Privacy Policy

Effective date: 21 May 2026
Last updated: 31 May 2026

This Privacy Policy explains how the Evora iOS app ("Evora", "we", "us") processes information when you use it. Evora is a calm AI wellness companion that helps you log meals, hydration, sleep and body data and provides personalized insights. Privacy is a core design principle: most of your data stays on your device, and AI processing happens on‑device whenever possible.

1. Who we are

Controller:
KSol.IT
Maximilian Kenfenheuer
maximilian.kenfenheuer@ksol.it

If you have any question about this policy or your data, please contact us at the address above.

2. Summary at a glance

Evora does not use analytics, advertising SDKs, or cross‑app/cross‑site tracking. We do not sell your data.

3. Data we process

3.1 Data you enter into the app

• Profile: optional display name, age range, height, weight, target weight, biological sex (when read from Apple Health), health goals, dietary preferences, allergies, dislikes, cuisines, pantry items.
• Logs: meals (name, portions, macros, kcal, optional photo), drinks (water), sleep entries (bedtime, wake time, quality), body weight, habits, journal entries.
• Coach interactions: free-text questions you ask the in‑app coach.
• Settings: notification preferences, units, language.

This data is stored locally on your device using Apple's SwiftData framework. If you have iCloud enabled, it can sync via CloudKit to your private iCloud database. We have no access to your CloudKit data — only you (signed in with your Apple ID) do.

3.2 Apple Health (HealthKit)

If you grant permission, Evora reads from Apple Health:

• Active and basal energy burned, step count
• Heart rate, resting heart rate, heart rate variability (HRV)
• Sleep analysis
• Dietary energy, protein, carbohydrates, fat, water
• Body mass, height, biological sex
• Workouts

Evora writes to Apple Health (so your logs stay in one place):

• Dietary energy, protein, carbohydrates, fat
• Water
• Body mass (when you log weight)
• Sleep analysis (when you log sleep)

Background delivery is enabled to keep the home view current. HealthKit data never leaves your device — it is not sent to our servers or any third party. Samples that Evora writes to Apple Health are tagged so they can be cleaned up if you delete the corresponding entry in the app.

3.3 Camera and photos

If you use meal capture by photo, the camera is used to take a picture (with your permission). The photo is then either processed locally on the device by Apple's on‑device AI (Apple Foundation Models) or, where on‑device recognition is unavailable or fails, sent to our analysis service (see §3.6) for one‑off analysis. Photos are not stored on our servers after analysis. You may optionally keep the photo locally with the meal entry.

3.4 Barcode scanning

When you scan a product barcode, only the barcode number is sent to Open Food Facts — a free, public, crowd-sourced food database — to look up product name, brand and nutrition. No personal data is sent. Open Food Facts' privacy policy is available on their website.

3.5 On‑device AI (Apple Foundation Models)

For meal planning suggestions and coach insights, Evora primarily uses Apple Foundation Models, which run entirely on your device. No prompt, input or output leaves your device for this processing.

3.6 Cloud AI analysis service

Some features require server-side processing. The Evora analysis service is operated by KSol.IT in the EU and is used for:

• Meal text analysis: we send the free-text description you typed (e.g. "chicken salad with rice, 400g") and your preferred language. The service returns structured nutrition data.
• Meal image analysis: we send the meal photo and your preferred language. The service returns the recognized food and nutrition.
• Coaching summaries: we send anonymous, aggregated daily metrics (kcal, macros, hydration, sleep duration, steps) needed to produce a personalized insight.
• Scanned-item coaching: when you ask the coach to rate a scanned product, we send the product details returned by Open Food Facts (barcode, title, brand, nutrition, ingredients) together with your primary goal and calorie/protein targets. We do not send your daily intake, history or recovery data for this call. The service returns a short rating, rationale and suggested alternatives, and caches the response by barcode + language + goals so identical scans are returned instantly.

What we do not send to the service: your name, email, Apple ID, device identifiers used for tracking, raw HealthKit samples, your full meal history, your profile (allergies/diet are only sent when needed for the specific request), photos that are not part of an analysis request.

The service does not have user accounts; we do not maintain a server-side profile of you. Request data is processed transiently and not persisted beyond what is technically necessary to fulfil the request and short-term operational logs (see §7).

Server-side AI inference is performed by trusted sub-processors (LLM and vision providers) under data-processing terms that prohibit use of submitted content for training their models. See §6.

3.7 Push notifications

If you enable notifications, Apple Push Notification service (APNs) assigns a device token. We use it only to deliver Evora's own reminders (hydration, daily briefing). We do not share it.

3.8 In‑app purchases

Purchases (Plus / Pro subscriptions) are handled by Apple via StoreKit 2. We do not receive your payment information. We only receive a receipt confirming whether you have an active subscription.

3.9 Diagnostics

Evora does not use third-party analytics or crash-reporting SDKs (no Firebase, no Sentry, no Mixpanel, no Meta/Google SDKs). If you opted in to share crash data with Apple via iOS Settings, Apple may share aggregate, anonymized crash reports with us via App Store Connect.

3.10 Device integrity (app authentication)

To protect the analysis service from abuse and to control the cost of AI processing, the app verifies that it is a genuine, unmodified copy of Evora running on a real Apple device before it calls our API. This uses Apple's App Attest (DeviceCheck) framework:

• A cryptographic key is generated on your device and an attestation is verified by Apple and by our API. Our API then issues short-lived tokens used to authenticate subsequent requests.
• The attestation contains no personal information and does not identify you. It is tied to the app installation, not to your identity, and is used only to authenticate requests and apply per-installation rate limits.
• No shared secret is embedded in the app; the token-signing key stays on our server.

4. Legal bases (GDPR, EU/EEA)

Where GDPR applies, we rely on the following legal bases (Art. 6 / Art. 9 GDPR):

• Performance of the contract (Art. 6(1)(b)): providing the core app features you requested (logging, syncing, AI analysis of content you submit).
• Explicit consent (Art. 6(1)(a) and Art. 9(2)(a)) for health data and Apple Health permissions, the camera, notifications and any optional cloud processing. You can withdraw consent at any time via iOS Settings or in‑app settings.
• Legitimate interest (Art. 6(1)(f)) for operating the service securely (device-integrity attestation, rate limiting, minimal short-term logs to protect against abuse and control processing cost).

Health data is Article 9 special-category data. It is processed only on the basis of your explicit consent and, with respect to HealthKit data, never leaves your device.

5. How long we keep data

• On-device data (SwiftData): kept until you delete the entry or uninstall the app.
• iCloud (CloudKit) data: kept in your private iCloud database until you delete it or sign out of iCloud. We cannot access it.
• Analysis service data: meal text, image and coaching content is processed transiently and is not stored as user history. Operational logs (timestamps, request size, status codes — no content) are kept up to 30 days for security and abuse prevention, then deleted.
• Sub-processor data (LLM providers): no retention for training; transient processing only.

6. Sub-processors and third parties

We use the zero data retention / no training modes of AI providers where available.

7. International transfers

Evora's analysis service is operated by KSol.IT in the EU. AI sub-processors may process content outside the EU/EEA (e.g. in the United States). Where applicable, transfers are protected by EU Standard Contractual Clauses and additional safeguards. Apple processes data according to its own terms; iCloud data is stored in regions chosen by Apple.

8. Security

• All network communication uses encrypted transport (HTTPS/TLS), with certificate pinning to our analysis service.
• Requests to our analysis service are authenticated using Apple App Attest and short-lived, server-issued tokens. No shared signing secret is stored in the app.
• App data is stored in Apple's protected SwiftData/CloudKit containers.
• HealthKit data is gated by iOS's permission system.

No system is perfectly secure. Please keep your device updated and protect it with a passcode/Face ID.

9. Your rights

Under GDPR (and equivalent rights in other regions, including the UK GDPR and CCPA in California), you have the right to:

• Access your data
• Correction of inaccurate data
• Deletion ("right to be forgotten")
• Restriction of processing
• Portability
• Objection, including to legitimate-interest processing
• Withdraw consent at any time
• Lodge a complaint with a supervisory authority

Because most of your data is stored locally on your device or in your private iCloud, you can exercise most of these rights directly:

• Delete individual entries in Evora (meals, drinks, sleep, weight, journal).
• Reset all app data: iOS Settings → Evora → reset, or delete the app. iCloud data: iOS Settings → Apple ID → iCloud → Manage Account Storage → Evora → Delete data.
• Revoke permissions (Health, Camera, Notifications): iOS Settings → Privacy & Security or iOS Settings → Evora.
• Manage your subscription: iOS Settings → [your name] → Subscriptions.

For any request that cannot be fulfilled directly in iOS, contact maximilian.kenfenheuer@ksol.it. We respond within 30 days.

10. Children

Evora is not directed at children under 16. We do not knowingly process data of children under 16. If you believe a child has provided data, please contact us so we can delete it.

11. Automated decision-making

Evora's AI features produce informational suggestions about meals, hydration and recovery. They are not medical advice and have no legal or similarly significant effect on you. You can ignore any suggestion. Evora does not perform profiling within the meaning of Art. 22 GDPR.

12. Not a medical device

Evora is a wellness and self-tracking app. It is not a medical device and does not diagnose, treat, cure or prevent any disease. Always consult a qualified healthcare professional for medical decisions.

13. Changes to this policy

We may update this policy as the app evolves. When we do, we will update the "Last updated" date above and, for material changes, notify you in-app.

14. Contact

KSol.IT — Maximilian Kenfenheuer
Email: maximilian.kenfenheuer@ksol.it