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Privacy Policy

Bite Balance — The measurable blood-sugar reset program

1.Who we are

[LEGAL ENTITY NAME] ("Bite Balance", "we", "us") operates the Bite Balance website, mobile application, and reset camps (the "Service"). For users in [India / the EEA, if applicable], we act as the "data fiduciary" / "controller" of your personal data.

  • Contact / Privacy team: [PRIVACY EMAIL]
  • Grievance Officer (India, DPDP Act): [NAME], [EMAIL], [ADDRESS]
  • Data Protection Officer, if appointed: [NAME / EMAIL]

2.Scope

This Policy covers personal information we handle when you use the Service in the United States and India. Some information we handle may be health-related and is treated with extra care (Section 5).

3.Information we collect

You give us:

  • Account details — name, email, phone (optional), preferred language, region.
  • Health-related information you choose to share — such as whether you have prediabetes or type 2 diabetes or are focused on prevention; age; height and weight; and optional home fingerstick (blood-glucose) readings.
  • Meal photos and the food information derived from them.
  • Messages and content you post in cohort or community features.
  • Payment information — processed by our payment provider; we receive confirmation and limited details (for example, the last four digits), not your full card number.
  • Support and survey responses.

We collect automatically:

  • Usage and device data — app/website interactions, device and browser type, approximate region, IP address, and similar diagnostic data.
  • Cookies / local storage — see Section 10.

From others:

  • Connected services you authorize — for example, activity and step data from [Fitbit].
  • Sponsors or clinicians — if a sponsor or clinician enrolls you or invites you to a camp, we may receive your name and contact details to set up your account.

We generate the Bite Balance Score and your predictions from the above.

4.How we use your information

We use personal information to:

  • provide the Service — generate meal predictions, your daily step, and your Bite Balance Score;
  • run your reset camp and cohort, and personalize predictions to you over time;
  • create your optional Food Response Report and operate the optional AI Recalibration Coach;
  • process payments for paid services;
  • communicate with you about your camp, account, and support requests, and (if you opt in) send our newsletter;
  • keep the Service secure, prevent fraud and abuse, and debug problems;
  • improve our models and the Service, using de-identified data wherever feasible (see Section 6); and
  • comply with legal obligations.

5.Health-related and sensitive information

Some information you share (for example, diabetes status, weight, or glucose readings) is health-related and may be "sensitive personal data" under laws such as the India DPDP Act 2023 and US state privacy laws (for example, the CCPA/CPRA in California). We:

  • collect it only to provide and personalize the Service;
  • process it based on your consent and the other legal bases in Section 7;
  • apply additional access controls and safeguards; and
  • do not sell it (Section 8).

Where we operate under a HIPAA-compliant posture (for example, when working with a clinician or health-plan partner that is a HIPAA covered entity), we apply the safeguards required of a business associate under an appropriate agreement. [Confirm with counsel whether/when you are a HIPAA business associate.]

6.Our AI models and automated processing

Your predictions are produced by AI models. To improve accuracy and the Service, we may use data to train and evaluate those models, using de-identified data wherever feasible so it is not reasonably linkable to you. Predictions are estimates, not medical measurements, and are not used to make legal or similarly significant decisions about you.

7.Legal bases for processing

Depending on where you are, we rely on one or more of: your consent (which you may withdraw); performance of a contract (to provide the Service you asked for); our legitimate interests (for example, security and improving the Service) balanced against your rights; and compliance with law. For sensitive/health data, we rely primarily on your consent.

Our promise

8.How we share information — and what we never do

We do not sell your personal information, and we do not share your individual health information with sponsors for their own marketing.

We share information only as follows:

  • Service providers / processors — hosting, analytics, payment processing, and communications vendors who act on our instructions under contract.
  • Sponsors — if a sponsor funds your camp, we share aggregate, de-identified outcomes (for example, completion rates and average score changes). We do not report results for any group smaller than [five] people, to protect individuals, and we do not identify you to a sponsor without your consent.
  • Clinicians — if a clinician hosts your camp, you control what, if anything, is shared back with them (for example, your Food Response Report). We share your individual information with a clinician only with your consent or your direction.
  • Connected services — only those you authorize (for example, [Fitbit]).
  • Legal and safety — where required by law, to enforce our Terms, or to protect the rights, safety, and security of users or the public.
  • Business transfers — in a merger, acquisition, or sale of assets, subject to this Policy.

9.Children

The Service is not directed to children and is intended for users [18] and older. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact [PRIVACY EMAIL] and we will delete it.

10.Cookies and similar technologies

We use strictly necessary cookies/local storage to make the Service work (for example, to remember your session and preferences) and [limited analytics] to understand usage. You can control cookies through your browser settings; blocking some may affect functionality. [If you add advertising or non-essential analytics, describe them and provide an opt-out / consent banner.]

11.How long we keep information

We keep personal information for as long as your account is active and as needed to provide the Service, then for a reasonable period to meet legal, accounting, security, and dispute-resolution needs, after which we delete or de-identify it. Aggregate and de-identified data may be kept indefinitely.

12.How we protect information

We store data securely in [the United States] and apply administrative, technical, and physical safeguards appropriate to its sensitivity, including access controls, encryption in transit, and use of de-identified data for development and model improvement. No system is perfectly secure, so we cannot guarantee absolute security.

13.International transfers

We operate in the United States and India, and your information may be processed in either country or by our service providers elsewhere. Where the law requires it, we use appropriate safeguards for cross-border transfers (for example, contractual protections) and process such transfers consistent with the DPDP Act and applicable US requirements. [Confirm transfer mechanism with counsel.]

14.Your rights and choices

Subject to local law, you may have the right to:

  • access the personal information we hold about you and get a copy;
  • correct inaccurate information;
  • delete your information (and close your account);
  • withdraw consent for processing that relies on consent;
  • object to or restrict certain processing, and opt out of non-essential communications; and
  • not be sold personal information — and we do not sell it.

US (for example, California under CCPA/CPRA): rights to know, delete, correct, and to opt out of "sale"/"sharing"; we will not discriminate against you for exercising them.

India (DPDP Act 2023): rights to access, correction, erasure, grievance redressal, and to nominate another person to exercise your rights; contact our Grievance Officer above.

To exercise any right, contact [PRIVACY EMAIL]. We will verify your request and respond within the time the law requires. You may also have the right to complain to your data-protection authority (in India, the Data Protection Board).

15.Third-party links and services

The Service may link to or connect with third-party sites and services. Their privacy practices are their own, and we encourage you to read their policies.

16.Changes to this Policy

We may update this Policy. We will change the "Last updated" date and, for material changes, give you reasonable notice (for example, by posting on the Service or emailing you). Your continued use after the effective date means you accept the updated Policy.

17.Contact us

[LEGAL ENTITY NAME][REGISTERED ADDRESS]Privacy: [PRIVACY EMAIL]Grievance Officer (India): [NAME], [EMAIL]

Bite Balance is a wellness and education tool, not a medical device. The Service provides predictions and estimates, not clinical measurements, and does not diagnose, treat, or prevent any disease. Always consult your doctor before making medical decisions.