Privacy Policy

Protecting your personal information is our top priority, which is why we only use your data in strict compliance with applicable data protection principles. Please read our privacy policy carefully. If you have any questions or comments about our privacy policy, you can always contact us at the e-mail address below.

1. Overview
The following privacy policy informs you about the nature and extent of the processing of personal data by Lowcal Technologies FZ-LLC, Office 118, Floor 1, Building 01, Dubai Internet City, Dubai, United Arab Emirates (hereinafter “Lowcal”, “we”, “us” or “our”). Personal data is any information that allows an individual to be identified directly or indirectly. The use of our app, products, services, technologies or features, and all related pages, applications and services (collectively referred to as the “Services”), is governed by this Privacy Policy.

When you register for the first time, or log on in the case of existing customers, you declare by means of a simple notification that you accept this privacy policy and expressly consent to the handling, use and disclosure of your personal data in the manner described herein.

The data gathered by Lowcal can be divided primarily into two categories:
o All data required for the processing, preparation and performance of an agreement with Lowcal. If other service provides are involved in the performance of the agreement, e.g. payment services, optimization services or hosts, your data will be forwarded to them to the extent required.
o When you access our Services, some information is exchanged between your device and our server, or the server of the services we use. This may include personal information. One of the ways in which the information gathered in this way will be used to further improve our Service.

Some of the advertisements you see on the Site are selected and delivered by third parties, such as ad networks, advertising agencies, advertisers, and audience segment providers. These third parties may collect information about you and your online activities, either on the Site or on other websites, through cookies, web beacons, and other technologies in an effort to understand your interests and deliver to you advertisements that are tailored to your interests. Please remember that we do not have access to, or control over, the information these third parties may collect. The information practices of these third parties are not covered by this privacy policy.

However, under this Privacy Policy, you have various rights that you can assert with us. These include the right to selectively object to the use of data, particularly for advertising purposes. Further information on your rights can be found in the additional section below and in the individual descriptions of the respective data uses.

Our Services are only available to users who are 18 years of age or older. If you are not at least 18 years old, you may only use our Services if your parents have given their consent herein, and you have provided sufficient proof of this consent.

The Website Policies and Terms & Conditions may be changed or updated occasionally to meet the requirements and standards. Therefore the Customers’ are encouraged to frequently visit these sections in order to be updated about the changes on the website. Modifications will be effective on the day they are posted.

If you have any questions about our Privacy Policy, you may contact our data privacy officer by email at: feedback@lowcaltech.com.

2. Important Contact Information
This privacy policy applies to the use of data by Lowcal Technologies FZ-LLC, Office 118, Floor 1, Building 01, Dubai Internet City, Dubai, United Arab Emirates, as the responsible party for the following services: www.lowcaltech.com and the Lowcal Mobile Apps. The company may be reached at the aforementioned address or by email at feedback@lowcaltech.com.

3. Purposes of Data Collection, Legal Basis and Legitimate Interests Pursued by Us or a Third Party, and Categories of Recipients

3.1. Accessing our Service
If you access our Services, especially by visiting our website or app, the app or the browser used on your device automatically sends information to our server and temporarily stores it in a log file. The following information is collected without your intervention and stored until it is automatically or manually deleted in the log file:
o Your device’s IP address
o Date and time of access
o The name and URL of the retrieved file, the website/app from which access was made (referrer URL)
o Your browser’s unique identifier
o The name of your Internet provider

Our legitimate interest arises from the uses listed below. At this point, we note that we are unable and do not attempt to draw any conclusions about your identity from the data collected. Your device’s IP address and the other information listed above are used by us for the following purposes:
o To ensure that a trouble-free connection can be established
o To ensure the convenient use of our Services
o To evaluate system security and stability
o Other administrative purposes

The data is stored in compliance with legally established data retention periods and then deleted automatically. We also use cookies, tracking tools, targeting methods and interfaces to other services such as social media platforms, payment processors or app store providers. The exact procedures, and how your data will be used for this purpose, are explained in more detail in Section 4 below.

3.2. Concluding, Performing or Terminating an Agreement
We primarily define our Services as those of a personal nutrition and fitness trainer. Based on your own self-defined training goals, we prepare your nutrition and workout plans that are equipped with suggested recipes and a broad variety of other information about health, fitness and nutrition. To do this, we collect the information required to conclude, perform or terminate an agreement. This includes:
o E-mail address
o First and last name
o Billing and payment information
o Information you enter yourself and that is generated during the use of our Services, such as gender, age, height, weight, training goals, training history, sporting activities, mealtimes, etc.

Unless we use your contact information for customer support or customer service (see details under Section 3.3), the information required to conclude the agreement is stored until it is no longer needed for this purpose and/or until the rights under any guarantee or warranty expire. Subsequently, we retain the required personal information for the periods established by law. During this retention period (usually six to 10 years after conclusion of the agreement), the information is used only in the case of an audit by the tax authority.

3.3. Data Processing for Customer Support or Customer Service
3.3.1. Informational purposes
If you have signed up for our Services, we manage you as an existing customer. In this case, we process your contact information in order to send you information about new, enhanced or improved features, products and services, etc.
3.3.2. Personalized ads
To ensure that you receive only information that corresponds to your interests, we classify and add information to your customer profile. For this purpose, both statistical information as well as information about you (such as basic or historical data from your customer profile) are used. The goal is to optimize our Services by adapting them to your actual or perceived interests and/or needs, and to send you the appropriate recommendations and not bother you with useless ads.
3.3.4. Newsletters
One of our Services is to offer prospective customers the opportunity to sign up for our newsletter. We use the double opt-in process to confirm that the email address entered actually corresponds to the prospective customer. After the email address is entered, we send you a confirmation link. Your email address will only be included on our mailing list after you click on this confirmation link. We store the information collected during this process only for purposes of documentation and proof. This includes:
o The email address you provide
o Your IP address
o The date and time of registration
o Form of address
o The date, content and time of the confirmation email
o The IP address of the device used for the confirmation
o The date and time of your confirmation

We store this information until the contract relationship ends as proof of the legality of sending the newsletter. After the contract relationship ends, we retain the required personal information for the period specified by law. During this period (usually 10 years from the conclusion of the agreement), the data will only be processed again in the event of a tax audit. You can revoke your consent at any time with effect for the future. Simply click on the unsubscribe button in the respective e-mail or send a short note by e-mail. Please use the options to contact the company’s data privacy officer for this purpose.
3.3.5. Right to Object
You may object to the use of your data for the aforementioned purposes at any time free of charge for each communication channel and with effect for the future. An email or a letter sent using the contact information shown under Section 2 is sufficient for this purpose.
Once you submit your objection, we will block the relevant contact address for future advertising data processing. We will process your objection as soon as possible and implement the appropriate blocking measures immediately after it is confirmed. Please note that in some exceptional cases the relevant information or product recommendations may still be received even after receipt of your objection. This is simply due to technical reasons and does not mean your objection has not been processed. Thank you very much for your understanding.

4. Data Processing for the Provision of our Services
In this section, we inform you about the data processing necessary for the provision of our Services:

4.1. Online Presence and Website Optimization
We will not sell or lease your information to third parties for their marketing purposes without your explicit consent. We only disclose certain information to third parties from time to time to be able to offer the best possible product to our customers, improve the quality of our Services and protect the interests of our customers. However, this disclosure will always be subject to strict limitations, which are described in more detail below.
4.1.1. Cookies – General Information
We use cookies on our website. Our interest in improving our Services is recognized as legitimate in the aforementioned provision. Cookies are small files generated automatically by your browser and stored on your device (laptop, tablet, smartphone, etc.) when you use our Services. Cookies do not harm your device, and do not contain viruses, Trojans or other malware. Cookies contain information downloaded by the specific device. This does not mean, however, that we receive direct knowledge of your identity. One purpose of cookies is to make it more convenient for you to use our Services. For example, we use session cookies to track your use of the individual pages of our website. When you use our Services again at a later time, the cookie automatically recognizes your previous visit to the website, as well as your input and settings, so that you do not have to enter them again. To make the site more user-friendly, we also use temporary cookies, which are stored on your device for a predetermined period of time. These cookies are automatically deleted when you log off.
If you already have a customer account and are logged on, the information stored in the cookies are associated with that account.
Another reason we use cookies is to gather statistics on the use of our Services and evaluate them in order to optimize your experience and to display information tailored to you. These cookies allow us to automatically recognize that you have visited our site before. The cookies are automatically deleted after a predefined period. Most browsers accept cookies automatically. However, you can disable cookies on your browser or choose to be notified when a new cookie is created. However, disabling cookies completely may mean that not all features of our Services will be available to you. The storage period of cookies depends on their purpose and may vary.
4.1.2. Braze
To design and continuously improve our customer engagement efforts, we use the external service provider Braze, 318 W 39th St, 10018 New York City, USA, (hereinafter “Braze”). We use Braze to control our email marketing campaigns and to reach out to our registered users. For this purpose, when you set up a Lowcal account using our website, we send the following information to Braze:
o Name
o Email address
o Time zone
o IP address
o Location
o Language used
o Device information (screen resolution, browser information and operating system)
You can object to this data processing at any time by either clicking on the unsubscribe button of the respective newsletter or simply informing us that you no longer wish to have such processing in the future. Please use the contact options of our company data privacy officer for this purpose.
4.1.3. Yahoo Gemini Tag
To manage our marketing campaigns, we use the Yahoo Gemini Tag tool, a product of Oath Ltd. (formerly Yahoo), 5-7 Point Square, North Wall Quay, Dublin, Ireland (hereinafter “Yahoo Gemini”). This service helps us to optimize our campaigns and adapt advertising media to specific behaviors and interests, and track their conversion. The tool is integrated into our Services as a Javascript library. The data processing initiated for this purpose is generally anonymous. The identification of an individual with the use of the tool is not intended or desired. However, the identification of an individual in exceptional cases cannot be ruled out with complete certainty, which is why we wish to inform you about it. The following data is collected when the tool is used:
o Device information (e.g. type, brand)
o Device operating system (e.g. iOS 11),
o IP address of the device
o Date and time our Services are accessed
o Type of campaign and content
o Response to the respective campaign (e.g. clicking on a button)
The data processing for advertising on the basis of behavior and interests is recognized as in our legitimate interest. The information is stored for the legally established retention periods and then deleted. More detailed information on this tool is available on the Yahoo Gemini website at https://policies.yahoo.com/ie/de/yahoo/terms/advertising/index.htm.
4.1.4. Facebook Pixel
To set up, continuously improve, and track the conversion of our Facebook campaigns as required, we use the individual visitor action pixel of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter “Facebook”). This pixel is integrated into our website’s code. This helps us ensure that the Facebook ads we initiate are only displayed to Facebook users who have shown interest in our Services. In this way we know that our Facebook ads correspond to the potential interest of the respective users and not bothering them. It also allows us to track the actions of Facebook users after they have viewed or clicked on one of our Facebook ads. At the same time, it helps us track the conversion of the respective campaign for statistical, market-research and billing purposes. The following information is collected during its use:
o Time stamp
o URL
o Campaign-related information (impression, form field and activated button specifications)
Information collected in this way is anonymous to us and therefore does not provide us with any information about the identity of the respective user. Such processing for behavioral and interest-based advertising purposes is recognized as in our legitimate interest. The data is stored in accordance with the legally established retention periods and then automatically deleted.
You should be aware that when you log on after placing the pixel on your Facebook account, or you visit our website while logged on, Facebook may store and process this information. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s data policy: https://www.facebook.com/about/privacy/. You can find more information about the Facebook pixel here. You can enable Facebook and its partners to display ads on and off Facebook.
4.1.5. Facebook Lookalike Audiences
To optimize targeting and track the conversion of our Facebook campaigns, we use the option of developing Facebook lookalike audiences offered to us by Facebook. You can find more information about the Facebook Lookalike Audiences at: https://www.facebook.com/business/help/365463786964246.
The data processing for advertising on the basis of behavior and interests is recognized as in our legitimate interest. If you belong to the Facebook Lookalike Audience, we send your email address and your device’s ID to Facebook.
4.1.6. Facebook Login
We allow you to sign up for and log on to our Services via the Login with Facebook feature. This replaces the otherwise necessary registration. To log in, you are redirected to the Facebook server, where you sign on using your user information. This links your Facebook profile to our Services. By using this simplified login feature, you give us your consent to use the following information from your publicly visible profile:
o Name
o Location
o Birth date
o Gender
o Email address
o Time zone
o Friends or
o Profile photo
The purpose of the data collection above is the simplified login and the establishment and fulfilment of an agreement. This information is required for the conclusion of the agreement in order to be able to identify it. For the purpose and scope of Facebook’s data collection and the further processing and use of the information, as well as the associated rights and setting options to protect your privacy, please consult the Facebook privacy information.
4.1.7. Pinterest Tag
To set up, continuously improve, and track the conversion of our Pinterest campaigns as required, we use a Pinterest Tag, an individual code snippet, from Pinterest Inc., 635 High Street, Palo Alto, CA, USA, (hereinafter “Pinterest”), which is integrated in our website. This helps us ensure that the Pinterest ads we initiate are only displayed to Pinterest users who have shown interest in our Services. In this way, we know that our Pinterest ads correspond to the potential interest of the respective users and not bothering them. It also allows us to track the actions of Pinterest users after they have viewed or clicked on one of our Pinterest ads. At the same time, it helps us track the conversion of the respective campaign for statistical, market-research and billing purposes. The following information is collected during its use:
o Device information (e.g. type, brand)
o Device operating system (e.g. iOS 11),
o IP address of the device
o Date and time our Services are accessed
o Type of campaign and content
o Response to the respective campaign (e.g. clicking on a button)
Information collected in this way is anonymous to us and therefore does not provide us with any information about the identity of the respective user. Such processing for behavioral and interest-based advertising purposes is recognized as in our legitimate interest. The data is stored in accordance with the legally established retention periods and then automatically deleted.
When you log in to your Pinterest account after visiting our website while logged on, Pinterest might store and process this information, which is why we would like to inform you about this. Pinterest can link this data with your Pinterest account and use it for its own advertising purposes. You can read more about Pinterest’s data policy at https://policy.pinterest.com/de/privacy-policy.
4.1.8. Taboola
We use an individual pixel from Taboola Inc., Oneustonsq, 40 Melton Street, 13th Floor, London, NW1 2FD OR 28 West 23rd St. 5th fl., New York, NY 10010 (hereinafter “Taboola”). This allows us to optimize our marketing campaigns, and customize them as much as possible to the personal interests of the target audience. It permits us to adapt our approach to their specific behaviors and interests. Ultimately, we are able to track the conversion of the respective campaign. For this purpose, the following information is processed:
o Device information (operating system, browser version)
o The (truncated) IP address of the device
o Browser type
This information is combined by Taboola into a user profile using pseudonyms. These user profiles are not merged with information about the bearer of the pseudonym and do not allow any conclusions to be drawn about your personal data. Data processed in this way to optimize the behavioural and interest-based marketing of our Services is considered to be in our legitimate interest. The information is stored in compliance with the legally established retention periods and then automatically deleted. You can find more information about Taboola’s data privacy policy at: https://www.taboola.com/privacy-policy.
4.1.9. Snowplow
For the custom design and continuous improvement of our Services, we use Snowplow open-source analytics of Snowplow Analytics Ltd., the Roma Building, 32-38 Scrutton Street EC2A 4RQ London, UK (hereinafter “Snowplow”). It is installed on our own servers. The following information is sent only to our webhost:
o Device information (e.g. type, brand)
o Operating system (e.g. iOS 11),
o Provider name (e.g. Vodafone),
o Events in the app and the use of individual features, such as your personal training plan, the activities you enter, access to recipes, or the period of use.
Data processed in this way to optimize our Services is considered to be in our legitimate interest. The information is stored in compliance with the legally established retention periods and then automatically deleted.
4.1.10. Google Analytics
For the custom design and continuous improvement of our Services, we use the web analytics service of Google Analytics of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”). Using cookies, Google creates pseudonymised user profiles. The information generated by the cookies for users includes:
o Browser type/version
o Operating system
o Referrer URL (previously visited page)
o Host name of the accessing computer (IP address)
o Time of the server request
This information is sent to a Google server in the U.S. and stored there. The information is used to evaluate the use of our Services, to compile reports on the activities, and to provide other related services for purposes of market research and customized design. This information may also be sent to third parties if required by law or if third parties process this data on behalf of Google. Under no circumstances will your IP address be merged with any other Google data. The IP addresses are anonymised so that assignment is not possible (IP masking).
You can prevent the installation of the cookies in advance by configuring your browser software accordingly or object to the continued processing of your data with the cookies by clicking on the opt-out link. Please note that if you disable cookies, it will not be possible to fully take advantage of all of the features of our Services. You can also prevent Google from collecting and processing the data generated by the cookies and related to your usage (including your IP address) by downloading and installing this browser add-on. On mobile devices, we recommend using private mode. You can find more information on protecting your privacy in relation to Google Analytics on the Google Analytics website.
4.1.11. Google Tag Manager
We manage website tags (website code) with Google Tag Manager. These tags help us manage and continuously improve our Services and reduce your loading time. Google Tag Manager only implements website code. Google Tag Manager itself does not generate cookies or collect any personal information. It merely integrates website code that we have stored elsewhere that may be used to collect data. It is therefore only used to facilitate the management of the respective code, but does not itself access the data processed by the code. In this privacy policy, we inform you about all tags that are integrated in this way. Consult the relevant Google pages for more information about Google Tag Manager and user guidelines.
4.1.12. PayFort Payment Service
For the fulfillment of the agreement and to process payments in particular, we send your name and email address to our payment gateway PayFort International FZ LLC, Office 202, BT Building, Dubai Internet City, Dubai, UAE (hereinafter “PayFort”). By using PayFort’s library, the information entered during the ordering process (e.g. address, account number, bank code, credit card number, invoice amount, currency and transaction number) will not be processed by us but sent directly to PayFort by your browser. The information is used by PayFort exclusively for the implementation and realization of the payment process and is securely transmitted via SSL encryption. All credit/debit cards details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties.

4.2. Mobile App
4.2.1. Adjust
For the custom design and continuous improvement of our App, and for purposes of our own market research, we use the Adjust usage analytical tool of Adjust GmbH, Saarbrücker Str. 36, 10405 Berlin (hereinafter “Adjust”). We use Adjust to help us understand how our users find us and install our app. If you click on a link operated by Adjust, it will take you to the App Store via an Adjust server. Here, Adjust processes anonymous IP and MAC addresses, as well as the associated installation and event data. It is not possible for us or for Adjust to draw conclusions about an individual. The information collected in this way is used solely for the aforementioned evaluation purposes, specifically to analyze the feature and the use of the app by creating anonymous evaluations and graphics on the number of visits, the number of pages viewed per user, etc.
4.2.2. Apple Health Kit and Google Fit
To improve fitness tracking and health management, you have the option of transmitting the data collected by our Services via the interface provided by the respective providers into the Apple Health Kit or the Google Fit app. This only happens if you explicitly agree to the process via your device settings. If you consent to this transfer, we store the following personal data on our servers:
o Start time of the steps taken
o Distance in meters of the steps taken
o Number of steps taken
We have no control over nor are we aware of how the health information is used in the Apple Health Kit or the Google Fit app. You can object to the processing of this data anytime by disabling the feature in your device settings. Before enabling the respective feature, we recommend reading the privacy policy of Apple or Google.
4.2.3. Snowplow
For the custom design and continuous improvement of our app, we use Snowplow open-source analytics. It is installed on our own servers. The following information is sent only to our webhost:
o Device information (e.g. type, brand, operating system, browser version, browser type, etc.)
o Operating system (e.g. iOS 11),
o Provider name (e.g. Vodafone),
o Events in the app and the use of individual features, such as your personal training plan, the activities you enter, access to recipes, or the period of use.
Data processed in this way to optimize our app is considered to be in our legitimate interest. The information is stored in compliance with the legally established retention periods and then automatically deleted.
4.2.4. Amplitude
For the custom design and continuous improvement of our app, we use the Amplitude analytical tool of Amplitude Analytics Inc., 501 2nd Street Suite 100, San Francisco, California 94107, USA (hereinafter “Amplitude”). This tool helps us to better understand the behavior of our users and gain insight on where improvements can be made. For this purpose, we use the Amplitude library, which collects the following data:
o Device information (type, brand, operating system)
o The IP address of the device
o Name of provider (e.g. Vodafone),
o Interaction with the app
o Name
o Email
o Age
o Weight
o Height
o Gender
User profiles may be created from this information, which we use exclusively for the aforementioned purpose. Amplitude is certified in compliance with the Privacy Shield Framework. You can object to this processing at any time by simply informing us that you no longer wish to have such processing in the future. Please use the contact options of our company data privacy officer for this purpose. You can find more information about data processing by Amplitude at https://amplitude.com/privacy.
4.2.5. Cloudinary
To more efficiently manage the photos uploaded by you via the app and display them in your profile, we use the Cloudinary cloud-based optimization tool of Cloudinary Ltd., 111 W Evelyn Ave, Suite 206, Sunnyvale, CA 94086, USA (hereinafter “Cloudinary”). When you upload a photo using the app, it is saved on Cloudinary’s servers. Cloudinary guarantees us by contract that we have exclusive access to these data.
4.2.6. Facebook Login
We allow you to sign up for and log on to our app via the Facebook Login feature. This replaces the otherwise necessary registration. To log in, you are redirected to the Facebook server, where you sign on using your user information. This links your Facebook profile to our Services. By using this simplified login feature, you give us your consent to use the following information from your publicly visible profile:
o Name
o Location
o Birth date
o Gender
o Email address
o Time zone
o Friends or
o Profile photo
The purpose of the data collection above is the simplified login and the establishment and fulfillment of an agreement. This information is required for the conclusion of the agreement in order to be able to identify it. For the purpose and scope of Facebook’s data collection and the further processing and use of the information, as well as the associated rights and setting options to protect your privacy, please consult the Facebook privacy information.

5. Your Rights
In addition to the right at any time to withdraw any consent you have given us, you are also entitled to the following if the respective legal conditions are met:
o The right to be informed about your personal data that is stored with us
o In the event of transmissions, the right to information, or references to suitable or appropriate guarantees that a copy of them can be obtained, or where they are available
o The right to correct inaccurate or incomplete data
o The right to the deletion of your personal information that is stored with us
o The right to limit the processing of your data
o The right to data portability

6. Data Security
We apply the highest standards to data security for our infrastructure and the processing of your data. For example, we use protection mechanisms for computers such as firewalls and data encryption. Our offices and data are subject to physical access controls. Access to the personal information of our customers is only possible for those employees who need them to carry out their activities.
All personal data sent by you, including your payment information, is also transmitted using the generally accepted and secure SSL (Secure Socket Layer) standard. SSL is a secure and proven standard, e.g. it is also used for online banking. You will recognize a secure SSL connection with the placement of an “s” at the end of http (i.e. https: // …) in the address bar of your browser, or with the lock icon at the bottom of the browser.
We also apply suitable technical and organizational security measures to protect your personal data stored with us against manipulation, partial or complete loss, and against unauthorized access by third parties. Our security measures are continuously monitored using the latest technology, and regularly adapted to the relevant risk, and improved if necessary.
In the event that personal data is compromised as a result of a breach of security, we will promptly notify those persons whose personal data has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.

7. Notification Procedures
It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on our website page, as determined by us in our sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

8. Changes to Our Privacy Policy
If we change our Privacy Policy and procedures, we will post those changes on our website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on our website.

9. HIPAA
We are not a “covered entity” under the U.S. Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). The HIPAA privacy rules and regulations apply to health plans, health care clearinghouses, any health care provider who transmits health information in electronic form in connection with transactions for which the Secretary of HHS has adopted standards under HIPAA (collectively, “covered entities”), and their service providers (“business associates”). This means that the personal data that you provide to us is not protected by the HIPAA privacy rules and regulations.

This Privacy Policy was last modified on 17th November, 2019.