This Policy is drafted to align with GDPR (EU) 2016/679 and Romanian Law no. 190/2018. Have a Romanian privacy lawyer review controller identity, processors, and retention before wide public launch.
1. Who is the controller?
The data controller (“operator”) for personal data processed in Robycal is the Robycal product operator, reachable at support@robycal.com.
When a Romanian company (SRL) is registered for Robycal, this Policy will be updated with the full legal name, CUI/CIF, and registered office.
Until that update, support@robycal.com remains the contact for all GDPR requests (access, erasure, objection, etc.).
Health and fitness data (special category under GDPR Art. 9 when related to health): age, sex/gender identity as provided, height, weight, body-fat estimates, activity level, nutrition goals, food logs, macros, workout logs, steps, Apple Health steps (if you connect HealthKit), streak and progress metrics.
Photos and media you upload for food or body analysis, plus derived AI outputs (estimates, labels).
Social data you choose to share: public profile fields, friend codes, direct messages, Flame Circle activity.
Technical, security, and abuse-prevention data: device/app diagnostics, push tokens, App Check / attestation signals where used, consent acceptance ledger (versions, timestamps, method), subscription entitlement status via Apple / RevenueCat, and investigation records for fraud or Terms abuse.
We do not require government ID. We do not sell your personal data.
3. Purposes and legal bases (GDPR Art. 6)
Provide the account and core app features (contract / Art. 6(1)(b)).
Security, fraud prevention, abuse prevention, chargeback defence, and enforcing Terms (legitimate interests / Art. 6(1)(f); sometimes legal obligation).
Customer support and service communications related to your account (contract / legitimate interests).
Subscriptions and billing records needed for App Store purchases and dispute handling (contract / legal obligation / legitimate interests).
Optional marketing messages only if you separately opt in (consent / Art. 6(1)(a)); you can withdraw anytime.
Product improvement using aggregated or de-identified insights where feasible (legitimate interests), without selling profiles.
4. Health data (GDPR Art. 9)
Body metrics, nutrition logs, workout data, and related photos can constitute special-category health data.
We process this data based on your explicit consent (Art. 9(2)(a)) given in the app before onboarding health fields and when enabling HealthKit sync.
You may withdraw health-data consent by stopping use of those features and/or deleting your account. Withdrawal does not affect processing already lawfully done.
Without health-data consent, core calorie/workout personalisation cannot function; you may still delete the account.
5. AI analysis
Food photos and related prompts may be sent to AI providers to estimate nutrition (e.g. Google Gemini and/or OpenAI models routed by our backend).
AI outputs are estimates only and may be wrong; you can edit results before saving.
We apply content-policy checks to reduce misuse and may retain limited moderation signals for safety and abuse prevention.
Do not upload sensitive images of other people without permission.
Providers act as processors / sub-processors under our instructions and applicable DPAs where in place.
6. Processors and international transfers
Google Firebase (Authentication, Realtime Database, Cloud Functions, Storage, Cloud Messaging) — hosting and backend.
Apple (Sign in with Apple, App Store / subscriptions, HealthKit on device when you enable it).
Google Sign-In when you choose that sign-in method.
RevenueCat for subscription entitlement status.
AI providers used for food/vision analysis as configured in production.
Some providers may process data outside the EEA. Where required, we rely on appropriate safeguards (e.g. Standard Contractual Clauses) and provider compliance programmes.
Account and logging data are kept while your account is active.
After account deletion, we delete or anonymise personal data from production systems within a reasonable period (target: up to 30 days), except where longer retention is required by law, dispute/chargeback handling, fraud investigation, or secure backup rotation.
Consent ledgers, security logs, and abuse/investigation records may be kept longer where needed to establish, exercise, or defend legal claims (GDPR Art. 17(3)(e) and related bases).
Local device caches are cleared when you sign out or uninstall, subject to OS behaviour.
8. Your rights (GDPR)
Access, rectification, erasure (“right to be forgotten”), restriction, and portability where applicable.
Object to processing based on legitimate interests.
Withdraw consent at any time for consent-based processing (including health data and marketing).
Erasure may be limited where we must retain data for legal claims, security, or mandatory law.
Lodge a complaint with ANSPDCP (Romania) or another EU supervisory authority of your habitual residence.
In-app: Settings → Privacy Policy / Terms; Settings → Delete Account for erasure of the account.
Email support@robycal.com to exercise rights; we respond within GDPR timelines (generally one month).
9. Supervisory authority (Romania)
Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP).
You can complain to ANSPDCP if you believe your data protection rights were infringed.
10. Children
Robycal is intended only for users aged 18 or older.
We do not knowingly collect personal data from children under 18.
If you believe a minor created an account, contact support@robycal.com for deletion.
11. Security
We use industry-standard measures appropriate to the risk (encryption in transit, authenticated access, least-privilege backend rules, account deletion pipeline).
No method of transmission or storage is 100% secure; please use a strong unique password and keep your device updated.