This policy describes how Cal Clark handles information in the mobile app and on calclark.app. We collect what we need to log meals, keep an account, and run a paid plan. We do not sell meal photos or profiles.
Who is responsible
The controller of your personal data is:
Dominik Sosnowski
c/o Impressumservice Dein-Impressum
Stettiner Str. 41
35410 Hungen
Germany
Email: support@calclark.app
What we collect
- Account: email, and Apple or Google sign-in.
- Profile you give us: name, sex, date of birth, height, weight, target weight, activity, goal, units, language, optional meal reminders.
- Meals: photos you choose to send, typed descriptions, barcodes, drafted names and macros, grams you edit, saved meals.
- Purchases: whether you have Premium, through Apple or Google. We never see your card number.
- Diagnostics: crash reports, with photos and text hidden. In some versions of the app, basic usage stats in the EU. Never for ads.
Photos and AI
A photo or description you send goes to our servers in the EU, is stored privately with your account, and is sent to OpenRouter (USA) to draft the log. OpenRouter passes it to an AI model from Google (Gemini) or, if that model is down, OpenAI. We do not send your name or email with it. We then check food names against published US government nutrition tables that we keep on those servers. Your photos never go to USDA. The app names these companies and asks for your permission before the first meal is sent. If you say no, AI drafts stay off; search, barcode, and manual logging still work.
Partner codes
Creators we work with have their own code. If you enter a code when you sign up, we store:
- the code you entered, with the date;
- whether you subscribed or got a refund;
- for partners: their code, the partner agreement, commissions, statements and payout details.
We use this to pay partners and prevent misuse. A partner never learns who used their code: they only see totals. We send the code you entered to RevenueCat, which runs subscriptions for us, so it is stored there with your purchases.
If you delete your account, we delete the record of the code you entered. Existing payment records may be kept with an internal account ID only, as long as we need them for accounting and to prevent misuse. Until 18 October 2026 every account had its own code. Records of free months earned with those codes are kept the same way.
Who processes data for us
- Clerk - so you can sign in with Apple, Google, or email.
- Hetzner - servers in the EU that hold your account and diary.
- Cloudflare - private photo storage.
- OpenRouter (USA) - routes a meal photo or description to the AI model.
- Google (Gemini) and OpenAI (USA) - the AI models that draft the meal. They receive the photo or text, not your name or email.
- Apple, Google, and RevenueCat - payments and subscriptions, including the code you entered. We never see your card number.
- Open Food Facts and FatSecret - packaged product labels. FatSecret nutrition information is provided by the fatsecret Platform API.
- Sentry - crash reports, with photos and text hidden.
- Resend - sends the email that confirms your waitlist signup on calclark.app.
- PostHog (EU) - usage stats in the app, and on calclark.app which search engine or AI assistant brought a visit, which pages were opened and whether it ended in a waitlist signup. No cookie unless you allow device storage in the cookie banner. Never for ads.
- Meta, TikTok, X and Google - ad pixels on calclark.app, only if you allow them in the cookie banner. They let us show our ads again to people who visited the site and count waitlist signups.
- AppsFlyer - in the app, tells us which link or ad brought an install. Only if you allow AppsFlyer in the app (Settings, Privacy & cookie preferences).
- Meta - in the app, counts installs, app opens, free trials and subscriptions that came from our Facebook and Instagram ads. Only if you allow Meta in the app (Settings, Privacy & cookie preferences). On iOS, free trials, subscriptions and the advertising identifier also need your OK in Apple's tracking prompt.
What we do not do
- No ads shown in the app, no sale of meal photos.
- No social feed. Your log is not shown to other members.
- We use the advertising identifier only if you allow it in the app and, on iOS, in Apple's tracking prompt. Your meals and health data are never used for ads.
How long we keep it
Account and meals stay while the account is open. Delete account in Settings, or use the account deletion page. That removes your profile, meals, and photos. Short backups and legal records may remain for a limited time.
Your rights (GDPR)
If you live in the EU/EEA or UK you can ask for access, correction, deletion, restriction, portability, or objection. Write to support@calclark.app. You may also complain to your local data protection authority (in Poland: UODO).
Children
Cal Clark is not for people under 16.
International transfers
Your account and diary are stored in the EU. OpenRouter, Google, OpenAI, Clerk, RevenueCat, and Sentry are US companies and may handle data in the USA. Those transfers rely on the EU-US Data Privacy Framework where the company is certified, and otherwise on the European Commission's Standard Contractual Clauses. We use them only to run Cal Clark. If you allow Meta or AppsFlyer, they may also handle data outside the EU on the same basis.
Waitlist on this website
If you join the waitlist we store the email you typed, the language of the page, and when you signed up and confirmed. We send you one email with a link to confirm the address. Resend sends that email for us. We only tell confirmed addresses when the app is on the stores. We keep the address until you ask us to remove it or we close the waitlist. To remove it, write to support@calclark.app. We do not sell that list. If you allowed Meta or TikTok in the cookie banner, they get a scrambled (hashed) copy of the address to count the signup. See cookies.
Health-related data
Height, weight, goal, activity, and meal logs can say something about health. We use them to set a calorie and protein budget and to keep your diary. We do not use them for ads. Apple Health and Google Health Connect are not wired in this version.
When a photo leaves the phone
A photo or description is sent only after you choose to analyze it. The app asks once before the first estimate leaves the device. We do not run a background camera upload.
Lawful bases (GDPR)
- Account, meals, and the paid plan: the contract to run Cal Clark.
- Health-related profile (height, weight, goal, activity) and your diary: your explicit consent, given in the app before you enter them. Withdraw it by deleting the account.
- Meal photos and descriptions sent to AI: your explicit consent, asked before the first meal is sent. Withdraw it by not starting AI scans or by deleting the account.
- Partner codes: the contract (the discount you get with a code, and the partner agreement). Preventing misuse: legitimate interest. Partner payout records: legal obligation (tax and accounting).
- Waitlist email: your request to be notified.
- Security, invoices Apple or Google keep, and legal holds: legal obligation or legitimate interest in running a lawful service.
Supervisory authorities
You may complain to your local authority. In Poland that is UODO. In Germany the competent state commissioner (or BfDI for federal matters). In Spain AEPD. In the UK the ICO.
Changes
Material changes will be dated on this page.