Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to SteelX Ventures, Wyoming, United States.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: Wyoming, United States.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Health Data means any data related to Your physical health, fitness, nutrition, or wellness that is collected through the Application, including but not limited to food logs, calorie and macronutrient data, meal photographs, dietary preferences, body measurements, weight, fitness goals, and activity information.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Application refers to Sugar AI, the software program provided by the Company.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the screens of our Application that You visit, the time and date of Your visit, the time spent on those screens, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Health and Nutrition Data

Sugar AI is a nutrition and fitness application. As part of providing the Service, We collect and process the following Health Data:

• Food and meal photographs: Images You upload or capture using the Application's food recognition feature. These images are processed by our AI system to identify foods, estimate portion sizes, and calculate nutritional information.
• Nutritional and calorie data: Food logs, calorie counts, macronutrient breakdowns (protein, carbohydrates, fat), micronutrient data, and meal history generated from Your food entries and image analyses.
• Dietary preferences and goals: Information You provide about dietary restrictions, allergies, nutritional goals, target calorie intake, and meal planning preferences.
• Body measurements and weight: Data You choose to enter such as height, weight, body mass index (BMI), and related body metrics used to personalize Your nutritional recommendations.
• Fitness and activity information: Exercise logs, activity levels, and fitness goals You provide to help calculate Your nutritional needs.

How We use Your Health Data: Health Data is used solely to provide and improve the core functionality of the Application, including food recognition, calorie tracking, nutritional analysis, and personalized dietary recommendations. We do not sell Your Health Data to any third party. We do not use Your Health Data for advertising purposes. Health Data may be used in anonymized, aggregated form to improve the accuracy of our food recognition AI and nutritional database.

How We protect Your Health Data: Health Data is transmitted using industry-standard encryption (TLS/SSL) and stored on secure servers. Access to Health Data is restricted to authorized personnel who require it for Service operation and improvement. Food photographs processed for recognition are not shared with any third parties.

Information Collected through the Application

When using our food recognition feature, we may collect images that you upload for analysis. These images are processed to provide you with food recognition services but are not shared with any third parties.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

Retention of Your Personal Data

The Company retains Your data for specific periods depending on the type of data and the purpose for which it was collected:

• Account Data (name, email, phone number): Retained for as long as Your account remains active, and for up to 90 days after account deletion to allow for account recovery and to resolve any outstanding issues.
• Health and Nutrition Data (food logs, meal photos, calorie data, body measurements, dietary preferences, fitness goals): Retained for as long as Your account is active. Upon account deletion, Health Data is permanently deleted within 30 days.
• Food photographs uploaded for AI recognition: Processed in real time and automatically deleted from our processing servers within 24 hours of analysis. Nutritional results derived from the analysis are retained as part of Your food logs.
• Usage Data (IP address, device info, session data): Retained for up to 12 months for analytics and service improvement, then automatically deleted or anonymized.
• Anonymized and aggregated data: Data that has been fully anonymized (so that it can no longer identify You) may be retained indefinitely for research, analytics, and service improvement purposes.

We may retain certain data beyond the periods stated above where required by law (for example, tax or accounting obligations), to resolve disputes, or to enforce our agreements. In such cases, the data is retained only for as long as the specific legal or business requirement persists.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. You can delete Your data in the following ways:

Option 1 — In-App Deletion: Open the Sugar AI app → Go to Settings → Tap "Delete My Account." This will permanently delete Your account and all associated Personal Data and Health Data within 30 days.

Option 2 — Email Request: Send an email to contact@sugarai.app with the subject line "Data Deletion Request" and include the email address associated with Your account. We will process Your request and delete Your data within 30 days of receiving the request.

Upon receiving a deletion request:

• Your account will be deactivated immediately.
• All Health Data (food logs, meal photos, calorie data, body measurements, dietary preferences, fitness goals) will be permanently deleted within 30 days.
• Account Data (name, email) will be permanently deleted within 90 days.
• Usage Data will be anonymized or deleted within 90 days.
• Any anonymized, aggregated data that can no longer identify You may be retained.

Please note that We may need to retain certain information where we have a legal obligation or lawful basis to do so (for example, financial transaction records for tax purposes). We will inform You if this applies to Your request.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. 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.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

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.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: contact@sugarai.app