Privacy Policy

Important notice: Fomo, Penseor's first product, is currently in a closed testing phase. The app is accessible by invitation only and is not yet publicly available. Data collected during this phase is limited to invited testers and is handled in accordance with this Privacy Policy.

1. About This Policy

Penseor Inc. (‘we’, ‘our’, ‘us’) operates human nutrition and wellness products. We take your privacy and health data seriously. This Privacy Policy applies to all users of the Penseor Inc. mobile application (iOS and Android) and any related services.

By using products, you agree to the collection and use of information as described in this Policy. If you do not agree, you can choose o discontinue use of the App.

This Policy is designed to comply with applicable laws Including India’s Digital Personal Data Protection (DPDP) Act 2023, the Information Technology Act 2000 and IT Rules 2011, GDPR (EU/UK), CCPA (California), PIPEDA (Canada), HIPAA (where applicable), and the health data requirements of the Apple App Store and Google Play Store.

2. Information We Collect

2.1 Health & Personal Information You Provide

When you create your profile or use the App, we collect:

Basic profile: name, email address, gender, and location
Health metrics: height, weight, body composition, fitness goals, dietary restrictions and preferences
Medical context: allergies, diagnosed health conditions, medications (optional, provided voluntarily)
Food logs: meals, snacks, water intake, and nutrient data you manually enter or scan
Activity data: exercise logs, step count, sleep patterns (if integrated with wearables)

2.3 Third-Party Integrations (Optional)

If you choose to connect third-party apps or devices:

Apple Health / Google Fit: activity, heart rate, sleep, biometric data
Wearable devices (Fitbit, Garmin, Oura, etc.): fitness and biometric metrics
Food databases: USDA, Open Food Facts for nutritional lookups

You might revoke these integrations at any time through your device's settings.

2.2 Automatically Collected Data

We automatically collect certain technical and behavioral data when you use our product:

Device information: device type, OS version, app version, device identifiers
Usage analytics: features accessed, screens viewed, session duration, button interactions, crash logs
Performance data: response times, error rates, feature adoption metrics
Location data: country/region (for regulatory compliance and local food databases not precise GPS unless you grant permission)

3. How We Use Your Data

3.1 Personalized Nutrition & AI conversations

The core purpose of Penseor Inc. is to provide nutrition guidance. We use your data to:

Build and continuously refine your individual AI nutrition model
Generate personalized meal plans, food recommendations, and portion suggestions
Provide contextual chat responses informed by your full health profile and conversation history
Identify nutritional gaps, patterns, and trends in your dietary behavior
Adapt recommendations over time as your health goals and body metrics change

3.3 Product Improvement & Analytics

Like all digital services, we analyze how users engage with our platform to improve the product:

Aggregate feature usage analytics (which features are used most, onboarding drop-off points)
App performance monitoring (crash reports, load times, API error rates)
User feedback and ratings you voluntarily provide
A/B testing of new features using anonymized or pseudonymized data

We use de-identified and aggregated data wherever possible. We do not sell your individually identifiable health data to third parties.

Chat History & Memory

To provide continuity across sessions, your chat history with the AI coach is stored securely in your Penseor account database (Supabase, encrypted at rest) for up to 30 days. After 30 days, chat history is automatically and permanently deleted from our servers.

You can at any time:

View your full chat history in the app
Download a copy of your chat history (JSON) from Settings
Permanently delete all chat history from Settings

Chat data is stored in your personal account only, is never used for AI training, and is never shared with third parties. Deleting your account permanently removes all chat history immediately.

3.4 Communications

We use your email to send you:

Account and service notifications (password resets, policy updates)
Weekly nutrition insights and progress summaries (opt-in)
In-app messages from your AI coach

You can manage communication preferences in Settings

4. Your Data Rights & Controls

Your Rights at a Glance

Download your data — export your health profile and food log data. Chat history can be downloaded separately from Settings → Security & Data
Delete your data - permanently delete your account and all associated data
Manage AI chat history — view, download, or permanently delete your conversation history from Settings → Security & Data
Correct your data - update or correct inaccurate health information
Data portability - receive your data in a machine-readable format.

5. Use of Cookies

5.1 What Are Cookies?

A cookie is a small file containing a piece of information that is sent between web pages and stored on your device by your web browser.

Cookies allow websites to recognise that you have visited before and to remember certain preferences or actions. Standard cookies are anonymous, they do not store personally identifiable information on their own.

5.3 How Can You Manage Cookies?

You have full control over cookies. If you prefer not to allow Penseor Inc's products to use cookies, you can:

Remove existing cookies from your device via your browser settings
Configure your browser to block cookies altogether, or to prompt you before accepting cookies from specific websites

You can also opt out of specific data collection programmes:

1. Google Analytics Advertising

Visit google.com/settings/ads and adjust your personal ad settings.

2. Google DoubleClick / Ads

Download the opt-out plugin at google.com/settings/ads/plugin (Chrome, Firefox, Safari)

3. Behavioural Advertising (General)

Visit youronlinechoices.com for guidance on managing behavioural advertising preferences

4. Cookie Information (General)

Visit aboutcookies.org for instructions on deleting and controlling cookies

Please note: disabling certain cookies may affect the functionality of our products. Some cookies are essential for the platform to operate correctly and cannot be disabled without impacting your experience.

5.2 How Does Penseor Inc Use Cookies?

Penseor Inc uses cookies and similar technologies to improve your experience of our products/ services and to help us understand how our product is being used. Specifically:

Website & App

We use session cookies to recognise your device as you navigate through the apps and to retain any information you have entered, such as search or filter preferences, for the duration of your session.

Measuring Web & App Traffic

We use analytics programmes such as Google Analytics to help us understand:

• How many users visit products and when

• Which features and screens are most frequently used

• How long users spend in each area of the app

• What content users are searching for

These insights allow us to improve product’s design and performance. Google Analytics uses cookies to collect non-personally identifiable information, including browser types, operating systems, referring sources, and visit timestamps.

Advertising & Retargeting

We may use advertising tools to display product promotions on other platforms you use. These tools may set cookies to measure the performance of our campaigns and to show you content that is relevant to your interests.

We may also use Google Analytics Advertising features, including remarketing and Display Network retargeting, to better understand our audience and to reach users who may benefit from our products.

We do not use advertising cookies to share your personal health data with advertisers. Health data collected within portfolio of our products is never used for advertising purposes.

6. Commercial or Business Purposes for Collecting Personal Data

6.1 Providing, Customizing and Improving the Services

Account & Service Delivery

We use your Personal Data to create and manage your account, process transactions and billing, and deliver the products, services, and information you request. This includes fulfilling the specific reason you provided your information, offering support, and ensuring the Services function as intended.

Improving & Personalizing the Services

We continuously work to enhance your experience. This involves testing, research, internal analytics, and product development, as well as personalizing content, website experiences, and communications based on your preferences. We also use your data for fraud protection, security monitoring, and debugging.

Marketing the Services

We may use your Personal Data to market and promote our Services, including showing you relevant advertisements and interest-based or behavioral advertising where applicable.

Corresponding with You

We use your information to respond to your messages, reach out when necessary, and keep you informed about products and our Services. This includes sending emails and other communications tailored to your preferences or featuring content we believe may be relevant to you.

Meeting Legal Requirements & Enforcing Legal Terms

We may use your Personal Data to comply with applicable laws, regulations, court orders, or other legal processes - including the prevention and investigation of security incidents and potentially unlawful activity. This also covers protecting the rights, property, and safety of you, Penseor Inc or others; enforcing our agreements; addressing third-party rights claims; and resolving disputes. Our practices are guided by applicable data privacy frameworks, including India's DPDP Act 2023, the Information Technology Act 2000 and IT Rules 2011, GDPR (EU/UK), CCPA (California), PIPEDA (Canada), and HIPAA where applicable.

6.3 Service Providers

Supabase provides our backend database and authentication infrastructure. Your health profile, food logs, activity data, and chat history are stored in Supabase, hosted on AWS. All data is encrypted at rest and protected by row-level security. Supabase acts as a data processor under GDPR and DPDP, bound by a Data Processing Agreement.

Anthropic (Claude AI) serves as the engine behind chat responses. Conversation inputs are shared with Anthropic in rea€l time to generate responses. Anthropic does not retain your data for their own purposes by default, subject to Anthropic's API usage policies.

Cloud Infrastructure (AWS/GCP) is used for app hosting and data storage. All app data is encrypted at rest.

An Analytics Platform supports product usage analytics, with only pseudonymized usage events shared to protect user privacy.

An Authentication Provider handles secure login. Email addresses and account identifiers are shared to verify and manage user access.

Payment Processor - We use a third-party payment processor to handle subscription billing securely. When you purchase a subscription, your payment details (such as card number and billing address) are entered directly into the payment processor's secure system. Penseor never sees, stores, or has access to your full payment card details. Only the information necessary to process your payment is shared with this provider. No health data, nutrition logs, or personal profile information is ever shared with or accessible to our payment processor.

6.5 Legal Disclosures

Where necessary, we may share your Personal Data with third parties to comply with legal obligations or protect our legal rights.

6.2 How We Share Your Personal Data

We disclose your Personal Data to the categories of parties described below. Depending on the data privacy laws applicable in your state, some of these disclosures may be considered a "sale" of your Personal Data. Please refer to the state-specific sections of this policy for further details.

Service Providers

We work with third-party service providers who help us operate the Services or carry out business functions on our behalf. These include hosting, technology, and communication providers; security and fraud prevention consultants; analytics providers; customer support vendors; and product fulfillment and delivery partners.

Business Partners

Certain third parties partner with us to offer or enhance our Services. This includes businesses engaged in medical and health research (including research related to the Services), companies with whom you already have an existing relationship, and partners with whom we collaborate to offer joint promotions or opportunities.

Parties You Authorize, Access, or Authenticate

In some cases, you may choose to connect with or grant access to third parties directly through the Services. This includes third-party platforms or tools you access via the Services, social media services, and other users of the platform.

6.4 We Never Sell Your Health Data

Penseor Inc. does not sell, rent, or broker your personal health information to advertisers, data brokers, insurance companies, or any other commercial third parties. Your health data is used exclusively to provide and improve the Penseor Inc. service.

6.5 Business Transfers

In the event of a merger, acquisition, bankruptcy, or similar transaction in which a third party assumes control of our business - whether in whole or in part - your Personal Data may be transferred as part of that process. Should such an event occur, we will make reasonable efforts to notify you before your information becomes subject to new or different privacy and security practices.

7. Security and Data Retention

Security

We take the protection of your Personal Data seriously. We implement appropriate physical, technical, organizational, and administrative safeguards tailored to the type of data we process and how it is handled. You can also play a role in keeping your data secure by choosing a strong password, limiting access to your devices and browser, and signing out of your account when you are finished.

While we are committed to protecting your information, please be aware that no method of transmitting or storing data online is entirely without risk. We encourage you to take reasonable precautions on your end as an added layer of protection.

Data Retention

We retain your Personal Data for as long as your account remains open or as otherwise needed to provide you with our Services. In certain circumstances, we may retain data for a longer period - for example, to comply with legal obligations, resolve disputes, or collect outstanding fees, or where retention is otherwise permitted or required by applicable law.

Where appropriate, we may also retain information in an anonymous or aggregated form that cannot be used to identify you personally.

8. Personal Data of Children

Our Services are not intended for children under the age of 18. As outlined in our Terms of Use, we do not knowingly collect or solicit Personal Data from anyone under 18, and we ask that minors do not attempt to register for or use our Services, or submit any Personal Data to us.

If we become aware that we have inadvertently collected Personal Data from a child under 18, we will take prompt steps to delete that information. If you believe a child may have provided us with their Personal Data, please reach out to us at contact@penseor.com.

9. Artificial Intelligence & Claude AI Disclosure

Penseor Inc uses Claude AI, developed by Anthropic, to power our AI coaching feature. Your conversation inputs are sent to Anthropic's API in real time to generate responses. Anthropic does not retain your data for their own purposes by default, subject to Anthropic's API usage policies.

Chat history is stored in your Penseor account for up to 30 days and then automatically deleted - see Section 3 for full details.

AI responses are not a substitute for professional medical or dietitian advice. Always consult a qualified healthcare professional for medical decisions. You can speak to a human member of our team at any time by contacting contact@penseor.com.

10. Access and Deletion

Access

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You have the right to request a full account of how we have collected and used your Personal Data over the past 12 months. Upon a verified request, we will tell you which categories of Personal Data we have collected about you and where that data came from, the business or commercial purpose for collecting it, which third parties we have shared it with, and the specific pieces of Personal Data we hold on you.

Where we have disclosed your Personal Data to third parties for a business purpose, we will identify both the data shared and the type of recipient it was shared with. Likewise, if any of your Personal Data has been sold, we will clearly identify what was sold and to whom.

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Deletion

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You have the right to request that we delete the Personal Data we have collected about you. We will honor such requests wherever we are able to do so, however certain exceptions apply under the laws mentioned above. In some cases, we may need to retain your data in order to complete a transaction, fulfill a service you have requested, or meet other legal obligations. Where an exception applies, we will explain why your request cannot be fully accommodated.

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11. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you via in-app notification and email at least 30 days before the changes take effect. Your continued use of the App after the effective date constitutes your acceptance of the updated policy. Previous versions of this policy are available upon request.

12. Contact Us

For privacy questions, data requests, or concerns:

Support :

contact@penseor.com

Mail us :

Penseor Inc.

Suite 281,

#100, 111 - 5 Ave SW,

Calgary, AB T2P3Y6