Privacy Policy

Actica, LLC. (“Company,” “we,” “us,” or “our”) establishes this Privacy Policy for the handling of user information in connection with the mobile application and related services provided under the name “Iromi” (the “Service”).

The Japanese version of this Privacy Policy is the legally controlling version. The English version is provided for reference purposes only.

1. Information We Collect

We may collect the following information from users of the Service:

• Account information, such as name, nickname, email address, Apple account identifier, authentication information, and subscription status.
• Food, meal, nutrition, lifestyle, and health-related information voluntarily entered or uploaded by users, including food photos, meal records, calorie information, nutrition information, body-related information, goals, preferences, and related notes.
• Images, prompts, text, and other content submitted by users for food recognition, nutrition estimation, AI analysis, or other Service features.
• Payment, billing, and subscription information processed through Apple, RevenueCat, Stripe, or other payment-related providers. We do not directly store complete payment card information.
• Device and usage information, such as device type, operating system, app version, language settings, identifiers, log data, crash reports, diagnostics, and usage activity.
• Attribution, advertising, and marketing measurement information, such as campaign information, referral source, install attribution, advertising identifiers where permitted, and interactions with advertisements or marketing campaigns.
• Information collected through cookies, SDKs, analytics tools, or similar technologies, where applicable.
• Information included in inquiries, support requests, survey responses, or other communications with us.

2. Sensitive Information and Health-Related Information

Some information voluntarily entered by users may include health-related information or other sensitive information under applicable law.

By voluntarily entering, uploading, or submitting health-related information, users expressly consent to our handling of such information for the purposes described in this Privacy Policy.

The Service is not intended to provide medical treatment, medical advice, medical diagnosis, or individualized dietary advice.

3. Purposes of Use

We use user information for the following purposes:

• To provide, operate, maintain, and improve the Service.
• To create, manage, authenticate, and secure user accounts.
• To provide food recognition, nutrition estimation, calorie estimation, meal tracking, AI-generated analysis, and related features requested by users.
• To provide subscription management, billing support, entitlement verification, and related customer support.
• To analyze usage, improve usability, develop new features, and maintain service quality.
• To measure marketing performance, understand referral sources, perform attribution, and improve advertising and promotional campaigns.
• To detect, prevent, investigate, and respond to fraud, abuse, security incidents, technical issues, and violations of the Terms of Service.
• To respond to inquiries, support requests, notices, and other communications.
• To send important notices regarding the Service, including changes to features, policies, terms, security, or operations.
• To comply with applicable laws, regulations, legal procedures, and requests from public authorities.
• To create statistical, aggregated, or anonymized information that does not identify individual users.

4. Third-Party Service Providers

We may use third-party service providers to operate, maintain, improve, analyze, secure, and provide the Service. These providers may process user information on our behalf and may be located outside Japan.

The providers we use may include, for example:

Provider	Purpose
Google Analytics	Analytics and usage measurement
Amplitude	Product analytics, usage analysis, and service improvement
Firebase	Analytics, authentication, cloud messaging, diagnostics, and related app services
AppsFlyer	Attribution, marketing analytics, campaign measurement, and fraud prevention
RevenueCat	Subscription management and entitlement verification
Stripe	Payment processing, billing, invoice management, and related payment support
Google Cloud	Cloud infrastructure, storage, computing, and related backend services
Cloudflare	Content delivery, network performance, and security
Sentry	Error monitoring, crash reporting, diagnostics, and service reliability
Apple Sign In	Authentication
OpenAI	AI-powered food recognition, nutrition estimation, text analysis, and related AI features
Anthropic	AI-powered analysis, text processing, and related AI features
Meta SDK	App analytics, advertising attribution, marketing measurement, and related Meta platform integrations

We use these services only to the extent reasonably necessary to provide, operate, maintain, improve, analyze, and secure the Service.

5. External Transmission of User Information

The Service and related websites may use cookies, SDKs, analytics tools, attribution tools, advertising and marketing measurement tools, error monitoring tools, authentication services, payment and subscription management services, cloud infrastructure, AI service providers, or similar technologies.

Through these technologies, user information such as device information, app usage information, identifiers, advertising identifiers where permitted, attribution and campaign information, diagnostic data, authentication-related information, payment-related information, subscription-related information, images, text, prompts, and other information submitted for AI features may be transmitted to the third-party providers listed above or their subprocessors.

Where required under applicable law, including Japan’s Telecommunications Business Act, this section serves as our disclosure regarding the external transmission of user information.

6. Outsourcing and International Transfers

We may outsource part of our business operations to third-party service providers to the extent necessary to provide the Service. In such cases, we exercise appropriate supervision over service providers in accordance with applicable law.

Some service providers and their subprocessors may process information outside Japan, including in the United States, the European Union, or other countries where those providers operate. We take reasonable steps required under applicable law when handling personal data through service providers located outside Japan.

7. Disclosure to Third Parties

We do not disclose personal information to third parties except in the following cases:

• When the user has consented.
• When disclosure is necessary to provide the Service through service providers acting on our behalf.
• When disclosure is required by law or legal process.
• When necessary to protect the life, body, or property of a person and it is difficult to obtain user consent.
• When necessary to cooperate with public authorities and obtaining consent may interfere with such cooperation.
• In connection with a merger, business transfer, corporate reorganization, or similar transaction, to the extent permitted by law.

8. Data Retention and Account Deletion

We retain personal information only for as long as reasonably necessary to provide the Service, fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, maintain security, prevent fraud or abuse, and enforce our agreements.

Upon account deletion, we will delete or anonymize personal information within a reasonable period unless retention is required or permitted by law or is reasonably necessary for legitimate business purposes, such as security, fraud prevention, dispute resolution, compliance, backup restoration, or service integrity.

Aggregated or anonymized information that does not identify individual users may be retained and used after account deletion.

9. Security

We take reasonable organizational, technical, and physical measures to protect user information against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

These measures may include access controls, encryption in transit where appropriate, authentication controls, monitoring, logging, and secure cloud infrastructure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. User Rights

Users may request disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of third-party provision of their personal information in accordance with applicable law.

To make a request, please contact us using the contact information below. We may ask users to verify their identity before responding to such requests.

11. Children and Minors

The Service is not intended for children under the age of 13.

If a minor uses the Service, the minor must obtain consent from a parent or legal guardian. If we learn that we have collected personal information from a child or minor in a manner inconsistent with applicable law, we will take appropriate action.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify users by an appropriate method, such as posting within the Service or on our website.

The revised Privacy Policy will become effective when posted or otherwise notified, unless otherwise specified.

13. Contact

For inquiries regarding this Privacy Policy or our handling of personal information, please contact:

Actica, LLC. Ebisu Urban House, 1-4-1 Ebisu, Shibuya-ku, Tokyo, Japan support@actica.jp