Privacy Policy - mmmEat Last updated: January 8, 2025 This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. Interpretation and Definitions Interpretation The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. Definitions For the purposes of this Privacy Policy: * Account means a unique account created for You to access our Service or parts of our Service. * Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority. * Application means the software program provided by the Company downloaded by You on any electronic device, named mmmEat. * Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California. * Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to mmmEat SAS, 10 rue de la Paix, 75002 Paris, France. For the purpose of the GDPR, the Company is the Data Controller. * Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose. * Country refers to: France * Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. * Device means any device that can access the Service such as a computer, a cellphone or a digital tablet. * Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. * Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You. * Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration. * Service refers to the Application. * Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors. * Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). * You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service. * Nutrition Professional means a healthcare professional specialized in nutrition (dietitian, nutritionist) using our platform to advise and monitor their patients/clients. * Health Data means information relating to the physical or mental health of a natural person, including allergies, diseases, dietary preferences and other medical information relevant for nutritional monitoring. Collecting and Using Your Personal Data Types of Data Collected Personal Data While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to: * Email address * First name and last name * Date of birth * Gender * Password (stored securely and encrypted) * Food allergies * Diseases or medical conditions relevant for nutritional monitoring * Dietary preferences * Usage Data Usage Data Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet application You use, unique device identifiers and other diagnostic data. We may also collect information that Your mobile device sends whenever You access the Service. Health Data - Special Processing As an application connecting users with nutrition professionals, mmmEat collects and processes health data considered as sensitive data under GDPR. This data includes: * Food allergies and intolerances * Medical conditions affecting diet * Medical history relevant for nutritional monitoring * Health and nutrition goals This data is collected solely for the purpose of enabling nutrition professionals to provide personalized and adapted advice. We apply enhanced security measures to protect this sensitive information. Use of Your Personal Data The Company may use Personal Data for the following purposes: * To provide and maintain our Service, including to monitor the usage of our Service. * To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user. * For connecting with nutrition professionals: facilitate the connection between users and qualified nutrition professionals for personalized monitoring. * For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service. * To contact You: To contact You by email or mobile application push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. * To manage Your requests: To attend and manage Your requests to Us. * For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience. We may share Your personal information in the following situations: * With Nutrition Professionals: We share Your personal information with the nutrition professionals You choose to consult via our platform. These professionals are subject to their own ethical and regulatory obligations regarding the confidentiality of health data. * With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You. * With Your consent: We may disclose Your personal information for any other purpose with Your consent. Retention of Your Personal Data The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Specific retention periods: * Active account data: retained as long as the account is active * Inactive account: an account is considered inactive after 2 years without login. Data may be deleted after this period * Login history: retained for a maximum of 30 days * Video call metadata: retained for a maximum of 30 days (content is not recorded) * Accounting data: retained according to French legal obligations (generally 10 years) The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. Transfer of Your Personal Data Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Data location: All data is stored on AWS servers located in Europe. No data transfer outside the European Union is performed. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information. Disclosure of Your Personal Data Law enforcement Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Other legal requirements The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: * Comply with a legal obligation * Protect and defend the rights or property of the Company * Prevent or investigate possible wrongdoing in connection with the Service * Protect the personal safety of Users of the Service or the public * Protect against legal liability Security of Your Personal Data The security of Your Personal Data is important to Us, but remember 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 Data, We cannot guarantee its absolute security. Security measures implemented: * Automatic encryption of data at rest via AWS * Passwords stored securely and encrypted * Restricted access to data according to the principle of least privilege * Monitoring of access and suspicious activities Incident response plan: In case of a personal data breach likely to result in a high risk to the rights and freedoms of natural persons, we commit to: 1. Notify the competent supervisory authority (CNIL) within 72 hours of becoming aware of the breach 2. Inform the data subjects without undue delay if the breach presents a high risk to their rights and freedoms 3. Document the breach and the measures taken to remedy it 4. Take all necessary measures to limit the consequences of the breach GDPR Privacy Legal Basis for Processing Personal Data under GDPR We may process Personal Data under the following conditions: * Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company. Our main legitimate interest is to facilitate the connection between users and nutrition professionals to enable personalized and adapted nutritional monitoring. * Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof. * Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject. * Consent: You have given Your consent for processing Personal Data for one or more specific purposes. In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. Your Rights under the GDPR The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to: * Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You. * Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected. * Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes. * Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it. * Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You. * Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service. Exercising of Your GDPR Data Protection Rights You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA. CCPA Privacy This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California. Categories of Personal Information Collected We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months. Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. * Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. Collected: Yes. * Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected: Yes. * Category C: Protected classification characteristics under California or federal law. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: No. * Category D: Commercial information. Examples: Records and history of products or services purchased or considered. Collected: No. * Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No. * Category F: Internet or other similar network activity. Examples: Interaction with our Service or advertisement. Collected: Yes. * Category G: Geolocation data. Examples: Approximate physical location. Collected: No. * Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No. * Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: No. * Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No. * Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No. Sources of Personal Information We obtain the categories of personal information listed above from the following categories of sources: * Directly from You. For example, from the forms You complete in our Application, preferences You express or provide through our Service. * Indirectly from You. For example, from observing Your activity in our Application. * Automatically from You. For example, through analytics We or our Service Providers collect as You navigate through our Application. Use of Personal Information for Business Purposes or Commercial Purposes We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples: * To operate our Service and provide You with our Service. * To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service. * To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. * To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. * As described to You when collecting Your personal information or as otherwise set forth in the CCPA. * For internal administrative and auditing purposes. * To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities. Sale of Personal Information We do not sell personal information to third parties for monetary or other valuable consideration. Your Rights under the CCPA The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights: * The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used. * The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. * The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. We do not sell personal information. * The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. * The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights. Exercising Your CCPA Data Protection Rights In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us by email: admin@mmmeat.com Sale of Personal Information of Minors Under 16 Years of Age We do not knowingly collect personal information from minors under the age of 16 through our Service. We do not sell the personal information of Consumers We actually know are less than 16 years of age. If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information. Children's Privacy Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information. Management of minors Our Service is not specifically addressed to persons under 16 years of age. However, we recognize that minors may use our service as part of nutritional monitoring. Responsibility of nutrition professionals: It is the responsibility of nutrition professionals using our platform to verify the age of their patients/clients and ensure that: * For minors under 16 years of age, appropriate parental consent has been obtained according to legal and ethical requirements * The proposed monitoring is appropriate for the patient/client's age * All professional and legal obligations regarding the treatment of minors are respected Our role: As a technological intermediary, we facilitate connections but are not responsible for age verification or obtaining parental consent. This responsibility lies entirely with the healthcare professionals. "Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA) Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser. Changes to this Privacy Policy We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Contact Us If you have any questions about this Privacy Policy, You can contact us: * By email: admin@mmmeat.com * By mail: mmmEat SAS, 10 rue de la Paix, 75002 Paris, France Data Controller: mmmEat SAS, represented by its President For any questions related to data protection or to exercise your GDPR rights, please use the email address above specifying the subject of your request.