BulkMate — Privacy Policy
Effective date: 12 July 2026
This Privacy Policy explains how Wayfinity Ltd, a company registered in Cyprus (company number HE 477899, registered office 77, Strovolos Center, Floor 4, Flat/Office 401, Strovolos, 2018 Nicosia, Cyprus) ("Wayfinity", "we", "us"), collects, uses, and protects your personal data when you use the BulkMate mobile application (the "App") and the website at bulkmate.app (together, the "Service").
Wayfinity Ltd is the data controller for personal data processed through the Service. We process personal data in accordance with the EU General Data Protection Regulation ("EU GDPR") and, where applicable to users in the United Kingdom, the UK General Data Protection Regulation and the Data Protection Act 2018 ("UK GDPR").
Contact: contact@wayfinity.io
1. Summary (the short version)
- BulkMate is local-first: your food logs, weigh-ins, and profile live in a database on your device. If you sign in, they are also synced to your private account in our cloud backend (Supabase) so you can back up and restore them.
- Progress photos are stored on your device and, when you are signed in, uploaded to a private storage bucket accessible only to your account. They are never public.
- Meal photos and nutrition-label photos that you choose to scan are sent to an AI model to estimate calories and macros. Your optional baseline photo can be processed by an AI model to generate an illustrative "target physique" image.
- We use PostHog (EU-hosted) for product analytics and session replay. In replays, all text inputs and all images are masked — your photos and personal entries never appear in recordings.
- Subscriptions are processed by Apple/Google and validated by RevenueCat. We never see your payment-card details.
- We do not sell your personal data and we do not show third-party advertising in the App.
- You can export your data as CSV and delete your account (and its cloud data) directly in the App.
2. What Data We Collect
2.1 Data you provide
| Category | Details |
|---|---|
| Account data | Email address and authentication identifiers when you sign in with Apple, Google, or an email one-time code. With Sign in with Apple you may choose to hide your email (Apple provides a private relay address). |
| Profile & onboarding data | Sex, date of birth, height, current/start weight, target weight, weekly gain rate, protein target, training/trajectory preferences, meals per day, wake/sleep times, reminder checkpoint times, coach-personality preference, onboarding questionnaire answers, and (if you tell us) how you heard about BulkMate. |
| Nutrition & weight logs | Foods you log (name, brand, serving, calories, protein, carbs, fat), how each entry was created (manual, barcode, photo scan, label scan, fast-fill), daily totals and day status, body-weight entries, and weekly check-in results (averages, reasons you select, plan adjustments). |
| Photos | Progress/physique photos you take or upload; meal photos and nutrition-label photos you choose to scan; barcode images processed on-device (only the decoded barcode number leaves your device). |
| Support communications | Messages you send us and the contact details you use. |
2.2 Data collected automatically
| Category | Details |
|---|---|
| Usage analytics | Events (e.g. screens viewed, features used, onboarding steps completed, paywall interactions, purchase started/completed/cancelled with product identifier, price, and currency), and masked session replays (see Section 5). |
| Device & app data | Device model, OS version, app version, language/locale, time zone, and pseudonymous analytics identifiers. On iOS, we request App Tracking Transparency permission before using device-linked identifiers for cross-session analytics; on Android, the advertising-ID permission may be used for the same purpose. |
| Purchase status | Subscription entitlement, product, renewal, and trial status via RevenueCat and the app stores. We never receive your card number or full payment details. |
2.3 Data from third parties (with your permission)
| Category | Details |
|---|---|
| Apple Health (HealthKit) | If you enable Health sync, we read your body-weight samples to keep your trend accurate and write your logged weigh-ins back to Apple Health. This happens only with your explicit permission, which you can revoke at any time in iOS Settings → Health. We never use Apple Health data for advertising or marketing and never disclose it to third parties for advertising, marketing, or data-brokerage purposes. |
| Sign-in providers | Apple or Google provide your email (or relay email) and a token confirming your identity. |
| Open Food Facts | When you scan a barcode, the barcode number is sent to the Open Food Facts database to fetch product nutrition data. No personal data is included in the lookup. |
2.4 Special-category (health) data
Your weight, height, nutrition intake, body photos, and Apple Health data are health-related data — "special category" data under UK/EU GDPR. We process this data only with your explicit consent, which you give when you enter it into the App, enable Health sync, or submit photos for AI processing. You may withdraw consent at any time by disabling the relevant feature, deleting the data, or deleting your account (see Sections 8 and 9). Withdrawal does not affect the lawfulness of processing before withdrawal.
3. How We Use Your Data, and the Legal Bases
| Purpose | Data | Legal basis (UK/EU GDPR) |
|---|---|---|
| Provide the core Service: targets, tracking, streaks, weekly adjustments, reminders | Profile, logs, weights | Contract (Art. 6(1)(b)); explicit consent for health data (Art. 9(2)(a)) |
| Account creation, sign-in, cloud sync, and backup/restore | Account data, synced content | Contract (Art. 6(1)(b)); explicit consent (Art. 9(2)(a)) |
| AI meal estimation, label parsing, and target-physique image | Photos you submit, weight/target values | Explicit consent (Art. 6(1)(a) and 9(2)(a)) — each scan/generation is user-initiated |
| Store and display your progress photos | Photos | Explicit consent (Art. 6(1)(a) and 9(2)(a)) |
| Apple Health sync | Weight samples | Explicit consent (Art. 6(1)(a) and 9(2)(a)); HealthKit rules |
| Process subscriptions and validate entitlements | Purchase status, app-store account identifiers | Contract (Art. 6(1)(b)); legal obligation for records (Art. 6(1)(c)) |
| Understand and improve the product (analytics, masked replays, funnel and retention analysis, A/B tests of app screens) | Usage analytics, device data | Legitimate interests (Art. 6(1)(f)) in improving the Service — with masking and EU hosting as safeguards; consent where required (e.g. iOS App Tracking Transparency) |
| Local reminders and pacing notifications | Schedule preferences (processed on-device only) | Contract (Art. 6(1)(b)) |
| Respond to support requests | Support communications | Legitimate interests (Art. 6(1)(f)) |
| Security, fraud prevention, and enforcing our Terms | Account, device, usage data | Legitimate interests (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) |
We do not use your data for third-party advertising, do not sell or rent personal data, and do not carry out automated decision-making that produces legal or similarly significant effects on you. Weekly plan adjustments are simple formula-based calculations of your own logged data that you can review and override.
4. Where Your Data Lives
- On your device. The App keeps your daily-use data in a local SQLite database. Photos are stored in the App's private storage. Reminders are scheduled locally on your device — we do not run a push-notification server.
- In our cloud backend (when signed in). Your profile, logs, weigh-ins, check-ins, and photo files are synced to your account in our backend hosted by Supabase (database, authentication, file storage, and serverless functions). Photos are stored in a private bucket readable only by your authenticated account, accessed via short-lived signed URLs.
- If you never sign in, your data stays on your device (analytics events described in Section 5 are still collected) — but it is then not backed up, and we cannot recover it if the device or app data is lost.
5. Analytics and Session Replay
We use PostHog, hosted in the European Union, for product analytics. This includes:
- event tracking (feature usage, onboarding progress, paywall and purchase events);
- screen-view tracking;
- session replay — a reconstruction of how the app screens were used. Replay is configured so that all text inputs and all images are masked: your photos, weights, food names, and any typed text are replaced with placeholders and never leave your device in replays.
Before you sign in, analytics are linked to a random device-level identifier. When you sign in, that identifier is linked to your account (user ID and email) so we can understand product usage across devices. On iOS we ask for App Tracking Transparency permission where required; if you decline, the App continues to work.
6. Who We Share Data With (Processors and Recipients)
We share personal data only with service providers ("processors") acting on our instructions under data-processing agreements, with the platforms that operate app distribution and billing, and where required by law:
| Recipient | Role | Data | Location |
|---|---|---|---|
| Supabase | Database, authentication, file storage, serverless functions | Account data, synced profile/logs/weights/check-ins, photos | EU |
| PostHog | Product analytics & masked session replay | Usage events, device data, user ID, email | EU |
| RevenueCat | Subscription management & receipt validation | App-store purchase receipts, entitlement status, app user ID | US |
| Alibaba Cloud (Model Studio / DashScope) | AI inference for meal estimation, label parsing, and physique-image generation | The specific photos you submit for scanning/generation and related target values | Singapore / international |
| Apple / Google | App distribution, sign-in, billing, Apple Health (on-device) | Account tokens, purchase data | Global |
| Expo (EAS) | App builds and over-the-air updates | Basic device/app-version data when checking for updates | US |
| Open Food Facts | Barcode → nutrition lookup | Barcode number only (no personal data) | EU |
Photos submitted to AI features are used only to generate your result. We instruct our AI providers not to use your content to train their models; if we cannot ensure this for a feature, we will say so in the App before you use it.
We may also disclose data if required by law, court order, or to protect our rights, users, or the public, and in connection with a business transfer (merger, acquisition), in which case this Policy will continue to apply to your data.
7. International Transfers
We are a Cyprus (EU) company and some of our processors are located outside the EEA and the UK (see Section 6). Where personal data is transferred outside the EEA (or, for UK users, outside the UK), we rely on safeguards recognised under EU/UK GDPR: adequacy decisions/regulations where available, and otherwise the EU Standard Contractual Clauses or the UK International Data Transfer Agreement/Addendum, together with supplementary measures where appropriate. You can contact us for more information about the safeguards applied to a specific transfer.
8. How Long We Keep Data
- Account and synced content: kept while your account is active. When you delete your account in the App, your cloud data — profile, logs, weigh-ins, check-ins, and photos — is deleted from our backend; residual copies in encrypted backups expire on backup rotation (within 30 days).
- On-device data: under your control; you can wipe it at any time with the App's "Reset app data" option or by deleting the App.
- AI processing: photos submitted for scanning/generation are processed transiently to produce the result and are not retained by us beyond what is described in Sections 4 and 6.
- Analytics: retained per our PostHog retention settings (up to 24 months), after which data is deleted or aggregated.
- Purchase records: retained as required for tax, accounting, and fraud-prevention obligations (typically 6 years).
- Support correspondence: up to 24 months after the matter is closed.
9. Your Rights
Under UK/EU GDPR you have the right to:
- Access your personal data (the App's CSV export gives you your logs and weigh-ins instantly; contact us for a full copy);
- Rectify inaccurate data (mostly editable directly in the App);
- Erase your data ("right to be forgotten") — use Settings → Delete account in the App, or contact us;
- Restrict or object to processing, including processing based on legitimate interests;
- Data portability — receive your data in a structured, commonly used, machine-readable format;
- Withdraw consent at any time (e.g. disable Health sync, stop using AI scans, revoke photo permissions in your device settings);
- Complain to a supervisory authority — our lead supervisory authority is the Office of the Commissioner for Personal Data Protection of Cyprus (dataprotection.gov.cy); you may also complain to your local data-protection authority in the EU/EEA or, in the UK, the Information Commissioner's Office (ico.org.uk).
To exercise any right, use the in-App controls or email contact@wayfinity.io. We respond within one month. We may need to verify your identity before acting on a request.
10. Security
We take reasonable technical and organisational measures to protect your data, including: encryption in transit (TLS) for all network traffic; authentication tokens stored in your device's secure storage (Keychain/Keystore); row-level access controls so your cloud data is readable only by your authenticated account; private photo storage with short-lived signed URLs; and least-privilege access to production systems. No system is completely secure; if a breach occurs that risks your rights and freedoms, we will notify the ICO and affected users as required by law.
11. Children
The Service is intended for adults and is not directed at anyone under 18. We do not knowingly collect personal data from children. If you believe a child has provided us personal data, contact us and we will delete it.
12. The Website (bulkmate.app)
The Site is an informational site. It does not use analytics tools and does not set cookies. Our hosting provider collects standard server logs (IP address, user agent, pages visited) for security and operation of the Site; these are retained per the hosting provider's log-retention settings. If we add analytics or any non-essential cookies to the Site in future, we will update this Policy and, where required, ask for your consent via a cookie banner.
13. Changes to This Policy
We may update this Policy from time to time. We will post the updated version at bulkmate.app/privacy with a new effective date, and for material changes we will notify you in the App or by email before they take effect.
14. Contact Us
Wayfinity Ltd — Data Controller Registered office: 77, Strovolos Center, Floor 4, Flat/Office 401, Strovolos, 2018 Nicosia, Cyprus Company number: HE 477899 Tax number: 60189170K Email: contact@wayfinity.io
If we appoint a UK representative or a Data Protection Officer, their details will be listed here.