Privacy Policy

1.General Provisions and Controller Information

"Company" or "Controller" in this policy refers to the business listed below. Pursuant to Article 30 of PIPA, the Company adopts and publishes this policy to protect the personal data of users and to handle related grievances promptly.

The Service currently launches in the Republic of Korea only. PIPA is the governing data-protection law. EU General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA) are not currently applicable; this policy will be updated at the time of any future expansion.

2.Personal Data We Collect

The Company collects only the minimum data necessary to provide the Service.

a. Automatically Collected (required)

b. Collected on Account Linking (optional)

• Sign in with Apple — email (or Apple-relayed private alias at user discretion), name (if shared)
• Sign in with Google — email, name, profile image URL
• Authentication tokens and provider user identifiers (sub)

c. User-Entered Data (optional)

• Meal photos (JPEG; EXIF/GPS metadata removed before upload)
• Meal memo text
• Macronutrient values (carbohydrate, protein, fat)
• Chat messages with the Ketomate AI coach
• Inquiry email and content (when contacting support)
• Launch-alert email address (when subscribed via the phare.me/ketomate landing page)

d. Sensitive Data (separate consent required)

The following items, collected during onboarding, are processed only with the user's explicit separate consent. See Section 3 for details.

• Statutory sensitive data (PIPA Article 23) — pregnancy/lactation status, chronic disease (e.g., diabetes), regular medication use, insulin-resistance proxy responses
• Additional protected data (not statutory sensitive but treated equivalently by the Company) — keto experience level, target weight and weight-loss intent

3.Sensitive Data — Separate Notice

Pursuant to PIPA Article 23, the Company obtains separate consent before processing sensitive data. Consent is collected via a checkbox separate from general personal-data consent; users may consent to general processing while declining sensitive-data processing.

Caution: Ketomate is not a medical device, drug, or diagnostic tool. Always consult your healthcare provider before adopting a dietary regimen during pregnancy, lactation, diabetes, or while taking medication. See Section 15.

4.Purposes of Use

• Service delivery — meal logging, AI dietary coaching, daily carb-target guidance
• User authentication and pseudonymous-session management
• Application of safety guardrails and surfacing of medical disclaimers
• Service quality improvement — usage analysis, bug and crash diagnosis
• Responding to inquiries and sending notification emails
• Sending launch-announcement emails to users who subscribed on the landing page
• Compliance with statutory obligations — dispute handling, fraud prevention, accounting/tax records

The Company will not use personal data beyond these purposes; if purposes change, separate consent will be obtained.

5.Retention and Disposal

a. Retention periods

b. Statutory retention

Where applicable law requires retention for a fixed period, such records are stored separately for that period.

• Contract / withdrawal records under the Act on Consumer Protection in Electronic Commerce: 5 years (when applicable)
• Consumer complaint / dispute records under the same Act: 3 years (when applicable)
• Service usage logs under the Protection of Communications Secrets Act: 3 months

* No paid features are offered in v1, so payment-related items do not yet apply.

c. Disposal procedure

• Electronic files: irrecoverable deletion (DB row delete plus backup rotation auto-purge)
• Printed materials: shredded or incinerated

6.Processing Delegation (Sub-Processors)

The Company delegates processing tasks to the following third parties to operate the Service. Pursuant to PIPA Article 26, delegation contracts forbid out-of-purpose processing, prescribe technical and managerial safeguards, restrict re-delegation, and provide for indemnification. Each processor publishes its own list of sub-processors at the URL shown; the Company reviews changes thereto.

Gemini data-use policy: The Company uses only the paid tier of Google's Gemini API. Per Google's official terms, data sent to the paid tier is not used for model training and is retained only briefly (up to 30 days, for responsible-AI safety review) before deletion (ai.google.dev/gemini-api/terms). The Company does not use the free tier.

iOS app advertising-tracking policy: The Ketomate iOS app contains no advertising SDKs (Meta SDK, AdMob, etc.) and does not use the Identifier for Advertisers (IDFA). The Apple App Tracking Transparency (ATT) prompt is not shown. The advertising trackers above (Meta Pixel/CAPI, Amplitude session replay) operate only on the web landing page. See Section 10.

7.Cross-Border Transfer

All processors above operate on US or global infrastructure, which entails cross-border transfer of user data. The following information is provided pursuant to PIPA Article 28-2.

How to Refuse Cross-Border Transfer

• Method — Email app.phare@gmail.com with subject "Refuse cross-border transfer", or use Settings → My Data → Delete Account in the app.
• Process — After identity verification, the request is processed within 7 business days. Analytics opt-out is effective immediately upon toggle.
• Effect — Transfers to Supabase, Apple, Google, and Gemini are essential to delivering the Service; refusal results in account withdrawal and discontinuation of Service. Transfers to Amplitude and PostHog can be refused via the opt-out in Section 10 without affecting core features. Refusal of Meta Pixel is handled via cookie controls on the landing page.

8.User Rights and How to Exercise Them

Users may exercise the following rights with respect to their personal data:

• Access — confirm the items and status of processing
• Correction / Deletion — correct inaccurate data or request deletion
• Suspension of processing — withdraw consent or suspend processing
• Account withdrawal — via Settings → Delete Account in the app, or by email

How to exercise

• Inside the app: Settings → My Data for direct access and deletion
• By email: app.phare@gmail.com (use subject "Privacy rights request"; include your sign-in email or session identifier for verification)

The Company will act without delay upon verification, and may request additional documents to confirm identity. Rights may also be exercised through a legal representative or duly authorized agent.

9.Security Measures

Pursuant to PIPA Article 29, the Company implements the following technical and managerial controls:

• Transport encryption — all client-server traffic uses TLS 1.2+
• Hashed token storage — pseudonymous session tokens are stored only as SHA-256 hashes (no plaintext)
• Access control — Supabase publishable anon key is bundled with the app, but data access is enforced per-user by Row Level Security (RLS) policies. Sensitive operations and service-role-key actions (e.g., 7-day photo deletion, linking pseudonymous sessions to accounts) run only on Supabase Edge Functions on the server side.
• Photo protection — private storage bucket, short-lived signed URLs, EXIF/GPS stripped before upload, 7-day auto-deletion
• Secret management — API keys and service-role keys live only in server-side environment variables; never bundled into the app
• Minimum operational personnel; access logs retained
• Incident response — impact assessment and notification within 72 hours of detection

10.Opting Out of Automatic Collection / Advertising-Tracking Policy

The iOS app does not perform advertising tracking. The Ketomate iOS app contains no advertising SDKs (Meta SDK, AdMob, TikTok, etc.) and does not use the Identifier for Advertisers (IDFA). Apple's App Tracking Transparency (ATT) prompt is not shown. The trackers below operate only on the web landing page (phare.me/ketomate).

In-app analytics

Ketomate uses Amplitude and PostHog as first-party analytics for product improvement inside the app. These measure in-app usage patterns in pseudonymous form only and are not combined with activity from other companies' apps or websites.

• Opt out: Settings → Disable analytics transmission
• Effect: limited input into product-improvement analyses; no impact on core features

Landing-page Amplitude session replay

For landing-page usability analysis and debugging, the Company runs the Amplitude analytics SDK and the session-replay plugin. Session replay reconstructs visitor click, scroll, mouse-movement, and page-input flows as video, sampled at 100% of all visitors. Form fields (e.g., email input) are masked per Amplitude's default policy, so actual entered values are not captured.

• Opt out: browser tracking blockers (Do Not Track), private browsing, or the Amplitude opt-out link (to be added in the landing footer)
• Effect: not counted in landing-page usability analytics; no impact on core features

Landing-page Meta Pixel + Meta Conversions API (CAPI)

To measure ad effectiveness on the landing page, the Company runs Meta Pixel (browser-side) together with Meta Conversions API (server-side). This applies to the web landing page only; the iOS app is not affected.

• Meta Pixel — sends a PageView event, browser cookies (_fbp/_fbc), and user agent to Meta on each landing visit
• Meta CAPI — sends a Lead event from the server when a user submits the launch-alert form. The email is SHA-256-hashed by the Company server before transmission; plaintext email is not sent to Meta
• Opt out: block browser cookies; refuse ad tracking via Meta ad preferences; or skip the launch-alert sign-up
• Effect: not counted in Meta ad-effectiveness measurement; no impact on landing-page core function

* If a paid-subscription feature is introduced in a future version of Ketomate, in-app advertising SDKs may be added at that time. Any such change will be announced 14 days in advance and an Apple ATT consent flow will be presented separately at that point.

11.Protection of Users Aged 14–17

Ketomate accepts users aged 14 or older. We do not collect personal data from children under 14; if registration indicates age under 14, signup is blocked.

For users aged 14–17, the Company applies these protections:

• A guardian-advisory notice on Service entry
• Emphasis that dietary regimens should be undertaken under guidance of a physician or dietitian
• "Enter with your guardian" prompts on screens involving pregnancy or medication
• Repeated reminders that Ketomate is not a medical decision-making tool

Minors and their legal representatives may exercise the rights in Section 8 to access, correct, or delete personal data.

12.Privacy Officer

The Company has appointed the following Privacy Officer to oversee personal-data processing and to address user complaints and remedies:

Users may direct any privacy-related inquiries, complaints, or remedy requests to the contact above. The Company will respond and resolve them without delay.

13.Remedies and Dispute Resolution

For redress of personal-data infringements, users may contact the following Korean authorities:

Where a user's rights or interests are infringed by the Company's action or inaction concerning rights under PIPA Articles 35 (access), 36 (correction/deletion), or 37 (suspension of processing), administrative appeal under the Administrative Appeals Act is available.

14.Changes to This Policy

Material additions, deletions, or amendments will be announced in-app and on this page at least 14 days before they take effect. Changes that materially affect user rights will be announced at least 30 days in advance, and renewed consent will be obtained where required.

Revision history is tracked at the top of this page and below:

• v1.3 (2026-04-29) — Reflected actual installations on `main`: Meta Pixel + Meta Conversions API (landing ad measurement), Amplitude session replay at 100% sampling (landing behavioral analytics) added to §6/§7/§10. Removed v1.2's incorrect "no advertising trackers installed" assertion.
• v1.2 (2026-04-29) — Second-round review reflected: Meta Pixel reclassified as "planned" to match actual non-installation; launch-alert email retention aligned with Resend Contacts reality; pseudonymous-identifier wording refined; weight-loss intent added to self-protected items in §3
• v1.1 (2026-04-29) — Incorporated external review feedback (PIPA Articles 23, 26, 28-2 disclosure items strengthened; Gemini paid tier specified; Meta SDK non-installation policy declared; pseudonymous-data wording corrected)
• v1.0 (2026-04-29) — Initial publication

15.Service Disclaimers (AI & Medical)

Ketomate is a lifestyle tool that helps users log keto meals and provides general dietary guidance. Specifically:

• Ketomate is not a medical device, drug, or diagnostic tool.
• Ketomate's responses are general dietary information; they do not replace diagnosis, treatment, or prescription.
• Users who are pregnant, lactating, diabetic, have kidney disease, or take medication — or otherwise have health concerns — must consult their healthcare provider before adopting any dietary regimen.
• To generate AI responses, user input is transiently transmitted to Google Gemini (paid tier) and is not used for Google's model training (see Section 6).
• The Company assumes no medical liability for outcomes resulting from use of the Service. This disclaimer does not exclude liability mandated by Korean consumer protection or other compulsory law.