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
Words whose initial letter is capitalized have meanings defined under the following conditions. The following definitions have the same meaning regardless of whether they appear in the singular or 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.
- Application means Frigolo, the software program provided by the Company.
- Company(referred to as "the Company", "We", or "Our" in this Policy) refers to Frigolo.
- Country refers to France.
- Device means any device that can access the Service, such as a computer, a cellphone, or a digital tablet.
- Personal Data means any information relating to an identified or identifiable natural person.
- 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 means data collected automatically, generated by the use of the Service or by the Service infrastructure itself.
- 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.
Collection and Use of 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. This information may include, but is not limited to:
- Email address (via Google authentication)
Application-Specific Data
To provide Frigolo's features, we also collect the following data that you enter into the application:
- The contents of your fridge (added ingredients, quantities, expiry dates)
- Shopping list
- Dietary preferences (vegetarian, vegan, gluten-free diet, etc.)
- Declared allergens
- Declared kitchen equipment
- Generated recipes and generation history
- Badges and progression statistics (gamification)
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as your Device's Internet Protocol address (IP address), browser type, browser version, the pages of our Service that you visit, the date and time of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
When you access the Service through a mobile device, we may automatically collect certain information, including the type of mobile device you use, your mobile device's unique ID, your mobile device's IP address, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data.
When you use the Frigolo mobile app and only if you have consented (a prompt is shown on first launch), we collect usage events (screen opens, additions to the fridge or shopping list, recipe generations, badge unlocks, sign-ins) via our processor PostHog (hosted in the European Union). These events are associated with a pseudonymous user identifier (your Supabase account ID) in order to measure feature adoption and improve the Service. The legal basis is your consent(Article 6.1.a of the GDPR), which you can withdraw at any time from Settings > Privacy in the app, with no impact on how the app works.
Also with your consent (the same prompt), we record a session replay: a visual reconstruction of your navigation in the app (screens shown, gestures), used to identify usability issues. All your text inputs are masked and never appear in these recordings, which are kept for a maximum of 30 days on PostHog's European servers.
Information Collected While Using the Application
While using our Application, in order to provide certain features, we may collect, with your prior permission:
- Images and other information from your Device's camera and photo library
We use this information to provide the features of our Service, in particular ingredient recognition. You can enable or disable access to this information at any time through your Device settings.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including monitoring the use 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 features of the Service that are available to you as a registered user.
- To perform 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 regarding updates or informative communications related to the features, products, or contracted services, including security updates.
- To manage your requests: to attend to and manage your requests to us.
- To generate personalized recipes: your ingredient data, dietary preferences, allergens, and equipment are sent to our artificial intelligence service to generate recipes tailored to your profile.
Service Providers
We may share your Personal Data with the following service providers for the purposes described above:
- Supabase - Database hosting and authentication management (secure storage of your account data and application data).
- Google Gemini (API) - Generative artificial intelligence service used to generate personalized recipes from your ingredients and preferences.
- Resend - Transactional email service (email address confirmation and password reset only).
- PostHog (European Union hosting - Frankfurt, Germany) - Analytics service used to understand how the application is used, measure feature adoption, and improve the Service. PostHog receives interaction events (adding a product to the fridge or shopping list, recipe generation, badge unlock, sign-in, etc.), a pseudonymous user identifier, as well as technical information (device type, operating system, application version). No payment information or private message content is transmitted to PostHog.
Transactional Emails
We use the Resend service to send transactional emails strictly necessary for the operation of your account. These emails include:
- Email address confirmation: an email is sent to you when you create your account to verify that the email address provided belongs to you.
- Password reset: an email containing a secure link is sent to you when you request to reset your password.
We do not send any marketing emails, newsletters, or promotional communications. Your email address is never shared with third parties for commercial or advertising purposes.
In-App Purchases
Frigolo offers a credit purchase system that allows you to generate recipes personalized by artificial intelligence. These purchases are processed via Google Play Billing (Android).
- One free credit is granted when you create your account.
- Additional credits can be purchased directly in the application.
- We do not collect or store any payment information (bank card, bank details). The entire payment process is handled by Google Play.
- We only keep a record of the number of credits purchased and used, associated with your user account.
- Refunds are handled in accordance with Google Play policies. You can contact Google Play directly for any refund request.
Sharing of Your Personal Data
We may share your Personal Data in the following situations:
- With Service Providers: we may share your Personal Data with our Service Providers to monitor and analyze the use of our Service, and to contact you.
- For business transfers: we may share or transfer your Personal Data in connection with any merger, sale of assets, financing, or acquisition of all or part of our business.
- With your consent: we may disclose your Personal Data for any other purpose with your consent.
Retention of Your Personal Data
The Company will retain your Personal Data only for as long as necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
We apply the following maximum retention periods:
- Account information: retained for the duration of your account relationship, plus up to 24 months after the account is closed.
- Usage data: up to 24 months to understand feature adoption and improve the Service.
- PostHog analytics events: up to 12 months. This period corresponds to the retention period applied by our processor PostHog under its free plan, after which the events are automatically deleted.
- Server logs (IP addresses, access times): up to 24 months for security monitoring and troubleshooting.
When the retention periods expire, we securely delete or anonymize the Personal Data.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other place where the parties involved in the processing are located. This means that this information may be transferred to - and maintained on - computers located outside of your country where data protection laws may differ from those of your jurisdiction.
Where required by applicable law, we will ensure that international transfers of your Personal Data are subject to appropriate safeguards. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
Deletion of 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.
Direct deletion from the Application: you can permanently delete your account and all of your data at any time from the My Profile > Settings > Danger zone > Delete my account tab. This action immediately and irreversibly deletes your account, the contents of your fridge, your shopping list, your saved recipes, your preferences, your badges, as well as your analytics event history associated with your user identifier.
Deletion by email: if you no longer have access to the Application, you can contact us at anthony@senan.fr to request the deletion of your account. We will process your request within a maximum of 30 days. Detailed instructions are available on our Account deletion page.
Our Service may also give you the ability to delete certain information about you without deleting your entire account (for example, removing a product from your fridge or a saved recipe).
Please note that we may need to retain certain information when we have a legal obligation or lawful basis to do so (anonymized technical logs for up to 12 months, data required by law for the applicable legal period).
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.
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.
Your Rights (GDPR - General Data Protection Regulation)
If you are located in the European Union or the European Economic Area, you have specific data protection rights under the GDPR.
Legal bases for processing
We process your Personal Data on the following legal bases:
- Performance of a contract: processing is necessary to provide the Service you have requested (fridge management, recipe generation, account management).
- Consent: you have given your consent to the processing of your Personal Data for one or more specific purposes (for example, access to your camera).
- Legitimate interest: processing is necessary for the purposes of the legitimate interests pursued by the Company (improvement of the Service, security).
- Legal obligation: processing is necessary to comply with a legal obligation.
Your rights
Under the GDPR, you have the following rights:
- Right of access: you have the right to obtain confirmation as to whether or not Personal Data concerning you is being processed, and to access that data.
- Right to rectification: you have the right to obtain the rectification of inaccurate Personal Data concerning you.
- Right to erasure: you have the right to obtain the erasure of your Personal Data in certain circumstances.
- Right to restriction of processing: you have the right to obtain the restriction of the processing of your Personal Data in certain circumstances.
- Right to data portability: you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format.
- Right to object: you have the right to object to the processing of your Personal Data in certain circumstances.
- Right to withdraw consent: if processing is based on your consent, you have the right to withdraw it at any time, without affecting the lawfulness of the processing carried out before the withdrawal.
To exercise any of these rights, please contact us by email at the address indicated below. We will respond to your request within 30 days.
You also have the right to lodge a complaint with your local supervisory authority. In France, this is the CNIL (Commission Nationale de l'Informatique et des Libertés).
Children's Privacy
Our Service is not directed to anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us.
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.
Changes to This 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 and updating the "Last updated" date.
We will let you know via email and/or a prominent notice on our Service, before the change becomes effective.
Contact Us
If you have any questions about this Privacy Policy, you can contact us:
- By email: anthony@senan.fr