This Privacy Policy applies to information collected about you by or on behalf of Morgal FB LLC (Alentia) (collectively, “Alentia”, “we”, “us”, “our”), including, but not limited to, Personal Information (as defined below) collected through our website at https://alentia.app, mobile versions of the website, our mobile application, (collectively, the “Site”), by phone, and anywhere else we display this Privacy Policy or collect Personal Information (collectively with the Site, the “Platforms”). This Privacy Policy outlines the information we collect, how we use, share, and protect that information, and your rights and choices with regard to your Personal Information. Please be sure to read and accept this entire Privacy Policy, our Website Terms and Conditions, and our App Terms and Conditions before using or submitting information via the Platforms or otherwise in connection with our Services (as defined below).
1. Collection of Information
“Personal Information” means information that directly identifies, relates to, or can be used to identify, you as an individual. When you visit or use any of the Platforms or services offered by us including, without limitation, the Alentia nutrition app services or any other services offered by us in connection with our business (collectively, “Services”), we collect your Personal Information. Some of this Personal Information is required in order to allow you to use certain features of the Platforms (for example, in order to use the app, you will need to provide us with certain Personal Information). Other Personal Information is submitted by you explicitly. Some information is collected automatically. The type of information we collect may vary depending on how or why you interact with the Platforms.
Types of Personal Information we collect:
Contact information such as your name, address, email address, telephone number, including mobile number
Profile information including health, dietary and wellness data to develop and facilitate your customized nutrition and training program, such as height, weight, date of birth, age, gender, estimated body fat percentage, activity level, allergies, intolerances, nutrition/dietary goals, current and completed training information, dietary details, health or conditions that you disclose, your daily mood for training, data obtained from wearable devices including health data, information about your menstrual cycle, meal images/data, water intake, workout sessions, or similar, recommended food, fatigue signals, sleeping details (collectively, “Dietary, health and Wellness Data”). Some of these data will be collected only with your consent if you decide to use specific features
Payment information such as your billing address and payment methods including “buy now pay later” systems
Transaction history such as purchase information, order history, and product/services interests
Loyalty points and benefits information including your participation in loyalty programs, earning of loyalty points and redemption of points, including eligibility, rewards, fraud prevention checks
Referral program information including name, contact details, transactions, eligibility, rewards, fraud, if you decide to benefit from our referral programs with third parties. Referral programs may imply sharing information with third party referees
Information on grocery products: products that you scan or photograph to check the fullness factor or products you indicate that you want to purchase
Data related to leagues and tournaments may include qualifications, information on performances, photographs, comments, calories, weight, training
Communications information and interaction history, including support messages or in-app activity, chats with Alentia’s AI chatbot, video interactions with AI assistants and training assistants, email messages, voice recordings, call transcripts, SMS records, message content and information that you share when you contact customer service
Feedback such as survey responses and comments you submit to us
Account information such as username and other login credentials and marketing preferences (to receive newsletter)
Browsing and device information such as the URL you just visited, the browser version your computer is operating, the date and time you visited, the pages you visited on the Site and your IP address, device types, IDs and settings, app version, push notification token, and other browsing data
Training-related data: type of exercise performed (e.g., gym, running, yoga, etc.), days per week of training, approximate workout duration, etc.
Photograph, voice, videos: if you decide to record or upload videos that may include your voice and photographs to interact with other users in groups or internal social media features
Social media-related data and content: interactions on social media and internal social media features: profile data, likes, conversations, comments
2. How We Collect Your Personal Information
We may collect information directly from you, automatically via your use of the Platforms, or from third-party sources.
You may provide information directly to us when you: use a Platform or request Services through a Platform (such as through our Contact page); register an account with us; set up a profile; input data to the app (e.g., logging meals, daily moods, and workouts); complete a survey; contact customer service; participate in our marketing campaigns (including contests, promotions, loyalty or other activities) or competitions, referral and loyalty programs, accept the connection of your wearable device; interact on social media including uploading content in internal social media features, interact with users groups, or otherwise communicate with us (including by phone, email, text or online live chat), scan grocery products, or if you integrate your grocery lists with supermarkets’ websites.
We collect Personal Information automatically when you visit the Platforms. We may collect information via cookies, analytics tools, and other online tracking technologies, as further described in Section 6: Cookies and Other Online Tracking Technologies; Third Party Tracking Disclosures and also if you authorize providing us with access to information collected through your wearable health devices. It may also be collected through your use of the Services. We may also receive and process such Personal Information from third parties. The Personal Information we may automatically collect includes the below categories of information (collectively, “Usage Data”):
Device and Browsing Information. When you visit the Site, we may collect IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information.
Wearables information. With your consent, we will have access to the health information that is collected through your wearable health devices.
Activities and Usage. We also collect activity information related to your use of the Site, such as information about the links clicked, searches, features used, items viewed, referrals, use of loyalty program, time spent within the Site, your interactions with us and other users within the Site, and other activity and usage information.
We may collect information from other sources, including service providers or referrals. If we share your Personal Information with third parties, we will sign confidentiality and privacy agreements that are intended to adequately protect your Personal Information.
3. How We Use Your Personal Information
We may use the Personal Information we collect from you to accomplish our business purposes including to:
Provide the Platforms and Services to you based on the information we have about you;
Provide you with customer support and personalized services and assistance;
Market our products and Services to you, including to provide notifications of, or evaluate your eligibility for, products, Services, competitions and loyalty and referral programs offered by us;
Offer you services from third parties;
Managing our loyalty or referral program;
Allow you to scan barcodes to check the applicable fullness factor;
Personalize your experience with the Services and Platforms, personalize the Services based on the information you provide us or that we collect, including through wearables, health, fatigue, mood or menstrual cycle information;
Communicate with you and otherwise notify you about your account or changes to the Platforms or Services, including our IA assistant and chatbot;
Protect you, us, or others from security threats by enhancing the security of our network and information systems;
Identify and prevent fraud;
Maintain your account with us;
Interact with you on social media or allow you to interact in our social media features and interact with other users including through users’ groups
Enable or administer our business (e.g., to service our equipment, secure or make improvements to the Platforms, prevent fraud, issue invoices, etc.);
Allow you to integrate with supermarkets to create shopping lists;
Comply with applicable laws and industry regulations and requirements from competent authorities; and
Improve, evaluate, and develop new Platforms, Services and products of Alentia, including by aggregating information to understand how our products and Services are being used, including browsing and device information. We may use IP addresses or other browsing and device information to analyze trends, administer the Platforms, track customer navigation on a Platform and gather aggregated demographic information.
No user data — active, inactive, or previous — is used to train, fine-tune, or modify any algorithm or third-party AI model. Each customer's data is used exclusively for that individual.
Important: Dietary, Health and Wellness Data is used exclusively and as strictly necessary to deliver the Services and not to provide healthcare assistance: e.g., to calculate your personalized nutritional and exercise plan, avoid recommending foods or exercises that are not suitable for you, provide coaching and support, and screen for potentially extreme restrictions. During onboarding, users must provide explicit consent for the use of their Health, Dietary and Wellness Data and acknowledge a health warning identifying contraindications including existing medical conditions, medication use, fasting over 18 hours, underweight status, minors, pregnancy, lactation, and eating disorders. With your explicit consent, we will collect information related to your mood, fatigue, sleep details or menstrual cycle as required to personalize the Services. We will not collect information on health other than health, dietary requirements or allergies that may be relevant for the Services. Please do not include health information that would not affect your use of the Services. The nutrition algorithm enforces minimum caloric thresholds to prevent dangerously low intake recommendations. The chatbot system is designed to provide training recommendations and assist you in the use of the Services, including prompt recommendations to prevent extreme restrictions or anything that could constitute medical treatment; it is designed to redirect users to licensed healthcare professionals for medical concerns.
Use of Artificial Intelligence. Certain features of the Services, including our ALIA chatbot, AI assistants, AI workout tracking, and food photo analysis, are powered by artificial intelligence. When you interact with these features, you are interacting with an AI system and not a human. AI-generated outputs may be inaccurate or incomplete, are not medical advice, and should not replace advice from a licensed healthcare professional. We do not use AI features to make decisions that produce legal or similarly significant effects concerning you. ALIA provides only the chat service itself: we do not analyze the content of your conversations with ALIA, and conversation data is not retained for more than 24 hours.
4. How We Share Your Personal Information
In some cases, we may share your Personal Information with business partners, or service providers including vendors or analytics and marketing partners. These entities act as independent data controllers and process your Personal Information in accordance with their own privacy policies. The legal basis for this sharing is consent, the need to fulfil a contract, compliance with applicable laws or our legitimate interest in efficiently managing and operating our business, which we have balanced against your rights and have determined that such sharing does not override your interests, rights, or freedoms.
Service Providers. We engage companies and individuals (e.g., vendors, contractors, attorneys, auditors and accountants) to perform certain Services on our behalf (such as conducting audits, performing legal services, processing credit card payments, providing subscription management services, providing underlying AI models, chatbot and analyzing data, providing customer service, providing customer database management services, providing email services, providing push notification services, providing marketing services). These third-party service providers may have access to Personal Information in order to perform the Services for which they are engaged. For example, Alentia uses AI services to offer assistance, generate meal plans, analyze food photos, and offer nutritional suggestions.
Business Transfers. When necessary in the case of a merger or combination with, or acquisition of a portion of our business by, another company or entity.
Compliance with Law. We may release Personal Information about you if we believe such a release is necessary to comply with the law or in response to a subpoena or subject to other legal process or as needed to protect our rights.
Other Third Parties. We may also share your Personal Information with third parties with whom we have joint marketing arrangements to market other products and Services to you, in compliance with privacy laws, including supermarkets, referral partners, bar code scanning providers, and companies offering other joint programs.
Social media providers and other Alentia users. When you decide to interact or share content in third party social media, in Alentia’s social media or with groups of Alentia users.
As necessary in connection with other lawful business purposes.
As otherwise necessary when required or permitted by law.
5. Protection of Your Personal Information
We have implemented and maintain an information security program consisting of physical, electronic and managerial procedures designed to safeguard and maintain the privacy, security, and integrity of your Personal Information, including encryption in transit and at rest. Please be aware, however, that no method of data transmission or storage is completely secure.
6. Cookies and Other Online Tracking Technologies
We and our third-party providers use cookies and other technologies to collect Usage Data. Cookies are files that are installed on your device when you visit a website. They are used to ensure the quality, usability, and proper functioning of websites, as well as to store and retrieve information about browsing habits and personalize content. They can also sometimes be used to recognize a website user. We may allow third parties to collect this Usage Data on our behalf and to retain and use this Usage Data themselves. We use this Usage Data to, for example, analyze and understand how you access, use, and interact with us through the Site, to identify and resolve bugs and errors in the Site, to assess, secure, protect, optimize, and improve the performance of the Site, analytics purposes, and to personalize content in the Site. We may also aggregate such information to analyze trends, administer the Site, and gather broad demographic information. We also use some cookies that are strictly necessary in order for the Site to function. We do not perform cross-device tracking. If you log in to your account on more than one device, your account information is synchronized only within that logged-in account; we do not otherwise track or link your activity across different devices.
We use Meta Pixel and other similar technologies to better measure, optimize, and retarget our marketing campaigns. This allows user specific behavior to be tracked after they have been redirected to the advertiser’s website by clicking on a social media or search ad. This enables us to measure the effectiveness of social media and search ads for statistical and market research purposes. The data collected in this way is anonymous to us, in other words, we do not see the Personal Information of individual users. This data is stored and processed by the social media and search providers. The social media and search providers may link this information to your social media or search account and also use it for its own promotional purposes, in accordance with their data privacy and usage policies. For more information, please visit: https://www.facebook.com/about/privacy/. For more information on opt-out options, please visit: https://www.facebook.com/help/568137493302217.
7. Third-Party Links
We may provide links on the Platforms to third-party websites we think may be of interest to you, including plug-ins that link to social media sites. These websites are independent from Alentia, are not under Alentia’s control, and have their own separate privacy policies. Alentia is not responsible for the privacy practices or content of such third-party websites and this Privacy Policy does not apply to the privacy practices of those sites or of any companies that Alentia does not own or control. Whenever you click on links on the Platforms that take you to a third-party website, you will be subject to the third party's privacy policies. We recommend that you review the third parties’ privacy polices before you visit these websites.
8. Social Media Sites and Sharing with other Alentia users
We may also receive information about you from social media platforms when you interact with us on those platforms, access our social media content, if you use a third-party account to sign-in to the Services, or link a third-party account to your account. Please note that the information we may receive from those third parties (such as Facebook, Twitter, LinkedIn, Instagram, TikTok, and YouTube) is governed by the privacy settings, policies and/or procedures of the applicable platform, and we strongly encourage you to review them before submitting any information using a social media platform. We may also process your Personal Information if you interact with other users in internal Alentia’s social media features. You have the ability to post social media content our internal social media service. You may define who may view your posts. Participation in competitions or tournaments may be posted or shared with a certain group of users with your consent. This may imply sharing data about your training, calories, weight or wellness.
9. Children’s Privacy
The Platforms are not intended for use by individuals under the age of 18. We do not knowingly collect or solicit any Personal Information from children under the age of 18 or knowingly allow such persons to register for an online account. Should we learn that someone under the age of 18 has provided any Personal Information to or on the Platforms, we will remove that information as soon as possible unless we are otherwise legally required to retain it.
10. Opting Out of Promotional Emails
If you decide for any reason that you no longer wish to receive promotional email information from us, you can unsubscribe from the Site’s email distribution list by clicking the “unsubscribe” link located at the bottom of each promotional email. You can also opt out of receiving promotional materials by updating your preferences in your account settings, or by notifying us by mail or email at the address and number listed below:
Alentia
1521 Concord Pike, Suite 201
Wilmington, Delaware 19803
United States
or
11. Your Privacy Rights and Choices (U.S.)
This section describes state-specific consumer rights afforded to residents of those states who have enacted comprehensive privacy laws (“State Privacy Laws”). Depending on where you reside in the United States, certain State Privacy Laws may apply to the processing of your Personal Information. Any terms defined in the applicable State Privacy Laws that we use here have the same meaning as the applicable State Privacy Law.
California Residents: If you are a resident of California, then please review Section 12 below, "California Residents Privacy Rights Notice" for information about your rights and choices.
Residents in Other States with Privacy Laws: The following rights may apply to the processing of your Personal Information if you reside in a state with an applicable privacy law (including, without limitation, Colorado, Virginia, Connecticut, Delaware, and Oregon):
The right to confirm whether we are processing your Personal Information and to access such Personal Information, including the right to know certain information about the third parties with whom Personal Information is shared.
The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information, and our purposes of the processing of such Personal Information.
The right to delete Personal Information provided by or obtained about you.
The right to obtain a copy of your Personal Information that you previously provided to us in a portable and if technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance.
The right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. This is not currently applicable to our processing.
The right to opt out of the sale of your Personal Information and the processing of your Personal Information for targeted advertising.
The right to obtain a list of the specific third parties (or categories of third parties, where permitted) to which we have disclosed your Personal Information, where provided by applicable law.
The right not to be discriminated against for exercising such rights.
Sensitive data. We process sensitive data, including dietary, health and wellness data, only with your prior opt-in consent and only as strictly necessary to provide the Services you request. You may withdraw your consent at any time through your account settings or by contacting us. We do not sell sensitive data.
Residents in the European Economic Area (“EEA”)(which includes the EU, Norway, Iceland and Liechtenstein), the United Kingdom (UK) and Switzerland (collectively, “Europe”): The following rights may apply to the processing of your Personal Information if you reside in Europe:
The right to confirm whether we are processing your Personal Information and to access such Personal Information, including the right to know certain information about the third parties with whom Personal Information is shared (right to access).
The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information, and our purposes of the processing of such Personal Information (right to rectification).
The right to object to the processing of your Personal Information (right to object).
The right to delete Personal Information provided by or obtained about you (right to erasure).
The right to obtain a copy of your Personal Information that you previously provided to us in a portable and if technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance (right to data portability).
The right to request the restriction of processing of your Personal Information if the accuracy of your Personal Information is contested, the controller no longer needs the Personal Information, the processing is unlawful, or you have otherwise objected to the processing.
The right to withdraw your consent.
The right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
The right to raise a claim before the corresponding data protection supervisory authority (please find here the contact details of EEA supervisory authorities: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en, UK: https://ico.org.uk/ and Switzerland: https://www.edoeb.admin.ch/en).
Exercising Your Privacy Rights: To exercise these rights and submit a privacy request, please email us at [email protected] with the subject line “Privacy Request”.
You may also correct or update much of your Personal Information at any time from the app. You can delete your Personal Information from Profile → Delete Account. Upon the earlier of the deletion of your account or termination of your subscription, your account will be deactivated and your Personal Information will not longer be used to provide the Services. Personal Information not subject to retention under the “Retention periods” table in Section 13 below will be permanently deleted from our servers within 6 months. The categories listed in that table will be kept only in a blocked or restricted state, with access limited and without processing for any other purpose, for the periods stated in the table and only to the extent necessary to establish, exercise, or defend legal claims or meet legal obligations. After the applicable retention period ends, the Personal Information will be permanently deleted or anonymized. Note: Deleting your account doesn't automatically cancel your subscription. You must manage the cancellation from your app store settings (App Store or Google Play).
We may need to collect additional information about your previous interactions with us to verify your identity. You may designate an authorized agent to submit requests on your behalf. To submit a request as an authorized agent on behalf of a consumer, please contact us at [email protected]. If we refuse to act upon your request, you may appeal such refusal by contacting us after your receipt of the refusal at [email protected].
To exercise your rights to opt out certain disclosures of Personal Information such as Usage Data, you may opt out through the settings in our cookie banner.
12. California Residents Privacy Rights Notice
The information included in this section applies to residents of California and contains disclosures required by the California Consumer Privacy Act (“CCPA”). If you have questions about this Privacy Policy, including anything in this section, please contact us at [email protected].
Personal Information We Collect and Disclose. In the preceding 12 months, Alentia collected and disclosed the following categories of Personal Information:
Personal and online identifiers (such as name, telephone number, email address, or other unique online identifiers)
Categories of information described in Cal. Civ. Code § 1798.80(e) (such as physical characteristics or description)
Characteristics of protected classifications under California or federal laws (such as sex/gender, age)
Commercial or transactions information (such as records of transactions with Alentia and information you associate with your Alentia account)
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
Audio, electronic, visual, or similar information (such as call/voice recordings and other communications information as described above)
Non-precise geolocation information (such as zip code or IP address)
Inferences drawn from the above information about your predicted characteristics and preferences (to create your nutrition plan)
Sensitive Personal Information (such as, (potentially), Dietary and Wellness Data)
Some of the categories of Personal Information listed above may be considered Sensitive Personal Information under the CCPA, such as Dietary and Wellness Data. We do not use or disclose Sensitive Personal Information, as defined by the CCPA, for purposes other than those specified in the CCPA. For example, to perform the Services of creating and providing your customized nutrition and training plan and support features.
We do not engage in sales of Personal Information for monetary consideration. However, the use of certain Personal Information such as Usage Data by some of our vendors for product development and similar purposes may constitute a “sale” or “share” of such data under the CCPA, and we do not sell or share Sensitive Personal Information. We do not otherwise engage in “sales” or “sharing” of Personal Information as defined by the CCPA. We do not knowingly collect the Personal Information of minors under age 16 and do not sell such information.
Categories of Sources. We collect Personal Information from the following categories of sources:
You;
Service providers.
Disclosure of Personal Information to Third Parties and Other Recipients
| Categories of Personal Information that May Be Disclosed | Categories of Third Parties to whom Personal Information May Be Disclosed | Business or Commercial Purpose of Disclosing Personal Information |
|---|---|---|
| Identifiers |
|
|
| Personal Information Categories Listed in The California Customer Records Statute (Cal. Civ. Code §1798.80(e)) |
|
|
| Characteristics of protected classifications |
|
|
| Commercial Information (including account information) |
|
|
| Inferences |
|
|
| Internet or Other Electronic Network Activity |
|
|
| Geolocation Data |
|
|
| Audio, Electronic, Visual Information |
|
|
| Sensitive Information |
|
|
| Scanned grocery data |
|
|
In all cases, the Personal Information identified above may be processed in order to comply with applicable laws and regulations, legal obligations, or other legal requirements, or pursuant to a business transfer, as described in Section 4, How We Share Your Personal Information. The Personal Information identified above may also be shared with your consent, and as notified.
Your CCPA Rights and How to Exercise Them
If you are a California resident, you have certain rights, pursuant to the CCPA. These CCPA rights may only apply in certain circumstances and are subject to certain exemptions. Please see the information below for a summary of your rights and how to exercise your rights. Please note that we may ask for certain information to verify the request in accordance with applicable law.
Right to Know. You have the right to request that we disclose Personal Information we collect, use, and/or share about you.
Right to Delete. You have the right to delete Personal Information that we collect or maintain about you. Please note that certain exceptions apply to this right, such as when we must retain your information to comply with law. We will notify you of any such exceptions as applicable to your request.
Right to Correct. You have the right to request we correct inaccuracies in the Personal Information we have collected about you.
Right to Opt-Out. You have the right to opt out of the sharing of Personal Information for cross-context behavioral advertising and the sale of Personal Information.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights.
To submit a privacy request, please email us at [email protected] with the subject line “Privacy Request”.
To exercise your rights to opt out of sale or sharing of Personal Information, you may opt out through the settings in our cookie banner/
Please contact us at [email protected] if you have any questions or issues regarding the opt out methods above.
You may be required to provide certain information to verify your identity and understand the scope of your request. We will require you to provide, at a minimum, your full name, email address or other contact information, and information about your relationship with Alentia.
You can exercise your CCPA rights yourself or you can designate an authorized agent to make a request on your behalf. Your authorized agent must be able to demonstrate authority to act on your behalf as further instructed when submitting a verifiable request.
13. Privacy Notice for European Economic Area (EEA), United Kingdom (UK), and Switzerland
Definition of Personal Information
For purposes of this Privacy Policy: (i) if applicable data protection legislation defines Personal Information more broadly than it is defined in this Privacy Policy, then the term “Personal Information” shall be deemed to be defined as indicated in such applicable data protection legislation; (ii) the term “Personal Information” shall be considered to include any equivalent term that may be used in applicable data protection legislation, including, without limitation, “personal data” as defined in the EU General Data Protection Regulation (“GDPR”) or personally identifiable information; and (iii) Personal Information shall not include data that is excluded from the scope of applicable data protection legislation. For the avoidance of doubt, pseudonymized Personal Information will be considered to be the Personal Information of EEA, UK and Switzerland residents.
Identity of the data controller
The data controller of your Personal Information will be Morgal FB LLC (Alentia) 1521 Concord Pike, Suite 201, Wilmington, Delaware 19803, United States. For data protection purposes, you may contact Alentia by email at [email protected].
Details of the data protection representative in the EU are as follows: GAREIS NUTRICIÓN SL(Ismael Galancho, Augusto González Besada 1, 7D, 29004 Málaga, España, [email protected]).
Legal bases for processing
| Categories of Personal Information Processed by Alentia | Purpose | Legal basis for the processing |
|---|---|---|
| Payment information, subscription data | To facilitate your payment and registration for the Services | To manage the subscription/fulfilment of the contract |
| Profile information including dietary, training and wellness data, suggested food, recipes | To develop and facilitate your customized nutrition and training program | Consent, separate consent is obtained for separate categories |
| Health data, including data obtained from wearable integration, daily mood check-in, injuries, fatigue, sleep and menstrual cycles | To adapt nutrition and training to health status | Consent, specific consent will be obtained to collect specific health data |
Contact information and communications information | Answering inquiries about the use of the Platforms Sending notices related to the Services | Fulfilment of the contract/Legitimate interest to answer inquiries |
| Transaction history and financial information | Managing your subscription | Fulfilment of the contract/legitimate interest to manage the relationship and the services |
| Feedback | Improving our Services | Legitimate interest to improve the services |
| Account information | To provide the Services and manage the subscription | Fulfilment of the contract/legitimate interest to improve the services |
| Browsing and device information | Analyzing the browsing habits of users, improving the Platforms and our products and Services. Enabling the use of the Services. | Legitimate interest to improve the Platforms and the browsing experience and allowing the use of the Platforms. |
| Data obtained from social media | Interacting and knowing users | Legitimate interest to know users and interact with them. |
| Grocery data, analytics from scanned groceries | Allowing you to scan products. | Legitimate interest to analyze which products are consulted |
| Integration with supermarkets | To allow you to create shopping lists and carts | Consent, to perform a contract |
| Video of training performances | To publish it or interact in social media or with other users. | Consent |
| Interactions in internal social media | To provide with social media services limited to publishing content or reactions | Consent, compliance with social media terms. |
| Participating in tournaments, leagues or sharing in groups | To allow you to participate in tournaments and receive communications or interact with a group | Consent, specific consent is provided to share health data |
| Use of ALIA: interactions with IA assistant | To provide you with the ALIA AI chat service. ALIA provides only the chat service itself; the content of your conversations is not analyzed. | Consent |
| AI workout tracking | To provide assistance while you are training. Includes access to camera. | Consent |
| Loyalty program | To manage the loyalty program | To perform the applicable terms and conditions of the program and provide the services |
| Referral program | To manage your participation in a referral program. It may imply sharing Personal Information with participating third parties. | To perform the applicable terms and conditions of the program and provide the services |
Retention periods
When an account is deleted or a Subscription terminates, the categories of Personal Information listed below will be retained in a blocked or restricted state, with limited access, for the retention period stated for the applicable category and only to the extent necessary to establish, exercise, or defend legal claims or meet legal obligations. For purposes of account deletion, unless otherwise stated below, the applicable retention period runs from the later of the date the subscription ends or the date the account is deleted. At the end of the applicable period, the Personal Information will be permanently deleted or anonymized.
| Categories of Personal Information | Retention period |
|---|---|
| Payment and financial information | 6 years |
| Profile information including health, dietary and wellness data | 6 years from the earlier of the date the subscription ends or the date the account is deleted Menstrual information, mood, fatigue, sleep: 3 years from the earlier of the date the subscription ends or the date the account is deleted and only to the extent necessary to establish, exercise, or defend legal claims or meet legal obligations |
| Contact information and communications information | 6 years |
| Interactions with Alia, AI assistant | No more than 24 hours after the conclusion of the chat. |
| Transaction history | 6 years |
| Feedback | 3 years |
| Account information | 6 years |
| Browsing and device information | 1 year |
| Data from social media | Until user stops interacting for 6 months |
| Information on tournaments and Alentia social media features | Until user stops interacting for 6 months |
| Videos, voice and photographs for training purposes | 2 years or until the user deletes the content |
| Information obtained from wearable devices | 2 years from the date of collection |
| Loyalty program and referrals | 6 years after each program ends or referral |
14. Third-Party Vendors/Processors
| # | Vendor | Function | Infrastructure | Data Processed |
|---|---|---|---|---|
| 1 | Google Gemini (2.0/2.5 Flash) | Food photo analysis, suggestions, ALIA chatbot, plan generation | Google Cloud, USA | Images + text (incl. dietary history) |
| 2 | OpenAI | Configured as fallback, NOT active in V1 | API, USA | Fallback provider. Does not process data in V1 |
| 3 | SendGrid (Twilio) | Email delivery (OTP, transactional) | Twilio, USA | Email + user name |
| 4 | Cloudflare R2 | Image storage | Cloudflare, us-east-1 | Images |
| 5 | PostgreSQL | Primary database | Hosted on Railway | All user data (PII, onboarding, meals, plans, health) |
| 6 | Railway | API hosting (Spring Boot) | Railway Cloud, USA | Access to all backend infrastructure |
| 7 | Apple Sign In | Apple ID authentication | Apple servers | Email + user name |
| 8 | Google OAuth | Google account authentication | Google, USA | Email + user name |
| 9 | Expo / EAS | Build, deploy, and push notifications | Expo Cloud, USA | Push tokens + app builds |
| 10 | RevenueCat | In-app purchase subscription management | RevenueCat, USA | Transaction and subscription data |
| 11 | Grafana Cloud Loki | Structured log storage | Grafana Cloud, USA | Logs (potentially containing PII) |
| 12 | Grafana Cloud OTLP | Application metrics | Grafana Cloud | Aggregated metrics (no PII) |
| 13 | Meta Meta/WhatsApp Business API | ALIA, our AI chat assistant, accessible through WhatsApp with the same functionality as the in-app chat (as described in Section 6.10 of the App Terms and Conditions) | Meta / WhatsApp Business API | Chat messages (text) and phone number, plus the same categories of data already processed by ALIA in-app |
15. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. You should check this Privacy Policy frequently to review the latest version of the Privacy Policy. If we make changes to this Privacy Policy, we will post the amended version on our Platforms and the effective date will be indicated by the last updated date. This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party.
16. Retention
We retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected, including to provide our products and Services, comply with legal obligations, resolve disputes, enforce our agreements, and protect our legal rights. The retention periods described in the Retention periods table in Section 13 apply to each category of Personal Information we collect, regardless of where you reside, and we will not retain any category of Personal Information for longer than is reasonably necessary for the disclosed purpose.
17. Transfer of Personal Information from Outside of the United States
If you use our Platforms from outside of the United States, please be aware that your information may be transferred to, stored or processed in the United States, where some of our service providers (and/or service provider infrastructure) are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but adequate safeguards will be adopted in compliance with applicable data protection laws and regulations.
18. California and Delaware Do Not Track Disclosures
Because there is no uniform industry standard for responding to Do Not Track browser requests, Alentia does not currently respond to Do Not Track signals.
19. How to Contact Us
If you have any questions, requests or concerns related to this Privacy Policy, please email us at [email protected] or write to us at the following address:
Alentia
1521 Concord Pike, Suite 201
Wilmington, Delaware 19803
United States
EIN/Tax ID: 41-5289993