Privacy Policy

Effective Date: May 10th, 2025
1. Introduction
Westpoint Capital OÜ (“Company,” “We,” “Us,” “Our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our iOS mobile application, LifeLog – Health Made Easy (the “App”), and its related services (collectively, the “Services”).
Please read this Privacy Policy carefully. By using the App, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this PrivacyPolicy, please do not access or use the App.
This Privacy Policy should be read in conjunction with our Terms and Conditions.
2. Information We Collect
We collect information that you provide directly to us, information collected automatically when you use our App, and information from third parties.
A. Information You Provide to Us:
  • Account Information: When you create a LifeLog account, we collect information such as your name, email address, password, age, weight, height, wellness goals (e.g., target weight, activity levels), and preferences for your AI coaching style.
  • Health and Wellness Data:
  • Manual Entries: You can manually input various health and wellness metrics and information, including but not limited to, dietary intake (calories, macronutrients, etc.), water consumption, sleep duration and quality, workout details (type, duration, intensity), mood, body measurements, and any other active metrics you choose to log.
  • Apple HealthKit Data: With your explicit consent, we access data from Apple HealthKit to enhance your experience within the App. This may include, but is not limited to, steps, distance traveled, flights climbed, heart rate, active energy, resting energy, sleep analysis, workout data, weight, height, body mass index, body fat percentage, dietary energy, and other health records you choose to share from HealthKit. You can manage HealthKit data sharing through the Health app settings on your iOS device. We only process HealthKit data to provide the App’s health and wellness features and do not use it for marketing or advertising.
  • User-Generated Content (UGC):
  • Food Scanner: We collect images of meals that you upload through the Food Scanner feature to analyze their nutritional content. We may also collect metadata associated with these images if provided by your device (e.g., timestamp, but not typically precise location unless explicitly enabled and relevant for a feature).
  • Scarleth AI Coach: We collect the text of your conversations (chat logs) with the Scarleth AI Coach to provide responses, maintain conversation history, and improve the AI’s performance for your benefit.
  • Other Entries: Any other information you voluntarily provide, such as notes, diary entries, or feedback.
B. Information We Collect Automatically:
  • Usage Data: We collect information about your interactions with the App, such as the features you use, the frequency and duration of your activities within the App, your progress in challenges, actions you take, and crash reports. We may use third-party analytics services like Google Analytics for Firebase to help us understand app usage. This may involve the collection of pseudonymized identifiers and usage patterns.
  • Device and Technical Data: We automatically collect certain information about your mobile device, including your device model, operating system version, IP address, unique device identifiers (e.g., IDFA, or other identifiers generated by our systems), app version, language preferences, and mobile network information.
  • Cookies and Similar Technologies: While the App does not use traditional browser cookies, it utilizes Software Development Kits (SDKs) and similar technologies (e.g., from Firebase) that may collect information to help us operate and improve the App, provide analytics, and ensure secure authentication.
C. Information from Third Parties:
  • As mentioned, we collect data from Apple HealthKit with your consent.
  • If you interact with us on social media, we may collect information you make public on those platforms.
D. Inferred Data:
To enhance your experience and provide personalized insights, we may derive inferences from the information we collect about you. For example, we might infer your general activity patterns, potential nutritional habits, or progress towards your goals to tailor the Scarleth AI Coach’s advice or suggest relevant challenges.
3. How We Use Your Information
We use the information we collect for various purposes, including:
  • To Provide and Maintain the Services:
  • Create and manage your account.
  • Enable you to track your health and wellness data.
  • Operate the Food Scanner and Scarleth AI Coach features.
  • Offer challenges, track your progress, and provide rewards.
  • Synchronize your data across devices (if applicable).
  • To Personalize Your Experience:
  • Tailor content, features, and insights to your individual needs and preferences.
  • Allow the Scarleth AI Coach to adapt its responses and guidance based on your collected data and interaction history, for your benefit.
  • To Operate AI Features:
  • Your interactions with the Scarleth AI Coach (chat prompts) and images submitted to the Food Scanner are processed by us and sent to our third-party AI service providers (e.g., OpenAI) to generate responses and nutritional analyses. These providers process your data according to their own privacy policies and terms. We use this data solely to provide you with the AI-driven features of the App. The Company does not use your personal data submitted to these AI features to train or improve third-party general AI models outside of the direct provision of service to you through our App, though the AI provider may have its own data usage policies for service improvement that you should review.
  • For Communication:
  • Send you service-related communications, including account verification, technical notices, updates, security alerts, and support messages via email or in-app notifications.
  • Send you promotional communications, such as newsletters, special offers, and information about new products, services, or challenges we think may interest you (where permitted by law and with your consent, if required). You can opt-out of receiving promotional emails by following the unsubscribe instructions in those emails or by adjusting your in-app notification settings.
  • For Research and Development:
  • To monitor and analyze usage trends, and to improve the App’s functionality, user experience, and features. For such purposes, we primarily use aggregated and/or anonymized data.
  • For Security and Fraud Prevention:
  • To protect the rights, property, or safety of the Company, our users, or others, and to detect, prevent, and respond to fraud, abuse, security risks, and technical issues.
  • To Enforce Terms and Comply with Legal Obligations:
  • To enforce our Terms and Conditions and other policies, and to comply with applicable legal requirements, lawful requests, and legal process.
4. How We Share Your Information
We do not sell your personal information. We may share your information in the following circumstances:
  • With Service Providers: We share information with third-party vendors, consultants, and other service providers who perform services on our behalf. These may include:
  • Firebase (Google): For backend infrastructure, including authentication, database storage (Firestore), file storage (Cloud Storage), cloud functions, analytics (Google Analytics for Firebase), and crash reporting (Crashlytics).
  • OpenAI: To power the Scarleth AI Coach and AI-driven aspects of the Food Scanner. We share relevant data (e.g., text prompts, food images, contextual user data like preferences) necessary for these features to function.
  • Google Cloud Text-to-Speech: To convert text to speech for voice features within the App.
  • Other service providers for functions like customer support, data analytics, or email delivery.
These service providers are contractually obligated to protect your information and are restricted from using your personal information for any purpose other than to provide services for us or as required by law.
  • For Legal Reasons: We may disclose your information if we believe it’s necessary to:
  • Comply with applicable laws, regulations, legal processes, or governmental requests.
  • Enforce our Terms and Conditions or other agreements.
  • Protect the rights, property, or safety of the Company, our users, or the public.
  • Detect, prevent, or otherwise address fraud, security, or technical issues.
  • Business Transfers: In the event of a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our App of any change in ownership or uses of your personal information.
  • Aggregated or Anonymized Data: We may share aggregated or anonymized information that does not directly identify you with third parties for research, analytics, reporting, or other purposes.
  • With Your Consent: We may share your information with third parties when we have your explicit consent to do so.
  • HealthKit Data: Data accessed from Apple HealthKit is never used for advertising or data mining purposes and is not disclosed to third-party advertisers or data brokers. It is used solely to provide health, motion, and fitness services in connection with the App, in accordance with Apple’s Developer Program License Agreement.
5. Data Storage and Security
  • Data Storage Location: Your information may be stored and processed on servers located in various countries around the world, including the European Union (EU) and the United States, by us or our third-party service providers (e.g., Firebase, OpenAI). If you are in the European Economic Area (EEA), this may mean your data is transferred outside the EEA.
  • Security Measures: We implement technical and organizational measures designed to protect your personal information from unauthorized access, use, alteration, or disclosure. These include using encryption for data in transit (e.g., TLS/SSL) and at rest, employing Firebase security rules, access controls, and regularly reviewing our security practices. However, no security system is impenetrable, and we cannot guarantee the absolute security of your information.
  • Data Breach Notification: In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable law.
6. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, and to provide you with the Services.
  • Account Information and Related Data: We generally retain your account information and related personal data (health metrics, UGC) as long as your account is active. If you delete your account through the App, we will take steps to delete your personal information within a reasonable timeframe, subject to our backup policies and any legal or regulatory obligations to retain certain information.
  • Backups: Your data may remain in our backup systems for a limited period after deletion from our active systems.
  • Anonymized Data: We may retain anonymized or aggregated data for longer periods for research, statistical, or service improvement purposes.
You can request deletion of your account and associated personal data through the designated account deletion feature in the App.
7. Your Data Rights (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation (GDPR):
  • Right of Access: You have the right to request copies of your personal information.
  • Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
  • Right to Erasure (Right to be Forgotten): You have the right to request that we erase your personal information, under certain conditions.
  • Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information, under certain conditions.
  • Right to Object to Processing: You have the right to object to our processing of your personal information, under certain conditions, particularly for direct marketing purposes.
  • Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
  • Right to Withdraw Consent: If we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us at support@thelifelog.app. We will respond to your request within a reasonable timeframe and in accordance with applicable law.
  • Automated Decision-Making and Profiling: While the App uses AI to personalize your experience, it does not currently make automated decisions that would have a legal or similarly significant effect on you based solely on automated processing. If this changes, we will update this policy and provide you with information about your rights.
  • Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR. The Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) is the supervisory authority in Estonia.
8. International Data Transfers
As mentioned in Section 5, your information may be transferred to, stored, and processed in countries outside of your country of residence or the EEA, where data protection laws may differ. We ensure that appropriate safeguards are in place for such transfers, such as by using Standard Contractual Clauses (SCCs) approved by the European Commission, relying on adequacy decisions, or obtaining your explicit consent for specific transfers where required by law.
9. Children’s Privacy
The App is not intended for or directed at children under the age of 16 (or the relevant age of consent for information society services in your jurisdiction) without verifiable parental consent. We do not knowingly collect personal information from children under this age without such consent. If you believe we have collected information from a child under this age without proper consent, please contact us at support@thelifelog.app, and we will take steps to delete that information. We strongly encourage parents and guardians to monitor their children’s internet usage and to help enforce this Privacy Policy.
10. Specifics for Apple HealthKit Data
We reiterate our commitment to handling Apple HealthKit data responsibly:
  • We will only access HealthKit data categories with your explicit consent.
  • You will be clearly informed why we are requesting access to each data type before you grant permission.
  • HealthKit data will be used solely to provide health, motion, and fitness tracking and analysis features within the App.
  • HealthKit data will not be used for advertising, marketing, or data-mining purposes.
  • HealthKit data will not be shared with or sold to third-party advertisers or data brokers.
  • We comply with all applicable Apple Developer Program License Agreement terms regarding HealthKit data.
11. Third-Party Links and Services
The App may contain links to third-party websites or services that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site or service. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy within the App, on our website, and/or by sending you an email to the address associated with your account. The “Effective Date” at the top of this Privacy Policy will indicate when the latest modifications were made. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of the App after such modifications will constitute your acknowledgment of the modified Privacy Policy and agreement to abide and be bound by that Policy.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Westpoint Capital OÜ
Email: support@thelifelog.app
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