1. Who we are
Defteri is operated by JCG Nutrition Ltd, Cyprus, company number HE 489188. JCG Nutrition Ltd is the controller of personal data processed through Defteri.
Registered office: Apostolou Pasiou 7A, Geroskipou 8201, Paphos, Cyprus
Privacy contact: support@defteri.eu
2. Data we process
- Account data: email address, Firebase user ID, display name, account creation time and verification state.
- App data: favourites, followed creators, language and notification preferences.
- Diary and nutrition data: meals, food names, recipe references, servings, calorie and macronutrient snapshots, personal targets, and private recipe nutrition adjustments.
- Subscription data: product, entitlement and App Store transaction identifiers, but not payment-card details.
- Security and technical data used for authentication, App Check/App Attest, fraud prevention, logs, diagnostics and app integrity.
- Support, export and deletion requests, plus a push token only if notifications are enabled.
If you choose AI Kitchen, we also process the ingredients, recipe preferences, dietary exclusions, serving count and recipe language you submit; the private recipe returned to you; limited digest-only request evidence; model/version metadata; and quota records. We do not send your name, email, account ID, food Diary or saved recipes to the AI provider.
Defteri v1 does not show advertising. We do not use diary entries, nutrition targets, AI Kitchen requests or similar data to build advertising audiences.
3. Why we process data
We process data to create and secure accounts; provide recipes, favourites, follows and the Plus diary; calculate totals; maintain entitlements; handle support and privacy requests; prevent abuse; diagnose faults; and comply with legal obligations.
Our legal bases are performance of our contract, compliance with legal obligations and our legitimate interests in operating and securing Defteri. We rely on explicit consent under Article 9(2)(a) for diary or nutrition-target information that constitutes health data. Defteri asks for that consent separately before enabling those features. Consent may be withdrawn for future processing without affecting processing already carried out lawfully.
AI Kitchen
AI Kitchen is an optional feature for eligible subscribers aged 18 or over. Defteri asks for explicit consent before sending an AI request. Dietary exclusions are optional and may reveal information about allergy, intolerance, health, religion or belief. You can decline or withdraw consent for future AI requests without losing access to non-AI features available under your plan.
The provider also returns an approximate per-serving calorie and macronutrient estimate for the proposed recipe. Defteri validates the response's structure, bounds and basic calorie/macronutrient plausibility, labels the values as an AI estimate and lets you save a private adjustment. It does not verify the estimate against the exact products or quantities you use. AI Kitchen is not medical or dietetic advice and must not be used for diagnosis or treatment. Always check ingredient labels, allergens and safe cooking requirements, and seek qualified advice where needed.
The legal basis for generating the requested recipe is performance of the service. We rely on explicit consent for the provider disclosure and, where a dietary exclusion is health or other special-category data, Article 9(2)(a) GDPR.
4. Providers and transfers
We use Google Firebase and Google Cloud for authentication, APIs, database and storage infrastructure, app integrity, security logging, diagnostics and notifications. We use Apple for App Store subscriptions, App Attest and device notifications. Our business-email provider processes messages sent to support.
For AI Kitchen, Google Cloud Vertex AI processes the allow-listed request using its EU multi-region service. Under the applicable Google Cloud terms, Google does not use Defteri Customer Data to train or fine-tune AI models without the customer's prior permission or instruction. Defteri does not enable provider request-response logging, grounding, web search, Maps or optional prompt storage for this flow. Google documents isolated in-memory caching that may last up to 24 hours and limited abuse-monitoring processing for suspected policy violations.
These providers may use approved subprocessors. Where personal data is transferred outside Cyprus or the EEA, we rely on an applicable European Commission adequacy decision or safeguards such as the European Commission's Standard Contractual Clauses. We do not sell personal data.
5. Retention
- Account, profile, favourites and followsWhile active; delete from active systems within 30 days after a verified deletion request unless a documented legal hold applies.
- Diary entries, nutrition targets and private recipe nutrition adjustmentsWhile active. An adjustment remains until you reset or replace it, delete its recipe or erase the account; delete from active systems within 30 days after a verified deletion request.
- AI Kitchen requests and recipesThe raw request is not stored by Defteri. A successful recipe is private; an unsaved recipe body is deleted after 72 hours. A saved recipe remains until you delete it or the account is erased. Limited digest/model/quota evidence follows the applicable security and audit retention rule.
- Private export files and access ticketsNo more than 7 days after delivery or expiry.
- Security, integrity and application logsNormally 30 days; longer only for a documented security incident or legal requirement.
- Support and privacy correspondence24 months after closure, unless longer retention is required for a specific legal claim or obligation.
- Subscription and transaction recordsWhile needed to provide the entitlement and, where required for accounting, consumer-protection or legal claims, for up to 6 years after the relevant financial year.
- Backups and point-in-time recoveryUp to 7 days through the documented rotation. Deleted data is not returned to normal use; if restored for disaster recovery, the deletion is applied again.
- Deletion evidenceA keyed digest of the deleted user ID, request and completion times, outcome and non-identifying operational metadata for 24 months. We treat this evidence as personal data while it could be linked using information under our control.
6. Your rights
Subject to law, you may request access, correction, deletion, restriction, portability or object to processing, and withdraw consent where it is the legal basis. You may request an export or deletion inside Defteri or email support@defteri.eu.
An export or deletion is not complete until the restricted production process finishes it. We normally respond to rights requests within one month, subject to the extensions and exceptions allowed by law. Active App Store subscriptions must be managed separately through Apple. You may complain to the Cyprus Commissioner for Personal Data Protection or another competent authority.
7. Security
Measures include verified accounts, authenticated APIs, app-integrity checks, access controls, encrypted transport, backups and audit records. No system is completely secure.
8. Age requirement
You must be at least 16 years old to create a Defteri account. Defteri does not offer a parental-consent account flow. AI Kitchen is available only to people aged 18 or over, who must confirm that requirement separately.
9. Changes and contact
We may update this policy when Defteri or its providers change. We will show the effective date and provide additional notice where required.
Privacy questions and rights requests
support@defteri.euJCG Nutrition Ltd · HE 489188 · Paphos, Cyprus
