Privacy Policy — Foobud

Version in force: 10 October 2026

1. Data Controller

The controller of your personal data within the meaning of the General Data Protection Regulation (GDPR — EU Regulation 2016/679) is:

Sébastien CAILLAUD, natural person, publisher of the Foobud application.

Email: contact@foobud.com

No data protection officer has been appointed, as the processing does not fall within the cases of mandatory designation set out in Article 37 of the GDPR.

2. Legal Basis and Health Data

The allergies, intolerances and diets you record constitute health data within the meaning of Article 9 of the GDPR. Their processing is based on your explicit consent (Art. 9(2)(a)), given when you enter them in the application. You may withdraw this consent at any time by deleting the data concerned or the application itself.

Other processing operations (running the application, synchronisation, notifications) are based on the performance of the service you requested (Art. 6(1)(b)).

Your contacts' restrictions: when you record a relative's dietary restrictions, you are processing health data concerning them. It is your responsibility to ensure that they are informed and consent to it. This data stays on your device (or in your cloud space if you are a Premium user) and is accessible to you alone.

3. Fundamental Principle: Your Data Stays With You

Foobud is designed with a local-first approach. Except in cases explicitly listed below, none of your personal data is transferred to our servers.

3.1 Free Users

All your content data — contacts, meals, dietary restrictions, photos, profile — is stored locally on your device in a SQLite database and is never transferred to our servers.

There are two exceptions. The first is purely technical: an anonymous identifier is created on the Firebase side from the very first launch, even if you never share anything (see section 4). The second does concern the content of your data: if you use a sharing function, your dietary profile — restrictions included — is published on our servers and remains there until you put an end to it (see section 5).

Important: if you lose or reset your device, your data is permanently lost. No backup is possible without a Premium subscription.

3.2 Premium Users

Your data is backed up to Firebase (Google Cloud service) with encryption at rest and encryption in transit (TLS). It is synced across your devices to enable multi-device access.

Hosting: the database (Cloud Firestore) is hosted in the Google Cloud region europe-west9 (Paris, France); photos (Firebase Storage) are stored in the United States. Detailed data locations and transfer safeguards are set out in section 11.

4. Anonymous Identification

Foobud generates, on first launch, an anonymous technical identifier via Firebase Anonymous Authentication. This identifier (UID):

• Contains no personal information (no name, email, phone)
• Is used only to enable profile sharing functions between users
• Remains tied to your device until you subscribe to Premium or sign in via SSO

This UID is retained on the Firebase side for the duration of the app's use. After 90 days of inactivity, the associated device record is automatically purged (checked daily).

This purge deletes neither your anonymous account, nor any profile you published by sharing, nor the access granted to the people who follow you. Those disappear only through the actions described in sections 5 and 8.

5. Profile Sharing Functions

Sharing your dietary profile — by QR code or by link — publishes that profile on our servers (Firebase), so that the people you sent it to can view and import it. This is not a one-off transfer: the published profile remains there and stays accessible to the people who follow you, until you put an end to it.

• Data published: display name, dietary restrictions, photo (optional), anonymous identifier
• Data NOT published: your contact list, your meal history, your account information
• Who can access it: only people holding a valid link or QR code that you sent them yourself

5.1 Consent

The act of sharing constitutes consent: by sending your link or QR code, you authorise its recipient to access your profile. There is no further approval step — anyone presenting a valid link is authorised immediately.

5.2 Link lifetime, access lifetime

Every link and every QR code carries a token valid for 14 days. After that, it can no longer be used to obtain new access.

This duration protects the creation of access, not the access itself. Someone who follows you keeps access to your profile after the link expires, and sees the updates you make to it, for as long as you have not removed them.

5.3 Your means of control

From "Share my profile", you stay in control at any time:

• Let it expire: with no action from you, a link you sent stops working after 14 days
• Revoke shared links: immediately invalidates every link and QR code you have issued. People who already follow you keep their access
• Remove a person: ends their access immediately and durably prevents them from returning by means of a link they might still hold

Removal ends access going forward. It cannot erase a copy the person may already have imported onto their device, as that copy is then beyond our reach.

5.4 People invited by link

When you invite someone to send you their profile by means of an invitation link, that person enters their first name and dietary restrictions on a web page, without having a Foobud account.

• Controller: Foobud, for the collection and hosting described here. Your subsequent use of that profile, on your device and in a personal context, falls within your private sphere (GDPR article 2.2.c)
• Purpose: to pass the person's restrictions on to you, so that you can take them into account
• Legal basis: the person's explicit consent (article 9.2.a), obtained through a dedicated checkbox before sending, and timestamped
• Recipient: you alone. Security rules forbid anyone else from reading it, and no client can write this data — only our server can
• Retention: the link is valid for 14 days; the invitation and the reply are deleted at most 30 days after the link was created
• Rights: the person may write to contact@foobud.com quoting the link they received, which is the only identifier of their data

A limit we must point out: once the profile is imported, you hold a copy on your device. We can delete what is on our servers, not that copy. An erasure request addressed to Foobud can therefore only cover the server side; for the rest, the person must approach you.

6. Premium Account Authentication

If you subscribe to Foobud Premium, or if you reconnect to an existing Premium account, you must authenticate your account. Three methods are offered, at your choice:

• Sign in with Google
• Sign in with Apple (on iPhone)
• Email address and password

With email and password, Foobud receives only the address you enter. The password is handled by Firebase Authentication and is never disclosed to us in clear text.

With Sign in with Google, at that precise moment and only then, Foobud receives from the provider: unique Google identifier, email address, full name, profile photo URL.

With Sign in with Apple, Foobud receives from Apple a unique identifier and, at the first sign-in only, the name and email address you choose to share. Apple lets you hide your real address: Foobud then receives a relay address (ending in @privaterelay.appleid.com) that forwards to your inbox.

No extended scope is requested: we do not request access to your contacts, your calendar, your files, or any other data in your Google account.

7. Retention Periods

Data	Duration	Deletion Trigger
Local data (Free)	As long as the app is installed	App uninstall or "Erase my data" action
Anonymous device record	90 days of inactivity	Automatic purge
Profile published by sharing	Until you revoke it — no automatic purge	"Revoke shared links", removing people, or account deletion
Sharing links and QR codes	14 days	Automatic expiry, or "Revoke shared links"
Access granted to people who follow you	For as long as you have not removed them	"Remove" action
Active Premium cloud data	As long as the subscription is active	Manual deletion or downgrade
Cloud data after Premium downgrade	30 days grace period	Automatic purge after 30 days
Cloud data after account deletion	Full purge within 30 days	"Delete my account" action
FCM tokens (notifications)	As long as token is valid	Uninstall or revocation
Usage analytics data (Firebase Analytics)	Per the retention settings of our Firebase project	Automatic purge by Google

8. Account Deletion and Data Removal

You can request deletion of your Foobud account and associated data at any time, in two ways:

• In the app: Settings → "Delete my account" (Premium users) or "Erase my data" (Free users).
• By email: send your request to contact@foobud.com; we process it within 1 month maximum.

Data deleted: the local on-device database, the Firebase Authentication account, the cloud data (contacts, meals, restrictions, profile, photos), and the notification token (FCM).

Data retained and durations:

• Account deletion: triggered immediately; the full purge of cloud data (Firestore + Storage) completes within 30 days at the latest.
• Anonymous identifier: automatically purged after 90 days of inactivity.
• Purchase and subscription records: retained by the relevant app store (Google Play or Apple App Store) under its own rules (outside our control).
• Any data we are legally required to retain, for the legally mandated duration only.

9. Your GDPR Rights

In accordance with articles 15 to 22 of the GDPR, you have the following rights:

• Right of access (art. 15): your data is on your device — you have direct access via the app
• Right to rectification (art. 16): modifications possible at any time from the app
• Right to erasure (art. 17 — right to be forgotten):
• Free: "Erase my data" action in Settings → wipes local database and removes your anonymous record from Firebase
• Premium: "Delete my account" action in Settings → Firestore + Storage deletion + subscription revocation + Apple token revocation if applicable
• Right to restrict processing (art. 18): contact us to suspend cloud sync
• Right to data portability (art. 20): PDF export available in Premium, JSON export on request
• Right to object (art. 21): contact us at contact@foobud.com

Response time: 1 month maximum.

Supervisory authority: you have the right to lodge a complaint with the CNIL (French DPA, www.cnil.fr) or any other European supervisory authority.

10. Security

• Local data: protected by the sandboxing mechanisms of your operating system (Android / iOS)
• Cloud data (Premium): encryption at rest by Firebase, encryption in transit (TLS 1.2+), Firestore security rules restricting access to the authenticated user only
• Photos: stored in Firebase Storage with access rules restricted to the owner

11. Processors and Transfers Outside the European Union

We use a single processor within the meaning of Article 28 of the GDPR: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), which provides the Firebase / Google Cloud platform (database, photo storage, authentication, notifications, usage analytics). Google processes this data solely on our instructions, under Google's Cloud Data Processing Addendum, which incorporates the European Commission's Standard Contractual Clauses (SCCs).

Data locations:

• Database (Cloud Firestore) — contacts, meals, restrictions, profiles: region europe-west9 (Paris, France)
• Photos (Firebase Storage) and server functions (Cloud Functions): United States (us-central1 region)
• Firebase Authentication and Cloud Messaging: global services operated in particular from the United States

Transfers to the United States rely on the European Commission's adequacy decision of 10 July 2023: Google LLC is certified under the EU–U.S. Data Privacy Framework (DPF). The Standard Contractual Clauses mentioned above apply as an additional safeguard.

Apart from Google, your personal data is not shared with any recipient, except the app stores (Google Play, Apple App Store), which process your purchases as independent data controllers.

12. Cookies, Trackers and Usage Analytics

Foobud is a native application: it uses no cookies and includes no advertising trackers or ad networks (no Facebook Pixel, no ad exchange). Your data is neither sold nor shared with data brokers.

The application does, however, include Firebase Analytics (Google), used solely to measure app usage:

• Events recorded: subscription screen displayed, subscription button tapped, completed purchase, onboarding completed, first contact created (with the time elapsed since installation).
• Associated data: a pseudonymous installation identifier generated by Google and technical information (device model, operating system, language, country inferred from the IP address).
• Never sent to Analytics: the content of your data — contact names, meals, dietary restrictions, photos, health data.

No Google Analytics advertising features (Google Signals, remarketing, export to advertising platforms) are enabled. This data is retained by Google according to the retention settings of our Firebase project, then automatically deleted.

13. Push Notifications

Push notifications (Firebase Cloud Messaging) inform you of actions related to sharing: when someone adds your profile, or when a guest completes the link you sent them. They are written in your app's language, which our servers read for that sole purpose.

The FCM token is stored on Firebase in a private location associated with your identifier, readable by you alone. You can disable notifications at any time from system settings.

14. Minors

Foobud is not intended for children under 15 (the age of digital consent in France). No data is knowingly collected from minors under 15.

15. Policy Changes

Any substantial change will be notified via the app and will require your consent for Premium users.

16. Contact

For any question regarding your personal data:

• Email: contact@foobud.com