Artichoke Privacy Policy

This Privacy Policy explains how Artichoke ("Artichoke", "we", "us", or "our") handles personal information when you use the Artichoke mobile application, the Artichoke learner portal, public pages, learning services, nutrition features, subscriptions, learner support, and related communications (together, the "Service").

Artichoke is the data controller for the learner-facing activities described in this policy. SkillFuel provides the hosted software platform and supporting infrastructure and generally processes personal information on Artichoke's behalf as a service provider and data processor.

This policy applies to visitors, prospective learners, registered learners, purchasers, subscribers, and other people who interact with the Service.

Privacy contact: marina.sahackaya@gmail.com

We collect information in the following ways: when you provide it to us, when you use the Service, when your device provides it with your permission, and when service providers send us information needed to operate the Service.

Account and profile information

We may collect your name, email address, password or authentication credentials, tenant membership, profile image, preferred language, account preferences, and communications with Artichoke or SkillFuel support. Passwords are stored using security measures designed to prevent them from being read in plain text.

Learning and service information

We may collect course enrollments, lesson and course progress, quiz or assignment activity, certificates, submissions, uploaded files, feedback, messages, support history, and other records generated when you use learning or coaching features.

Nutrition and health-related information that you provide

If you use Nutrition, we may collect information you enter or upload, including age, sex selection, height, current and target weight, activity level, dietary goals, eating style, allergies or intolerances, custom allergy information, calorie and nutrient targets, water intake, meal descriptions, meal photos, voice recordings, meal entries, calories, macronutrients, coach feedback, and related nutrition history.

Nutrition information may reveal sensitive details about your health, diet, allergies, or lifestyle. We use it only to provide the nutrition, coaching, progress, and related features you request. Nutrition features are intended for general wellness and informational purposes and are not a substitute for medical diagnosis or treatment.

Apple Health information

If you choose to connect Apple Health, the app requests your permission to read only the supported categories needed to display your health summary: steps, active energy, resting energy, exercise minutes, sleep, and weight. Permission is controlled separately for each category through Apple Health and iOS settings.

Apple Health information is read directly on your device and displayed in the app for the selected day. The current Artichoke health-summary feature does not upload Apple Health data to Artichoke, SkillFuel, Adapty, the nutrition AI provider, or our servers. We do not use Apple Health data for advertising or marketing, sell it, or share it with data brokers.

You can change or withdraw Apple Health permissions at any time in iOS under Settings > Privacy & Security > Health > Artichoke, or in the Health app. Withdrawing permission stops the app from reading the affected categories but does not delete information that you entered directly into Artichoke, such as your nutrition profile or meal history.

Photos, camera, and microphone

If you choose to take or select a meal photo, profile image, or record a meal voice note, the app accesses the camera, photo library, or microphone only after you initiate that action and grant the relevant device permission. Meal photos and voice recordings selected for nutrition analysis are uploaded to the Service and may be sent to the configured nutrition AI provider as described below.

Subscription and transaction information

When you purchase an auto-renewable subscription through the Apple App Store, Apple processes the payment. We do not receive or store your complete payment-card details. We may receive and retain subscription and transaction information such as product identifier, transaction identifiers, purchase and renewal dates, price and currency, store country, subscription status, expiration date, refund status, and whether the purchase occurred in a sandbox or production environment.

We use Adapty to present subscription offers, associate purchases with your account, restore purchases, and synchronize subscription access. We may provide Adapty with a stable account or membership identifier, email address, first and last name, app and device information, and subscription events. Apple and Adapty process information under their own privacy notices and, where applicable, under data-processing terms with the relevant business customer.

Technical, security, and usage information

We may automatically collect IP address, device and operating-system information, app version, browser information, language, timestamps, session information, request and error logs, security and audit events, and records used for fraud prevention, troubleshooting, service integrity, and subscription reconciliation. We do not use Apple Health information for these purposes.

We use personal information to:

• create, authenticate, secure, and administer accounts;
• provide courses, coaching, nutrition features, progress tracking, subscriptions, and support;
• calculate personalized nutrition targets from information you provide;
• analyze meal text, photos, or voice recordings when you ask us to do so;
• allow authorized Artichoke staff or assigned nutrition coaches to review nutrition entries and provide feedback;
• process purchases, determine subscription access, restore purchases, and maintain billing records;
• send service, security, purchase, feedback, and other transactional communications;
• remember preferences and improve the operation, reliability, accessibility, and security of the Service;
• detect, investigate, and prevent misuse, fraud, and unauthorized access;
• comply with legal, tax, accounting, regulatory, and contractual obligations; and
• establish, exercise, or defend legal claims.

We do not sell personal information. We do not use nutrition information or Apple Health information for targeted advertising, marketing profiles, or data-broker activities.

When you actively request AI-assisted meal analysis, the meal description, photo, or voice recording you submit is processed by SkillFuel and sent to the AI service provider configured for Artichoke. The provider analyzes the material to identify likely foods and estimate calories and nutrients. AI-generated estimates can be inaccurate, and you should review and correct them before relying on them.

We share this material with an AI provider only to perform the analysis you requested, operate and secure that feature, and address technical failures. We do not send Apple Health data to the AI provider. Before using photo or voice analysis, the app may provide an additional notice or consent request explaining this transfer.

The identity of the configured AI provider and its applicable privacy information can be requested from marina.sahackaya@gmail.com. If Artichoke changes the provider in a way that materially changes how personal information is handled, this policy and any necessary in-app notices will be updated.

Where the General Data Protection Regulation, UK GDPR, or similar laws apply, we rely on one or more of the following legal bases:

• Contract: processing needed to create and administer your account and provide the Service, paid subscription, learning, coaching, or nutrition features you request.
• Consent: processing based on an optional choice, such as device permissions, Apple Health access, AI analysis of submitted media where consent is required, or non-essential communications. You may withdraw consent at any time, without affecting processing that occurred before withdrawal.
• Legitimate interests: operating and securing the Service, preventing fraud, troubleshooting, maintaining audit records, improving reliability, and protecting users and the platform, where those interests are not overridden by your rights.
• Legal obligation: processing needed for tax, accounting, consumer-protection, regulatory, law-enforcement, or other applicable legal requirements.
• Legal claims: processing needed to establish, exercise, or defend legal claims.

Where nutrition or other information qualifies as special-category data, we process it only when an additional lawful condition applies, such as your explicit consent or another condition permitted by applicable law.

We share personal information only as needed for the purposes described in this policy, including with:

• SkillFuel, which hosts and supports the platform on Artichoke's behalf;
• authorized Artichoke personnel and assigned coaches who need access to provide learning, nutrition, feedback, administration, or support services;
• Apple, for App Store purchases, subscription management, and Apple Health functionality that you control on your device;
• Adapty, for paywalls, subscription attribution, entitlement status, purchase restoration, and subscription analytics;
• the configured AI service provider, only when you request AI-assisted nutrition analysis;
• hosting, storage, content-delivery, email, notification, security, monitoring, and customer-support providers used to operate the Service;
• professional advisers, auditors, insurers, or transaction counterparties where reasonably necessary and subject to appropriate duties of confidentiality; and
• courts, regulators, law enforcement, or other authorities when disclosure is required or permitted by law.

We require service providers processing information on our behalf to use appropriate confidentiality, security, and data-protection measures and to process information only for authorized purposes. We do not authorize third parties to use Apple Health data for their own purposes because Apple Health data is not transmitted to them by the current health-summary feature.

Some service providers may process information in countries other than the country where you live. Where data-protection law requires safeguards for an international transfer, Artichoke or SkillFuel, as applicable, uses an available lawful mechanism such as an adequacy decision, standard contractual clauses, the EU-U.S. Data Privacy Framework where applicable, or another legally recognized safeguard.

We retain personal information only for as long as reasonably necessary for the purposes described in this policy. Retention depends on the type of information and may include the following:

• account, learning, nutrition, and support information is generally retained while your account is active and for the period needed to provide the Service;
• individual meal entries or uploaded materials may be removed when you delete the relevant entry, subject to temporary backups and records required for security, dispute resolution, or legal compliance;
• subscription, transaction, invoice, tax, accounting, fraud-prevention, security, and audit records may be retained after account closure for the period required by applicable law or reasonably necessary to resolve disputes and protect the Service;
• technical logs and backups are retained on limited operational schedules and are deleted, overwritten, or anonymized when no longer needed; and
• information subject to a valid legal hold may be retained until the hold is lifted.

When retention is no longer necessary, information is deleted, anonymized, or minimized.

You can initiate account deletion directly in the mobile app under Account > Privacy > Delete account. After you confirm, access to the account is ended and the app signs you out. The account is immediately anonymized rather than remaining in an approval queue: direct identifiers such as your name and email address are removed or replaced so the retained account record can no longer be used as an ordinary identifiable learner account.

Some records may remain in anonymized form or may be retained where required for audit, security, payment, accounting, fraud-prevention, legal, or dispute-resolution purposes. Information contained in backups may remain until the applicable backup is overwritten under the normal backup cycle.

Deleting your Artichoke account does not automatically cancel an Apple App Store subscription. You must cancel the subscription through your Apple Account subscription settings. Apple may continue processing the subscription until it is cancelled or expires. Artichoke may retain limited transaction records needed to reconcile the purchase and meet legal obligations.

Depending on applicable law, you may have the right to:

• access personal information held about you;
• correct inaccurate or incomplete information;
• request deletion or anonymisation;
• restrict or object to certain processing;
• receive certain information in a portable format;
• withdraw consent where processing relies on consent; and
• complain to the data-protection authority responsible for your place of residence or work.

The app provides controls for privacy preferences, requesting a data export, and deleting your account. You may also contact marina.sahackaya@gmail.com. We may need to verify your identity before completing a request. These rights may be subject to lawful limitations, including obligations to retain transaction, security, or legal records.

You can manage Apple Health access through Apple Health or iOS settings. You can manage or cancel an App Store subscription through your Apple Account subscription settings.

Artichoke and SkillFuel use reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. These measures include access controls, tenant separation, encryption in transit, logging, monitoring, and restricted administrative access. No method of storage or transmission is completely secure, and we cannot guarantee absolute security.

The Service is not intended for children under 13. A person under the minimum age required to consent to digital services in their country should use the Service only where a parent, guardian, or other legally authorized person has provided any required consent. If you believe a child has provided personal information without the required authorization, contact marina.sahackaya@gmail.com.

We may update this policy to reflect changes in the Service, service providers, law, or our privacy practices. We will publish the updated policy and revise the "Last updated" date. Where a change materially affects your rights or how sensitive information is handled, we will provide additional notice or obtain consent where required.

For privacy questions, requests, or complaints, contact:

Artichoke

Email: marina.sahackaya@gmail.com

You may also have the right to contact the competent data-protection authority in your country.