (GDPR)

Our legal basis for processing your data under GDPR:

• Legitimate Interest: For app functionality, analytics, and improvement
• Contract: To provide the services you request through the app
• Legal Obligation: To comply with applicable laws and regulations

13. DATA PROTECTION OFFICER

For data protection inquiries, you can contact our designated representative at privacy@carbsyapp.com with the subject line “Data Protection Inquiry.”