BatchDog

Draft. This document has not yet been reviewed by a lawyer. Highlighted fields like {{…}} are details still to be provided.

BatchDog Privacy Policy

Version: draft 11, rev. 2026-10-26 · Effective date: {{EFFECTIVE_DATE}}

This policy explains what BatchDog collects, why, who else handles it and what you can do about it. We wrote it in plain language. If something is unclear, write to us at hello@relaxgames.studio.

Short version. We store what you enter so the app can plan meals for your family. Health details (allergies, pregnancy, conditions, medications, weight and your food diary) leave your device only if you give separate, explicit consent; without it they stay on your device, and you can withdraw consent at any time. We do not sell your data, show third-party ads or put third-party tracking tools in the app; we count how BatchDog is used on our own servers, and only if you turn on usage statistics do we collect them from the app and pass them under a pseudonym to PostHog, our analytics service in the EU; the bot may tell you about BatchDog+ once, and you can easily opt out. AI menus are made by our AI model provider (named in Subprocessors); we send it only what is needed to plan the menu, and neither we nor the provider train AI models on it. You can download or delete everything from the app.

1. Who we are

BatchDog is made by Relax Games Studio, the trade name of Maksim Paleyeu, a self-employed sole trader (autónomo) registered in Spain. They are responsible for your data (the "controller"):

Maksim Paleyeu, trading as Relax Games Studio, NIF Z2207759V
Address: Calle Sant Ignasi de Loiola 27, piso 4, puerta 10, 46008 Valencia, Spain
Privacy contact: hello@relaxgames.studio
Representatives in the United Kingdom and Switzerland: none; BatchDog is not offered there (see section 12)
Data protection officer: none appointed; write to the privacy contact above
Representatives and contacts in other countries, where the law requires them: see section 12

Because we are established in the EU, we do not need a separate EU representative. Our supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD, https://www.aepd.es). Legal information about the operator (aviso legal): Legal Notice.

BatchDog currently runs as a Telegram Mini App inside our Telegram bot. Web and mobile apps (iOS, Android) will follow; this policy covers all of them.

2. What we collect and why

What	Examples	Why we need it	Legal basis (GDPR)
Account	Telegram user ID, first and last name, username, language. A technical sign-in address `tg<ID>@tg.batchly.app` that never receives email	To sign you in, show your name to your family and send you reminders in Telegram	Contract (Art. 6(1)(b))
Profile and goals	Calorie and macro targets, diet type, foods you exclude, time zone, reminder settings	To plan menus that fit you	Contract (Art. 6(1)(b))
Health answers (only with consent)	Allergies and intolerances, pregnancy or breastfeeding, diagnoses such as diabetes or kidney disease, medications that interact with food	To leave out foods you tell us to avoid and to flag possible conflicts with your answers (these checks look for words and can miss ingredients)	Your explicit consent (Art. 9(2)(a) and Art. 6(1)(a)), see the Health Data Consent
Body data and food diary (only with consent)	Weight, height, age, sex, activity level, body measurements, target weight, your food diary and your Batchy (the dog character), which is calculated from it	To calculate your calorie needs and show your progress	Your explicit consent (Art. 9(2)(a) and Art. 6(1)(a)), a separate checkbox in the same consent
Family	Your family group, its members' names and roles, invitations	To share a pantry, recipes, menus and a shopping list	Contract (Art. 6(1)(b))
Family members without an account	Name, birth year, calorie target, diet and foods to avoid that an adult in the family enters. For a child under 18, also the child's food diary, but only if a parent or guardian consents. If an adult marks a child's diet as "Prescribed by a doctor", also that mark and when it was confirmed	To include them in family menus	Contract with the adult who enters the data (Art. 6(1)(b)); for a child's food diary, the consent of a parent or guardian (Art. 9(2)(a), Art. 8); for the "Prescribed by a doctor" mark, the explicit consent the parent or guardian gives when turning it on (Art. 9(2)(a)); see section 9
Consent records	Which consent you gave or withdrew, the version of the text, the language, the time; your confirmation that you are 18 or older	To prove that we asked for and recorded consent (Art. 7(1)) and to stop processing when you withdraw it	Legal obligation (Art. 6(1)(c))
Your kitchen	Pantry items and expiry dates, recipes, menus, cooking batches, shopping lists	This is the app	Contract (Art. 6(1)(b))
Game progress	Your Batchy's level, mood and daily scores	Part of the app; because Batchy is calculated from your food diary, it is stored with the body data consent	Explicit consent (Art. 9(2)(a))
Recipe imports	A recipe link or a photo of a recipe that you send	To turn it into a recipe in the app. We do not store the photo or the page, only the resulting recipe	Contract (Art. 6(1)(b))
AI usage counters	How many AI menus your family made per day; for each AI menu, how many days it covers and how many AI tokens it used	To apply plan limits, prevent abuse and measure what an AI menu costs us	Contract and legitimate interest (Art. 6(1)(f))
Interest in BatchDog+	Family-level marks, without your name or Telegram ID: when the bot sent a BatchDog+ reminder and whether the family turned it off	Not to send the reminder twice	Legitimate interest (Art. 6(1)(f))
Service statistics	Pseudonymous records of what our servers already do for you, without content: a menu was created, confirmed, shopped for and cooked; the profile was set up and the taste quiz completed (how many dishes you picked and rounds you skipped, the cooking skill you chose); which days of a menu cooked day by day were cooked or skipped (how many dishes); a draft menu was deleted; a complaint about an AI menu (how many reasons, not which ones or your comment) and its outcome; signing in to our apps with a code from the bot and where the code was requested; which kinds of bot reminders were sent (food diary reminders are not recorded); an AI menu or a recipe import worked or failed (error code, AI tokens used); sign-up, joining a family, invites; which consents were given or withdrawn; invoices, payments, refunds, withdrawals and cancellations (product and amount, not the reason you wrote); the days you used the app. Linked to your account and family IDs, not to your name or Telegram ID	To see whether BatchDog works and what it costs: first steps, return visits, the path from menu to cooking, payments, AI costs and failures	Legitimate interest (Art. 6(1)(f)); you can object
Usage statistics (only if you turn them on)	Which screens and buttons you use in the app: opening the app, starting a menu, "Eat" (without the dish or nutrition), liking a dish, importing a recipe, opening a delivery service (which one), sharing an invite, editing a menu by hand (the kind of change), sharing the weekly summary (how), the BatchDog+ offer shown, opening BatchDog+ (from where) and its buy buttons, app errors (type and screen, no text); the platform and app version	To understand which features help and to fix problems. With this consent we also pass these and the service statistics about you to PostHog under a pseudonym (see Statistics below)	Your consent (Art. 6(1)(a)); off by default
Payments (BatchDog+)	Payment ID, product, amount, date, status, refunds, and your Telegram ID as the payer. We never see your card details: Telegram processes payments in Telegram Stars (later also Apple, Google or Stripe)	To provide BatchDog+, handle refunds and keep the records tax law requires	Contract (Art. 6(1)(b)), legal obligation (Art. 6(1)(c))
Invites ("Invite a friend")	Your personal invite code; for each friend who opened your link: a pseudonymous code of their Telegram ID (calculated with a secret key, the ID itself is not stored), when the link was opened, whether it came through the app or the bot, whether and when the bonus days were given or why not. For a deleted account: the same pseudonymous code of its Telegram ID and the deletion date	To give bonus days for invites (section 4b of the Terms) and to prevent abuse: one bonus per person, no bonus for accounts we have seen before, including deleted and re-created ones	Contract for the bonus (Art. 6(1)(b)); legitimate interest in preventing abuse (Art. 6(1)(f))
Technical logs	IP address, device and browser type, request time, errors	To keep the service secure and fix problems	Legitimate interest (Art. 6(1)(f))
Sign-in codes	For signing in on the web and in our apps: the one-time sign-in code as a fingerprint calculated with a secret key (the code itself is not stored), your account ID, a fingerprint of the random code the app made for this sign-in if you used its button, when the code was created, until when it is valid and when it was used. For a wrong code: a pseudonymous code of the IP address (calculated with a secret key; the address itself is not stored) and the time	To sign you in to the same account outside Telegram and to stop codes from being guessed	Contract (Art. 6(1)(b)); legitimate interest in security (Art. 6(1)(f))
Support messages	What you write to us and our replies	To help you	Contract and legitimate interest

Messages from the bot. The bot sends service messages: the reminders you set up in Profile and payment confirmations. Apart from these, once your family's free AI menu days run out or fewer than 3 are left, it may send one promotional message about BatchDog+, and only if your reminders are on. A button in that message turns it off for the whole family; you can turn off all reminders in Profile. The "Batchy is hungry" reminder uses your food diary, so it is sent only if you consented to body data.

What we do not collect. We do not put advertising SDKs or third-party analytics or tracking tools in the app, we do not track you across other apps or websites, and we do not access your Telegram contacts or chats. If you turn on usage statistics, our server passes pseudonymous events to PostHog (see Statistics below); the app itself does not load anything from PostHog.

On your device. The app keeps a copy of your data on your device (browser storage, IndexedDB) so it works offline. Deleting the app or clearing its storage removes this copy. Deleting your account from the app removes it too, and withdrawing a consent removes the data of that consent from the device as well as from our servers. Your other devices remove it at their next sync, including a device that was offline at the time. If you turn on usage statistics, events not yet sent wait there for up to 7 days.

You decide what to enter and where it is kept. Only your Telegram account is required. When you sign in, the app asks for the health data consent before it sends any health data; nothing is ticked in advance. If you choose "Keep on this device only", BatchDog works the same on that device: it still calculates your targets, keeps your diary and checks menus against your answers, but that data is not sent to our servers, is not shown to your family, is not used in AI menus and is not on your other devices. This choice works offline and deletes nothing. If health data was already on our servers from an earlier version of the app, it is not deleted at once: your personal copy is visible only to you, and the copy in your shared profile has been removed (your family sees your health answers only if you consented to show them). We delete the personal copy in a scheduled clean-up of data without consent, which we will announce in the app.

Statistics

We measure how BatchDog is used in our own database in the EU. Service statistics come from what our servers already do for you; we keep them on the basis of legitimate interest, and if you object, write to us and we delete them. Without your consent they stay in our database and are not passed to anyone. Usage statistics from the app are sent only if you turn them on in Profile → Data & privacy → Usage statistics. The app asks you about this once, with equal “Yes” and “No” buttons; “No” or closing the question means they stay off, and we do not ask again on any of your devices. If you agreed to an earlier version of this text, under which statistics stayed in our database only, the app asks you once more. They are off by default and can be turned off in the same place at any time. Statistics never contain dish names, nutrition, weight, your food diary, health answers, text you typed or your IP address.

PostHog. If you turn on usage statistics, our server passes your usage statistics and the service statistics about you, from the moment you consented, to PostHog, our analytics service (PostHog Inc.; data stored in the EU, in Frankfurt), about once an hour. Before sending, we replace the IDs of your account, your family and objects with pseudonyms calculated with a secret key that PostHog does not have, so PostHog cannot link the events to you or your Telegram account. PostHog does not create a profile of you, does not determine your location and does not receive your IP address, because the data is sent by our server, not by your device. "Eat" entries from your food diary and records of your consents are never sent. The app itself contains no PostHog code or cookies, and there is no session recording. Turning usage statistics off stops sending at once and deletes the app's statistics from our servers and your device at once. What PostHog has already received is not deleted at once: it carries only pseudonyms, so PostHog cannot find it for a person; it is deleted when PostHog's retention period ends (up to 7 years).

3. AI features

BatchDog uses an AI model from our AI model provider (named in Subprocessors) to create menus and to read recipes from links and photos. Menus, recipes, cooking plans and nutrition figures produced this way are AI-generated and can contain mistakes.

When you ask for an AI menu, we send the AI model provider: the number of days, calorie targets, your diet description, foods to avoid, the items in your pantry, your budget if you set one, and, for a family menu, each member's first name and calorie target. Foods to avoid that come from your health answers (for example "peanuts" for a peanut allergy) are sent only if you consented to health answers or to food restrictions. Without either, the app does not request an AI menu if you have allergies or restrictions: it explains why and your AI menu allowance is not used. A menu without AI still works and is checked against your answers on your device. We do not send your Telegram ID, your weight, your diagnoses or medications by name, or your food diary. For recipe imports we send the page text or the photo.

The AI model provider processes this data for us under a data processing agreement, does not use it to train its models, and deletes it within the period stated in Subprocessors (currently 30 days). We do not use your personal data to train large language models, and our AI model provider does not use it for training either. If we replace the AI model provider while the purpose, the data sent, the data processing agreement, the no-training commitment, the retention period and the level of protection stay the same, we update the Subprocessors list and announce the change in the app and in the bot at least 14 days before the switch. If the country or transfer safeguards, the retention period or the training terms change, we ask for your consent again before sending health data to the new provider. Do not put personal information in recipe photos.

AI is not used to make decisions about you that have legal or similarly significant effects (GDPR Art. 22). The app's suggestions are not medical advice; see the Terms of Service.

Your family. Members of your family group can see the shared pantry, recipes, menus and shopping list, the family members without an account, your name, targets and diet, and your Batchy if you consented to body data. They see your health answers only if you gave the separate consent "show my health answers to my family". With the consent "food restrictions for family and AI" they see only what you must not eat (allergens and restrictions such as "no peanuts"), so that a family menu one of them builds takes it into account. Without it, they see "food restrictions unknown" and must leave you out of the menu or confirm that they will check it themselves. Your food diary, weight and body data are visible only to you. A child's food diary is visible to the whole family if a parent or guardian consented. Think about this before you join a family or invite someone. If you add a family member without an account, please tell them, or for a child the other parent, what you entered and where to find this policy.

Service providers (processors). We use a small number of companies to run BatchDog. They may process data only on our instructions and under a data processing agreement. The current list, with what each one does and where, is in Subprocessors: Supabase (database, EU), Cloudflare (servers and hosting), our AI model provider (AI menus and recipe import), PostHog (usage statistics, EU, only with your consent), and later Stripe, Apple and Google for payments.

Telegram runs the platform BatchDog lives on and is a separate controller for what you do in Telegram; see the Telegram Privacy Policy (https://telegram.org/privacy). Telegram does not get your BatchDog data from us, except the messages our bot sends you, including the data export file if you ask the bot to send it.

Others. We share data with authorities only when the law requires it, and with a buyer or successor only if BatchDog is sold, under this policy. We do not sell your personal data and do not share it for targeted advertising.

5. International transfers

Our database is in the European Union (Frankfurt, Germany). Some providers process data outside the EU, mainly in the United States (Cloudflare's network is global; the AI model provider may process AI requests outside the EU, currently in the US, see Subprocessors). PostHog stores statistics in the EU (Frankfurt), but PostHog Inc. is a US company, so access from the US cannot be ruled out; this is covered by its data processing agreement with the Standard Contractual Clauses. We protect these transfers with the EU-US Data Privacy Framework where the provider is certified, and otherwise with the European Commission's Standard Contractual Clauses (GDPR Art. 46). For UK users, we rely on the UK Extension to the EU-US Data Privacy Framework where the recipient is certified and otherwise on the UK International Data Transfer Addendum to the Standard Contractual Clauses. For users in Switzerland, we rely on the Swiss-US Data Privacy Framework where the recipient is certified and otherwise on the Standard Contractual Clauses with the amendments required by Swiss law. You can ask us for a copy of these safeguards.

If you live outside the EU. Your data is stored in the EU and processed in the countries named above, so it leaves your country when you use BatchDog. What your country's law requires us to tell you about these transfers, and the safeguards we use, is in section 12.

6. How long we keep data

Your account data: while you have an account. When you delete it, it is erased from the live database at once, together with your consent records, and the copy on your device is erased too.
Shared family content: while the family exists. If you delete your account and others stay in the family, the shared pantry, recipes and menus stay with them, with your name removed from family menus. If you were the last member, the whole family is deleted.
Health consent: if you withdraw a consent, we delete the data of that consent from the live database and from your device at once. Withdrawing the consent to health answers also ends showing them to your family.
Family members without an account: when you remove one, their profile and food diary are deleted for the whole family; old menus keep only the first name. When a child turns 18 (by birth year), the parent's consent for their diary ends and the diary is deleted.
Backups: up to 30 days, then overwritten.
Technical logs: up to 7 days.
Sign-in codes and failed attempts: deleted after 24 hours.
AI requests at the AI model provider: deleted within the period stated in Subprocessors (currently 30 days).
Payment records: as long as tax and accounting law requires, currently 6 years after the end of the year of payment (Spanish Commercial Code, Art. 30). After you delete the account, your Telegram ID in them is kept for about 90 days after the later of the end of the paid period and the deletion, then replaced with a pseudonymous code. The code is calculated from the Telegram ID with a secret key, so it is still personal data (pseudonymised, not anonymous): it lets us match a later refund or dispute to the payment without storing your ID.
Invites: a link opening without a new account is deleted after 90 days; a decided invite (bonus given or refused) and the pseudonymous code of a deleted account are kept for 2 years against abuse, then deleted. Bonus days already given stay on the family balance.
Statistics: records with your account ID are kept for 13 months, then only daily totals without any ID remain. They are deleted with your account; turning usage statistics off deletes the app's statistics at once. Copies sent to PostHog with your consent are kept there for up to 7 years and are not deleted per person, because they carry only pseudonyms.

Details: data retention schedule, available on request.

7. Your rights

You can at any time:

See and download your data (access and portability, GDPR Arts. 15 and 20): Profile → Data & privacy → Download my data. You get a JSON file with your profile, consents, diary, family and payments; in Telegram the bot sends it to you, at most once every 10 minutes. The same screen also saves the data held on your device, including data kept on this device only.
Correct it (Art. 16): edit it in the app.
Delete your account and data (Art. 17): Profile → Data & privacy → Delete account, or send /deletedata to the bot for instructions. Step by step, how to delete only some data and what we keep: Delete your account or data.
Withdraw consent (Art. 7(3)): Profile → Data & privacy → Consents → Withdraw, separately for health answers, body data, food restrictions for family and AI, showing answers to your family, and for each child's diary. Withdrawing is as easy as giving consent. We then delete the data of that consent from our servers and your device; the app keeps working with that data on the device only if you enter it again. Withdrawal does not affect processing done before it. Usage statistics are turned off on the same screen, under Usage statistics.
Restrict or object to processing based on legitimate interest (Arts. 18 and 21). For statistics, write to us and we delete the records linked to your account.
Complain to a data protection authority: the Spanish AEPD (https://www.aepd.es) or the authority of the EU country where you live or work, or, outside the EU, the authority of your country (see section 12). We would appreciate the chance to fix things first: hello@relaxgames.studio.
United Kingdom. You can complain to us first at hello@relaxgames.studio; we acknowledge your complaint within 30 days and tell you the outcome without undue delay. You can also complain to the Information Commissioner's Office (ico.org.uk).

We reply within one month (extendable by two months for complex requests, with notice). We may need to confirm it is you, usually by asking you to write from the Telegram account linked to BatchDog.

8. United States

California

CCPA/CPRA notice. In the last 12 months we collected these categories: identifiers (Telegram ID, name, username); personal records; sensitive personal information (health information, when you consent); internet activity (technical logs); and inferences (calorie targets). Sources: you and your device. Purposes: those in section 2. We do not sell or share personal information for cross-context behavioral advertising, and we use sensitive personal information only to provide the service you asked for. You have the right to know, delete, correct and opt out of sale or sharing, and not to be discriminated against for using these rights. Use the in-app tools or write to hello@relaxgames.studio; an authorized agent may act for you with your written permission.

Consumer health data

Our Consumer Health Data Privacy Policy (Washington My Health My Data Act, Nevada SB 370, Connecticut Data Privacy Act and similar laws) is a separate page: Consumer Health Data Privacy Policy. It lists what consumer health data we collect, where it comes from, how we use and share it and how to use your rights.

Other US states

If you live in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, Nebraska or another state with a consumer privacy law, you can ask us to confirm whether we process your personal data, to access, correct and delete it, and to get a copy in a portable format. These laws also let you opt out of targeted advertising, the sale of personal data and profiling with legal or similarly significant effects; we do none of these, so a Global Privacy Control signal or an opt-out request changes nothing for you. We process sensitive data (health information, including conditions and diagnoses) only with your consent and only to provide the features you asked for (see the Health Data Consent), and we never sell it. Use the in-app tools or write to hello@relaxgames.studio; we answer within 45 days, extended once by 45 days where the law allows and we tell you why.

Appeals (US)

If we decline your privacy request, you can appeal by replying to our decision within 60 days. We will answer within 60 days (45 days where your state requires). If we deny your appeal, you can contact your state Attorney General.

Breach notification

If health data is ever accessed or disclosed without authorization, we will notify you and the authorities as required, including under the FTC Health Breach Notification Rule.

9. Children

You must be at least 18 to create your own BatchDog account, wherever you live. When you first open the app we ask you to confirm that you are 18 or older; if you answer that you are younger, the app asks you to confirm and then does not let you continue on that device. The data already on the device stays there and can be saved as a file, and "I made a mistake" asks your age again. We do not knowingly let anyone under 18 have their own account.

Parents and guardians can add a child to their family without an account: a name, birth year, calorie target, diet and foods to avoid. The child does not use BatchDog. Use a first name or nickname only. The child's food diary is stored on our servers and shown to the family only if a parent or legal guardian ticks the consent in the child's card (Family → Edit). Where the child is old enough to consent under local law (for example 14 in Spain), the parent confirms that the child agrees. Without that consent the diary stays on the device where it was entered. No one can give consent for another adult: for a family member without an account who is 18 or older (or whose birth year is not given), BatchDog stores only the name, calorie target, diet and foods to avoid, and their diary stays on the device.

You can withdraw the consent for a child or remove the child at any time (Profile → Data & privacy, or Family). Removing a child deletes their profile and diary for the whole family. If you think a child has an account or that we hold a child's data without permission, write to hello@relaxgames.studio and we will delete it.

10. Security

Data is encrypted in transit (HTTPS) and at rest in our database. Every family can read only its own data, enforced in the database itself; your private profile (body data and health answers you did not share) can be read only by you. The database also refuses health data for which there is no consent record. Server keys are kept in secret storage and are never in the app. Only people who need it for their work have access to production systems. If a breach puts your rights at risk, we will tell the authority within 72 hours and tell you without undue delay (GDPR Arts. 33 and 34).

11. Changes

We will post changes here with a new effective date. If a change is significant, we will tell you in the app or through the bot before it takes effect, and ask for consent again where the law requires it.

12. Information for your country

BatchDog is run from Spain and applies this policy, built on the GDPR, to everyone. The law of the country where you live may give you more rights or require us to tell you more; this section adds what it requires. Where it says more than the rest of this policy, it applies to you. The rights in section 7 and the tools in Profile → Data & privacy work in every country.

United Kingdom

BatchDog is not offered in the United Kingdom at the moment (Terms, section 18), and we have not appointed a representative there. If the UK GDPR and the Data Protection Act 2018 apply to your use of BatchDog anyway, references to GDPR articles in this policy mean the same articles of the UK GDPR, transfers from the UK are described in section 5, and complaints in section 7. BatchDog is meant for adults (section 9): it does not profile anyone for marketing, does not use your location and keeps the most protective settings by default.

Switzerland

The Federal Act on Data Protection (FADP) applies. Health data is sensitive personal data; we process it only with your explicit consent. BatchDog is not offered in Switzerland at the moment (Terms, section 18), and we have not appointed a representative there: the FADP requires one (Art. 14) only where processing is connected with offering services in Switzerland and is large-scale, regular and high-risk at the same time. Your data is disclosed to recipients in Germany and other EU countries, which Switzerland recognises as providing adequate protection, and in the United States (safeguards: section 5); Cloudflare's network handles requests in the data centre nearest to you. You can complain to the Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch).

Brazil

The General Data Protection Law (LGPD, Law 13,709/2018) applies. We process your data for the purposes in section 2 on these legal bases: performance of a contract (Art. 7, V), compliance with a legal obligation (Art. 7, II), legitimate interest (Art. 7, IX) and consent (Art. 7, I). Health data is sensitive personal data: we process it only with your specific and highlighted consent (Art. 11, I), given in the Health Data Consent. Your rights (Art. 18): confirmation that we process your data, access, correction, anonymisation, blocking or deletion of unnecessary or excessive data, portability, information about whom we share it with, information about the possibility of not consenting and what that means, withdrawal of consent, and petition to the National Data Protection Authority (ANPD, gov.br/anpd). Our person in charge of data protection (encarregado) is Maksim Paleyeu, hello@relaxgames.studio; you can write to hello@relaxgames.studio in Portuguese. International transfers (Art. 33): our providers are in the EU and the United States (section 5); we transfer data under the ANPD's standard contractual clauses where our provider has agreed to them, because it is necessary to perform our contract with you (Art. 33, IX), and health data on the basis of your specific consent (Art. 33, VIII). A child's data is processed only with the specific consent of a parent or guardian (Art. 14; section 9).

Canada

The Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial laws apply, including Quebec's Act respecting the protection of personal information in the private sector. The person in charge of the protection of personal information is Maksim Paleyeu, hello@relaxgames.studio. We collect health information only with your express consent. Your information is stored and processed outside Canada, in the EU and the United States (section 5), and may be accessible to the courts and authorities of those countries. Before personal information of Quebec residents is communicated outside Quebec, we assess whether it will be adequately protected (privacy impact assessment). Our settings are the most protective by default: usage statistics are off, and health data stays on your device until you consent. Quebec residents can also ask for their computerised data in a structured, commonly used format. The one promotional message about BatchDog+ that the bot may send (section 2) names us and has a button to turn it off. You can complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca) or, in Quebec, to the Commission d'accès à l'information (cai.gouv.qc.ca).

Australia and New Zealand

Australia. The Privacy Act 1988 and the Australian Privacy Principles apply. Health information is sensitive information; we collect it only with your consent. We disclose personal information to overseas recipients in Germany and other EU countries and in the United States, and Cloudflare handles requests in the data centre nearest to you; our data processing agreements require them to protect it to a standard comparable to the Australian Privacy Principles. Please complain to us first; if we have not resolved your complaint within 30 days, you can complain to the Office of the Australian Information Commissioner (oaic.gov.au).

New Zealand. The Privacy Act 2020 applies. We disclose personal information overseas (section 5) only to providers bound by contract to protect it in a way comparable to New Zealand law. When you add a family member, please let them know (section 4). You can complain to the Privacy Commissioner (privacy.org.nz).

Japan

The Act on the Protection of Personal Information (APPI) applies. Business operator: Maksim Paleyeu (Relax Games Studio), address in section 1, represented by Maksim Paleyeu. Purposes of use: section 2. We obtain special care-required personal information (such as medical history and conditions) only with your prior consent. We entrust the handling of personal data to the providers in section 4. Some are in foreign countries: in the EU, which Japan's Personal Information Protection Commission recognises as having a system equivalent to Japan's, and in the United States, which has no comprehensive federal privacy law; the US providers are bound by contract to measures equivalent to those required of us under the APPI, we check that they continue to take them, and we give you information about them on request. Security control measures: a basic policy and handling rules; one responsible person and an incident procedure; confidentiality for everyone with access; no paper records, and data only in our providers' secured data centres; access control, encryption in transit and at rest, and family-level access rules in the database. We store data in Germany (EU) and process it in the United States, and take these measures knowing those countries' systems for the protection of personal information. To ask for disclosure, correction, suspension of use, deletion or the records of provision to third parties, use the in-app tools or write to hello@relaxgames.studio; there is no fee.

South Korea

The Personal Information Protection Act (PIPA) applies. Our chief privacy officer is Maksim Paleyeu, hello@relaxgames.studio. We process health information, which is sensitive information, only with your separate consent. When a retention period in section 6 ends, we delete the data so that it cannot be restored. To provide BatchDog we transfer personal information overseas as follows (PIPA Art. 28-8):

Recipient	Country	Personal information	Purpose	When and how	Retention
Supabase, Inc. (supabase.com)	Germany	All data stored in BatchDog	Database and sign-in	Over the network whenever you use the app	As in section 6
Cloudflare, Inc. (cloudflare.com)	United States and the data centre nearest to you	Data passing between your device and the database, IP address, request logs	Hosting and network	Over the network with every request	Logs up to 7 days
Our AI model provider (named in Subprocessors)	United States	Menu settings, food restrictions (with consent), pantry items, first names, recipe text or photo	AI menus and recipe import	Over the network when you ask for an AI menu or an import	Up to 30 days
PostHog Inc. (posthog.com)	Germany	Pseudonymous usage events	Usage statistics, only with your consent	Over the network about once an hour	Up to 7 years

You can refuse these transfers. BatchDog cannot work without the first two, so refusing them means deleting your account; data goes to the AI model provider only when you ask for an AI menu or an import, and to PostHog only if you turn on usage statistics. For help or remedies you can contact the Personal Information Dispute Mediation Committee (kopico.go.kr) or the Personal Information Infringement Report Center (privacy.kisa.or.kr, phone 118).

India

The Digital Personal Data Protection Act 2023 and its Rules apply as they come into force. We are the data fiduciary. You can get a summary of your personal data and of whom we shared it with, correct, complete, update and erase it, withdraw consent, have your grievances redressed, and nominate another person to exercise your rights if you die or become unable to do so (write to us). Grievances: Maksim Paleyeu, hello@relaxgames.studio; we answer within 30 days at most. If you are not satisfied, you can complain to the Data Protection Board of India. We process a child's data only with the consent of a parent or lawful guardian (section 9), and we do not track or monitor the behaviour of children or target advertising at them.

Turkey

The Personal Data Protection Law No. 6698 (KVKK) applies. We are the data controller. BatchDog is not yet offered in Turkey (Terms, section 18), so we have not yet appointed a data controller representative in Turkey or registered in VERBIS; we will do both before we offer BatchDog there. We process your data for the purposes in section 2 because it is necessary for our contract with you, to comply with legal obligations, for our legitimate interests or with your explicit consent (Art. 5); health data, a special category, only with your explicit consent (Art. 6). We transfer data abroad (section 5) under standard contracts notified to the Personal Data Protection Authority (Art. 9). Your rights (Art. 11): to learn whether we process your data and to get information about it, its purpose and the recipients in Turkey and abroad, to have it corrected or erased and the recipients told, to object to a result against you that comes only from automated analysis, and to claim compensation for damage caused by unlawful processing. Write to us first; we answer within 30 days free of charge. You can then complain to the Personal Data Protection Board (kvkk.gov.tr).

Belarus

The Law of the Republic of Belarus No. 99-Z "On Personal Data Protection" applies. Health data is special personal data; we process it only with your consent. Your data is transferred to Germany and other EU countries and to the United States (section 5). The United States has no comprehensive data protection law comparable to Belarusian law, so the protection there may be lower and US authorities may obtain access to data under US law; we reduce this risk with contracts that bind our providers, by sending the AI model provider only what a menu needs, and by sending food restrictions that come from your health answers only with your consent. We transfer data abroad because it is necessary to perform our contract with you, and health data on the basis of your consent (Health Data Consent). You can ask what data we process and why, get it, have it corrected or deleted, withdraw consent and find out to whom we provided it: use the in-app tools or write to hello@relaxgames.studio, and we answer within the time the Law sets. You can complain to the National Personal Data Protection Center (cpd.by).

Gulf countries

If you live in Saudi Arabia, the United Arab Emirates, Qatar, Bahrain, Oman or Kuwait, your country's personal data protection law applies. You can ask to be informed about the processing, to access and get a copy of your data, to have it corrected or deleted, and to withdraw consent. We process health data only with your explicit consent. Your data is transferred to the EU and the United States (section 5) under contracts that bind our providers to protect it, as your country's transfer rules allow. In Saudi Arabia you can complain to the Saudi Data and AI Authority (SDAIA, sdaia.gov.sa).

Other countries

If you live elsewhere, for example in Singapore, Malaysia, Thailand, the Philippines, Mexico, Argentina, Chile, Colombia or South Africa, your national data protection law may apply. We apply this policy to you in full, process health data only with your explicit consent, protect transfers out of your country with contracts that bind our providers (section 5), and answer requests within the time your law sets and no later than one month. You can complain to your national data protection authority. If your law requires something this policy does not cover, write to us at hello@relaxgames.studio.

13. Contact

Maksim Paleyeu (Relax Games Studio), Calle Sant Ignasi de Loiola 27, piso 4, puerta 10, 46008 Valencia, Spain. Email: hello@relaxgames.studio. In Telegram: send /privacy to the bot.