Privacy Policy

This Privacy Policy explains how Shivendra Ananthan Chelliah, the independent developer and operator of Moraea (“Moraea,” “we,” “us,” or “our”), collects, uses, shares, retains, and protects personal information. It applies to:

• The Moraea website at caltrakplus.app, including the marketing/launch pages, any waitlist signup surfaces that may be available from time to time, signed unsubscribe and exit-survey pages, and this policy (the “Site”); and
• The Moraea mobile application for iOS (the “App”), a personal health- and nutrition-tracking tool for people using GLP-1 and other weight-management medications.

Together, the Site and the App are the “Services.” By using the Services, you acknowledge the practices described here. If you do not agree with this policy, please do not use the Services.

Moraea is a personal tracking tool. It is not a medical device and does not provide medical advice, diagnosis, or treatment. We are not a healthcare provider, health plan, or healthcare clearinghouse, and we are not a “covered entity” or “business associate” under the U.S. Health Insurance Portability and Accountability Act (HIPAA). Some information you enter may nonetheless qualify as “consumer health data” under newer U.S. state laws; see Section 15.

The data controller (and the “business” under U.S. state privacy laws) responsible for your personal information is:

Shivendra Ananthan Chelliah (operating as Moraea), an independent developer based in Malaysia.
Email: developer@rainfroglabs.com

For any privacy question, request, or complaint, contact us at the email above. We are a solo independent developer and do not currently maintain a separate data protection officer. The developer is the privacy contact for the Services. We do not currently maintain an EU/UK Article 27 representative; see Section 15 for the resulting availability limitation and compliance notice.

Moraea is designed to keep your most sensitive information on your own device wherever possible:

• Your food, water, weight, dose, side-effect, and chat logs are stored on your device by default, not on our servers.
• The limited data we do hold on our servers (your account, subscription status, security/abuse-prevention records, and any legacy Friends/Circle records created by an older app version) is described in Section 4 and kept to what each feature needs.
• Optional analytics and crash reporting are off by default, separate from your health data, and never include the contents of your logs, chats, or photos.
• We do not sell your personal information, we do not sell or share your consumer health data, and we do not use your information for cross-context behavioral advertising or third-party ad targeting.
• We do not use Apple Health (HealthKit) data for advertising or marketing, and we do not share it with third parties.

4.1 Information you provide on the Site (waitlist and email)

• Email address. If you joined (or later join) the Moraea waitlist, we collect the email address you submit and store it in normalized form (trimmed and lowercased) so we can manage signups consistently and email you: launch and availability notices, occasional Moraea product updates, occasional requests for your feedback, and occasional news about other apps we develop. The Site primarily drives App Store downloads; waitlist signup may not always be shown, but emails already collected, and any future waitlist submissions, continue to be processed as described here. Every such email includes a way to unsubscribe, and unsubscribing stops all of these emails. We do not ask for your name, health information, or payment details on the Site, and we never rent, sell, or share your email with other companies for their own marketing. Transactional and marketing emails are sent through our email delivery provider (see Section 9).
• Optional in-app feedback email. In the App (Profile → Feedback email), you may separately opt in to product-feedback emails by entering an email address. You may choose to use your Apple Sign in email, an Apple private relay address, or another address you control. We use that address only for occasional product research, including a short exit survey if you later turn off App Store auto-renew or your subscription expires. This is not advertising or marketing for unrelated products. Every feedback email includes an unsubscribe link; unsubscribing (or turning the preference off in Settings) revokes this consent. We do not silently use your Apple Sign-In email for this purpose without your opt-in.
• Exit-survey responses. If you opted into feedback email and later cancel renewals (or your subscription expires), we may email a signed link to a short survey on the Site. The survey asks why you left and one follow-up based on that reason (for example, a price range you would consider, features you wanted, or which app you switched to). We store your selected reason, the follow-up answer, and any optional short note you submit, together with a reference to the survey send and your account identifier, so we can improve Moraea. Survey answers are product research. Please do not include medical details, photos, or other sensitive health information. Links are signed so only the intended recipient can submit; we rate-limit the survey API.

4.2 Information collected automatically on the Site

When you visit the Site or submit the waitlist form, our hosting and analytics providers may process limited technical information, including:

• Pages viewed and approximate visit timing
• Referring URL or link that brought you to the Site
• Browser type, device type, operating system, and language
• IP address and similar network identifiers in server and platform logs

To reduce abuse of the waitlist form, our server temporarily uses your IP address, and the email you submit, in short-lived in-memory rate limiters (for example, a per-IP, a per-email, and an overall limit). These counters are held only transiently in server memory, are not written to our waitlist database, and are not retained as a permanent record.

4.3 Information stored on your device in the App

The App is built so that your health and lifestyle data stays on your device by default. We do not receive this content on our servers except where a specific cloud feature below requires it. On-device data includes:

• Food, water, weight, dose, and side-effect logs; custom foods; and clinician export PDFs you generate. Dose entries may include optional notes and related measurements you choose to record (such as waist, glucose, or blood pressure). Food entries may be created from typing, photos, barcode scans, voice dictation, chat, or saved favorites.
• Your conversations with “Eve AI,” the in-app AI food assistant (chat history is kept on your device)
• Profile details (such as name, sex, height, birth date, weight goals, activity level, medication and dosing schedule, chatbot name and tone preferences, and a profile photo if you add one) and your nutrition targets

Depending on your iOS backup settings, Apple may include local App data in an encrypted device or iCloud backup. Those backups are controlled by Apple and your Apple-account settings, not stored on Moraea servers, and may persist until you delete the applicable backup.

Your profile photo is stored on your device and is not uploaded to our servers or shown to other users. Home-screen widgets, if you add them, read a limited snapshot of on-device data through an App Group on your device; that widget data is not sent to our servers.

4.4 Account information and authentication

After onboarding, you must authenticate to use the App. Sign-in is also required for online AI features. Sign in with Apple is the primary sign-in method; a passwordless email code is supported and may be offered in some app versions. Older app versions additionally used the same account for Friends/Circle.

• Sign in with Apple. Apple provides an identity token and, depending on your choices, your name (the first time) and either your email address or a private Apple relay email.
• Passwordless email (where offered). If you sign in with an email code, we send a short-lived one-time code to the email address you provide. Supabase stores the normalized address as your account credential; Resend delivers the code. A non-persistent Cloudflare Turnstile challenge helps prevent automated abuse and may process your IP address, device/browser signals, challenge outcome, and a short-lived challenge token. We do not receive a password.

Supabase exchanges the selected credential for a session stored in the device Keychain. The server account includes a user identifier and the associated email or Apple relay email. We use an authentication email only to create, secure, and communicate about your account; it is not enrolled in product-feedback, exit-survey, or marketing email unless you separately opt in as described in Section 4.1. Server-side, identity is derived from the signed session token rather than an account identifier supplied in a request body.

4.5 Eve AI, the AI food assistant

When you choose to use Eve AI, your device sends a request to our relay (a Supabase Edge Function), which routes it through the Vercel AI Gateway to third-party AI providers so they can estimate the nutritional content of your meal. Each request may include:

• The meal description or message you type (or the text produced after on-device voice dictation)
• Any meal photo you attach
• Recent chat text from the same conversation (up to about the last 10 messages), so the assistant can keep context
• Names of your frequent meals from the last 30 days (meal names only, not full macros or photos)
• Your local time of day, and your chosen assistant name and writing tone

Routing is server-controlled and may change as models improve. In the current design, text requests are handled primarily by OpenAI through the Vercel AI Gateway; photo requests first use Google for bounded visual evidence and then OpenAI for the nutrition estimate, with reciprocal fallbacks if a provider is unavailable. Eve may also use Perplexity-powered nutrition web search to look up published nutrition facts for branded or restaurant foods. The first time you open the chat, the App requires you to acknowledge an in-app notice that these messages and photos leave your device. We do not store the meal text or photos in our database; they are processed to return your estimate. We do not use your Eve requests to train our own AI models, and we mark gateway requests so prompt training is disallowed. Providers may still retain request content for a limited period for abuse monitoring, security, or legal compliance under their applicable terms.

4.6 Progress AI insights

If you choose to generate a Progress AI insight, the App sends a small weekly aggregate snapshot to our Supabase relay, which forwards it through the Vercel AI Gateway to third-party AI providers (currently OpenAI as primary and Google as an availability fallback). This snapshot may include weight progress, protein, hydration and calorie averages, days logged, weigh-in count, and the targets you set in the App. The App requires a separate in-app acknowledgment before sending this snapshot. We do not send detailed food names, dose entries, side-effect notes, chat text, photos, or raw HealthKit samples for this feature, and we do not store the snapshot in our database. As with Eve AI, we do not use these snapshots to train our own models, and we apply available no-training configuration on supported providers.

4.7 Daily AI breakdowns

If you choose a daily AI breakdown, the App sends an allowlisted snapshot for the selected calendar date to our Supabase relay and then through the Vercel AI Gateway to OpenAI. It may include the date key; food, water, weight, dose, and side-effect log counts; the highest side-effect severity; nutrition and hydration totals and targets; and an optional current weight. It does not include food or medication names, notes, photos, exact event times, chat text, or raw HealthKit samples. The App asks for a separate acknowledgment before the first daily snapshot is sent. The snapshot is not stored in our database; the generated breakdown is cached on your device.

4.8 Legacy Friends/Circle data (older app versions)

Friends/Circle is not available in the current app version. We retain its authenticated server endpoints temporarily so people using an already-released older version do not lose the feature without notice. If you used Friends/Circle in an older version, we may continue to process the following on our servers (Supabase Edge Functions and database), linked to your account:

• Your community profile: a display name you choose and a cosmetic profile-card style.
• Weekly activity signals: for each week, the number of days (a count from 0 to 7) on which you hit your protein target, hit your hydration target, and logged food, plus current streak lengths.
• Activity-feed events and interactions: events such as closing your weekly anchors or logging food, and the cheers and nudges you send to or receive from buddies.
• Your buddy graph: the buddy relationships you form and the invite codes you create or redeem.

We do not share your food names, calories, macros, weight, medication, doses, side effects, meal photos, chat text, or any other free-text content with your buddies. The only free-text you choose is your display name.

4.9 Apple Health (HealthKit)

Only if you grant permission, the App reads certain values from Apple Health (such as weight, steps, and active energy) and can write food, water, and weight entries back to Apple Health. HealthKit data flows between Moraea and Apple Health on your device under Apple’s policies. We never send HealthKit samples to our servers or analytics providers, never use HealthKit data for advertising or marketing, never sell it, and never share it with third parties.

4.10 Subscriptions, purchases, and App Store notifications

Subscriptions are sold and processed by Apple through the App Store. We do not receive your full payment card number. To unlock and verify paid features, we use:

• RevenueCat: a subscription-management provider that receives a pseudonymous account identifier (your Supabase user ID) and App Store purchase/trial lifecycle information (such as product, entitlement status, renewals, expirations, cancellations, and refunds). We do not send RevenueCat your name, email, health logs, meal data, chat content, or photos.
• Our server entitlement record: which plan you have, whether it is currently active, its expiry, and an Apple-provided transaction identifier. This record is created and updated from Apple’s App Store Server Notifications (often forwarded via RevenueCat) and is linked to your account by its random, app-generated account identifier rather than by your Apple ID. We use it only to confirm whether your paid features should be available.

If you redeem a promotional offer code, redemption happens entirely through Apple’s system redemption flow. We never receive, store, or log the code itself; we only learn of the resulting subscription entitlement.

4.11 Security, abuse-prevention, and service-limit data

To keep the Services secure, enforce fair-use limits, and prevent abuse of our paid AI features, our backend records limited operational data:

• Service-limit counters: per-account counts of how many AI requests (Eve, Progress, and Daily) you have made, used to enforce daily quotas.
• Rate-limit and abuse counters: short-window request counters keyed to your account and, for some endpoints, to a network identifier, used to throttle and block abusive traffic.
• Security event logs: privacy-safe records of security-relevant events (for example, a blocked request). These contain only a function name, an event type, a short non-identifying detail token, a truncated/redacted reference to the account, and a truncated IP-address prefix. They do not contain your name, email, tokens, request bodies, health data, or message content.

4.12 Optional usage analytics (off by default)

If you opt in under Profile → Data & account → Privacy, we collect anonymous product-usage analytics through PostHog: event names (such as which screen or tab you viewed), coarse feature usage, app version, and device OS version, tied only to an anonymous device identifier. This never includes your name, email, Apple ID, account identifier, food, macros, weight, medication, doses, side effects, chat text, photos, or HealthKit values. We disable session replay, UI autocapture, surveys, and person profiling. It is off by default and you can turn it off again at any time.

4.13 Optional crash and error reports (off by default)

If you opt in separately, we collect crash and error diagnostics through PostHog Error Tracking: stack traces, exception types, app build version, and device model/OS. Symbol files (dSYMs) are uploaded at build time so crashes translate into readable code locations; they do not contain your personal logs. These reports do not include health data or chat content, and properties are sanitized before transmission.

4.14 Reminders and notifications

Reminders (such as hydration or dose reminders) are scheduled locally on your device using iOS notifications. We do not operate a push-message server for these reminders and do not collect a device push token.

4.15 Camera, microphone, speech, and barcodes

With your permission, the App may access:

• Camera and photo library: to capture or attach meal photos for Eve AI, and to scan product barcodes for food lookup.
• Microphone and speech recognition: so you can describe a meal out loud. Speech recognition is configured to run on your device; the resulting text stays on your device unless you send it to Eve AI as a chat message.

Dictated text remains on your device unless you include it in an Eve AI request. When you scan a barcode, the numeric barcode is sent directly from the App to Open Food Facts to look up the product. As with any internet request, Open Food Facts and its hosting providers may receive technical data such as your IP address and request time. The barcode is not sent to our database.

Some information you enter into the App (such as weight, medication, doses, side effects, and meal photos) relates to your health and is treated as “sensitive,” “special category,” or “consumer health” personal data under laws such as the EU/UK GDPR, the California Privacy Rights Act, and the Washington My Health My Data Act.

• We minimize collection of this data on our servers by keeping it on your device wherever possible.
• Where sensitive data does leave your device, specifically the meal text, photos, and related Eve AI context you send (recent chat text, frequent meal names, local time, and assistant preferences), and the weekly aggregate snapshots you send for Progress AI insights, and allowlisted daily snapshots you send for Daily AI breakdowns, we process it only with your explicit, informed consent (the in-app acknowledgment) and solely to provide the estimate or insight you requested.
• Older versions using Friends/Circle share only the limited, non-content weekly signals described in Section 4.8, and only after you sign in and choose to use that feature. The current version does not collect or synchronize those signals.
• We do not use sensitive or health-related data to infer characteristics about you for advertising, and we do not sell or share it.

Consumer Health Data Privacy Notice. The categories we may collect are the profile, nutrition, activity, medication, dose, side-effect, weight, meal, photo, and AI-snapshot information described in Sections 4.3 and 4.5 to 4.9. We collect it directly from you, from your device, and, only with permission, from Apple Health. We use it only for the product purposes in Section 6. When you request an online AI feature, we disclose the minimum listed inputs to the relay and AI providers in Section 9; older clients may disclose the limited Circle signals in Section 4.8 to approved circle members. We do not sell consumer health data and do not use it for advertising. The categories we “share” as that term is defined by applicable consumer-health laws are none; disclosures to processors solely to provide a requested feature are described above and in Section 9. Section 14 explains how to access, delete, or withdraw consent for this data. This paragraph is our consumer health data privacy notice for laws that require one.

We use personal information to:

• Operate the App: store and display your logs, calculate nutrition targets, generate clinician export PDFs, schedule reminders, and provide the features you use.
• Provide Eve AI: estimate the macros of meals you describe or photograph.
• Provide Progress AI insights: summarize your own weekly aggregate tracking numbers after you acknowledge the Progress AI privacy notice.
• Provide Daily AI breakdowns: summarize an allowlisted snapshot of a selected day after you acknowledge the Daily AI notice.
• Support older Friends/Circle clients: temporarily retain authenticated compatibility services for weekly activity signals and interactions created by already-released app versions.
• Operate subscriptions: verify your entitlement and unlock paid features.
• Secure the Services and enforce limits: detect, prevent, and respond to abuse, spam, and security incidents, and enforce fair-use quotas and rate limits.
• Manage waitlist and email communications: record interest from waitlist signups and contact you as described in Section 4.1.
• Product research (opt-in feedback email): if you opted in under Section 4.1, send occasional product-feedback emails and, when App Store notifications show that you turned off auto-renew or your subscription expired, at most one exit-survey email with a signed link; store your survey answers to improve the product.
• Communicate with you: send launch-related and occasional product update emails about Moraea (waitlist), occasionally tell you about other apps we develop, and respond to your requests. You can unsubscribe from non-essential emails at any time.
• Improve the Services: only with your opt-in consent for analytics and crash reporting.
• Comply with law: meet legal obligations, respond to lawful requests, and enforce our terms and rights.

We do not use your information for personalized advertising and we do not sell your personal information.

If you are in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases:

• Consent (Art. 6(1)(a); Art. 9(2)(a) for health data). For joining the waitlist and receiving launch, product-update, feedback, and other-app emails; for optional in-app feedback email and exit-survey emails and storing survey answers; for sending meal text/photos to Eve AI; for sending weekly aggregate snapshots for Progress AI insights; for sending allowlisted daily snapshots for Daily AI breakdowns; and for optional analytics and crash reporting. You may withdraw consent at any time.
• Performance of a contract (Art. 6(1)(b)). To provide the App features you request, including account sign-in, managing your subscription entitlements, and temporary support for Friends/Circle in already-released older app versions.
• Legitimate interests (Art. 6(1)(f)). To secure the Services, prevent abuse and fraud, enforce fair-use limits, verify paid entitlements, and operate the Site, where those interests are not overridden by your rights.
• Legal obligation (Art. 6(1)(c)). Where processing is required to comply with law.

Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

Eve AI, Progress AI, and Daily AI use automated systems to generate nutrition estimates and summaries of your own tracking numbers. These features:

• run only when you choose to use them and acknowledge the relevant in-app notice;
• may receive limited contextual inputs for Eve AI (recent chat text, frequent meal names, local time, and assistant preferences) in addition to the meal text or photo you send;
• produce estimates and informational summaries, not decisions that produce legal effects or similarly significant effects concerning you;
• are advisory only. You remain in control and can edit, accept, or ignore any output; and
• are not medical advice, diagnosis, or treatment, and are not a substitute for guidance from a qualified clinician.

We do not use these features to profile you for advertising, we do not use your Eve, Progress, or Daily requests to train our own AI models, and we do not make solely automated decisions about you that have legal or similarly significant effects within the meaning of Article 22 of the GDPR.

We share personal information only with service providers (processors) that help us run the Services, and only as needed for them to perform services on our behalf under contractual terms that limit their use of the information:

• Apple, Inc.: Sign in with Apple, HealthKit, App Store subscription processing, and App Store Server Notifications.
• RevenueCat, Inc.: subscription identity and entitlement management using a pseudonymous account identifier and App Store purchase lifecycle events (no health logs, meal data, chat, or photos).
• Supabase, Inc.: stores waitlist email addresses and your account, subscription-entitlement, optional feedback-email consent and exit-survey send/response records, security/abuse-prevention, and legacy Friends/Circle records, and powers authentication, the Eve AI relay, the Progress AI relay, the Daily AI relay, feedback-email consent, App Store notification handling, and compatibility Edge Functions used by older app versions.
• Vercel, Inc.: hosts the Site, serves API routes, provides privacy-focused web analytics, and routes Eve AI, Progress AI, and Daily AI requests via the Vercel AI Gateway.
• Resend, Inc.: delivers waitlist, launch, product update, optional in-app feedback / exit-survey, and related emails on our behalf.
• Google LLC and OpenAI, L.L.C.: process Eve AI requests (meal text/photos and related context), Progress AI snapshots (OpenAI primary; Google fallback), and Daily AI snapshots (OpenAI) to generate estimates and insights. Current routing is described in Sections 4.5 to 4.7 and may change as models improve.
• Perplexity AI, Inc.: may process concise nutrition-search queries from Eve AI when the assistant looks up published nutrition facts.
• PostHog, Inc.: processes optional, opt-in, anonymous usage analytics and crash/error diagnostics.
• Cloudflare, Inc.: provides the non-persistent anti-bot challenge used for passwordless email sign-in.
• Open Food Facts: receives scanned barcode values and ordinary request metadata when the App performs a direct product lookup.

We may also disclose information if required by law, court order, or valid government request, or to protect the rights, safety, and security of Moraea, our users, or others, or in connection with a business transfer (such as a merger or acquisition), subject to this policy.

We do not sell personal information, we do not sell or share consumer health data, and we do not share personal information for cross-context behavioral advertising.

The Site does not set advertising cookies and does not use third-party advertising trackers. We use Vercel Web Analytics, which is designed to measure page views and performance without third-party advertising cookies. Our hosting infrastructure may still process technical data such as IP addresses and user-agent strings in server logs as part of normal operation.

The App does not use web cookies. Optional in-app analytics rely on an anonymous device identifier rather than advertising identifiers, and only when you opt in. The passwordless email sign-in screen uses a non-persistent embedded web view for Cloudflare Turnstile; Cloudflare may use necessary local storage or similar technology to complete its anti-bot challenge.

Because we do not sell or share personal information and do not serve targeted advertising, there is nothing to opt out of via browser-based opt-out preference signals such as Global Privacy Control (GPC); where applicable, we treat such a signal as a valid request not to sell or share your personal information.

Moraea is operated from Malaysia and may be accessible in many countries, subject to the availability limits in Section 15. Our service providers (including Apple, RevenueCat, Supabase, Vercel, Resend, Cloudflare, Google, OpenAI, Perplexity, Open Food Facts, and PostHog) may store and process information in the United States and other countries that may have data-protection laws different from those in your country. Malaysia and several of these countries have not received an EU “adequacy” decision. Where required for transfers out of the EEA, UK, or Switzerland, we and our providers rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, and equivalent mechanisms. You may contact us for more information about these safeguards.

• On-device App data: retained until you delete it in the App or delete your account.
• Account and legacy Friends/Circle records (Supabase): retained until you delete your account through the in-app deletion flow or until the applicable legacy-service retention period ends.
• Subscription entitlement records: retained while your account exists and deleted when you delete your account. Related RevenueCat subscriber records associated with your account identifier are also deleted as part of in-app account deletion.
• Service-limit and rate-limit counters: per-account counters are deleted when you delete your account; short-window network (IP-based) counters expire automatically as their time windows age.
• Security event logs: retained for approximately 90 days and then deleted.
• AI requests and results: Eve messages/photos and Progress/Daily snapshots are processed to return your result and are not stored in our database. The gateway request is marked to disallow prompt training. AI providers may retain inputs for a limited period (which can be up to 30 days under applicable API terms) for abuse monitoring, security, or legal compliance. Eve chat history and Daily results remain on your device until you delete them or your account.
• Optional analytics and crash data (PostHog): retained per our configuration (currently up to 7 years) unless deleted earlier at your request. Withdrawing consent stops future collection; you may separately request deletion of data already collected.
• Authentication records: retained while your account exists and deleted through the in-app account-deletion flow, subject to limited security, fraud-prevention, or legal records we must retain.
• Waitlist email: retained while we continue to send the emails described in Section 4.1, and deleted or suppressed when you unsubscribe or ask us to delete it.
• In-app feedback email consent: retained until you revoke consent in Settings, unsubscribe from a feedback email, or delete your account.
• Exit-survey sends and responses: we keep a record that a survey email was sent (so we do not email you again for the same subscription) and your reason, follow-up answer, and optional note. These records are deleted when you delete your account, or earlier if you ask us to erase them.
• Server, hosting, and analytics logs: retained per our providers’ default schedules, used for security, debugging, and aggregate measurement.

We use reasonable administrative, technical, and organizational measures to protect personal information, including:

• HTTPS/TLS encryption in transit and Apple platform encryption for on-device data
• Storing the account session token in the device Keychain
• Server-only access to database credentials (never exposed in the browser), with row-level security and least-privilege access on our backend
• Input validation, rate limiting, and abuse protections on our APIs
• Security headers such as a Content Security Policy, HSTS, and frame protections on the Site
• Sanitizing telemetry before transmission and disabling session replay, UI autocapture, and person profiling in PostHog

No method of transmission or storage is completely secure. If we become aware of a personal-data breach that affects you, we will notify you and the relevant authorities where and as required by applicable law (for example, within the timelines set by the GDPR and U.S. state breach-notice laws). If you believe your interaction with us is no longer secure, please contact us promptly. Where the FTC Health Breach Notification Rule or a similar consumer-health breach law applies, we will also provide the required notices to affected individuals, regulators, and, when required, the media.

Depending on where you live, you may have some or all of these rights:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Delete your information
• Withdraw consent where processing relies on consent
• Object to or restrict certain processing
• Receive a portable copy of information you provided
• Opt out of any “sale” or “sharing” and limit use of sensitive data
• Appeal a decision we make about your request
• Lodge a complaint with your local data protection authority

How to exercise your rights. Email us at developer@rainfroglabs.com. We may need to verify your request before responding, you may use an authorized agent where the law allows, and we will not discriminate against you for exercising your rights. If we decline your request, you may appeal by replying to our response; you may also complain to your local supervisory authority (for example, your EEA data protection authority, the UK Information Commissioner’s Office, or Malaysia’s Personal Data Protection Department).

Account deletion. You can delete your account directly in the App (Profile settings). In-app deletion wipes your local data and, for signed-in users, deletes your server-side records, including your authentication record, any legacy Friends/Circle profile and membership graph, service-limit and rate-limit counters, subscription-entitlement record, associated RevenueCat subscriber record, optional feedback-email consent, and exit-survey send/response records, and clears your session, AI-consent choices, and on-device AI-result caches. Deleting your account does not cancel your App Store subscription (manage that in your Apple Settings) and does not remove data you previously wrote to Apple Health. It also does not automatically erase analytics or crash data already collected under an earlier opt-in; you may request deletion of that data by emailing us. To delete a waitlist email, email us and we will remove it.

Communication choices.You can unsubscribe from non-essential emails using the link in those emails or by contacting us. For optional product-feedback / exit-survey email, you can also revoke consent in Profile → Feedback email. You can toggle in-app analytics and crash reporting under Profile → Data & account → Privacy, and control HealthKit access in iOS Settings. You can withdraw consent for future Eve, Progress, and Daily AI processing under Profile → AI Chatbot → Privacy choices. Withdrawal does not undo processing already completed; you may request deletion of any provider-held data that can reasonably be linked to your request by emailing us.

California (CCPA/CPRA)

In the past 12 months we have collected the following categories of personal information: identifiers (such as email address, account identifier, and IP address); commercial information (such as your subscription/entitlement status); internet or other electronic network activity (such as pages viewed and opt-in analytics events); other information you provide (such as optional exit-survey reasons and follow-up answers, which are product research and should not include medical details); and, within the App and only as described above, health-related information you choose to enter, which may be treated as sensitive personal information. We collect this from you, from your device, and from Apple and RevenueCat (sign-in and subscription events). We use it for the business purposes described in Section 6, and we disclose it to the service providers listed in Section 9. We do not sell or share personal information for cross-context behavioral advertising, and we do not use sensitive personal information for purposes that would trigger the right to limit its use beyond providing the Services you request. We do not knowingly sell or share the personal information of consumers under 16. California residents may exercise access, deletion, correction, and opt-out rights by emailing developer@rainfroglabs.com. Under California’s “Shine the Light” law, we do not share personal information with third parties for their own direct marketing.

Washington, Nevada, and other consumer health data laws

The Washington My Health My Data Act, the Nevada consumer health data law (SB 370), and similar laws regulate “consumer health data.” We are not a HIPAA covered entity or business associate. Where these laws apply, we collect consumer health data only to provide the features you use and with your consent; we do not sell consumer health data (which would require a separate valid authorization that we do not seek); and we restrict access to it. You may exercise rights to access, delete, and withdraw consent regarding your consumer health data by emailing developer@rainfroglabs.com. Section 5 identifies the categories and sources of consumer health data, the purposes for collection and use, the processors and other recipients, and how to exercise these rights.

Other U.S. states

Residents of states with comprehensive privacy laws (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others) may have rights to access, correct, delete, and obtain a copy of their personal data, to opt out of targeted advertising, sale, and certain profiling, and to appeal a denied request. Because we do not engage in targeted advertising, sale, or such profiling, there is nothing to opt out of, but you may still exercise your access, correction, deletion, and appeal rights by contacting us.

EEA, UK, and Switzerland

See Sections 7, 8, 11, and 14. You have the right to lodge a complaint with your local supervisory authority, and the right to withdraw consent at any time. We have not yet appointed an EU or UK Article 27 representative. Until representatives are appointed or qualified counsel documents an applicable exemption, we do not intentionally offer or market the Services to individuals in the EEA or UK. Storefront visibility by itself does not override this limitation.

Canada (PIPEDA and Quebec Law 25)

We obtain consent appropriate to the sensitivity of the information, limit collection to what is necessary, and let you access and correct your personal information by contacting us. Residents of Quebec may have additional rights under Law 25, including in relation to automated processing and data portability.

Australia

We handle personal information in line with the Australian Privacy Principles, including limits on use and disclosure of sensitive information. Submit a privacy complaint using the contact email with the subject “Privacy complaint.” We will investigate and respond within a reasonable period. If you are not satisfied, you may complain to the Office of the Australian Information Commissioner.

Malaysia (PDPA)

We are based in Malaysia. Where the Malaysian Personal Data Protection Act 2010 (as amended) applies, we process personal data with your consent and for purposes a reasonable person would consider appropriate, give notice of our processing, keep data accurate and secure, and honor withdrawal-of-consent, access, and correction requests. You may contact us at the email above as our point of contact for PDPA matters, and you may contact Malaysia’s Personal Data Protection Department (Jabatan Perlindungan Data Peribadi).

The Services are intended for adults aged 18 and older and are not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal information, contact us and we will take steps to delete it.

Moraea is distributed through the Apple App Store and follows Apple’s requirements:

• Sign in with Apple data (identity token, and the name/email or relay email you allow) is used to create and secure your account. We do not use that email for product-feedback or exit-survey messages unless you separately opt in under Section 4.1.
• HealthKit data is used only to provide app features on your device, is never used for advertising or marketing, is never sold, and is never shared with third parties or our analytics providers.
• App Store subscriptions are handled by Apple; we do not receive your payment card details. We use RevenueCat and Apple’s App Store Server Notifications only to keep your subscription-entitlement status current.
• Our App Privacy details on the App Store product page are kept consistent with this policy.

The Services may link to or rely on third-party websites and services with their own privacy practices governed by their own policies, not this one. We encourage you to review those policies, including Apple, RevenueCat, Supabase, Vercel, Resend, Cloudflare, Google, OpenAI, Perplexity, Open Food Facts, and PostHog.

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above. If changes are material, we may provide additional notice on the Site or request renewed consent in the App when the law requires it. This policy is a notice of our practices, not a contract accepted merely by continued use. A change will not reduce your rights or retroactively expand a consent without any notice or choice required by applicable law.

If you have questions about this Privacy Policy or our privacy practices, contact:

Shivendra Ananthan Chelliah
Moraea
Email: developer@rainfroglabs.com