Privacy Policy
This Privacy Policy (the "Policy") describes how Individual Entrepreneur Eduard Zviagintsev (Georgia, Tbilisi, Krtsanisi District, Nino and Ilia Nakashidze Street, N1, (former Avlevi), area flat N3, building N3; the "Operator") processes and protects the personal data of users of the Gooze service (the "Service") — a Telegram bot and Telegram Mini App. The Policy is applied in accordance with applicable data-protection legislation of Georgia.
By using the Service, you confirm that you have read this Policy and consent to the processing of your personal data on the terms set out herein. If you do not agree with this Policy, stop using the Service.
1. What data we process
The Operator processes the following personal data, which the User provides themselves or which is received from Telegram when using the Service:
- Telegram account data: the numeric identifier, name, username, and profile photo, where available;
- profile data: sex, date of birth, height, weight, goal, activity level, dietary restrictions, time zone, and interface language;
- nutrition and health data within the Service: meal logs, the composition and calorie content of dishes (calories and macronutrients), weight values, and their dynamics;
- the content of messages the User sends to the bot — it is processed to recognise meals, calculate metrics, and generate responses;
- subscription and payment information: the fact, amount, currency, status, and date of a transaction. The Operator does not receive or store bank card payment details — these are processed by the payment provider.
2. Purposes of processing
Personal data is processed solely for the operation of the Service and related processes:
- providing the Service's features: food diary, AI meal analysis, calculation of calorie and macronutrient targets, weight tracking, reminders;
- arranging and maintaining the subscription, processing and refunding payments;
- communicating with the User about the Service and providing support;
- ensuring security, preventing abuse, and improving the quality of the Service.
3. Legal grounds
Processing is carried out on the basis of the consent of the data subject, given when using the Service, and to perform the contract (the Terms of Service) to which the User is a party. The Operator does not process special categories of personal data and does not use data for automated decision-making that produces legal effects.
4. Transfer to third parties and cross-border transfers
To operate the Service, the Operator engages service providers, to whom data is transferred strictly to the extent necessary to provide the relevant service:
- Telegram — the messenger through which the Service operates and messages are delivered;
- Anthropic (Claude models) — the AI analysis provider: the content of the User's nutrition messages is transferred to recognise meals and calculate metrics. Processing takes place on servers outside Georgia;
- the payment provider — acceptance and processing of subscription payments.
5. Consent to cross-border transfers
Because the AI analysis is performed by a provider whose servers are located outside Georgia, the processing of personal data involves cross-border transfers. By accepting this Policy, the User consents to the transfer of their personal data to the extent necessary for the AI analysis, as permitted under applicable Georgian law. The Operator takes reasonable measures to ensure that the transferred data does not contain excessive information.
6. Retention periods
Personal data is stored while the User's account in the Service is active and while a legal ground for processing remains. When the account is deleted or consent is withdrawn, the data is subject to deletion, except where its retention is required by law. Certain payment information may be retained for the period required by applicable accounting and tax rules.
7. User rights
The User has the right to access, rectify, erase, or restrict the processing of their personal data, and to withdraw consent at any time. To exercise these rights, contact the Operator at the email address in the "Contacts" section. Withdrawal of consent entails the cessation of processing and, consequently, the inability to continue using the Service.
The User can delete most profile data themselves within the Service; full account deletion is performed upon a request to support.
8. Data protection
The Operator takes the necessary legal, organisational, and technical measures to protect personal data from unlawful access, destruction, alteration, blocking, copying, and distribution. Only authorised persons who need it to perform their duties have access to the data.
9. Files and local storage
The Service and the website use the browser's local storage (localStorage) for technical purposes only — for example, to remember the chosen interface language. No advertising trackers or third-party marketing analytics systems are used.
10. Changes to this Policy
The Operator may amend this Policy. A new version takes effect upon its publication in the Service. Continued use of the Service after the changes are published constitutes the User's acceptance of the new version.
11. Contacts
Personal-data operator: Individual Entrepreneur Eduard Zviagintsev, Georgia, Tbilisi, Krtsanisi District, Nino and Ilia Nakashidze Street, N1, (former Avlevi), area flat N3, building N3. For questions about the processing of personal data and to exercise your rights, contact us by email: support@gooze.fit
