ReBody Privacy Policy

Effective date: 24 July 2026

Data controller:
Individual Entrepreneur Maksim Maksimovich Vartsibasov
Data contact: support@rebody.tech

EU/EEA representative (GDPR Art. 27): to be appointed; until then, please use the data contact above for any request.

This Policy explains how the ReBody app (the “App”) collects, uses and protects your personal data, including health data. It is designed to comply with the EU General Data Protection Regulation (GDPR), the UK GDPR and Data Protection Act 2018, and — for users in California — the CCPA/CPRA.

1. Data we process

• Account data: email address; with Sign in with Apple — the Apple ID identifier and, if you share it, an email.
• Profile data: name, age/date of birth, sex, height, weight, country, goal, activity level, smoking status — provided by you.
• Health & activity data from Apple Health (HealthKit): heart-rate variability, heart rate and resting heart rate, sleep, steps, workouts, active energy, VO₂max, respiratory rate, mindful sessions. This is a special category of data (GDPR Art. 9). We do NOT read Clinical Health Records.
• Nutrition data: meal photos and text descriptions, computed calories and macronutrients, water intake.
• Technical data required to operate the App.

2. Purposes & legal bases

Your data is used solely to operate the App: computing your energy, recovery, sleep, stress, activity and nutrition scores; generating personalized recommendations and weekly reports; authenticating and maintaining your account; and keeping the service operational and secure. Legal bases: your explicit consent for health data (GDPR Art. 6(1)(a) and Art. 9(2)(a)) and performance of our agreement with you (GDPR Art. 6(1)(b)). We do NOT use your health data for advertising, marketing, ad profiling, sale to third parties, or legally significant automated decisions.

3. Where your data is processed & stored

Your personal data, including health data, is stored on DigitalOcean infrastructure located in London, United Kingdom (managed database and object storage for meal photos and avatars).

Analysis of meal photos and text descriptions is performed by a stateless AI processing service located in Amsterdam, the Netherlands (EU/EEA): your meal image or description is sent there only to recognize the food and compute its nutritional value; the result is returned and stored in the United Kingdom. This service does not retain your data.

For EU/EEA users, the United Kingdom benefits from a European Commission adequacy decision, and the Netherlands is within the EEA — so your data remains within the EEA or an adequate jurisdiction. We do not sell your data or share it for advertising.

4. Storage & security

• Row-level access control so that only your account can access your rows; transport over TLS/HTTPS; authentication tokens stored in the device Keychain.
• Meal photos are deleted automatically after 30 days; your nutrition data (calories/macros) is retained.
• Data is retained for the lifetime of your account, until you delete it or withdraw consent.

5. Your rights

Under the GDPR/UK GDPR you have the rights of access, rectification, erasure, restriction of processing, data portability, and objection, and the right to withdraw consent at any time. You can: delete your account and all associated data directly in the App (Settings → Delete account) — deletion is irreversible; and revoke Apple Health access in iOS Settings at any time. You also have the right to lodge a complaint with your local data protection supervisory authority (in the UK, the Information Commissioner’s Office). California users (CCPA/CPRA) have the rights to know, delete, correct and opt out of “sale”/“sharing” — we do not sell data. To exercise any right, contact support@rebody.tech.

6. Children

The App is not intended for persons under 16 and does not knowingly collect their data.

7. Changes

We may update this Policy. The current version is available in the App and at https://eu.rebody.tech/privacy.

8. Contact

Individual Entrepreneur Maksim Maksimovich Vartsibasov
Data contact: support@rebody.tech