Fasting App Privacy Policy

You can see our previous Privacy Policy here.

Effective date: November 17, 2025

INTRODUCTION AND SCOPE

This Fasting App Privacy Policy (“Privacy Policy”) is delivered on behalf of Municorn Limited (“Municorn,” “we”, “us”, and “our”) and governs the Personal Data (as defined below) collected from or processed about you when you use the Fasting App mobile application, which provides an easy way to track your fasting periods from phone or tablet on the go (“Fasting App”), including by downloading, installing, registering with, accessing or otherwise using the application (collectively referred to herein as “Use”).

We provide this Privacy Policy to explain our practices for collecting, using, processing, and disclosing the Personal Data we process about Fasting App users (“users”, “you”, or “your”, as applicable), and to tell you about the rights you may have in relation to your Personal Data and choices you may be able to make in relation to it. By Personal Data we mean (i) information that is associated with an identified or identifiable natural person, and (ii) protected as personal data under applicable data protection laws.

Please read this Privacy Policy carefully to understand our privacy practices. We also encourage you to get acquainted with our Terms of Use to understand how we provide services to you.  

By accepting this Privacy Policy, you acknowledge that you understand and agree to the processing of your Personal Data and other information as described in this Privacy Policy. You consent to our collection, use, and sharing of data to provide and improve the functionality of the Fasting App. This includes the processing of Personal Data and other information necessary for the operation of the Fasting App.

Please note that if you choose to limit or withhold certain data, some features of the Fasting App may not function as intended, and you may experience a reduced user experience.

If you do not wish to have your data processed in accordance with this Privacy Policy, please refrain from using the Fasting App.

Questions? If you have any questions about this Privacy Policy or Fasting App, please contact us at fasting-support@municorn.com. For additional contact information, please see Section 14: How to Contact Us.

U.S. State Supplements:

This Privacy Policy is designed to comply with data privacy laws across the United States, including:

• California Consumer Privacy Act (CCPA),
• Colorado Privacy Act (CPA),
• Connecticut Data Privacy Act (CTDPA),
• Virginia Consumer Data Protection Act (VCDPA),
• Texas Data Privacy and Security Act (TDPSA),
• Tennessee Consumer Privacy Act (TCPA),
• Oregon Consumer Privacy Act (OCPA) and other applicable state laws.

If you are a resident of California, please see our California Notice at Collection and Privacy Notice, which provides detailed information about your rights and additional disclosures specific to California.

If you are a resident of Colorado, Connecticut, Virginia, Texas, Oregon, Tennessee, or any other U.S. state with privacy laws, please see our U.S. State Privacy Supplement (Non-California). The rights granted to you under these laws are also outlined in this Privacy Policy. These include:

• The right to access, correct, delete, or receive a copy of your personal data.
• The right to opt out of the sale or sharing of your personal data, targeted advertising, and profiling with legal or significant effects.

You may exercise these rights by contacting us at fasting-support@municorn.com or through the in-app privacy settings, where available.

TABLE OF CONTENTS

• Introduction
• Section 1: Personal Data We Collect and How We Collect It
• Section 2: Personal Data You Provide To Us Directly
• Section 3: Personal Data and Other Data We Collect Automatically
• Section 4: The Purposes and Our Legal Bases For Processing Your Personal Data
• Section 5: To Whom We Disclose Personal Data
• Section 6: Cookies, Software Development Kits, and Other Tracking Technologies 
• Section 7: Your Rights In Relation to Your Personal Data
• Section 8: Your Choices About Our Communications With You
• Section 9: Data Security
• Section 10: Data Retention
• Section 11: Cross-Border Data Transfers
• Section 12: Children's Privacy
• Section 13: Third-Party Websites and Services
• Section 14: How to Contact Us
• Section 15: Changes to Our Privacy Policy

1. PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

We may collect Personal Data from and about you:

• Directly from you when you provide it to us, to provide the app’s services (contractual necessity).
• Automatically when you Use Fasting App, for app functionality and analytics (legitimate interest). Information collected automatically may include Usage details and internet protocol (“IP”) addresses.
• From third parties, for example, our service providers, partners and vendors, when necessary for service delivery or marketing (consent or contractual necessity).

2. PERSONAL DATA YOU PROVIDE TO US DIRECTLY

You may provide Personal Data to us directly, or to service providers that act on our behalf, when you Use Fasting App. The Personal Data you provide depends on which features of Fasting App you Use and how you interact with the app.

• Authentication Data. When you create or access your personal account:

• If you're using Google, we may collect your name and email address through Google’s authentication API.
• If you're using Apple, we may collect your name and email address based on your Apple ID sharing settings.
• If you're signing up via email, you provide your email address and verify it with a one-time password sent to your inbox.

These credentials are stored in Fasting App to maintain your account and profile.

• We collect personal data to provide the services of Fasting App. By using Fasting App, you consent to the collection and processing of your personal data for the purposes outlined in this Privacy Policy. This includes data such as your age, height, weight, calorie intake, frequent foods. We only collect and process this information as part of our contract to provide the service and for specific marketing purposes as outlined below.
• Photos that you upload to Fasting App. If you grant us permission to access your camera or your device’s photo library, we will process the photos you select to upload to Fasting App to provide features of the app that you choose to Use.          

• If you contact us or communicate with us, we will collect and receive records and copies of your correspondence with us and contact details that you have provided us while making your inquiries (such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted).

• Sensitive data. We do not require or intentionally process sensitive data from the documents you upload. Sensitive data may include, but is not limited to:

• Personally Identifiable Information (PII), such as names, addresses, phone numbers, or financial information.
• Medical, biometric, or other confidential information.

Sensitive information is provided solely at the user’s discretion and under their control. If sensitive data is uploaded voluntarily, it is done at the user’s own responsibility, and we encourage users to avoid including such data in their documents.

In cases where sensitive data is uploaded unintentionally:

• We do not knowingly collect or process any sensitive personal data except to the extent strictly necessary to provide you with the service you have requested.
• We do not analyze the content you upload; therefore, we cannot actively monitor or identify sensitive data within your uploads.

If we become aware that sensitive data has been uploaded unintentionally, we will make reasonable efforts to delete it promptly, where technically feasible.

Please note we rely on you to avoid uploading sensitive personal data (such as health information, biometric data, or data revealing racial or ethnic origin) unless it is strictly necessary for your Use of the service. By uploading documents, you acknowledge that the decision to include sensitive information is yours, and we are not liable for any sensitive data uploaded without request or consent.

Users under the minimum age defined in Section 12: Children's Privacy must not provide personal information. Any data collected from users under the age limit will be deleted immediately upon discovery.

3. PERSONAL DATA AND OTHER DATA WE COLLECT AUTOMATICALLY

When you Use Fasting App, we or third parties we permit to do so, may automatically collect certain information, including Personal Data, from you (this is subject to your consent where this is required by law). The information collected from you automatically when you Use Fasting App may include:

• Account and Authentication Data. When you create or log into an account (for example, using email, Apple ID, or other supported login methods), we collect identifiers such as your name, email address, authentication tokens, and subscription status.
• Log file information. Log file information is automatically reported by your browser each time you make a request to access (ie, visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device. When you use Fasting App, our servers automatically record certain log file information, including your web request, IP address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Fasting App, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our services.

• Subscription and device data. Information related to your subscription and device used for technical authorization.
• Marketing and cookies data. Collected through cookies and analytics services integrated into the app.
• Device information. Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system and version, mobile network information, device type and device language.
• App and country information. Information regarding the version of the app that you are using and the country version of the app store from which you downloaded Fasting App.
• Geolocation data. The state or country associated with your IP address.
• Usage details. Details of your Use of Fasting App, including frequency of Use, areas and features of the application that you access and information regarding engagement with particular features of the app.
• Details about your in-app purchases. For example, details regarding the time you made certain purchases.
• Uploaded documents and photos. Files provided by users, such as photos, images in JPG or PDF format. etc.
• Payments. When enabling payment processing, you will integrate with Stripe. The payment account details are stored by Stripe, not by us. Payment links or QR codes may be generated and shared to facilitate client payments.
• Permissions for Camera, Photos and videos, Files. After you grant us the relevant permission, we may have technical access to your camera that is required to be able to scan documents via the Fasting App and/or to take photos you want to add to your documents. Additionally, if you try to upload any image, photo or file from your Photo Library/Gallery or Files to the Fasting App, the relevant technical access of the Fasting App to your Photos and videos or Files is required. The technical access you provide to your Photos and videos (either limited or full), Files is necessary for us solely to enable you to upload photos, images, files from your device to the Fasting App, use them to create and edit documents in the Fasting App, i.e. to operate the Fasting App Services and provide you with the Fasting App functionality. You can manage, change access permissions to your Camera, Photos and videos, Files at any time via the Settings app on your device.
• (If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by Fasting App, please follow the instructions below.

If you use an iOS device:

1. Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.
2. Tap to turn off or turn on permission to track for Fasting App.

If you use an Android device:

1. Open Settings app
2. Navigate to “Privacy” > “Ads”
3. Tap “Delete Advertising ID”
4. Tap it again on the next page to confirm.

Other than with respect to Image Data, we and third-parties we engage may use cookies, Software Development Kits (SDKs), and other tracking technologies to automatically collect the Personal Data set forth above. For more information regarding our use of these technologies, please see Section 6: Cookies, Software Development Kits, and Other Tracking Technologies.

4. THE PURPOSES AND OUR LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

We may use your Personal Data for a variety of purposes depending on the category of Personal Data and the way you Use and interact with the Fasting App, including the following:

• To present to you and others with Fasting App and its contents and any other information, products or services that you request from us, including to provide various features of the app and its functionality. We do so to provide you with the services according to our contractual obligation.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to Fasting App (e.g., the Terms of Use). This is for the performance of our contract with you and for our legitimate interests in performing and enforcing our contracts with you.
• To provide you with customer and technical support, investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other users’ inquiries in relation to Fasting App. It is our legitimate interest to provide you with high-quality support.
• To communicate with you, such as to notify you about changes to Fasting App or any products or services we offer or provide through Fasting App, including by sending you technical notices, notices about your account/subscription, including expiration and renewal notices, updates, security alerts and support and administrative messages, which we may send through an in-app or a push notification (you may opt-out of push notifications by changing the settings on your mobile device). It is our legal obligation to keep you informed about your subscription and your account and otherwise in our legitimate interests of keeping you informed about your Fasting App account.
• To conduct research, analytics and monitor performance and other metrics regarding Fasting App and your Use of Fasting App. This may include data regarding the total number of users of our app, traffic, and demographic patterns related to the use of our app. Where this data is collected through the technologies described in Section 6: Cookies, Software Development Kits, and Other Tracking Technologies and where required by law, we rely on your consent; otherwise, it is our legitimate interest to conduct analytics as it helps us understand our business metrics and improve our product. For marketing and analytics purposes, we may use aggregated and anonymized data related to the types of foods you consume and your usage patterns. This data is used to enhance the app’s features and provide tailored promotional content.
• To improve, test, and monitor the effectiveness of Fasting App. It is our legitimate interest to conduct such analyses to understand our product and business metrics.
• Geolocation data is collected in an aggregated, non-identifiable format for analytics and service enhancement. We do not use your precise location for any marketing purposes without your explicit consent.
• To provide personalized content and information to you in relation to Fasting App and so that we, and third parties on which we rely, can advertise to you. This may include using your Personal Data to build advertising audiences that we believe are similar to our user base, serving online ads to you, or engaging in other forms of advertising. Where required by law, we rely on your consent to engage in such activities and/or offer you the opportunity to opt-out. Please see Section 3: Personal Data and Other Data We Collect Automatically for more information.  
• To send marketing and promotional communications to you, such as via email, push notification or in-app messaging either with your consent or as otherwise permitted by law. Please see Section 8: Your Choices About Our Communications With You for more information.
• In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.
• As permitted or required by law, including for auditing, fraud and security monitoring purposes.
• We may use automated decision-making technologies, including profiling, to improve app functionality, provide personalized content, and optimize advertising. For example, automated profiling may be used to recommend features based on your usage patterns.
• You have the right to:

• Request more information about any automated decision-making processes,
• Object to profiling that significantly affects you, and
• Request human intervention in cases where automated decisions impact your rights under applicable laws.

Where processing is based on legitimate interest, we ensure that our interests do not override your fundamental rights and freedoms. You may object to such processing at any time by contacting us at fasting-support@municorn.com.

5. TO WHOM WE DISCLOSE PERSONAL DATA

We may disclose the information we process about you, including any Personal Data, as follows:

• We may disclose your Personal Data, and other data and collected information to trusted third-party organizations such as contractors, business partners, service providers, and vendors that we use to support our business operations and who assist us in providing Fasting App. These service providers may include:

• Microsoft Azure – subject to their Terms of Use.
• OpenAI – subject to their Business Terms.
• ConvertAPI – subject to their Terms of Service.

• We may disclose your Personal Data to third-party analytics providers and advertising partners or otherwise permit them to collect or access it. For more information, please see Section 6: Cookies, Software Development Kits, and Other Tracking Technologies.

These analytics providers may include:

• Amplitude – subject to their Terms of Service.
• AppsFlyer – subject to their Terms of Use.
• Firebase – subject to their Terms of Service.
• Appfigures – subject to their Terms of Use.
• Facebook Pixel – subject to their Facebook Terms and Policies.
• Google Ads – subject to their Google Ads Terms and Conditions.

• We may disclose your Personal Data in the event that we or any of our affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, liquidation. In such cases, your Personal Data and any other collected information may be among the items sold, transferred, or otherwise disclosed as part of that transaction or proceeding.
• We may use Stripe as our third-party payment processor. All payment-related information, including card details, billing address, and other financial data, is provided directly by you to Stripe and is not stored, processed, or accessed by us at any point. Stripe independently collects, processes, and stores your payment information in accordance with its own privacy policy and terms of service. We do not retain any sensitive payment data submitted through Stripe forms. For more information, please refer to Stripe’s Privacy Policy and Stripe Connected Account Agreement.
• We may disclose your Personal Data in response to legal requests and for purposes of preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
• Payments and Data Processing. We do not collect, store, or directly process sensitive payment details such as credit card numbers, expiration dates, or CVV codes. All payment transactions are securely handled by third-party payment providers, including Apple Pay and Stripe, in accordance with their respective terms of service and privacy policies. We recommend reviewing Apple Pay & Privacy and Stripe Privacy Policy for detailed information.

While payment details are exclusively processed by these providers, we may process limited metadata related to transactions. This includes transaction IDs, payment status, or non-sensitive identifiers necessary for order confirmation, fraud prevention, service continuity, and compliance with applicable legal or regulatory requirements. These activities are carried out with strict adherence to data protection laws and solely for purposes directly related to service provision.

Our processors (Apple Pay, Stripe) certify PCI DSS compliance.

We encourage you to review the privacy policies of Apple Pay and Stripe for comprehensive details on how your sensitive payment data is managed. For questions or further assistance, please contact our Support team at fasting-support@municorn.com.

• Some of the third-party service providers and partners we share data with are located outside the EU/UK. Section 11: Cross-Border Data Transfers explains the safeguards we have in place to protect your personal data during international transfers.

6. COOKIES, SOFTWARE DEVELOPMENT KITS, AND OTHER TRACKING TECHNOLOGIES

Analytics providers. When you Use Fasting App, we and our service providers, vendors, and partners, including third parties, may use technologies to collect or receive certain information about you and/or your Use of Fasting App. We also use third-party analytics tools like Google Firebase, AppsFlyer, and Amplitude to help us measure traffic and usage trends for Fasting App and for other purposes. Such analytics tools collect information via third-party SDKs incorporated into Fasting App, which includes information about features of Fasting App you visit or Use, your actions in Fasting App, and information about your subscription. Such information may be used to provide content, advertising, or functionality or to measure and analyze ad performance on Fasting App or other websites or platforms. Third parties may also use such information for their own purposes. For the avoidance of doubt, we do not use Image Data for advertising purposes.

Interest-based Advertising. We may partner with ad networks and other ad-serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information ad networks and ad serving providers collect about your Use of the app over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

Consumption Information. We collect and process consumption data by default to assist Apple in evaluating refund requests, ensuring compliance with applicable laws and regulations, including GDPR and CCPA. By accepting our Privacy Policy, you agree to this data collection and sharing practice.

If we receive a refund request for an in-app purchase, we may provide Apple with information about your in-app purchase activity.

This data may include:

• Account Tenure: the duration of your account's existence;
• App Account Token: an anonymous account identifier used for the transaction;
• Consumption Status: the extent to which the in-app purchase was used or consumed;
• Delivery Status: confirmation of whether the purchased content was successfully delivered;
• Lifetime Dollars Purchased: the total amount spent on in-app purchases in our app, in USD;
• Lifetime Dollars Refunded: the total amount refunded to you for in-app purchases, in USD;
• Platform: the platform where the in-app purchase was consumed;
• Play Time: the total time spent using our app;
• Sample Content Provided: whether a free trial or sample of the in-app purchase was available before purchase;
• User Status: the current status of your account.

We process this data solely to assist Apple in evaluating refund requests, ensuring compliance with applicable laws and regulations, including GDPR and CCPA. We obtain your explicit consent before collecting any data for these purposes. Users can withdraw their consent to this processing at any time through the app settings or by contacting us.

Users can withdraw their consent to this processing at any time by adjusting the app settings:
Open the App > Go to Settings > Analytics > Toggle Off "Share consumption information".

For further assistance or to withdraw consent directly, users can also contact us via fasting-support@municorn.com. 

Your Choices. Most browsers and devices are configured to accept cookies and similar tracking technologies automatically. You may be able to set your browser and device options so to limit such technologies. You can visit the Digital Advertising Alliance (“DAA”) Webchoices tool at www.aboutads.info to learn more about this interest-based advertising and how to opt out of this kind of advertising by companies participating in the DAA self-regulatory program, and http://www.aboutads.info/appchoices for information on the DAA’s mobile app opt-out program. You can also opt out of receiving interest-based ads from members of the Network Advertising Initiative (“NAI”) by visiting the NAI consumer opt-out page at http://optout.networkadvertising.org/?c=1#!/. Opting out of receiving interest-based ads does not mean that you will no longer receive ads from us, but rather that the ads will not be tailored to your perceived interests. 

For users in the European Economic Area, United Kingdom and United States. You can opt out from processing of Personal Data via cookies, SDKs and other tracking technologies by clicking sending a request to fasting-support@municorn.com.

You may find that some parts of the app may not function properly if you have refused certain tracking technologies, and you should be aware that disabling certain tracking technologies may prevent you from accessing some of our content. You can control cookies and other tracking technologies through your browser settings.

We honor Global Privacy Control (GPC) signals as required by U.S. and international privacy laws. GPC is a browser or device setting that allows you to control the sale or sharing of your personal data. If GPC is enabled on your device, we will process it as a valid opt-out request under applicable laws. For more information on enabling GPC, please visit globalprivacycontrol.org.

7. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

Access, modification, correction and erasure. You can send us an email at fasting-support@municorn.com to request access to, modification, correction, update, erasure or portability of any Personal Data that you have provided to us and that we have about you. You can also request deletion of your account inside the app, both for iOS and Android users. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

EEA/UK individuals. Individuals in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain statutory rights in relation to their Personal Data including under the General Data Protection Regulation (Regulation (EU) 2016/679) (“EEA GDPR”) and the UK version of the EEA GDPR (“UK GDPR”) (collectively, the “GDPR”), including the rights specified below. You can exercise these rights by contacting us (for contact information, please see Section 14: How to Contact Us). We will do our best to accommodate your request or objection but please note that not all rights are absolute.

• Access to your Personal Data: You have a right to request information about whether we have any Personal Data about you, and to receive a copy of such Personal Data.
• Rectification of your Personal Data: You are responsible for ensuring the accuracy of your Personal Data that you provide to us. Inaccurate information may affect your experience when Using Fasting App features and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is incomplete or inaccurate, you have a right to contact us and ask us to correct such Personal Data.
• Restriction of processing: You also have the right to demand restriction of processing of your Personal Data, for example, if you contest the accuracy of the Personal Data which inaccuracy is verified by us.
• Erasure of your Personal Data: In certain circumstances, you may ask us to erase your Personal Data. Please be aware that erasing some Personal Data may affect your ability to Use Fasting App.
• Right to portability of your Personal Data: In certain circumstances, you have the right to request us to receive any Personal Data you provided us in a structured, commonly used and machine-readable format. You may further ask us to give that Personal Data to another party.
• Right to object to processing or otherwise using your Personal Data: Where we are processing your Personal Data based on our legitimate interest, you may object to the processing or otherwise using your Personal Data. Please be aware that our inability to process or otherwise use some of your Personal Data may affect your ability to Use Fasting App. If you have opted in to receiving marketing communications, you have the right to opt out of those at any time.
• Right to withdraw your consent at any time: Where you may have provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.
• Right to lodge a complaint with a supervisory authority: Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and the UK’s supervisory authority (ICO) here.
• Rights related to Automated Decision-Making and Profiling. You have the right to request more information about any automated decision-making processes. Apart from that, you may object to profiling that significantly affects you, and you may request human intervention in cases where automated decisions impact your rights under applicable laws.

Please keep in mind that we accommodate your requests free of charge. However, if your request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee or refuse to act on the request.

Besides, in case of a vague request to exercise any of the aforementioned rights we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse granting your request.

Following the provisions of the applicable law, we might also ask you to prove your identity (for example, by requesting your username or some other proof of your identity) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties is violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.

Consent for Third-Party Data. If you include third-party personal data in your uploaded documents, you are responsible for obtaining the necessary consent from those individuals before sharing such data with us.

Prohibited Content and User Responsibility

By using this app, you agree not to upload any illegal, harmful, or unlawful content, including but not limited to:

• Personal data of third parties without their consent,
• Sensitive personal data of third parties, such as medical, financial, or biometric data, unless you have explicit consent,
• Infringing content, including but not limited to copyrighted material, trademark violations, or any content that breaches intellectual property rights,
• Defamatory or offensive material, including hate speech, threats, or discriminatory content,
• Pornographic, sexually explicit, or obscene content,
• Fraudulent or deceptive content, such as phishing attempts, scams, or misleading information.

Uploading such content is done at your own risk and responsibility. You are solely responsible for ensuring that the documents you upload do not contain illegal or unlawful material or content you do not have the right to share.

In the event that we detect unlawful content in the documents uploaded by users, we reserve the right to report such content to the relevant authorities for further investigation. This may include providing user-uploaded content or other relevant information to law enforcement or other regulatory bodies, as required by law.

We do not bear responsibility for any legal consequences arising from the uploading of prohibited content.

Manage your privacy rights. To enhance your experience, we provide in-app tools to manage your privacy rights, such as:

• Accessing your personal data,
• Deleting your account and associated data,
• Managing consent for tracking and analytics technologies.

For additional assistance, contact us at fasting-support@municorn.com.

Requests related to personal or other data. If you are an individual in the EEA or UK, we will respond to your requests without undue delay and at the latest within one month from the date we receive your request. If your request is complex or if we receive a large number of requests, we may extend this period by an additional two months. In such cases, we will inform you of the extension and the reasons for the delay within the initial one-month period.

In any other case, we will process your requests related to personal data within 45 days from the date we receive them. If additional time is required due to complexity or volume of requests, we may extend this period by an additional 45 days. In such cases, we will notify you within the initial 45-day period.

You may submit your request by contacting us at fasting-support@municorn.com  or through the app’s privacy settings.

8. YOUR CHOICES ABOUT OUR COMMUNICATIONS WITH YOU

Necessary communications. If you are using Fasting App you may receive electronic communications from us (e.g., by posting in-app notices in Fasting App, push notifications or emails).  We send some of these communications to you, such as those related to your subscriptions, technical and security notices and updates to the Privacy Policy and Terms of Use, where necessary to perform our contract with you to provide Fasting App or otherwise based on our legitimate interest in contacting you.

OTP Delivery. For authentication purposes, we may send you a One-Time Password (OTP) via email. These emails are also processed via the providers mentioned above and initiated only by user request (e.g., during login or identity verification).

Marketing & Promotional Emails. Additionally, with your consent (if required by law), we may send you marketing communications, including promotional offers, updates, and new feature announcements related to Fasting App. If you wish to opt-out of our promotional and marketing emails, you can do so by following the opt-out links in any marketing email sent to you or by contacting us at fasting-support@municorn.com.

Push Notifications. If you wish to opt-out of push notifications, you can do so through your mobile device settings by tapping “Settings” -> “Notifications” -> Choose Fasting App - > press the toggle to allow or forbid push notifications from the app.

9. DATA SECURITY

We use reasonable and appropriate information security safeguards to help keep your Personal Data secure and, in an effort, to protect it from accidental loss and unauthorized access, use, alteration and disclosure. We also require our third-party service providers to maintain equivalent safeguards. Unfortunately, the transmission of information via the internet is not completely secure. Although we take measures to do our best to protect your Personal Data, we cannot guarantee the security of the collected information transmitted to or through Fasting App or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed.

Any transmission of your Personal Data is at your own risk. We are not responsible for the circumvention of security measures contained in Fasting App. Please understand that there is no ideal technology or measure to maintain 100% security.

The safety and security of your information also depends on you. For instance, we are not responsible for how you choose to share the photos or other information processed in your Fasting App account, such as via social media services. We are not responsible for the functionality, privacy, or security measures of any other organization.

In the event of a personal data breach, we have procedures to promptly assess, contain, and remediate the breach. Where required by law, we will notify the relevant data protection authorities and affected users in accordance with GDPR and applicable laws.

If you believe your data has been compromised, please contact us immediately at fasting-support@municorn.com.

10. DATA RETENTION

We will retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy or until you request the deletion of your account, whichever comes first.

Specific retention periods include:

• User account data. Retained until account deletion.
• Payment and transactional data. Retained for seven (7) years for compliance with financial and tax regulations.
• Uploaded documents. Retained on our servers for as long as needed to provide requested services. Users may delete documents at any time via the app’s settings.
• Analytics and usage data. Retained in anonymized form for business purposes.

You may request account deletion by contacting fasting-support@municorn.com or using the in-app functionality.

Even if we delete some or all of your Personal Data, we may continue to retain and use anonymized data previously collected that can no longer be used for personal identification.

11. CROSS-BORDER DATA TRANSFERS

Your personal data may be transferred to and stored in countries outside your country of residence. Certain of our service providers are incorporated in the United States. Accordingly, your Personal Data may be transferred to and stored in the United States.

Where required under the EEA GDPR, in case of transfers of personal data from the EEA to countries outside the EEA, where we cannot rely on adequacy decisions adopted by the European Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.

Where required under the UK GDPR, in case of transfers of personal data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on UK Addendum and the UK International Data Transfer Agreement please see here. We may also guarantee the protection of your personal data by relying on adequacy decisions adopted or approved by the authorities in the United Kingdom.

Azure servers’ usage. As to the location of our servers, we use Azure servers located in the USA for Fasting App operation and Google LLC multiregional servers locations, while our analytics operations are processed both on the servers provided by Azure and by Google LLC.

OpenAI usage. We may use OpenAI’s services to recognize and analyze recipes, food, and other related content within the app to provide and improve the functionality of our app and enhance the user experience. You have the right to access, correct, or delete your data processed by OpenAI through our app. For more information on how OpenAI handles data, please refer to their privacy policy.

Image Recognition. When you upload a food image to the app, OpenAI’s AI tools are used to recognize and categorize food, and related content. Only processed data regarding the content of the images (e.g., recognized types of food and ingredients) is shared with OpenAI. Original images are not transmitted.

AI Chat Assistant. We provide an AI-powered chat tool that allows users to ask questions and receive automated assistance. When you use this feature, the text you submit may be processed by OpenAI to generate a response. We do not share any additional personal data with OpenAI beyond what you choose to enter in the chat. You should avoid providing sensitive information. You may request access, correction, or deletion of any personal data processed through this feature. For details on how OpenAI handles data, please refer to their privacy policy.

Data Processing and Security. We ensure that appropriate security measures are in place to protect your data during transmission and processing. OpenAI processes this data strictly in accordance with our instructions, under a Data Processing Agreement (DPA) that ensures compliance with GDPR requirements. For more information on how OpenAI handles data, please refer to their privacy policy.

For further information please contact fasting-support@municorn.com.

12. CHILDREN’S PRIVACY

General age limitation. Fasting App is not intended for or directed at children under 13, and we do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to use Fasting App.

If you are a parent or guardian and believe we have collected information from your child who is under the age of 13, please contact us at fasting-support@municorn.com.

Age limitation for EEA and UK individuals. You must be at least 16 years old in order to use Fasting App. We do not allow use of Fasting App by EEA and UK individuals younger than 16 years old. If you are aware of anyone younger than 16 using Fasting App, please contact us at fasting-support@municorn.com and we will take the required steps to delete the information provided by such persons.

13. THIRD-PARTY WEBSITES AND SERVICES

We are not responsible for the practices employed by any websites or services linked to or from Fasting App, including the information or content contained within them. Where we have a link to a website or service, linked to or from Fasting App, we encourage you to read the privacy policy stated on that website or service before providing information on or through it.

14. HOW TO CONTACT US

General contact details. If you have any questions about this Privacy Policy or Fasting App, please contact us via email at fasting-privacy@municorn.com.

Data protection officer. If you are an individual in the EEA or the UK and you wish to exercise your rights under Section 7: Your Rights In Relation to Your Personal Data, or you have any questions about this Privacy Policy or Fasting App, you can contact our data protection officer via email at fasting-privacy@municorn.com.

15. CHANGES TO OUR PRIVACY POLICY

The date this Privacy Policy was last revised is indicated at the top of the page. We may modify or update this Privacy Policy from time to time. Some changes do not require your consent. However, if we determine that the changes may pose risk to your rights and freedoms, we will ask for your consent to those changes separately from this Privacy Policy.