Privacy Policy & Information Notice
At CaloriPanda (the "Application", "we"), we value your privacy. This text is an information notice under Article 10 of Turkey's Personal Data Protection Law No. 6698 ("KVKK"): a one-way notification explaining which personal data we process, for which purposes and on which legal grounds, with whom we share it, and your rights under KVKK.
Explicit consent is separate. The explicit consent required for your special-category health data is obtained through a separate Explicit Consent Text, in the app, before you enter the relevant data. Pursuant to the Turkish DPA Board's Principle Decision No. 2026/347, the information notice and explicit consent are separate texts; this page does not collect consent, it only informs.
1. Data Controller
Your personal data is processed by CaloriPanda in its capacity as data controller. Contact: info@caloripanda.com; for KVKK-related requests, kvkk@caloripanda.com. The data controller is Eyüp Sabri Şirin (Uşak, Türkiye).
VERBIS: The data controller is currently exempt from the obligation to register with the Data Controllers' Registry (VERBIS) under the micro-enterprise exemption in the Turkish DPA Board's Decisions No. 2025/1572 and 2025/2393; therefore no VERBIS registration number exists. This notice will be updated if that status changes.
2. Personal Data We Process
- Account data: your email address and (if you choose) your name; and the basic identity information provided by the relevant provider when you sign in with a third party.
- Profile data: your gender, age, height, weight, activity level, goal, and your calorie/macro targets.
- Health data (special category): your weight and body measurements, your goals, and, if you declare them, conditions such as pregnancy/breastfeeding or diabetes. This data is considered special category under KVKK Article 6 and is processed only with your explicit consent.
- Content data: the food photos you take for meal tracking and the meal/water/weigh-in records you enter.
- Usage and technical data: device type, application version, crash logs, and anonymous/statistical data about how features are used.
3. Health Data and Separate Explicit Consent
Your weight and body measurements, your goals, and — if you declare them — your pregnancy/breastfeeding or diabetes status are special category personal data under KVKK Article 6 and are processed solely on the basis of your explicit consent. This explicit consent is obtained through a separate Explicit Consent Text, in the app, before you enter the relevant data; you can withdraw it at any time and delete your account and data (see Section 10). Declaring pregnancy/breastfeeding and diabetes is optional; the Application's core calorie tracking works even if you do not provide them.
4. Purposes for Which We Process Data
- To provide the calorie and nutrition tracking service; to perform food recognition from photos and to produce portion/calorie estimates.
- To calculate your daily calorie and macro targets from your profile; to display your progress, streak, and water tracking.
- To create your account, manage your session, and handle support requests.
- To improve the Application, fix errors, and ensure security.
- To carry out subscription/purchase transactions.
5. Legal Basis for Processing
Your data is processed on the following legal grounds under KVKK Articles 5 and 6:
- Your health data (special category): your explicit consent only (Art. 6). Special category data cannot be processed on the basis of legitimate interest.
- Account, profile and provision of the service: the conclusion or performance of a contract (Art. 5/2-c).
- Security, error handling and legal obligations: compliance with a legal obligation (Art. 5/2-ç) and — for non-special-category data only — legitimate interest (Art. 5/2-f).
- Waitlist email: your explicit consent (Art. 5).
6. Sharing of Data
We do not sell your data. In order to provide the service, to the extent necessary and in the capacity of data processors, we may share data with providers in the following categories:
- Cloud infrastructure and database/storage provider,
- Artificial-intelligence-based image analysis (food recognition from photos) provider — the photo you upload is transmitted only for the recognition process and is not permanently stored by us,
- Analytics and error-monitoring providers,
- Subscription/payment infrastructure providers (including the App Store / Google Play).
In addition, data may be shared with authorized public authorities in the event of a legal obligation. (The definitive list of providers used will be finalized before publication.)
7. Transfer Abroad
The servers of some of the service providers we use are located abroad (including the European Union and the USA); your personal data is therefore transferred abroad. As Türkiye has not issued an "adequacy decision" for any country, all cross-border transfers — including transfers to servers in the European Union — are carried out on the basis of appropriate safeguards (primarily the standard contract published by the DPA Board) under KVKK Article 9. The legal basis for these continuous and systematic transfers is the standard contract; the transfer abroad does not rely on your explicit consent.
8. Retention Period
We retain your data for as long as your account is active and for the periods required by the relevant legislation. When you delete your account, your personal data is deleted or anonymized within a reasonable time, without prejudice to legal retention obligations.
9. Data Security
To protect your data, we apply administrative and technical measures, including encryption in transit and at rest. You can permanently delete your account and all your data using the "Delete account" option within the Application.
10. Your Rights Under KVKK
Pursuant to KVKK Article 11, you have the right to learn whether your personal data is being processed, to request information if it has been processed, to learn whether it is used for its intended purpose, to request that it be corrected if processed incompletely/incorrectly, to request its erasure or destruction, to object to processing, and to request that any resulting damage be remedied. You can submit your requests to kvkk@caloripanda.com (or info@caloripanda.com); your request will be concluded free of charge within 30 days at the latest.
11. Analytics and Cookies
Our website uses only the technical/strictly-necessary cookies required for the site to function; it does not use third-party analytics or marketing tracking cookies, so there is no cookie that additionally requires consent. If such cookies are added in the future, a cookie notice requesting your active consent will be provided. Within the Application, limited analytics data that contains no personal data is used to measure performance.
12. Children's Privacy
The Application is not directed at users below the designated age limit. We do not knowingly collect data from such individuals.
13. Not Medical Advice
CaloriPanda is a healthy-living assistant; the information it provides is for informational purposes and does not replace medical advice. In the event of a complaint or illness, consult a physician.
14. Early Access / Waitlist
Before the Application is launched, we may optionally collect your email address through the early-access pages ("waitlist") on our website. This is a separate and independent activity from the in-app account and from health data processing.
- Data collected: only your email address; and, if you arrived at the page via a content creator's link, attribution information about which link/campaign you came through (creator tag and UTM parameters). No health data or special category data is collected.
- Purpose: solely to deliver the launch and early-access announcement to you. It is not used for any other purpose and is not sold.
- Legal basis: your explicit consent (KVKK Art. 5). No registration is made without ticking the consent box.
- Retention: your email address is retained until the launch announcement is made or until you withdraw your consent (at the latest 12 months from launch); it is deleted thereafter. If you withdraw your consent, your record is deleted without delay.
- Withdrawal: you can leave the list at any time and request the deletion of your data by writing to info@caloripanda.com.
15. Changes and Contact
We may update this policy from time to time; we will notify you of significant changes through the Application or by email. For any questions and requests: info@caloripanda.com