Privacy Policy

1. What Information Do We Collect?

Personal information you provide to us

In Short: We collect only the personal information you directly provide when you create an account.

When you register for a Fridge First account, we collect the following personal information:

• First name
• Last name
• Email address

We do not collect phone numbers, physical addresses, date of birth, identity documents, or any other categories of personal information beyond those listed above.

Information collected automatically

We may collect limited technical data automatically when you use the Services, such as device type, operating system, app version, session duration, and feature usage patterns. This data is used solely for the purpose of maintaining, improving, and securing the Services. It does not identify you personally.

Payment data

We do not collect, store, or process any payment card numbers, bank account details, or financial instrument data. All payment processing is handled exclusively by DPO (by Network) Payments. Please see Section 6 for details.

All personal information you provide must be true, complete, and accurate. Please notify us of any changes to your information.

2. How Do We Process Your Information?

In Short: We process your information to provide and improve the Services, manage your account, communicate with you, and comply with law.

We process your personal information for the following purposes:

• Account creation and authentication. We use your name and email address to create and maintain your Fridge First account and to enable you to log in securely.
• Service delivery. We use your email address to communicate service-related information, such as account confirmation, subscription confirmations, and important notices about the Services.
• Customer support. We may use your contact information to respond to support requests and resolve issues you raise with us.
• Marketing and promotional communications. With your consent, we may send you updates, newsletters, or promotional information about Fridge First. You may opt out at any time by clicking the unsubscribe link in any marketing email or by contacting us at [email protected].
• Security and fraud prevention. We may use your information to protect the integrity of the Services and to detect and prevent fraudulent activity.
• Legal compliance. We may process your information where required to comply with applicable laws or regulatory obligations.
• Service improvement. We may use aggregated and anonymised usage data to understand how users interact with the Services and to improve features and functionality.

3. What Legal Bases Do We Rely On?

In Short: We only process your personal information where we have a valid legal basis to do so under applicable law.

For users in Mauritius, we process your personal data in accordance with the Data Protection Act 2017 of Mauritius and rely on the following legal bases:

• Performance of a contract: Processing your name and email address is necessary to create and manage your Fridge First account and to provide the Services you have signed up for.
• Legitimate interests: We may process technical and usage data for security, fraud prevention, and service improvement, where our legitimate interests are not overridden by your rights.
• Consent: Where we send marketing communications, we rely on your consent, which you may withdraw at any time.
• Legal obligation: We may process your information where required by applicable law.

For users in the EU/EEA or UK, the equivalent legal bases under the GDPR (or UK GDPR) apply as described above. If you have questions about the specific legal basis applicable to your situation, please contact us.

4. When and With Whom Do We Share Your Information?

In Short: We share your information only with trusted third-party service providers necessary to operate the Services, and do not sell your personal data.

We may share your personal information with the following categories of third parties:

• Google AI Studio: Your content inputs (such as ingredients you enter into the app) are processed by Google AI Studio to generate AI-powered suggestions. Please see Section 5 for important details about how Google may handle this data.
• DPO (by Network) Payments: Your payment transaction is handled by DPO. We share only the minimum information necessary to facilitate payment processing. We do not share your name or email address with DPO beyond what is required by DPO for their own processing. Please see Section 6.
• Infrastructure and hosting providers: We may use cloud hosting, analytics, and infrastructure services. These providers process data only on our behalf and under appropriate data processing agreements.
• Legal and regulatory authorities: We may disclose your information where required by law, court order, or government authority.

We do not sell, rent, or trade your personal information to any third party for their own marketing or commercial purposes.

5. AI Technology and Google AI Studio

In Short: Fridge First uses Google AI Studio to power its AI features. Data you input may be used by Google to improve its AI models. You should be aware of and accept this before using the Services.

All AI-powered features within Fridge First — including recipe generation, ingredient suggestions, meal plans, and grocery list creation — are powered by Google AI Studio, a third-party artificial intelligence platform operated by Google LLC.

Important: Data use by Google. When you interact with AI features in Fridge First, the content you provide (such as ingredient inputs, dietary preferences, and queries) is transmitted to Google AI Studio for processing. Google's standard terms of service for AI Studio may permit Google to use this data to train, improve, and refine its AI models. ZenSkayl Ltd does not control how Google processes data transmitted to Google AI Studio.

By using the AI features of Fridge First, you acknowledge and accept that:

• Your input data may be processed by Google AI Studio and may be used by Google in accordance with Google's own privacy policy and terms of service.
• You should not enter into Fridge First any information that you consider to be highly sensitive, confidential, or that you would not want processed by a third-party AI provider.
• ZenSkayl Ltd has no control over and accepts no responsibility for how Google processes data transmitted through Google AI Studio.

We encourage you to review Google's privacy policy at https://policies.google.com/privacy and Google AI Studio's terms of service for further information.

6. Payment Processing (DPO)

All payment processing for paid subscription tiers (Starter and Pro) is handled exclusively by DPO (by Network) Payments, our third-party payment provider.

ZenSkayl Ltd does not store, access, or process your payment card numbers, bank account details, or any other financial instrument data. When you make a payment, you are submitting your payment information directly to DPO's secure payment environment. ZenSkayl Ltd receives only a confirmation of a successful or failed transaction.

Please review DPO's privacy policy to understand how they collect, store, and use your payment data: https://dpogroup.com/privacy-policy/.

7. Do We Use Cookies and Tracking Technologies?

In Short: We may use limited cookies and similar technologies for essential app functionality and analytics.

We may use cookies or similar tracking technologies (such as local storage tokens) for the purpose of maintaining your logged-in session, remembering your preferences, and collecting anonymised usage analytics to improve the Services. We do not use tracking technologies for advertising or to build behavioural profiles for sale to third parties.

Most browsers allow you to control cookie settings. Disabling certain cookies may affect the functionality of the Services.

8. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to provide the Services and comply with our legal obligations.

We retain your personal information (first name, last name, and email address) for as long as your account is active or as needed to provide you with the Services. If you delete your account, we will delete or anonymise your personal information from our active databases within a reasonable period, unless we are required to retain it by applicable law (for example, for tax or fraud prevention purposes).

Anonymised and aggregated usage data that cannot identify you personally may be retained indefinitely for analytical purposes.

9. How Do We Keep Your Information Safe?

In Short: We implement reasonable technical and organisational security measures, but no system is perfectly secure.

We have implemented appropriate technical and organisational security measures to protect your personal information from unauthorised access, disclosure, alteration, and destruction. These measures include encrypted data transmission, secure server infrastructure, and access controls limiting who can access personal data.

However, please be aware that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You transmit information to us at your own risk.

10. Do We Collect Information from Minors?

In Short: We do not knowingly collect data from or market to children under 13 years of age.

The Services are not intended for children under the age of 13. We do not knowingly solicit, collect, or store personal information from children under 13. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at [email protected] and we will take steps to delete that information promptly.

11. What Are Your Privacy Rights?

In Short: Depending on your location, you may have rights to access, correct, or delete your personal information, and to withdraw consent.

Users in Mauritius have rights under the Data Protection Act 2017, including the right to access the personal data we hold about you, the right to request correction of inaccurate data, and the right to request erasure of your data in certain circumstances.

Users in the EU/EEA or UK have additional rights under the GDPR or UK GDPR, including the right to data portability, the right to object to processing, and the right to lodge a complaint with your local data protection authority.

To exercise any of your rights, please contact us at [email protected]. We will respond to all valid requests within the timeframes required by applicable law.

Withdrawing Consent

Where we process your information on the basis of your consent (for example, for marketing communications), you may withdraw your consent at any time by contacting us or using the unsubscribe link in any email we send. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

Account Deletion

You may request deletion of your account and associated personal data at any time by contacting us at [email protected]. We will process your request within a reasonable period. Please note that we may retain certain information where required by law or for legitimate business purposes such as fraud prevention.

12. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

13. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws and to reflect changes to our Services.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top of this notice. If we make material changes, we will notify you by prominently posting a notice within the app or by emailing you at the address associated with your account. We encourage you to review this Privacy Notice periodically.

14. How Can You Contact Us About This Notice?

If you have questions or concerns about this Privacy Notice or our data practices, please contact us at:

ZenSkayl Ltd
Email: [email protected]

15. How Can You Review, Update, or Delete the Data We Collect from You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we hold about you, to request that inaccuracies be corrected, or to request deletion of your personal information.

To exercise any of these rights, please email us at [email protected] with the subject line "Data Request" and a description of your request. We will respond within the timeframes required by applicable data protection law.