Privacy Policy

1. Data Controller

kerntrack is operated by:

MindDev53
Owner: Umekulsum Muffadal
Emmastraße 25
45130 Essen
Germany
Email: support@kerntrack.de

A Data Protection Officer is currently not required under Art. 37 GDPR / § 38 BDSG, as all health data is processed exclusively locally on your device and no large-scale server-side processing of special categories of data takes place. Please direct privacy inquiries to: support@kerntrack.de

2. Overview: Your Data Belongs to You

kerntrack stores all health and nutrition data exclusively on your device. We have no access to this data, unless you explicitly enable an optional cloud backup in the future.

We do not use any advertising SDKs, no Facebook SDK, no Google Analytics, and no other tracking services that process your health data.

3. What Data Is Processed?

a) Locally on your device (SQLite database):

• Name and age
• Height and weight
• Nutrition goal (lose / maintain / gain)
• Daily calorie target
• Food entries (meals, calories, macronutrients)
• Weight history (entered by you or, if connected, imported automatically from a smart scale)
• Water intake
• Activity level and the weekly plan for your daily target (calculated from your answers and, if connected, from wearable data)
• Reminder settings (enabled reminders, times, contents of the daily check)

If you use COACH mode, additionally, also exclusively local:

• GLP-1 companion mode: medication name, dose in mg, date and injection site of every logged injection, and your notes on it
• GLP-1 side effects: your daily entries for nausea, constipation, fatigue, headache, vomiting, diarrhoea and heartburn, plus free-text notes
• Tolerance markers on individual foods (“tolerated” / “problematic”)
• Intermittent fasting: start and end times of your fasting periods, the chosen protocol and the history
• Coach mode settings (e.g. protein and water targets, eating window, calorie cycling)
• Locally computed analyses derived from this data (weekly insights)

This list is not exhaustive: if further features are added, the data they require will likewise be stored exclusively on your device.

Information about medication and side effects is particularly sensitive health data within the meaning of Art. 9 GDPR. That is precisely why it does not leave your device: kerntrack transmits it to no server, no processor and no health insurer. You alone decide whether to share it via the PDF/CSV export; in which case the file is passed on by you, not by us.

This data is NOT transmitted to our servers. It does not leave your device.

Reminder notifications are scheduled and displayed exclusively locally on your device; no data is transmitted to servers. Optionally, you can enable discreet notification texts so that no health-related terms appear on your lock screen.

b) Optional user account (Supabase, EU / Frankfurt):

• Email address
• Authentication tokens (encrypted)

If you create an account, only your email address is stored on servers in the EU (Frankfurt, Germany). Processing is based on Art. 6(1)(b) GDPR (performance of a contract).

You can delete your account at any time directly in the app (Profile → Account → "Delete account") or request deletion at kerntrack.de/konto-loeschen. This permanently removes your account, your email address, your support requests and the AI usage counter from our servers. Active subscriptions are not cancelled by this; manage and cancel them via Google Play. The email copy of your support requests in our support mailbox is not technically covered by this; we delete it on request, at the latest 90 days after the matter is closed, and in any case no later than 365 days after receipt.

c) API requests to Open Food Facts:

When you search for foods or scan a barcode, a request is sent to the Open Food Facts API (https://world.openfoodfacts.org). Your search term or barcode is transmitted, along with your IP address, technically required for every internet request. No other personal data is transmitted. Open Food Facts is an open, non-profit project (ODbL license).

d) AI Photo Recognition (Google Gemini API, PRO only):

When you use AI photo recognition (PRO feature), your photo is forwarded via a kerntrack server (Supabase Edge Function, EU / Frankfurt) to the Google Gemini API (Google LLC, Mountain View, USA). The photo is sent solely for the purpose of food recognition and is not stored on our server; for abuse and cost control we store only the number of your daily AI requests (user identifier, date, counter). Further data processing by Google is governed by Google Gemini API terms of service. Your photo leaves your device storage and is transferred to servers outside the EU/EEA.

Processing is based on your explicit consent (Art. 6(1)(a) GDPR), obtained in the app before the feature is first used; without it no photo is sent. The transfer to the USA relies on the European Commission’s adequacy decision for the EU-US Data Privacy Framework (Implementing Decision (EU) 2023/1795); Google LLC is certified under that framework. You can withdraw consent at any time by no longer using the feature or by clearing the app’s data. For more information on data processing by Google, see https://policies.google.com/privacy.

If you do not wish to use this feature, simply don't use AI photo recognition. All other app functions are unaffected.

e) Payment Processing and Subscription Management (RevenueCat):

For managing in-app subscriptions, we use RevenueCat, Inc. (San Francisco, USA). RevenueCat processes only purchase data (transaction IDs, subscription status, device type); no health data. Legal basis: Art. 6(1)(b) GDPR (performance of a contract). Data transfer: USA, secured by EU Standard Contractual Clauses (SCCs). For more information: https://www.revenuecat.com/privacy

f) Crash Reporting (Sentry):

To detect and fix app crashes, we use Sentry (Functional Software, Inc.) with data processing in the EU. When the app crashes, only technical details are transmitted: device model, operating system version, app version, error message, and stack trace. Health and nutrition data are never included; network and console contents are removed before sending. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a stable app). Crash data is automatically deleted after 90 days. For more information: https://sentry.io/privacy/

g) Wearable sync (PRO only, optional):

When you connect a wearable, kerntrack reads health data. This is health data within the meaning of Art. 9 GDPR. The legal basis is your explicit consent (Art. 9(2)(a) GDPR), which you can withdraw at any time by disconnecting in the app or revoking the permission.

Health Connect (Android): Health Connect is an interface on your Android device. kerntrack reads the data directly on the device; there is no transfer to Google or to us, and no account and no access token are required. The following are read: steps, active calories, heart rate, sleep duration and weight. The data is stored exclusively locally in the app database and does not leave your device. You can revoke access at any time in your device's Health Connect app, individually per data type.

Oura Ring: Oura requires a connection to the servers of Oura Health Oy (Finland, EU). Credentials are exchanged via a kerntrack server (Supabase Edge Function, EU) but are not stored there; on your device they are stored encrypted. The retrieved values are likewise stored only locally. Processing by Oura is governed by its own privacy policy.

Use: From this data kerntrack calculates your activity level, your daily target and your insights. The calculation happens entirely on your device. Health data from wearables is never transmitted to our servers, to analytics services or to third parties.

Deletion: Disconnecting deletes the credentials. “Delete all data” and account deletion remove all wearable data from your device.

h) Support requests:

If you use the contact form in the app, your details (category, name (optional), email address, message, device information) are stored on servers in the EU (Supabase, Frankfurt) to process your request. Legal basis: Art. 6(1)(b) or (f) GDPR. The data is deleted automatically 30 days after your request is resolved (the window covers follow-up questions and refund disputes); unresolved requests are deleted after 365 days at the latest. If you delete your account, your requests are removed immediately. In addition, the content of your request is forwarded by email to our support mailbox (support@kerntrack.de, Zoho Mail, EU) so that we can reply to you. For this we use Resend, Inc. (USA) as a processor; the same basis described in section 3i, secured by EU Standard Contractual Clauses (SCCs). Your sender address is set as the reply address. The email copy remains in the support mailbox until the matter is closed and is deleted at the latest 90 days thereafter, and in any case no later than 365 days after receipt. We delete it earlier on request.

i) Announcements and service emails:

We display important product announcements in the app. If you have an account, we may additionally inform you by email about material changes. For sending, we use Resend, Inc. (USA) as a data processor; recipient addresses are always hidden (BCC). Data transfer to the USA is secured by EU Standard Contractual Clauses (SCCs). Legal basis: Art. 6(1)(b) GDPR (performance of a contract) or (f) GDPR (legitimate interest in informing you about material changes). For more information: https://resend.com/legal/privacy-policy These emails are purely service messages about material changes, not advertising; we do not collect a marketing consent. Where sending is based on Art. 6(1)(f) GDPR, you may object at any time under Art. 21 GDPR, informally by email to support@kerntrack.de. We will then stop emailing you; important notices remain visible in the app. Alternatively you can delete your account, which removes your email address entirely.

j) Photo contributions to Open Food Facts (optional):

If a scanned barcode is not found in the database, you can photograph the product and voluntarily contribute it to the public Open Food Facts database (Open Food Facts, non-profit association, France). What is transmitted: your product photos, the barcode, and a randomly generated device identifier (no link to your name or account). The purpose is to expand the public food database. Legal basis: your consent for each transfer (Art. 6(1)(a) GDPR).

Important: the photos are published on Open Food Facts under an open license (ODbL) and become part of a globally public database; later deletion there is de facto no longer fully possible. Therefore, photograph only the product packaging, no people or private objects. Before transfer, an automatic pre-check (Google Gemini, via our EU server as described in section d) verifies that the image shows product packaging; unsuitable images are rejected and not forwarded to Open Food Facts. The transfer to Open Food Facts is routed through a kerntrack server; your IP address is not transmitted to Open Food Facts. For abuse control, we store the number of your daily contributions (device identifier, date, counter); no photos. For assistance with deletion requests for already-published photos, contact support@kerntrack.de.

k) This website (kerntrack.de):

This website is delivered via Cloudflare Pages (Cloudflare, Inc., USA). When you visit, Cloudflare processes technically necessary connection data (in particular your IP address) to deliver the site and protect against attacks. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure, performant delivery); third-country transfer secured by EU Standard Contractual Clauses (SCCs). This website does not set cookies and uses no tracking or analytics services. For more information: https://www.cloudflare.com/privacypolicy/

4. Legal Basis (GDPR)

• Art. 6(1)(a) GDPR (Consent): You consent to local processing of your health data during initial setup.
• Art. 6(1)(b) GDPR (Performance of a contract): For providing app functionality.
• Art. 6(1)(f) GDPR (Legitimate interest): For crash reports (Sentry), service notifications, and the technical delivery of this website.
• Art. 9(2)(a) GDPR (Explicit consent): Health data is a special category of personal data. You provide explicit consent during onboarding (step 4) or when connecting a wearable.

5. Data Storage and Deletion

Local data:

You can permanently delete all data at any time via Profile → "Delete all data". Uninstalling the app also deletes all locally stored data.

Retention periods at a glance:

6. Data Export

You have the right to data portability (Art. 20 GDPR). Data export in CSV and PDF format is available directly in the app (Coach → Export; included in the COACH plan). Independently of that, you can request a copy of the data we hold (essentially your email address) informally by email at any time.

Backup file: You can additionally export your data manually as a backup file (Profile → Data & Privacy). The file is encrypted on your device with a password only you know; we have no access to it and can neither reset it nor restore the file without it. Where the file goes is your decision (for example a cloud storage of your choice, or a folder on your device); where a cloud provider is involved, that provider is responsible for the processing there.

7. Your Rights

Under the GDPR, you have the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to withdraw consent (Art. 7(3) GDPR)

Since your health data is stored exclusively on your device, you can exercise most rights yourself (view, modify, delete data).

For requests regarding your account or other privacy concerns, contact: support@kerntrack.de

8. Right to Complain

You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The responsible authority is typically the authority in your German federal state.

9. Minors

kerntrack is intended exclusively for persons aged 18 and older. The app is not intended for minors; only adults may create an account. Age is requested during sign-up and use below 18 is refused.

10. Changes to This Privacy Policy

We reserve the right to update this privacy policy when app functionality or legal requirements change. The current version is always available in the app under Profile → Privacy.

11. Not a Medical Device

kerntrack is not a medical product and not a medical device within the meaning of Regulation (EU) 2017/745 (MDR). The calculated calorie targets do not replace medical or nutritional advice.