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Privacy Policy & Data Retention Practices

App: GetFlow — Nutrition & Fitness Tracker (com.totsrl.getflo)
Data Controller: T.O.T. Software S.R.L. | Official Support: supportgetflow@gmail.com
Effective Date: October 2026

This Privacy Policy explains how GetFlow ("we", "our", or "the App"), developed and operated by T.O.T. Software S.R.L., collects, processes, protects, and retains your personal and health-related data in full compliance with the European Union General Data Protection Regulation (GDPR - Regulation EU 2016/679), UK GDPR, the EU AI Act (Regulation EU 2024/1689), United States state privacy and consumer health data laws (including the Washington My Health My Data Act, Nevada SB 370, CCPA/CPRA), the FTC Health Breach Notification Rule, and Google Play Developer Policies.

1. Age Requirement: Adults Only (18+)

GetFlow is strictly designed and offered exclusively to individuals who are at least 18 years of age. We do not offer our services to minors, nor do we knowingly collect or solicit personal data or health metrics from anyone under the age of 18. If we become aware that personal data of a person under 18 has been collected, we will take immediate steps to permanently delete such information from our systems.

2. Categories of Information We Collect

To provide personalized nutritional tracking, workout planning, AI meal analysis, and fitness metrics, GetFlow processes the following data categories:

3. Legal Bases for Processing (GDPR & UK GDPR)

We process your personal data under the following legal bases:

4. Data Retention and Deletion Practices

In accordance with Google Play User Data policies, our explicit data retention and disposal practices are defined as follows:

  • Active Account Data: Stored while your account remains active to provide continuous progress tracking.
  • Permanent Account Deletion (30-Day Purge): You may permanently delete your account at any time in-app (Profile → Data & Privacy → Delete Account Permanently) or by emailing supportgetflow@gmail.com. Upon request, all personal identifiers, profile data, dietary logs, fitness history, and credits are permanently and irreversibly purged from our database within 30 calendar days.
  • Meal Photo Cleanup: When you delete your account, all associated food images stored on ImageKit CDN are permanently removed.
  • Health Connect Step Data: Cached locally on your device for immediate display; never transmitted to our external databases and can be cleared instantly via device settings or app uninstall.
  • Ephemeral AI Queries: Images and text queries sent to Google Gemini for AI meal recognition are processed ephemerally solely to return nutritional analysis. Google does not use your food images to train foundation models under commercial API developer terms.
  • Diagnostics Retention: Anonymized crash logs on Sentry are retained for a rolling maximum of 90 days before automated deletion.

5. Google Health Connect Policy Disclosure

GetFlow's use of data received from Google Health Connect adheres to the Google Health Connect Permissions Policy, including Limited Use requirements:

6. United States Consumer Health Data & State Privacy Notice

This section applies to residents of Washington (under the Washington My Health My Data Act, RCW 19.373), Nevada (under Nevada SB 370), California (under CCPA/CPRA), Connecticut, Texas, Virginia, and other US states with enacted privacy laws:

7. FTC Health Breach Notification Rule Compliance

GetFlow is a direct-to-consumer health and wellness application and vendor of personal health records (PHRs) subject to the Federal Trade Commission (FTC) Health Breach Notification Rule (16 CFR Part 318). GetFlow is not a covered entity or business associate under HIPAA. In the unlikely event of an unauthorized acquisition of unsecured identifiable health data, GetFlow will notify affected individuals and the FTC in accordance with statutory requirements without unreasonable delay.

8. AI Transparency & Safety (EU AI Act Art. 50)

GetFlow Coach is an artificial intelligence assistant designed to offer general nutrition and fitness suggestions. It is NOT a medical doctor, licensed dietitian, or healthcare professional. Coach suggestions are for informational and educational purposes only and do not constitute clinical medical advice or diagnosis.

9. European Accessibility Act (Directive EU 2019/882)

T.O.T. Software S.R.L. is a microenterprise under European Commission Recommendation 2003/361/EC (employing fewer than 10 persons with annual turnover under EUR 2,000,000), qualifying for the statutory microenterprise exemption under Article 4(5) of Directive (EU) 2019/882. Regardless of exemption, GetFlow adheres to high accessibility standards, including scalable text, screen reader labels, and reduced motion settings.

10. Third-Party Service Providers (Subprocessors)

We work exclusively with vetted infrastructure providers bound by Data Processing Addenda (DPAs) and Standard Contractual Clauses (SCCs):

11. Contact Information

For any questions, requests, or to exercise your GDPR or US privacy rights:

Email: supportgetflow@gmail.com
Company: T.O.T. Software S.R.L.
Country: Romania, European Union