1. Who we are and how to contact us
The controller of your personal data is Anastasia Dremkova, a sole trader registered in the Czech Trade Licensing Register, Business ID (IČO) 17411408, Korunní 2569/108f, Vinohrady, 101 00 Prague 10, Czech Republic (“we”, “us”).
- Privacy and your rights: soukromi@davkapp.com
- Support and other questions: podpora@davkapp.com
2. What this policy covers
This policy covers the Dávka app for iPhone and Android, the davkapp.com website and emails with us. We follow Regulation (EU) 2016/679 (GDPR) and Czech Act No. 110/2019 Coll.
The app is intended only for adults aged 18 and over. If we learn that someone younger is using it, we will delete their account.
Providing data is voluntary. Without an account, backup won’t work, and without consent, AI meal recognition won’t work; everything else does.
3. What stays only on your phone
Everything you log or photograph in the app is stored on your phone. We cannot access it unless you switch on backup (section 5) or use AI (section 6).
We never send progress photos to our server or to AI. Your phone schedules reminders itself. PDF or JSON exports and error logs are created only on your phone. Your system backup in iCloud or with Google may include app data; you, Apple or Google control it, and we have no access to it.
4. Account and sign-in with Apple or Google
An account is optional and is used only to back up and restore your entries. You sign in with Apple or Google, with no password.
- Data: your Apple or Google account identifier, a hash of your email address (we do not store the address itself), your internal account number, when the account was created and last active, sign-in tokens, possibly a device label and, for Apple, a token used to revoke the link when you delete your account.
- Purpose: signing in, restoring your backup and verifying requests about your account.
- Legal basis: performance of a contract, namely our Terms of Use (Art. 6(1)(b) GDPR).
- Retention: until you delete your account. If you don’t use the app for 180 days, your sign-in expires.
Anonymous technical account for AI. If you use AI without signing in, the app creates, after your consent, a technical account with no name or email, used only to authenticate requests and enforce the daily limit. We delete it if you don’t use AI for 90 days.
5. Backup and sync
You switch on backup separately for each category (Medications & doses, Food & drink, Feelings & symptoms, Weight & measurements), always with your explicit consent. It is off by default. With an account, we also store records of your consents and app settings that contain no health data.
- Purpose: backup, restoring and syncing between your devices.
- Legal basis: for the categories, your explicit consent (Art. 9(2)(a) and Art. 6(1)(a) GDPR); for consent records, our obligation to demonstrate consent (Art. 6(1)(c) and Art. 7(1) GDPR); for settings, performance of a contract (Art. 6(1)(b) GDPR).
On the server, your entries are encrypted with a key that belongs to your account, and we do not look at their content. This is not end-to-end encryption: we manage the keys.
You withdraw consent in Profile → Privacy & data. We then delete that category’s copy from the server; the data on your phone stays.
6. AI meal recognition
From a photo of a meal or nutrition label, or from a meal description, this feature estimates individual items and approximate nutritional values. It only works with your separate consent; without it, nothing is sent.
How the data travels: your phone → our server in Czechia (checks your consent and the daily limit) → OpenRouter, Inc. (USA) → an AI model provider, currently Google (Vertex AI) or Mistral AI, processing in the EU. The result is returned only to your phone.
The app reduces the photo and strips its metadata, such as location. We never pass on your name, email, account identifier or IP address. We require zero data retention: inputs are not kept after processing and are not used for training. OpenRouter has contractually committed to deleting inputs and outputs once the request is handled, unless retention is required by law or to prevent abuse.
- Legal basis: for the photo and description, your explicit consent (Art. 9(2)(a) and Art. 6(1)(a) GDPR). For the account identifier, usage counter and request records (without content), our legitimate interest in protecting the service against abuse (Art. 6(1)(f) GDPR).
- Retention: we do not store the photo or text. We delete usage counters and request records after 30 days.
You withdraw consent in Profile → Privacy & data → AI meal recognition. Learn more in How AI works in Dávka.
7. Apple Health and Health Connect
Connecting is optional. With your permission, the app reads your weight and daily step totals (for the last 30 days when you connect, then while you use the app) and writes only the weight you enter manually. It fetches nothing in the background. Values are stored in your journal on the phone and reach our server only with Weight & measurements backup.
This data is never used for advertising, marketing or profiling, never sold or shared with third parties, and never used to assess creditworthiness, insurance or employment. Our use of information received from Health Connect adheres to the Health Connect Permissions policy, including the Limited Use requirements. You can revoke access in the Health app on iPhone or in Health Connect on Android.
8. Other features that communicate outside your phone
- Voice input: speech is converted to text by Apple’s or Google’s speech recognition, on the device if possible, otherwise on their servers. We never receive the audio.
- Barcodes: your phone sends the barcode number directly to the Open Food Facts database (France, an independent controller). Your IP address is technically transmitted as well.
9. Operations and security
The servers behind the app and website keep technical access logs (IP address, time, requested page, type of app or browser) without the content of your entries. To protect against abuse, we count requests per IP address, storing only a hash of the address for up to 2 days. For accounts, we record security events, such as sign-in, without the IP address. The legal basis is our legitimate interest in operating the service securely (Art. 6(1)(f) GDPR).
We keep technical access logs for up to 14 days, account security events for 180 days and the record of an account deletion for 60 days. Communication is encrypted (HTTPS). We back up the database every night in encrypted form to servers in Czechia and delete backups after 14 days.
10. Contacting us and the davkapp.com website
When you email us (support, a complaint, a GDPR request), we process your email address, your name if you include it, and your message to handle it, comply with legal obligations and protect our legal claims (Art. 6(1)(b), (c) and (f) GDPR). Please don’t include health information in your email.
We never email you on our own initiative. The only exception is a one-time notification that the app has launched, sent only if you ask for it (consent, Art. 6(1)(a) GDPR). We delete your address once it has been sent.
The davkapp.com website uses no cookies, no analytics or advertising tools and loads no third-party content.
11. Who receives your data
We do not sell your data, use ad networks or data brokers, or track you across apps or websites.
Processors (only on our instructions, under a data processing agreement):
- INTERNET CZ, a.s. (FORPSI), Czechia: servers, database, backups and website.
- OpenRouter, Inc., USA, and AI model providers: AI meal recognition (section 6).
- Namecheap, Inc., USA: forwarding of emails sent to @davkapp.com addresses.
Independent controllers under their own policies: Apple and Google (app stores, sign-in, Apple Health and Health Connect, phone backups, speech recognition) and Open Food Facts (barcodes). We disclose data to public authorities only when required by law.
Transfers outside the EU. Transfers to the USA (OpenRouter, Namecheap) are based on the European Commission’s Standard Contractual Clauses (Decision (EU) 2021/914) or, where applicable, the EU-US Data Privacy Framework. We will send you a copy of the safeguards on request.
12. How long we keep data
| Data | Retention |
|---|---|
| Account and consent records | until you delete your account |
| Backed-up categories | until you withdraw consent or delete your account; from server backups within 30 days |
| Anonymous technical account for AI | 90 days after the last AI use |
| Photo and text sent to AI | not stored |
| AI usage counters and request records (without content) | 30 days |
| Sign-in tokens | up to 180 days; invalid immediately after sign-out, deleted within 30 days |
| Technical access logs | 14 days |
| IP address hash for request limits | 2 days |
| Account security events | 180 days |
| Record of an account deletion | 60 days |
| Record of a consent withdrawal or backup deletion (no content) | 60 days |
| Emails | 3 years after resolution |
13. Your rights
You have the right to access, rectify and erase your data (section 14), to restrict its processing and to data portability (JSON export in the app). You can object to processing based on legitimate interest. You can withdraw consent at any time, as easily as you gave it; this does not affect processing before the withdrawal. You can lodge a complaint with the Czech Office for Personal Data Protection (uoou.gov.cz) or with the data protection authority in the country where you live.
You can exercise your rights in the app (Profile → Privacy & data) or at soukromi@davkapp.com. We reply free of charge within one month, or within three months for complex requests. We may ask you to confirm your identity.
We do not carry out automated decision-making or profiling with legal or similarly significant effects (Art. 22 GDPR).
14. Deleting your account and data
- With an account: Profile → Account → Delete account. We delete your account and all data on the server, and the app deletes its data on your phone. If you use Sign in with Apple, we ask Apple to revoke Dávka’s link to your Apple Account.
- Without an account: Profile → Privacy & data → Delete all data. This deletes the data on your phone and any technical account for AI.
- Offline: choose Delete on this phone only. Data on the server remains until you delete your account or ask us to.
- Without the app: follow the Delete your account and data page.
We delete data from the live database immediately and from encrypted backups within 30 days. We keep only a record that the account was deleted (a pseudonymous account number and the time) for 60 days, so that we can repeat the deletion if we ever restore a backup. Emails are kept as set out in section 12. You manage shared exports and phone backups yourself.
15. Changes to this policy
We update this policy when the app or the law changes. We will inform you about material changes in the app in advance, and if new consent is needed, we will ask for it.
Version 2026-10-v1, effective from October 20, 2026.