Privacy Policy — FoodClone
This document explains what data FoodClone collects, why we collect it, with whom we share it, for how long we keep it, and what your rights are.
If something is unclear, write to support@foodclone.ai.
TABLE OF CONTENTS
- 1. 30-second summary
- 2. Who is the data controller
- 3. Data we collect
- 4. How we collect it
- 5. What we use your data for (purpose and legal basis)
- 6. Who we share with
- 7. International data transfer
- 8. How long we keep it
- 9. Your rights
- 10. How to exercise your rights
- 11. Information security
- 12. Cookies and similar technologies
- 13. Children and adolescents
- 14. Changes to this policy
- 15. Region-specific provisions
- 16. Contact and Data Protection Officer (DPO)
1. 30-second summary
- We collect data you provide (registration, profile, declared health conditions, generated content) and app usage data.
- We use it to operate the service, personalize clones, improve the product, and — with your consent — communicate.
- We do not sell your data. Ever.
- We do not train AI models with your sensitive personal data.
- We share only with service providers strictly necessary to operate (cloud, payment, AI, email) — under data protection contracts.
- You have rights: access, correct, erase, port, object to processing. Exercising them is simple, at Settings → Privacy.
- In situations of risk to life, we may process sensitive data without prior consent (LGPD art. 11, II, "e" and GDPR art. 9(2)(c)) for your protection — displaying immediate professional resources.
2. Who is the data controller
The data controller (responsible for decisions about processing) is the FoodClone operator, identified in the Terms of Use §18.3.
Address for legal correspondence: support@foodclone.ai. Data Protection Officer/DPO: support@foodclone.ai.
3. Data we collect
3.1 Data you provide directly
| Category | What it is | Sensitivity |
|---|---|---|
| Identification | Name, email | Common |
| Access | Single-use sign-in links sent to your email (magic link) and OAuth data (Google) — we do not use a password of our own | Common |
| Physical profile | Weight, height, biological sex, age (declared, optional) | Sensitive (health) |
| Health conditions | List of declared conditions (PCOS, lipedema, diabetes, etc.) | Sensitive (health) |
| Medication | Current use of GLP-1 and similar | Sensitive (health) |
| Allergies and dietary restrictions | Declared list | Sensitive (health) |
| Food aversions | Free text | May contain sensitive data depending on what you write |
| Market | Brazil / US / Spain | Common |
| Product preferences | UI language, units, communications | Common |
| Content you create | Dish descriptions, refinements, S.O.S. notes, Discover feed publications | Common |
3.2 Usage data (automatically generated)
| Category | What it is | Sensitivity |
|---|---|---|
| Product events | Which features you use, how many times, when | Common |
| S.O.S. episodes | Technique used, recorded emotion, initial and final intensity, duration | Sensitive (mental health) |
| Usage metrics | Clones generated, monthly counters | Common |
| Technical logs | IP (kept for a short period), browser/device, language, time zone | Common (IP is personal data under LGPD/GDPR) |
| Errors and failures | Stack traces, error messages (with sensitive data automatically filtered) | Common |
3.3 Payment data
When you subscribe to Pro or Max:
- Financial data (card number, expiration, CVV) is processed exclusively by our payment provider. FoodClone does not store this data on its servers.
- We cache only: last 4 card digits, brand, and subscription status. This appears in Settings → Subscription.
3.4 Data we DO NOT collect
To make clear what we do not collect:
- ❌ Images of you or your body (we do not request a public profile photo, we do not use the camera)
- ❌ Precise GPS location (only country by IP approximation)
- ❌ Your phone's contact list
- ❌ Browsing history outside FoodClone
- ❌ Biometric data (iris, fingerprint, voice, face)
- ❌ Racial or ethnic origin, sexual orientation, religion, political opinion, union membership
4. How we collect it
4.1 Data you provide actively
- During registration
- During onboarding (physical profile, conditions, medication, allergies)
- When generating clones, making refinements
- When publishing on the Discover feed
- When recording weight/measurements in the evolution panel (opt-in)
- In support interactions
4.2 Data collected automatically
- When you use the application (events, navigation)
- Cookies and similar technologies (§12)
- Server logs (IP, browser, etc.)
4.3 Third-party data
When you use social login (Google/Apple), we receive from the provider:
- Name
- Unique provider ID
We do not receive nor request contact list, browsing history, or other provider data.
5. What we use your data for (purpose and legal basis)
LGPD and GDPR require that we declare the specific purpose and the legal basis for each processing operation. This is the complete table:
5.1 Processing based on performance of contract
LGPD art. 7º, V · GDPR art. 6(1)(b)
| Data | Purpose |
|---|---|
| Email, name | Create and operate your account |
| Payment data (via provider) | Charge subscription |
| Content you create (clones, refinements) | Deliver the service you contracted |
| Subscription history | Manage plan, renewal, cancellation |
5.2 Processing based on explicit consent
LGPD art. 7º, I and art. 11, I · GDPR art. 6(1)(a) and art. 9(2)(a)
| Data | Purpose |
|---|---|
| Physical profile (weight, height, biological sex) | Personalize clones and macro estimates |
| Declared health conditions | Personalize clones and adequacy badges |
| GLP-1 use and other medications | Personalize clones for that condition |
| Allergies and restrictions | Filter ingredients in generations |
| Promotional communications (Sunday emails, news, promotions) | Communicate per your preferences |
These processing activities require your active consent. You manifest consent during onboarding and may revoke at any time in Settings.
5.3 Processing based on protection of life or physical integrity
LGPD art. 11, II, "e" · GDPR art. 9(2)(c)
| Data | Purpose |
|---|---|
| Crisis word detection (in any text you write in the app) | Immediately display professional crisis resources (988, 024, CVV 188, etc.) |
| Intense S.O.S. usage pattern (3+ episodes in 7 days with high intensity) | Suppress promotional communications that could aggravate sensitive moments |
These processing activities occur regardless of prior consent, because protection of life and integrity prevails. You are informed and may question at any time.
5.4 Processing based on legitimate interest
LGPD art. 7º, IX · GDPR art. 6(1)(f)
| Data | Purpose |
|---|---|
| Aggregated usage events (anonymized) | Improve the product, calibrate Taste Match, identify bugs |
| Technical logs | Security, fraud prevention, debugging |
| IP (short term) | Fraud detection, abuse, rate limiting |
We apply the balancing test (LIA — Legitimate Interest Assessment): our interests are proportional and do not override fundamental rights of the data subject. You have the right to object (§9.6).
5.5 Processing based on legal obligation
LGPD art. 7º, II · GDPR art. 6(1)(c)
| Data | Purpose |
|---|---|
| Billing and invoice data | Tax and fiscal compliance |
| Access and transaction logs | Compliance with legal investigations or court orders |
| Data subject rights requests (LGPD/GDPR) | Proof of compliance with legislation |
5.6 What we DO NOT do with your data
- ❌ We do not train AI models with your individual clones, your health data, or any personal data of yours. Neither our models, nor those of providers we use.
- ❌ We do not sell your data.
- ❌ We do not use your data in targeted advertising segmentation (neither FoodClone's, nor lookalike audiences in third parties).
- ❌ We do not share sensitive health data with third parties for economic advantage (LGPD art. 11, §4 prohibition).
- ❌ We do not profile for discriminatory purposes (insurance, credit, employment).
6. Who we share with
6.1 Principle
We share your data only with service providers strictly necessary to operate FoodClone, always under a Data Processing Agreement (DPA) that obligates the third party to the same standards as us.
6.2 Provider categories
Without identifying specific platforms (the exact list is available upon request at support@foodclone.ai), we work with providers in the following categories:
| Category | For what | Where they process |
|---|---|---|
| Cloud infrastructure (database, authentication, storage) | Operate and host the service | US / European Union |
| Application hosting | Serve the web and mobile app | Distributed globally |
| AI model provider | Clone generation | US |
| Payment provider | Process charges | Ireland / US |
| Workflow orchestration | Renewals, dunning, scheduled deletions | US |
| Cache and rate limiting | Performance and protection against abuse | US |
| Product analytics | Aggregated usage metrics | US (with EU region available) |
| Error monitoring | Bug detection and correction | US |
| Transactional email | Sending confirmations and communications | US |
6.3 When we may share with non-provider third parties
- By court order or legal requirement (only what is strictly requested)
- To protect life or physical integrity of persons in serious risk
- In case of incorporation, acquisition, or corporate reorganization, with prior notice to data subjects (LGPD art. 7º, §5º)
6.4 Up-to-date list of subprocessors
The exact and up-to-date list of subprocessors is available upon request at support@foodclone.ai or in a dedicated page in the application (under development). We notify relevant changes at least 30 days in advance.
7. International data transfer
7.1 What this means
Some providers we use process data on servers outside of Brazil, especially in the United States and the European Union.
7.2 Safeguards we apply
- Standard Contractual Clauses (SCC) approved by the European Commission, ensuring level of protection equivalent to that of the EU.
- Country adequacy: we prioritize providers in regions recognized as adequate by ANPD or the European Commission.
- Additional guarantees when applicable: encryption in transit and at rest, pseudonymization, restricted access.
7.3 Specific legal basis for transfer
LGPD art. 33 (Brazil): international transfer permitted when the destination country has adequate level of protection, or when there is SCC, or with specific consent from the data subject.
GDPR art. 44-50 (EU/EEA): transfer permitted under SCC or other equivalent safeguards.
8. How long we keep it
We do not keep your data indefinitely. Each category has a defined period:
| Data category | Active retention | After the period |
|---|---|---|
| Account (basic profile, email, name) | While the account is active | 30 days after deletion (for reversal window and backups) |
| User content (clones, saved recipes) | While the account is active | Hard delete within 30 days after deletion |
| S.O.S. episodes (metadata, no message content) | 24 months | Anonymized or deleted |
| Crisis flags | 60 days without new signals | Anonymized |
| Payment data and invoices | 7 years (fiscal compliance) | Pseudonymized after account deletion |
| Security logs | 6 months | Hard delete |
| Product events (aggregated analytics) | 24 months | Aggregated anonymization |
| Data subject rights requests | 5 years | For proof of legal compliance |
8.1 When you delete your account
As detailed in Settings:
- Immediate: access terminated, account deactivated, subscription cancelled
- 24 hours: PII (name, email) — hard delete
- 30 days: clones, S.O.S. episodes, measurements — hard delete
- 7 years: pseudonymized payment data (Brazilian tax law)
9. Your rights
LGPD (art. 17 to 22) and GDPR (Chapter III) guarantee you the following rights:
9.1 Right of access
Know whether we process your data, which data we process, and obtain a copy of it in structured format.
9.2 Right of rectification
Correct incomplete, inaccurate, or outdated data.
9.3 Right of erasure ("forgetting")
Request deletion of your data. We comply except where law requires retention (e.g., fiscal data for 7 years in Brazil).
9.4 Right of portability
Receive your data in structured, interoperable format (JSON) for transfer to another service.
9.5 Right to withdraw consent
Withdraw consent previously given, at any time, without prejudice to processing prior to withdrawal.
9.6 Right to object
Object to processing based on legitimate interest, with justification.
9.7 Right not to be subject to automated decision-making
Right to request human review of decisions taken exclusively by algorithms that affect your interests (LGPD art. 20, GDPR art. 22). FoodClone does not make automated decisions with legal effect on you — generated clones, S.O.S. technique recommendations, and similar are suggestions you choose to follow or not.
9.8 Right to information
Know with which entities we share your data (§6).
9.9 Right to petition
Complain directly to ANPD (Brazil), to the data protection authority of your country (EU, UK, LATAM), or other applicable authorities.
10. How to exercise your rights
10.1 Through the interface itself (fastest)
Go to Settings → Privacy:
- Download my data → receive a complete JSON export by email within 24h
- Delete my account → definitive deletion with confirmation flow
10.2 By direct contact
For other rights, send email to support@foodclone.ai with:
- Your name and registered email
- Type of request (access, correction, objection, etc.)
- Clear description of what you want
We respond within 15 business days. In complex cases, we may extend by another 15 days with justified notice (limit of 30 days).
10.3 No costs
Exercising your rights is free. We do not charge fees for access, rectification, deletion, or portability.
10.4 Identity verification
To protect against improper access, we may request identity confirmation (e.g., validation via account email). This protects you, not us.
11. Information security
11.1 Technical measures
- Encryption in transit (TLS 1.3) in all communications
- Encryption at rest of sensitive data in the database
- Passwordless authentication — single-use magic links by email and OAuth (Google); we do not store passwords
- Session tokens with expiration and automatic renewal
- Rate limiting to prevent brute force attacks
- Continuous monitoring of anomalous access attempts
11.2 Organizational measures
- Restricted internal access to the minimum necessary (least privilege principle)
- Training of team in data protection
- Confidentiality contracts with providers
- Defined incident response procedure
11.3 In case of a security incident
If a security incident occurs with risk to data subjects' rights, we notify ANPD within 72 hours (LGPD art. 48, GDPR art. 33) and communicate affected data subjects when risk is relevant.
11.4 Realistic limits
No system is 100% secure. We maintain high standards, but cannot guarantee absolute invulnerability. You are also part of security: protect access to your email and your Google account (two-factor authentication) and watch out for phishing.
12. Cookies and similar technologies
12.1 What we use
| Type | For what | Necessary? |
|---|---|---|
| Session cookies | Keep you logged in | Yes (does not work without them) |
| Preference cookies | UI language, market | Yes (basic functionality) |
| LocalStorage | Interface state (unsent drafts, etc.) | Yes |
| First-party analytics | Aggregated usage metrics | Optional (opt-out available) |
12.2 What we DO NOT use
- ❌ Third-party advertising cookies (Google Ads, Meta Pixel, etc.) inside the authenticated application
- ❌ Device fingerprinting
- ❌ Cross-site tracking
- ❌ Data sharing with advertising brokers
12.3 On the landing page
On foodclone.ai (public, non-authenticated page), we use:
- Essential cookies (session, language preference)
- Conversion pixels to measure which campaigns bring visitors (Meta, Google, TikTok)
Consent banner is displayed as required by each jurisdiction (EU/UK mandatory).
12.4 How to manage
- In the app: Settings → Privacy
- In the browser: browser settings (clear cookies, block third-party cookies)
- On the landing: consent banner + "Manage preferences" link
13. Children and adolescents
FoodClone is restricted to adults over 18 years old (or the civil majority age of your country, whichever is greater).
We do not intentionally collect data from minors under 18 years old.
If we identify use by a minor:
- The account is immediately terminated
- Data is removed as per §8.1
- We notify the legal guardian, if it is possible to identify them
If you are a guardian of a minor who has created an account improperly, write to support@foodclone.ai and we will delete quickly.
14. Changes to this policy
14.1 When we update
We may update this policy to reflect:
- New product features
- New providers or changes in providers
- Changes in legislation or regulation
- Clarifications and corrections
14.2 How we notify
- Material changes: email with 30 days of advance notice + in-app notification
- Minor changes (grammar, formatting): silent update, with updated version date
- Change history available at foodclone.ai/privacy/changelog
14.3 If you do not agree
If you do not agree with material changes, you may delete your account before the effective date (Settings → Privacy → Delete my account).
15. Region-specific provisions
15.1 Brazil — LGPD (Law 13,709/2018)
- Authority: ANPD — Brazilian National Data Protection Authority (gov.br/anpd)
- DPO: support@foodclone.ai
- Applied legal bases: art. 7º (common data) and art. 11 (sensitive data, especially health)
- Specific rights: all rights of LGPD art. 18 (access, correction, anonymization, portability, deletion, information, objection, review of automated decision)
- Response deadline: 15 days for simple requests (LGPD art. 19)
- How to complain to ANPD: gov.br/anpd → Electronic petition
15.2 Latin America (except Brazil)
Local data protection laws apply:
- Argentina: Law 25,326 and updates. Authority: AAIP.
- Chile: Law 19,628 and new Data Protection Law (2024). Authority: Agencia de Protección de Datos Personales.
- Colombia: Law 1581/2012 and Decree 1377/2013. Authority: SIC.
- Mexico: LFPDPPP and 2025 reform. Authority: INAI (in transition).
- Peru: Law 29,733. Authority: ANPD.
- Uruguay: Law 18,331. Authority: URCDP.
- Other LATAM countries: local legislation applicable.
Common rights guaranteed across LATAM:
- Access, rectification, deletion, portability, objection, withdrawal of consent
To exercise, send email to support@foodclone.ai indicating your country of residence.
15.3 United States
California — CCPA/CPRA
If you reside in California, you have additional rights:
- Right to Know: which personal data we collect and why
- Right to Delete: request deletion (with legal exceptions)
- Right to Correct: correct inaccurate data
- Right to Opt-Out of Sale/Sharing: we do not sell or share your data for targeted advertising purposes, so this right is always exercised by default on FoodClone
- Right to Limit Use of Sensitive Personal Information: sensitive data is processed only for the declared purpose
- Right to Non-Discrimination: exercising rights does not cause penalty
Verified consumer requests: we may request identity validation as per CCPA requirements.
Other states (Virginia, Colorado, Connecticut, Utah, etc.)
We apply the rights provided in corresponding state laws (VCDPA, CPA, CTDPA, UCPA, etc.).
HIPAA
Does not apply to FoodClone. We are a wellness/food education service, not a HIPAA covered entity or business associate.
15.4 Canada — PIPEDA + provincial laws
- Federal law: PIPEDA (Personal Information Protection and Electronic Documents Act)
- Applicable provincial laws: Quebec Law 25, BC PIPA, Alberta PIPA
- Quebec Law 25: if you reside in Quebec, you have additional rights to automated portability and the right to know when automated decisions are made about you. As mentioned in §9.7, FoodClone does not make automated decisions with legal effect on you.
- CASL: commercial communications respect your preferences at Settings → Communications.
15.5 United Kingdom — UK GDPR + Data Protection Act 2018
- Authority: ICO — Information Commissioner's Office (ico.org.uk)
- Data subject rights: equivalent to EU GDPR (§15.6)
- PECR (Privacy and Electronic Communications Regulations): consent for non-essential cookies
- Complaints: directly to ICO
15.6 European Union (including Spain) — GDPR
- Regulation: GDPR (EU 2016/679) + applicable national legislation (LOPDGDD in Spain)
- Applied legal bases: art. 6 (common data) and art. 9 (special categories, including health)
- Specific rights: access (art. 15), rectification (art. 16), erasure (art. 17), restriction (art. 18), portability (art. 20), objection (art. 21), not subject to automated decision (art. 22)
- Response deadline: 1 month (may be extended by an additional 2 months in complex cases, with notice)
- DPO: support@foodclone.ai
- National authority: AEPD in Spain, CNIL in France, BfDI in Germany, Garante in Italy, etc.
- International transfer: applicable SCC (§7)
- EU Data Act (Regulation 2023/2854): since 12 September 2025, you have additional rights to portability and migration without barriers
15.7 Other countries
If you use FoodClone from a country not listed:
- Applicable local laws apply
- You may exercise the rights provided in this policy via support@foodclone.ai
- You have the right to petition the local data protection authority, when one exists
16. Contact and Data Protection Officer (DPO)
16.1 For privacy matters
Main email: support@foodclone.ai DPO: support@foodclone.ai
16.2 For other matters
| Subject | |
|---|---|
| General support | support@foodclone.ai |
| Legal | support@foodclone.ai |
| Press | support@foodclone.ai |
16.3 Controller identification
FoodClone's operator is identified in the Terms of Use §18.3.
16.4 Complaints to authorities
You can always complain directly to the data protection authority of your country:
- Brazil: ANPD — gov.br/anpd
- Argentina: AAIP — argentina.gob.ar/aaip
- Chile: Agencia de Protección de Datos Personales
- Colombia: SIC — sic.gov.co
- Mexico: INAI (in transition)
- United States — California: California Privacy Protection Agency
- European Union: authority of your country (AEPD, CNIL, BfDI, Garante, etc.)
- United Kingdom: ICO — ico.org.uk
- Canada: Office of the Privacy Commissioner of Canada
Version history
| Version | Date | Main changes |
|---|---|---|
| 1.0 | June 2026 | Initial version |
Complete history available at foodclone.ai/privacy/changelog.
Effective date: [PRODUCT LAUNCH DATE]
This is an English translation provided for convenience. In case of divergence between versions, the original Brazilian Portuguese (PT-BR) version prevails.