Privacy Policy

The Company is committed to protecting Your privacy. This Privacy Policy explains how We collect, use, and safeguard Your information when You use the Service.

By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

1. Definitions

"Account" means the unique profile created for You to access the Service.

"Application" means the mobile application titled "BulkMode," designed exclusively to help users gain weight in a healthy manner. The Application is not intended for weight loss, calorie restriction, or maintaining a caloric deficit.

"Company," "We," "Us," or "Our" means Simplify Possible LLC, an Illinois limited liability company, with mailing address 4235 N Mobile Ave, Chicago, IL 60634, United States.

"Device" means any device used to access the Service.

"Health Data" means information You provide relating to Your physical characteristics, health, nutrition, or goals, including weight, height, date of birth, gender, food logs, calorie targets, and body metrics.

"Personal Data" means information that identifies or can reasonably be linked to an individual, including identifiable health information.

"Usage Data" means data collected automatically through use of the Service, including device information, activity logs, IP addresses, and analytics data.

"User Content" means photos, images, text, food entries, or other inputs You upload or submit through the Service.

"Website" means bulkmode.app.

"You" means the individual using the Service or the organization on whose behalf the Service is used.

Important Health Disclaimer

For complete health and safety information—including metabolism system disclaimers, AI accuracy limitations, eating disorder resources, and guidance for minors—please review Our Health Disclaimer and Terms of Service.

If You or someone You know is struggling: Contact the National Eating Disorders Association (NEDA) at 1-800-931-2237 or text "NEDA" to 741741. In crisis, call 988.

2. Information We Collect

Personal Information

When You create an Account or use the Service, We may collect:

• Display name and avatar emoji (optional, for personalization)
• Sign in with Apple: If You choose to sign in with Apple, Apple may share Your name and email address (or a private relay email) with Us, depending on Your Apple ID settings. We do not store passwords—authentication is handled entirely by Apple. Sign in with Apple is available in the iOS Application.
• Sign in with Google: If You choose to sign in with Google, Google may share Your name and email address with Us, depending on Your Google Account settings. We do not store passwords—authentication is handled entirely by Google. Sign in with Google is available on both iOS and Android.
• Anonymous accounts: You can use the Service without signing in or providing contact information such as Your name or email address. Anonymous accounts are authenticated through a secure session stored on Your Device (in the iOS Keychain or Android encrypted storage). Your data syncs to Our servers and can typically be restored if You reinstall the Application, but cannot be recovered if Your Device's secure storage is cleared (e.g., new device or factory reset).

Health and Nutrition Data

When You use the Service's calorie tracking features, You provide Health Data:

• Food logs and meal entries
• Calorie and macronutrient intake
• Weight and body metrics (body fat percentage is required during onboarding to calculate personalized targets)
• Date of birth — Used to calculate Your age for accurate calorie and nutritional recommendations. This is collected during onboarding.
• Food photos for AI analysis: Photos are resized and compressed before being sent to Our AI providers for analysis. These processed images are used in real-time to identify food items and estimate nutritional content, then immediately discarded from Our servers—only the nutritional results are stored in Your Account. We do not perform facial recognition, biometric scanning, or any identification of individuals who may appear in photos.
  
  Thumbnail storage: Compressed, low-resolution thumbnail previews are stored locally on Your Device to display Your food log entries. These thumbnails are deleted when You delete the corresponding food log entry, Your Account, or the Application.
  
  We reserve the right to retain anonymized, de-identified versions of food photos to improve Our AI food recognition technology in the future. If We begin retaining photos on Our servers, We will update Our App Store privacy labels accordingly. See Section 4 (AI Providers) for details on how photos are processed.
• Dietary goals and preferences
• Target weekly weight gain rate (to personalize Your calorie recommendations)
• Hard gainer status (whether You have difficulty gaining weight)
• Individual ingredient breakdowns within meals — When Our AI analyzes Your food photos, We store the name, quantity, estimated weight, and nutritional values (calories, protein, carbs, fat) for each identified ingredient. You can view and edit these breakdowns in the Application.
• Streak repair history — If You use the streak repair feature, We record when repairs were applied and the streak values before and after repair. This helps prevent abuse and provides You with accurate streak records.
• Any other health information You choose to enter into the Application

Apple Health (iOS)

On iOS, the Service can connect to Apple Health (HealthKit). The connection is off by default and is never enabled without Your explicit permission—You choose to connect during onboarding or later in Profile → Apple Health, and iOS then presents its own permission sheet in which You approve each data type individually.

Two independent settings control what is exchanged:

• Sync Weight: When enabled, We read body weight samples only from Apple Health, so weigh-ins recorded by Your smart scale or another app appear in the Application automatically, and weights You log in the Application are saved back to Apple Health. Imported weigh-ins are stored in Your Account and synchronized to Our servers exactly like weights You enter by hand (see Supabase in Section 4). We keep at most one reading per day, and the first import is limited to the period since You created Your Account, capped at 365 days—older readings are never imported.
• Save Nutrition: When enabled, We write Your daily totals for dietary energy, protein, carbohydrates, and total fat to Apple Health. This setting is write-only: We do not read any nutrition data from Apple Health, and individual meals, food names, and food photos are never written to it.

What We never read. We request read access to body weight and nothing else. We do not read steps, workouts, heart rate, sleep, blood glucose, reproductive health, date of birth, biological sex, or any other Apple Health category, and the Application contains no code capable of requesting them.

Alongside Your profile We store whether each setting is enabled and the date You first connected Apple Health, so Your choice is remembered across Your devices. These are settings, not health measurements.

You can turn either setting off at any time in the Application, and You can revoke Our access entirely in iOS Settings → Privacy & Security → Health → BulkMode. Either action stops all further reading and writing immediately. See Section 6 for how to remove data that has already been exchanged.

Health Connect (Android)

On Android, the Service can connect to Health Connect. The connection is off by default and is never enabled without Your explicit permission—You choose to connect during onboarding or later in Profile → Health Connect, and Health Connect then presents its own permission screen in which You approve each data type individually.

Two independent settings control what is exchanged:

• Sync Weight: When enabled, We read body weight records only from Health Connect, so weigh-ins recorded by Your smart scale or another app appear in the Application automatically, and weights You log in the Application are saved back to Health Connect. Imported weigh-ins are stored in Your Account and synchronized to Our servers exactly like weights You enter by hand (see Supabase in Section 4). We keep at most one reading per day, and We never reach back further than the date You created Your Account, capped at 365 days—older readings are never imported. Health Connect may also limit how much history it shares with Us, so the first import can cover a shorter period than that.
• Save Nutrition: When enabled, We write Your daily totals for energy, protein, carbohydrates, and total fat to Health Connect. This setting is write-only: We do not read any nutrition data from Health Connect, and individual meals, food names, and food photos are never written to it.

What We never read. We request read access to body weight and nothing else. We do not read steps, exercise, heart rate, sleep, blood glucose, cycle tracking, or any other Health Connect data type, and the Application declares no permission capable of requesting them.

Alongside Your profile We store whether each setting is enabled and the date You first connected Health Connect, so Your choice is remembered across Your devices. These are settings, not health measurements.

You can turn either setting off at any time in the Application, and You can revoke Our access entirely in Health Connect → App permissions → BulkMode. Either action stops all further reading and writing immediately. See Section 6 for how to remove data that has already been exchanged.

Barcode Scanning

When You scan a product barcode, We send the barcode number to Our servers to look up the product. The barcode number identifies a product, not a person—no personal data accompanies the lookup. If the product is not already in Our shared product database, Our server queries Open Food Facts, a nonprofit collaborative food-products database, for the product's name, brand, and nutrition facts. Retrieved product data is stored in a shared product cache that is not linked to Your Account—which products You personally log is recorded only in Your private food logs. If a barcode cannot be found, You may photograph the product's nutrition label, which is processed by Our AI providers in the same way as food photos (see Section 4). Product data sourced from Open Food Facts is made available under the Open Database License (ODbL).

Automatically Collected Information

We automatically collect certain Usage Data:

• Device information (device type, operating system, Application version)
• Device identifier — On iOS, the Apple-assigned vendor identifier (IDFV); on Android, the system-assigned Android ID. Used for device-level sync and fraud prevention. These are NOT advertising identifiers (IDFA / Android Advertising ID) and cannot be used for cross-app tracking.
• IP address — Stored by Our authentication provider (Supabase) in session logs and audit trails for security and fraud prevention purposes. Retained for up to 90 days per Supabase's data retention policies. IP addresses are not stored in general application activity logs.
• Usage data (features used, time spent, interactions) - anonymized
• Timezone information (to display food logs and streaks in Your local time, and to adjust for timezone changes when You travel)
• Daily usage counts — We track how many food photos You analyze each day to enforce usage quotas and prevent abuse of Our Service. This includes timestamps of analysis attempts for rate limiting purposes.

Referral Program Data

If You use a referral code or refer others to the Service, We store:

• Your unique referral code
• The relationship between referrer and referee (if applicable)
• Referral reward status

This data is used solely to grant referral rewards.

Feedback and Preferences

During onboarding, We may collect:

• Your main challenges with nutrition tracking
• Your desired accomplishments and fitness goals
• Your commitment level (on a 1-10 scale)
• Your confidence rating in achieving Your plan (plan achievability rating) — A rating You may provide after Your first day indicating how achievable You feel Your nutrition plan is
• How You heard about the Service (optional)
• Previous nutrition or calorie tracking apps You've used (optional)

You may also optionally provide feature requests in Your profile settings. This feedback helps Us improve the Service and is not shared with third parties.

Derived and Aggregated Data

We automatically generate aggregated summaries of Your daily nutrition data to power features like streak tracking, achievements, and progress analytics. This includes:

• Daily totals of calories, protein, carbohydrates, and fat
• Goal achievement status (whether You hit Your daily targets)
• Meal type distribution (breakfast, lunch, dinner, snacks logged)
• Food log counts per day

This data is derived from Your food logs and is used solely to provide You with progress insights and unlock achievements.

Technical Sync Data

To ensure reliable data synchronization and prevent duplicate requests, We temporarily store:

• Device identifier — Used to coordinate sync operations across Your devices
• Idempotency keys — Unique request identifiers stored for up to 24 hours to prevent duplicate processing of achievement updates and other operations
• Migration identifiers — When You upgrade from an anonymous Account to an authenticated Account, We track the migration relationship to ensure Your data transfers correctly and to prevent duplicate migrations

This technical data is used solely for operational reliability and is automatically cleaned up after its retention period.

On-Device Data Storage

To provide offline functionality and a seamless experience, We store certain data locally on Your Device:

• Local database: Your profile, food logs, weight logs, streaks, and achievements are stored in an on-device database (SwiftData on iOS, Room on Android). This enables offline access and syncs with Our servers when You are online.
• Secure credentials: Authentication tokens and session data are stored in the iOS Keychain or in Android Keystore-backed encrypted storage, both of which provide hardware-level encryption.
• Preferences: Your app settings, notification preferences, and privacy choices are stored locally on Your Device.
• Cached data: Subscription status and certain settings may be cached locally to ensure the app works correctly even when offline.

This local data remains on Your Device and syncs with Our servers when connected to the internet. Deleting the Application from Your Device removes all locally stored data. To delete Your data from Our servers, use the Account deletion feature before uninstalling.

Background Data Synchronization

The Application uses an offline-first architecture, meaning Your data is saved locally first and then synchronized to Our servers in the background. This ensures You can use the Application even without internet connectivity. When You regain connectivity:

• Your data automatically syncs in the background without requiring any action from You
• We use intelligent sync throttling to minimize battery usage and cellular data consumption
• If conflicts occur (e.g., You edited data on multiple devices while offline), Our servers are treated as the source of truth and the most recent server version is used
• Sync operations include unique request identifiers to prevent duplicate data processing

Notifications

Notification Permissions: With Your consent, We may send notifications for meal reminders, streak maintenance, subscription status, and progress updates. These notifications are scheduled locally on Your Device—the Application does not use remote push notifications, and no push token is collected or stored on Our servers. You can disable notifications at any time in Your Device's system settings or in the Application settings.

Meal Timing Pattern Learning

To provide personalized meal reminder notifications, the Application learns from Your meal logging habits:

• We analyze when You typically log breakfast, lunch, dinner, and snacks to determine Your personal meal schedule
• After sufficient logging history (typically 21+ entries over 7+ days), We adjust reminder times to match Your actual patterns
• Pattern data (median meal times, clustering information) is stored locally on Your Device and is not shared with third parties
• Patterns are re-evaluated periodically to adapt to changes in Your schedule
• Reminder times are adjusted within reasonable bounds (±60 minutes of defaults) to prevent disruptive timing

This feature helps ensure You receive reminders at times that work for Your lifestyle rather than generic times that may not fit Your routine.

Biometric Information

Illinois BIPA Compliance: The Service does NOT collect, capture, purchase, receive through trade, or otherwise obtain biometric identifiers or biometric information as defined under the Illinois Biometric Information Privacy Act (740 ILCS 14/1 et seq.). Our AI food analysis technology identifies food items in photographs only and does not perform facial recognition, facial geometry analysis, fingerprint scanning, voiceprint analysis, iris scanning, retina scanning, or any other biometric identification of individuals who may appear in photographs.

Home Screen Widget

The Service offers Home Screen widgets on iOS and Android that display Your daily calorie progress, macro breakdown, and streak information at a glance.

Widget Data Sharing

• Widget data is shared between the main Application and widget using secure, on-device mechanisms (App Groups on iOS; app-private storage on Android)
• Data shared with widgets includes: daily calorie totals, macro totals, calorie goal, current streak count, and Your top saved foods for quick logging
• This data never leaves Your Device—it is shared locally between the Application and widget only
• Widget data is refreshed when You log food or when iOS requests an update

Social Sharing Features

The Service may offer features that allow You to share Your progress on social media platforms, including:

• Weekly Summary sharing: A shareable card showing Your weekly statistics (streak, average calories, achievements unlocked)

What You Control When Sharing

• Sharing is always initiated by You—We never automatically post to social media
• Weight data is opt-in: Your weight change is NOT included in share cards by default. You must explicitly choose to include it.
• Share cards display relative changes (e.g., "+2 lbs this week") rather than absolute weights
• You can preview and customize share cards before sharing

Share cards include BulkMode branding and Our website URL. When You share to external platforms (Instagram, Twitter, etc.), those platforms' privacy policies govern how the shared content is handled.

Siri and Voice Commands (iOS)

On iOS, the Service supports Siri Shortcuts, allowing You to log food and check Your progress using voice commands. When You use Siri with the Application:

• Voice commands are processed by Apple according to Apple's privacy practices
• The Application receives only the interpreted command (e.g., "log 500 calories"), not Your voice recording
• Food logged via Siri is treated identically to food logged manually within the Application
• You can view and manage Siri Shortcuts in iOS Settings → Siri & Search → BulkMode

3. How We Use Your Information

We use Your information to:

• Provide and maintain the Service
• Process User Content through AI to estimate nutritional information
• Calculate calorie goals and track Your progress
• Manage Your subscription and process payments
• Send important Service updates and support messages
• Improve the Service through anonymous analytics (see Section 8 for details)
• Detect and prevent technical issues or abuse

Service Improvement

We may use anonymized and aggregated data, including food photos and meal information, to improve Our AI food recognition technology. This data is de-identified before use and is not linked to Your identity. Photos submitted for analysis may be used for these improvement purposes in an anonymized form.

We may also integrate with third-party nutrition databases and update Our analysis methods, data sources, and AI providers at any time to enhance accuracy and Service quality.

Automated Decision-Making

Our AI-powered nutritional analysis involves automated processing of Your food photos to estimate calorie and macronutrient content. This is automated decision-making as defined under GDPR Article 22.

Personalized Target Calculations: The Service uses automated algorithms to calculate Your calorie and macro targets based on Your profile data (height, weight, age, gender, activity level, body fat percentage, exercise frequency, training experience, weight history, and recent weight trend). These calculations use established nutrition science formulas with adjustments based on Your individual characteristics.

Adaptive Learning: Over time, the Service learns Your actual metabolic rate by analyzing Your food intake and weight changes. This learned data is blended with formula-based estimates to provide increasingly personalized recommendations. You can view and override these calculations at any time in Your profile settings.

You have the right to:

• Edit or override: Manually edit any AI-generated nutritional estimates directly in the Application
• Delete: Remove any food logs containing estimates You disagree with
• Manual entry: Enter nutritional data manually instead of using photo analysis
• Request review: Contact Us to request human review of how automated decisions affect Your Account

AI estimates are approximations based on visual analysis and may vary from actual nutritional values. You are responsible for verifying nutritional information, especially for medical dietary requirements. The Service does not make automated decisions that have legal or similarly significant effects on You—nutritional estimates are informational tools only.

4. Information Sharing and Disclosure

We do not sell, trade, or rent Your Personal Data. We only share data with trusted service providers who help Us operate the Service:

Service Providers

• Supabase - Cloud hosting and database (stores Your Account and Health Data securely)
• PostHog - Anonymous analytics (no person profiles, IP addresses discarded; see Section 8 for full details)
• RevenueCat, Apple App Store & Google Play - Subscription and payment processing. RevenueCat helps Us manage subscriptions across platforms. When You subscribe or make a purchase, We share the following data with RevenueCat:
  • Your anonymous user identifier (to link purchases to Your Account)
  • Purchase receipts and transaction identifiers from Apple or Google Play
  • Subscription status (active, expired, trial, etc.)
  • App version and platform information
  RevenueCat does NOT receive Your name, email, Health Data, food logs, or any personally identifiable information unless You choose to provide it during support requests. All payment processing is handled securely by Apple or Google Play—We never see or store Your credit card information.
  
  RevenueCat SDK Automatic Collection: The RevenueCat SDK automatically collects certain device information to process subscriptions and prevent fraud, including: device model, operating system version, app version, locale/language, and approximate location derived from IP address. This data is collected by RevenueCat's SDK independently of Our Application code. See RevenueCat's Privacy Policy for complete details on their data practices
• AI Providers - AI-powered features including food photo analysis and personalized recommendations. Our AI features are currently powered by:
  • OpenAI - Privacy Policy
  • Google Gemini - Privacy Policy
  Each request is routed to one of these providers, with the other available as a fallback; which provider is active may change at any time as We tune for accuracy and reliability. For food photo analysis, We send only the following minimal data to these providers:
  • The compressed food photo image
  • Your timezone (for meal timing context)
  • A unique request identifier (idempotency key) to prevent duplicate processing
  We do NOT send Your user ID, account information, name, email, or any other personally identifying information to AI providers during food photo analysis. For personalized meal recommendations, We may send the following data to these providers:
  • Your current day's calorie and macronutrient totals
  • Your calorie and macro goals
  • Your dietary preferences and restrictions (e.g., vegetarian, gluten-free)
  • Your timezone
  This data is used solely to generate personalized food suggestions and is not stored by AI providers beyond their standard processing retention periods. AI Provider Data Retention: Our third-party AI providers (OpenAI, Google) may temporarily retain submitted data for up to 30 days for abuse monitoring and safety filtering, after which it is automatically deleted. Per their API terms, Your data is NOT used to train their AI models. This retention is governed by each provider's privacy policy linked above.
  
  BulkMode AI Improvement: Currently, We do not retain food photos after processing—only the nutritional analysis results are stored. We reserve the right to retain anonymized, de-identified versions of food photos in the future to improve Our own AI food recognition technology. If implemented, photos would be stripped of all identifying information (user IDs, timestamps, location data) before being added to training datasets and could not be linked back to You or Your Account. We will update Our App Store privacy labels if We begin retaining photos.
  
  We may change AI providers at any time to improve accuracy and service quality, and will update this policy accordingly.

Apple Health Data

Health Connect Data

Data Processing Agreements

We have executed Data Processing Agreements (DPAs) with Our primary sub-processors as required by GDPR, including Supabase (database hosting), RevenueCat (subscription management), and PostHog (analytics). These agreements ensure that Our service providers process Your data in compliance with applicable data protection laws.

Legal Requirements

We may disclose Your information if required by law or in response to valid legal requests from public authorities.

Business Transfers

If the Company is acquired or merged with another company, Your data may be transferred. We'll notify You before this happens.

5. Data Security

We implement strong security measures to protect Your information:

• Encryption of data in transit (HTTPS/TLS) and at rest
• Secure authentication with industry-standard hashing
• Regular security assessments and updates
• Access controls limiting who can view data
• Automatic security monitoring and alerts

However, no method of transmission over the internet is 100% secure. While We strive to protect Your information, We cannot guarantee absolute security.

Data Breach Notification

If We discover a security breach affecting Your Personal Data, We will:

• Notify affected users without undue delay via an in-app notice and/or email (where We have an email address on file for You)
• Describe what data was affected and the nature of the breach
• Explain steps We are taking to address and remediate the breach
• Provide guidance on protective measures You can take (such as monitoring Your accounts or changing passwords)
• Report the breach to relevant data protection authorities as required by applicable law (including GDPR supervisory authorities within 72 hours where required)

6. Your Rights and Choices

You have the following rights regarding Your Personal Data:

• Access: Request a copy of Your Personal Data
• Correction: Update or correct inaccurate information
• Deletion: Delete Your Account and all associated data
• Portability: Export Your data in a machine-readable format. Your exported data is provided as a ZIP archive containing JSON files: profile.json (Your account and profile information), food_logs.json (all meal entries with ingredients and nutritional data), and weight_logs.json (all weight entries). This format can be opened with standard tools or imported into spreadsheet applications.
• Opt-out: Disable analytics sharing in Application settings

How to Delete Your Account

You can delete Your Account at any time:

1. Open the Application and go to Profile
2. Tap "Account Settings" (iOS) or "Account Management" (Android)
3. Tap "Delete Account"
4. Confirm deletion

Apple Health Data (iOS)

Apple Health is a separate store on Your Device that We write into with Your permission—it is not part of Your Account, so deleting Your Account does not remove data We previously saved there. Three controls are available to You:

• Remove BulkMode data from Health: The Application's Apple Health screen (Profile → Apple Health) includes a "Remove BulkMode Data from Health" action that deletes the weight and nutrition samples this iPhone wrote. Samples written by a different device must be removed on that device or in the Health app.
• Delete from the Health app: Open Health → Browse → the relevant category → tap BulkMode under "Data Sources & Access" → Delete All Data from BulkMode.
• Revoke access: iOS Settings → Privacy & Security → Health → BulkMode. Revoking access stops future imports and writes, but does not by itself delete anything already exchanged.

In the other direction, weigh-ins already imported from Apple Health become part of Your BulkMode weight history and remain until You delete the individual entry or Your Account. Deleting Your Account removes them from Our systems like all other Health Data. Turning off weight sync does not retroactively delete weigh-ins that were already imported.

Health Connect Data (Android)

Health Connect is a separate store on Your Device that We write into with Your permission—it is not part of Your Account, so deleting Your Account does not remove data We previously saved there. Three controls are available to You:

• Remove BulkMode data from Health Connect: The Application's Health Connect screen (Profile → Health Connect) includes a "Remove BulkMode Data from Health Connect" action that deletes the weight and nutrition entries BulkMode wrote. Readings from Your scale and other applications are untouched.
• Delete from Health Connect: Open Health Connect on Your Device, where You can review the data BulkMode has written and delete it by category, by app, or by date range.
• Revoke access: Health Connect → App permissions → BulkMode. Revoking access stops future imports and writes, but does not by itself delete anything already exchanged.

In the other direction, weigh-ins already imported from Health Connect become part of Your BulkMode weight history and remain until You delete the individual entry or Your Account. Deleting Your Account removes them from Our systems like all other Health Data. Turning off weight sync does not retroactively delete weigh-ins that were already imported.

Anonymous Accounts

If You use the Service without signing in (anonymous account), Your account is authenticated through a secure session stored on Your Device (in the iOS Keychain or Android encrypted storage). This session typically persists even if You delete and reinstall the Application, allowing Your data to be restored from Our servers.

You can delete Your anonymous account and all associated data at any time using the "Delete Account" option in Account Settings—no sign-in required.

However, if Your Device's secure storage is cleared (e.g., factory reset, new device, or certain backup restoration methods), You will permanently lose access to Your anonymous account and will not be able to recover, export, or request deletion of it.

To ensure You never lose access to Your data, We strongly recommend signing in with Apple (iOS) or Google (iOS and Android), which allows account recovery on any device. Orphaned anonymous data will be automatically deleted after 3 years of inactivity per Our retention policy.

Orphaned Anonymous Account Data

If an anonymous Account becomes inaccessible (e.g., keychain cleared, device lost without backup), We cannot identify or contact You. Such orphaned data will be automatically deleted after 3 years of inactivity. We cannot fulfill data access, correction, or deletion requests for orphaned anonymous accounts as We have no way to verify ownership without the original session credentials.

State-Specific Privacy Rights

California Residents (CCPA/CPRA)

If You're a California resident, You have additional rights:

• Right to know what Personal Data is collected and used
• Right to delete Personal Data
• Right to opt-out of sale of Personal Data (We do not sell Your data)
• Right to non-discrimination for exercising Your rights

Do Not Sell or Share My Personal Information

We do not sell Your Personal Data. We do not share Your Personal Data for cross-context behavioral advertising. Because We do not sell or share Personal Data as defined by California law, there is no need to opt out—but if You have questions, contact Us at support@bulkmode.app.

Sensitive Personal Information

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), Health Data—including Your weight, food logs, calorie intake, and nutritional information—is classified as "Sensitive Personal Information." We collect and process this data solely to provide the core functionality of the Service (tracking Your nutrition and progress toward Your weight gain goals). We do not use Sensitive Personal Information for purposes other than providing the Service, and We do not sell or share it for advertising or profiling purposes.

Virginia, Colorado, Connecticut, and Utah Residents

You have similar rights including access, deletion, correction, and data portability. You can also opt-out of targeted advertising and profiling (We do not engage in these practices).

Washington and Nevada Residents (Consumer Health Data)

Under the Washington My Health My Data Act and the Nevada Consumer Health Data Privacy Law, "consumer health data" includes information related to Your physical health, nutrition, body measurements, and fitness. The following describes how We handle consumer health data as defined by these laws:

Categories of Consumer Health Data We Collect:

• Body metrics (weight, height, body fat range, date of birth, gender)
• Nutrition data (food logs, calorie and macronutrient intake, dietary preferences)
• Fitness-related inputs (exercise frequency, lifting experience, NEAT level)
• Weight history and recent weight trend
• Metabolism Intelligence System outputs (TDEE estimates, calorie targets)
• Food photos (processed in real-time for AI analysis, then immediately discarded)

Purpose: We collect this data solely to provide personalized nutrition tracking, calorie target calculations, and progress insights through the Service.

Processors: Consumer health data is processed by Supabase (cloud hosting), OpenAI and Google Gemini (AI food analysis — photos only, immediately discarded), and stored locally on Your Device. RevenueCat and PostHog do not receive consumer health data.

Your Rights: You may access, correct, or delete Your consumer health data at any time through the Application (Profile → Account Settings → Delete Account) or by contacting Us at support@bulkmode.app.

Appeals: If We deny a deletion or access request, You may appeal by emailing support@bulkmode.app with the subject line "Consumer Health Data Appeal." If You are unsatisfied with the outcome, You may contact the Washington Attorney General or the Nevada Attorney General.

European Union Residents (GDPR)

If You're in the EU/EEA, You have rights under GDPR including all the above, plus the right to lodge a complaint with Your local data protection authority.

Legal Basis for Processing (GDPR)

For users in the European Union, European Economic Area, or United Kingdom, We process Your data under the following legal bases:

• Personal Data: Performance of contract (to provide the Service You requested) and legitimate interests (to improve and secure the Service)
• Health Data: Your explicit consent, which You provide through Our GDPR consent screen before any health data is collected (GDPR Article 9(2)(a)). This includes Your weight, food logs, nutritional data, and body metrics.
• Analytics Data: Legitimate interests (data is fully anonymized and aggregated, containing no personal information)

You may withdraw consent at any time by deleting Your Account. However, withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Withdrawing consent will prevent Us from providing the Service to You.

Important: Due to the nature of the Service, withdrawing consent for health data processing requires Account deletion, as the Service cannot function without processing this data. The core purpose of the Application is to track and analyze Your nutrition and health metrics—without consent to process this information, We cannot provide any meaningful functionality.

When You provide consent, We record the date and time of Your consent for Our compliance records.

To exercise these rights, contact Us at support@bulkmode.app. We'll respond within 30 days.

7. Data Retention

We retain Your data only as long as necessary:

• Account data: Until You delete Your Account or after 3 years of inactivity
• Health Data: Until Account deletion, plus up to 7 days for disaster recovery backups
• Apple Health connection settings (iOS): Whether weight sync and nutrition writing are enabled, and the date You first connected, are retained with Your profile until Account deletion. Weigh-ins imported from Apple Health are retained on the same terms as all other Health Data above.
• Health Connect connection settings (Android): Whether weight sync and nutrition writing are enabled, and the date You first connected, are retained with Your profile until Account deletion. Weigh-ins imported from Health Connect are retained on the same terms as all other Health Data above.
• Anonymous analytics: Retained for 1 year under PostHog's data retention policy
• Support messages: Up to 3 years for quality assurance
• Food photos: Currently processed in real-time by AI and immediately discarded—only nutritional results are stored. We reserve the right to retain anonymized, de-identified photos for AI improvement in the future; if implemented, such photos would not be linked to Your identity.
• Authentication logs: Security-related logs (login attempts, session data) are retained for up to 90 days for fraud prevention and security monitoring, then automatically deleted.
• Streak repair history: Retained for the lifetime of Your Account to maintain accurate streak records and prevent abuse of the repair feature.
• Daily usage quota data: Retained for 30 days for rate limiting and quota enforcement, then automatically deleted.

Account Inactivity

Accounts that have been inactive for 3 years are automatically deleted. An Account is considered "inactive" if there has been no activity for 3 years, including:

• Logging in to the Application
• Logging any food or weight entries
• Modifying Account settings or profile information

To prevent deletion, simply log in to Your Account before the 3-year inactivity period expires. We recommend exporting Your data periodically if You anticipate extended periods of non-use.

8. Analytics and Performance Monitoring

Privacy-First Analytics

The Service uses PostHog, an analytics service configured for anonymous usage, to understand how people use the Application. This helps Us fix bugs and improve features.

What We Collect (Anonymous)

All analytics data is completely anonymous and cannot be linked to Your identity:

• App usage: Which screens You view, tab changes, and navigation patterns
• App lifecycle: App launches, foreground events, and session duration
• Onboarding funnel: Which onboarding steps You start, complete, or abandon (no specific answers recorded)
• Authentication events: Sign-up and login attempts and outcomes (success/failure, no credentials)
• Subscription events: Paywall views, purchase outcomes, trial starts (no exact prices or payment details)

What We DON'T Collect

• Your identity: No names, emails, phone numbers, or user IDs
• Your Health Data: No specific food names, no exact calories, no weights, no body measurements, no meal details, and no data read from Apple Health or Health Connect
• Your location: No GPS coordinates or location tracking
• Your payment details: No credit card numbers or exact prices
• Your photos: No images or photo content
• Exact timestamps: We do not report the dates or clock times at which You use the Application. Where an event carries a duration—how long a deleted entry existed, how long a scan took—it is an elapsed time only, never a date or a time of day

Opting Out of Analytics

You can disable anonymous analytics collection at any time via Settings → Privacy & Data → Share Analytics toggle in the Application. When disabled, no Usage Data is sent to Our analytics provider.

PostHog Details

PostHog is configured for anonymous, privacy-respecting analytics:

• Stores data in the United States (AWS us-east-1, Virginia)
• No person profiles are created — the service is configured with person profiles disabled, so no individual user profiles exist
• IP addresses are discarded at ingestion — the server-side "Discard client IP data" setting ensures IP addresses are not stored
• Uses anonymous identifiers, not personal identifiers — these identifiers cannot be linked to Your name, email, or identity
• Event data is retained for one year under PostHog's data retention policy
• Privacy policy: posthog.com/privacy

Note: We never use analytics for advertising, cross-app tracking, or selling data. Analytics is solely for improving Your Service experience.

9. International Data Transfers

Your data may be processed in countries other than Your own. When We transfer data internationally, We implement appropriate safeguards to protect it in accordance with this policy and applicable laws.

Data Storage Locations

• Supabase (Primary Database): Your Account and Health Data is stored on servers in the United States (AWS us-east-2, Ohio region)
• Apple Health (iOS): Apple Health data remains on Your Device under Apple's control. It reaches Us only as described in Section 2—body weight readings You have permitted Us to import—and those readings are then stored with Your Account on Supabase in the United States.
• Health Connect (Android): Health Connect data remains on Your Device, managed by the Health Connect platform and under Your control. It reaches Us only as described in Section 2—body weight readings You have permitted Us to import—and those readings are then stored with Your Account on Supabase in the United States.
• PostHog (Analytics): Anonymous analytics data is stored in the United States (AWS us-east-1, Virginia)
• AI Processing: Food photos are processed by OpenAI (United States) and Google Gemini (United States) but are not permanently stored by these providers beyond their standard processing retention periods (up to 30 days for abuse monitoring)
• RevenueCat (Subscriptions): Subscription data is processed in the United States
• Apple (Authentication & Payments): Sign in with Apple and App Store purchases are processed according to Apple's data practices
• Google (Authentication & Payments): Sign in with Google and Google Play purchases are processed according to Google's Privacy Policy
• Open Food Facts (Barcode Lookups): Product barcode lookups are processed by Open Food Facts, a nonprofit association based in France. Only the product barcode number is transmitted—no personal data.

International Transfer Safeguards

For users in the European Union, European Economic Area, or United Kingdom, international data transfers to the United States rely on Standard Contractual Clauses (SCCs) approved by the European Commission, as well as supplementary security measures including encryption in transit and at rest.

10. Children's Privacy

COPPA Compliance: We comply with the Children's Online Privacy Protection Act (COPPA). The Service is not intended for children under 13 years of age. We do not knowingly collect Personal Data from children under 13. If We become aware that We have collected Personal Data from a child under 13, We will delete that information promptly.

If You believe a child under 13 has provided Us with Personal Data, please contact Us at support@bulkmode.app.

Users Ages 13-17

If You are between 13 and 17 years old, We strongly recommend parental or guardian supervision when using the Service. Consult with Your parents, guardians, or healthcare professionals before starting any diet or nutrition program.

Eating Disorder Resources: If You or someone You know is struggling with an eating disorder, please contact the National Eating Disorders Association (NEDA) Helpline at 1-800-931-2237 or text "NEDA" to 741741.

11. Changes to This Privacy Policy

We may update this Privacy Policy occasionally to reflect changes in Our practices or for legal reasons.

When We make changes, We will:

• Update the "Last updated" date at the top
• Notify You of significant changes through the Application or by email
• Give You the opportunity to review the updated policy

Your continued use of the Service after changes indicates Your acceptance of the updated policy.

12. App Store and Google Play Privacy Information

Our iOS App Store listing includes a Privacy Nutrition Label and Our Google Play listing includes a Data Safety section, each describing the data We collect and how We use it. These disclosures are designed to help You understand Our data practices at a glance before downloading the Application.

We keep these store disclosures accurate and up-to-date. If Our data practices change (for example, if We begin retaining food photos for AI improvement), We will update this Privacy Policy, Our App Store privacy label, and Our Google Play Data Safety section accordingly.

These disclosures reflect that We:

• Do NOT track You across other companies' apps and websites
• Do NOT use the Apple Advertising Identifier (IDFA) or the Android Advertising ID
• Collect Health & Fitness data (weight, nutrition) linked to Your Account
• Read body weight from Apple Health, and write weight and daily nutrition totals to Apple Health, only on iOS and only where You have connected it
• Read body weight from Health Connect, and write weight and daily nutrition totals to Health Connect, only on Android and only where You have connected it
• Collect identifiers (user ID, device ID) for Account functionality
• Collect usage data (anonymized) for analytics