1. Controller

The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) is:

2. General information

The protection of your personal data is important to us. We process personal data exclusively in accordance with the applicable data protection laws, in particular the GDPR.

This privacy policy applies in particular to the SimCalories app and explains how we process your data, including data from Apple Health (HealthKit) and when using our AI-based features. It is also intended to meet the privacy policy requirements for apps that use HealthKit on the Apple App Store.

3. Use of Apple Health / HealthKit

Our iOS app can access health and activity data from Apple Health via HealthKit after your explicit consent.

We use this data only to provide core functions of SimCalories, such as calorie and activity analysis, progress tracking and personalized recommendations within the app and the AI assistant.

Handling of HealthKit / Apple Health data

• Health data is processed solely for health, fitness, and wellness purposes directly related to SimCalories' functionality.
• Health data is not used for advertising, marketing, tracking, or data mining that is unrelated to improving your health and fitness.
• Health data is never sold to third parties.
• Health data is not shared with third parties for their own marketing, advertising, or analytics purposes.
• Where possible, health data is stored locally on your device. If we temporarily transmit selected values to our servers or to our AI provider to generate a response, this takes place via encrypted connections and we do not create long-term profiles from this data.
• You can revoke access to health data at any time in the Apple Health settings on your device. After revocation, the app can no longer read new health data from Apple Health.

4. Use of AI features (chat assistant)

When you use the AI chat assistant in the app, the content you enter (questions, messages) and — if you have enabled it — selected context data (for example, your activity, nutrition and health-related data from Apple Health) may be processed in order to generate suitable answers.

For this purpose, your data is transmitted to our servers and to an AI service provider, where it is processed to generate responses. We do not use this information to personally identify you or to show you personalized advertising.

Please avoid entering information about third parties or other sensitive data that is not necessary for using the app.

5. Use of OpenAI as AI service provider

For some AI-based functions (for example, the chat assistant) we use the service provider OpenAI as a technical processor.

What data may be transmitted to OpenAI?

• Text content that you enter in the chat or other AI functions.
• Context data required for the response, for example aggregated or selected health and fitness information (such as steps, energy expenditure, weight, workouts), if you have enabled access.
• Technical metadata (e.g. time of request, language, app version, possibly truncated IP address) necessary for delivery and security.

Purpose and legal basis

Data is processed for the purpose of providing AI-based answers and improving the quality and security of the service. The legal basis is your consent (Art. 6(1)(a) GDPR), which you give by activating and using the AI functions, and — where necessary — the performance of a contract (Art. 6(1)(b) GDPR).

Transmission to OpenAI takes place via encrypted connections. We do not permit the use of this data for OpenAI's own marketing purposes. Storage periods and further processing at OpenAI are governed by OpenAI's own privacy policy and terms.

6. Server log data

For the technical provision and security of our services, the following data may be processed on our servers:

7. User account

If you create an account, we store the data that is necessary to provide and manage the app:

• Login information (e-mail, password hash, if applicable)
• Settings and preferences
• Subscription status

8. In-app purchases and subscriptions

Subscriptions and in-app purchases are processed via Apple. We do not receive any full payment card data from Apple.

Apple's privacy policy:
https://www.apple.com/legal/privacy/

9. Disclosure of data

Data is only shared with technical service providers that we use to provide the app (for example, hosting providers, analytics where applicable) and with AI service providers (such as OpenAI) to generate answers, or where we are legally obliged to do so.

Personal data, and in particular health data, is not sold to third parties.

10. Your rights

Under the GDPR, you have in particular the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to withdraw consent (Art. 7 GDPR)
• Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

11. Withdrawal of consent

You can withdraw your consent to the processing of personal data at any time with effect for the future, for example by changing the corresponding settings in the app or in Apple Health. From that point on, no new data will be transmitted for the respective purposes.