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PRIVACY POLICY

Last updated: August 25, 2026

1. GENERAL PROVISIONS

1.1. This Privacy Policy (the "Policy") describes what data the operator of the Healthy app — GMD Media FZE LLC (the "Operator", "we") — processes when you use the app, for what purposes, and on what legal grounds.

1.2. By using the app, you consent to the processing of data in accordance with this Policy. If you do not agree, do not use the app.

2. APPLE HEALTHKIT DATA AND HEALTH DATA

2.1. With your explicit permission, the app may receive health data from Apple HealthKit, including: sleep, heart rate, heart rate variability (HRV), workouts, steps, energy expenditure, and other activity and health metrics (the "Health Data").

2.2. Health Data is used SOLELY to provide the app's features: calculating your recovery score, generating personalized recommendations, and displaying your metrics.

2.3. Health Data is NOT shared with third parties; is NOT used for advertising or marketing; and is NOT sold or provided to anyone for commercial purposes.

2.4. Health Data is processed on the Operator's secure servers solely to calculate your personal metrics and recommendations.

2.5. You may revoke the app's access to Apple HealthKit at any time in iOS settings (Settings → Privacy & Security → Health). Revoking access stops the collection of new Health Data.

2.6. You have the right to request the deletion of previously processed Health Data by sending a request to support@healthysocial.ai. We will delete such data within the period provided by law, except where its retention is required by law.

2A. WEARABLE DEVICES AND WHOOP INTEGRATION

2A.1. With your explicit consent, the app may connect to your WHOOP account via the official OAuth 2.0 authorization protocol. During connection you grant consent directly on WHOOP's side, and the app receives limited access to your WHOOP data within the requested permission scopes.

2A.2. From WHOOP, the app may receive physiological metrics, including: recovery, strain, sleep, heart rate, and heart rate variability (HRV), as well as related metrics. This data constitutes Health Data and is protected on par with the data in Section 2.

2A.3. Data from WHOOP is used SOLELY to provide the app's features (displaying metrics, calculating recovery, personalized recommendations), is NOT shared with third parties for commercial purposes, is NOT used for advertising, and is NOT sold.

2A.4. For access, the app stores WHOOP access and refresh tokens on the Operator's secure servers. Tokens are used only to retrieve your data at your request and during background synchronization.

2A.5. You may disconnect the WHOOP integration at any time directly in the app (Settings/Devices → Disconnect WHOOP). Upon disconnection, the Operator deletes the stored WHOOP tokens and stops collecting new data. You may also revoke access on WHOOP's side within your WHOOP account.

2A.6. Data processing on WHOOP's side is governed by WHOOP's privacy policy. We recommend reviewing it on the WHOOP website.

2B. PROCESSING OF DATA USING ARTIFICIAL INTELLIGENCE (AI)

2B.1. Some app features (the AI health & nutrition assistant, food recognition from photos, decoding of lab-test results, personalized recommendations, and voice input) use a third-party artificial-intelligence service — Anthropic Claude (Anthropic PBC, USA). Requests to the AI service are routed through the Operator's secure servers.

2B.2. What data may be sent to the AI service: the text of your messages and questions to the AI assistant; food photos and images/lab results that you voluntarily upload for recognition; and a de-identified context of your health metrics (for example, sleep, recovery, and activity indicators) needed to generate a recommendation. We do NOT send your identifying data (name, email, payment information) to the AI service, and we do not use it for advertising.

2B.3. Consent. Before any data is sent to the AI service for the first time, the app shows a dedicated consent screen explaining what data is sent and to whom. Data is transmitted to the AI service ONLY after you tap “Accept”. If you decline, AI features remain off, no data is sent to the AI service, and the app will not prompt for consent again automatically. If you later choose to use an AI feature, the app will offer to enable AI and show the consent screen again (Accept / Decline) — only upon your explicit action.

2B.4. The AI service provider (Anthropic) processes the transmitted data in accordance with its own privacy policy and under terms providing a level of protection comparable to this Policy. Under Anthropic's terms, data sent via the API is not used to train models. Data is transmitted solely to provide the feature you requested; it is not sold and is not used for advertising.

3. WHAT DATA WE COLLECT

3.1. Account data: username, email address, identifiers, profile settings.

3.2. User content: reels, stories, posts, texts, comments, images, and audio that you publish.

3.3. Health and activity metrics: see Section 2 (data from Apple HealthKit and metrics you enter).

3.4. Payment data: processed by the relevant providers. Purchases of subscriptions and in-app currency are processed by the Apple platform (App Store) and a subscription management service; payouts to authors are processed by a payment provider (MCPay / MediaCube). The Operator does not store full payment details (card numbers) itself.

3.5. Technical data: device information, OS and app versions, event and crash logs necessary for the operation and security of the service.

4. PURPOSES OF PROCESSING

4.1. Providing and supporting the app's features (including recovery calculation and recommendations).

4.2. Registration and authentication, ensuring security, and preventing fraud.

4.3. Processing subscriptions, donations, and payouts to authors.

4.4. Improving the app, providing technical support, and communicating with you on service-related matters.

4.5. Compliance with the requirements of applicable law.

5. LEGAL GROUNDS

5.1. Processing is carried out on the basis of: your consent (in particular, for access to Apple HealthKit); performance of a contract (the Terms of Use); the Operator's legitimate interests (security, fraud prevention, service improvement); and compliance with legal obligations.

6. DATA SHARING

6.1. We may engage service providers (hosting, payment providers, error analytics) solely to the extent necessary to provide their services and subject to confidentiality obligations. Health Data (Section 2) is not shared with third parties.

6.2. We may disclose data at the request of authorized authorities where required by law.

6A. PROCESSORS (SERVICE PROVIDERS)

6A.1. To operate the service, we engage the following processors, each strictly to the extent necessary to provide the service and subject to confidentiality obligations:

6A.2. Hosting, content delivery, and media storage — Bunny.net (BunnyWay d.o.o., EU/Slovenia): CDN, video streaming, and object storage for user content; a Data Processing Agreement (DPA) has been executed with this processor.

6A.3. Payments and subscriptions — Apple (App Store, in-app purchases and subscriptions); Lava.top and Stripe (payment acceptance on the web platform); payouts to authors — MCPay / MediaCube.

6A.4. Wearable devices — WHOOP, Inc. (USA): source of physiological data when the integration is connected (see Section 2A).

6A.5. Platform health data — Apple HealthKit (data remains on your device and is transmitted to us only with your permission; see Section 2).

6A.6. AI features — artificial intelligence model providers used for dish recognition, speech recognition, and generating recommendations; identifying Health Data is not sent to such services beyond what is necessary to fulfill the request.

6A.7. The list of processors may be updated as the service evolves; the current version is published in this Policy.

7. RETENTION PERIOD

7.1. We retain data for as long as necessary for the purposes set out in this Policy, or for the period established by law. Once the need ceases, data is deleted or anonymized.

8. USER RIGHTS

8.1. You have the right to: access your data; request its correction or deletion; restrict or object to processing; withdraw previously given consent; and request data portability — to the extent provided by applicable law.

8.2. To exercise your rights, including the deletion of data and your account, contact: support@healthysocial.ai.

9. SECURITY

9.1. We apply reasonable technical and organizational measures to protect data from unauthorized access, alteration, and destruction. Absolute security of data transmission over the internet cannot be guaranteed.

10. CHANGES TO THE POLICY

10.1. The Operator may update this Policy. The current version is published in the app. Continued use of the app after changes constitutes acceptance of the new version.

11. CONTACTS

11.1. The Operator is GMD Media FZE LLC. For questions regarding the processing of personal data, contact: support@healthysocial.ai.

© 2026 GMD Media FZE LLC. All rights reserved.