PRIVACY POLICY — SHELEAN

Effective Date: 8th June 2026

This Privacy Policy (“Policy”) is issued by Shelean (“Company”, “we”, “us”, or “our”) in relation to the Shelean mobile application (“App”). This Policy is intended to provide notice, in accordance with applicable data protection laws, including but not limited to the UK GDPR and relevant privacy legislation, regarding the collection, use, disclosure, retention, and safeguarding of Personal Data.

By accessing, downloading, installing, or otherwise using the App, you acknowledge that you have read, understood, and consented to the practices described herein.

1. DEFINITIONS

For the purposes of this Policy:

• “Personal Data” means any information relating to an identified or identifiable natural person.

• “Processing” means any operation performed on Personal Data, whether automated or manual.

• “User” means any individual accessing or using the App.

• “Health Data” refers to sensitive personal data obtained via Apple HealthKit or similar frameworks.

2. CATEGORIES OF DATA COLLECTED

We may collect, store, and process the following categories of Personal Data:

2.1 Data Provided Directly by the User

• Account identifiers (including Apple Sign-In identifiers and/or email address where applicable)

• Demographic and profile attributes (including age, weight, height, and fitness objectives)

• Food intake logs, nutritional tracking data, and dietary records

• Health and fitness-related inputs voluntarily provided by the User

• Photographic content submitted or captured within the App

• Any other content voluntarily submitted through in-App features

2.2 Health and Sensitive Data (Apple HealthKit)

Subject to explicit user consent, the App may access Health Data including, without limitation:

• Energy expenditure (calories burned)

• Activity and movement data

• Step counts and exercise metrics (where available)

Such data is processed strictly for the purpose of providing core App functionality, including but not limited to nutritional analysis and calorie tracking. Health Data shall not be utilised for behavioural advertising or unrelated secondary purposes.

2.3 Camera and Photographic Data

Where permission is granted by the User, the App may access:

• Device camera (for image capture functionality)

• Photo library (for image selection and upload)

Such data is processed solely for App features including food recognition, logging, and related computational analysis.

2.4 Automatically Collected Data

We may automatically collect technical and usage-related information including:

• Device metadata (model, operating system version, hardware identifiers)

• Application usage metrics (feature interaction, session duration, navigation events)

• Diagnostic data including crash logs and performance telemetry

• Network-related data including IP address and approximate geolocation (for security, analytics, and fraud prevention purposes)

2.5 Payment and Subscription Data

All payment processing is conducted via third-party platforms including Apple In-App Purchases and Superwall.

We do not directly collect, store, or process full payment card details.

3. PURPOSES OF PROCESSING

Personal Data may be processed for the following lawful purposes:

• Provision, maintenance, and operation of the App

• Delivery of calorie tracking and nutritional insights

• Generation of AI-assisted outputs and recommendations

• Subscription management and paywall enforcement

• Performance monitoring, debugging, and service optimisation

• Analytical evaluation of usage patterns

• Fraud detection, abuse prevention, and system security

• Delivery of personalised advertising (where applicable and consented)

4. ARTIFICIAL INTELLIGENCE PROCESSING

The App integrates third-party artificial intelligence application programming interfaces (“AI APIs”) for the purpose of generating automated outputs.

Accordingly:

• User inputs may be transmitted to third-party AI service providers for processing

• Such processing is limited strictly to response generation and service functionality

• Personal Data is not sold or used for independent model training outside service provision, where applicable

• AI outputs are generated in an automated manner and may not always be accurate

5. ADVERTISING AND TRACKING

Here's the updated Section 5 with explicit tracking data type disclosure, which satisfies Apple's requirement that your privacy policy specify which data types are used for tracking when NSUserTrackingUsageDescription is present:

5. ADVERTISING AND TRACKING

The App utilises third-party advertising services, including Meta Ads SDK (Facebook and Instagram advertising systems), for the purpose of measuring advertising performance and delivering relevant advertising.

In accordance with Apple's App Tracking Transparency framework, the App will request your permission before "tracking" you, where tracking means linking data collected from the App with data collected from other companies' apps, websites, or offline properties, or sharing such data with a data broker, for purposes of targeted advertising or advertising measurement.

The following categories of data may be used for such tracking purposes, where permission is granted:

• Device identifiers and advertising identifiers (e.g. IDFA)

• Usage data and in-App interaction events (e.g. installs, purchases, subscription events)

• Approximate, coarse geolocation data

• Advertising engagement and conversion metrics

If you do not grant tracking permission, the App will continue to function normally; advertising delivered to you may simply be less relevant, and our ability to measure advertising performance across platforms will be limited.

Such processing is governed by the respective third-party privacy policies, including that of Meta Platforms, Inc.

Users may grant, deny, or revoke tracking permission at any time via device-level settings, including: iOS Settings → Privacy & Security → Tracking, or by responding to the in-App tracking permission prompts

6. THIRD-PARTY SERVICE PROVIDERS

We engage the following categories of third-party processors:

• Supabase (backend infrastructure, authentication, and data storage)

• Meta Ads SDK (advertising and analytics)

• Superwall (subscription management and paywall infrastructure)

• AI API Providers (automated content generation and inference services)

• Apple HealthKit (health and fitness data integration, subject to consent)

Each third party operates under its own independent privacy terms.

7. DATA STORAGE AND SECURITY

Personal Data may be stored using a combination of:

• Secure cloud-based infrastructure (including Supabase)

• Local device storage on the User’s device

We implement commercially reasonable technical and organisational safeguards designed to protect Personal Data against unauthorised access, disclosure, alteration, or destruction. However, no method of transmission or storage is entirely secure.

8. DISCLOSURE OF DATA

We do not sell Personal Data.

We may disclose Personal Data only under the following circumstances:

• To authorised service providers acting on our behalf

• To comply with applicable legal obligations or lawful requests

• To enforce our rights, prevent fraud, or ensure App security

9. DATA RETENTION

Personal Data is retained only for as long as necessary for:

• The provision of App services

• Compliance with legal and regulatory obligations

• Legitimate operational and security purposes

Users may request deletion of Personal Data subject to applicable legal requirements.

10. USER RIGHTS

Subject to applicable data protection laws (including UK GDPR where applicable), Users may be entitled to:

• Request access to Personal Data

• Request rectification of inaccurate Personal Data

• Request erasure of Personal Data

• Withdraw consent at any time where processing is based on consent

• Request restriction or portability of data where applicable

11. ACCOUNT TERMINATION AND DELETION

Users may request account deletion at any time via in-App functionality or by contacting us directly.

Upon deletion:

• Personal Data associated with the account shall be removed from active systems

• Certain anonymised or aggregated data may be retained for analytical purposes where legally permitted

12. CHILDREN’S PRIVACY

The App is not intended for individuals below the age of digital consent as defined by applicable jurisdictional law (including but not limited to 13 years of age in certain jurisdictions).

We do not knowingly collect Personal Data from children.

13. AMENDMENTS

We reserve the right to amend or update this Policy at any time. Any changes shall be communicated by updating the “Effective Date” and, where required, via in-App notification mechanisms.

Continued use of the App following such amendments constitutes acceptance of the revised Policy.

14. CONTACT INFORMATION

For any enquiries relating to this Privacy Policy or data subject rights, you may contact:

Email: ribhi1100@gmail.com