PRIVACY POLICY
Last update: 15/10/2026

We’re committed to protecting the privacy of all individuals that provide Personal Information to us, including the data recorded by customers in Foodzilla that relates to their clients or patients. This Privacy Policy explains how we collect, protect, use and share personal information.

Foodzilla is a professional platform designed exclusively for nutrition and health professionals such as dietitians, nutritionists, and health coaches. The Service is not publicly available to consumers. Only clients of registered professionals may access the Foodzilla mobile app, and only at the invitation of their practitioner.

We may review and change this policy from time to time. When we do, we’ll update this version located at https://foodzilla.com/privacy and in other suitable places.

• "Zilla Technologies", or Zilla Technologies Ltd, is us - the company behind Foodzilla platform and mobile apps.
• "Foodzilla" is the Foodzilla software platform, mobile application, and services related to it that don’t have a separate privacy policy.
• "Agreement" refers to the Foodzilla Terms of Service found at https://foodzilla.com/terms
• "Customer" is a nutrition or health professional who has registered for a Foodzilla account and agreed to our Terms of Service.
• "Client" is a patient or client of a Customer who accesses the Foodzilla mobile app at the invitation of their practitioner.
• "Personal Information" means information that can identify an individual.
• "Services" means the provision of the Foodzilla software platform, mobile applications and related platform, and services related thereto (such as customer support).

IF YOUR PRACTITIONER USES FOODZILLA

If you are a Client, your practitioner (the Customer) decides what information they record about you in Foodzilla and why. Zilla Technologies holds and processes that information for your practitioner, under their instructions and our Data Processing Agreement. Your practitioner is responsible for your record, so please contact them first about it, including to see it, correct it, or make a complaint. We help them to answer you. If you contact us directly about a Client record, we pass your request to your practitioner, unless the law requires us to answer it ourselves.

In New Zealand, we hold Client information as your practitioner's agent under section 11 of the Privacy Act 2020, so your practitioner remains responsible for it. In Australia, we handle it for your practitioner under our contract with them. In the EU, the EEA and the UK, your practitioner is the controller and we are their processor.

Before you first use the Foodzilla app, the client portal or a form from your practitioner, we show you a privacy notice and ask you to agree to how your health information is used. You can read it again, and withdraw your agreement, at any time in the Privacy and consent section of your account.

SECTION 1 - PERSONAL INFORMATION WE COLLECT

We collect personal data in a couple of ways - directly and indirectly.

PERSONAL INFORMATION WE COLLECT DIRECTLY

We directly collect Personal Information if you send an enquiry to us from our website, use Foodzilla platform and/or mobile apps, or get in touch with us by chat, email, or phone. We may also collect some Personal Information if you engage with us through social media.

This information can include your name, gender, age, email addresses, and banking details.

As part of our registration process, we require all new professionals to provide a valid payment method to begin their free trial. This serves as an identity verification measure to prevent spam, abuse, and unauthorised access to the Service. Payment details are processed securely by Stripe and are not stored on Foodzilla servers.

When a Client uses the Foodzilla mobile apps, we collect special category data for their practitioner, as their processor. This includes details about their nutrition, exercise and overall health metrics.

We do not directly collect details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership. Nor do we collect any information about criminal convictions and offences.

Foodzilla's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

PERSONAL INFORMATION WE COLLECT INDIRECTLY

We indirectly collect Personal Information when someone uses Foodzilla to record data about someone other than themselves. A typical scenario would be when a healthcare professional records information about a patient or client.

This information can include names, genders, dates of birth, email addresses, information about nutrition and exercise, and patient treatment notes and records. This can include sensitive information such as health records.

• Browser and hardware data, such as IP address, type of device, operating system, browser type, screen resolution, language, device make and model, as well as the versions of the above mentioned services.
• Cookie and tracking technology data, which would include pages visited, time spent on pages, language preferences, and other anonymous traffic data. For more details on the cookies we use and how to manage them, please see our Cookie Policy.
• Transaction data, including details about your Foodzilla subscription, payment dates, and renewal dates.

SECTION 2 - HOW THIS INFORMATION IS USED

Generally speaking, the Personal Information we collect is used by us to operate Foodzilla.

The Personal Information we collect about our own Customers is mostly used for billing, identification, authentication, and for contacting them if we need to.

The special category of Personal Information such as nutrition and exercise data is used to help our Customers visualize their health data and/or their patients' health data.

We may, with consent, use email addresses to share news, tips, updates and special offers. People who receive these promotional emails can unsubscribe at any time.

We may use other data about Customers and website visitors for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of other data as “personal data” under applicable data protection laws. Where this is the case, we will process other data only for the same purposes as “personal data” under this Privacy Policy.

Foodzilla uses third-party AI services for some features. Client personal information, health data and dietary records never go to OpenAI. When a food amount must be converted to grams, only the food name, amount and unit go to OpenAI, with nothing that identifies the person. Where an AI feature needs Client information, it runs on open-source models on Cloudflare Workers AI, and Cloudflare doesn't use this content to train AI models. There are four of these features. The first reads a food photo or a nutrition label that a Client or Customer scans, and the photo isn't stored. The second reads a food diary that a Client fills in, so their practitioner gets a nutrient breakdown. The third is Foodzilla Meet call summaries, which a Customer can choose to turn on. Cloudflare transcribes the call, and the transcript is summarised on Workers AI. The transcript and summary are stored with the rest of the Customer's data in our primary database. Foodzilla doesn't record or store the video or audio of calls. The fourth translates the name and notes of a Client's meal plan, and the name of a recipe collection, when a Customer exports it as a PDF in another language. A Client's name is never translated. The one exception is when a Client connects their own AI assistant through Foodzilla Autopilot. The information they ask it about goes to the company that runs that assistant, as described in Section 11. When any other AI feature is used, only the minimum non-personal data needed for the output goes to the AI provider. Your Personal Information isn't used to train AI models. Our AI providers process data under their data processing agreements and don't keep input or output data for training.

Meal plans are not generated by AI. Our staff create the recipes, and Foodzilla's own software chooses them and scales them to match a Client's nutrition targets. AI is used in two places only. When a Customer describes a meal plan in their own words, AI turns that description into meal plan settings, and our software then makes the plan. When a plan must leave out foods a Client avoids, AI reads food words and ingredient names (for example, that "no seafood" also means prawns), with nothing that identifies the person.

Auto Plans. A Customer can turn on Auto Plans, which builds meal plans for their Clients on a schedule. It uses the Client's nutrition targets, diet, allergies, foods to avoid and favourite foods, or the Customer's own templates, and builds the plan from Foodzilla's recipes with the software described above. It does not use AI to make the plan, and it does not decide whether a Client can get a service or what they pay. The Customer is responsible for each plan. They have 3 days to review and change each plan before the Client gets it, and can stop Auto Plans at any time. A plan the Customer does not review is still sent on its schedule. A Client who does not want plans made this way can ask their practitioner to stop it.

Other ways we may use your Personal Information:

• To deliver customer service and assist you with any inquiries you may have.
• To analyze trends, administer or optimise Foodzilla, monitor usage or traffic patterns (including to track users’ movements around Foodzilla) and gather demographic information about our user base as a whole.
• To control unauthorised use or abuse of Foodzilla, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal.

We use the trends, usage and demographic data above only for Customers and website visitors. We use Client information only to provide and support the Service for the Client's practitioner, to keep it secure, and where the law requires it. We don't use Client information for our own marketing, advertising or product research, and we don't make anonymised data from it for our own use.

SECTION 3 - HOW INFORMATION IS DISCLOSED

Except as described in this Privacy Policy, Foodzilla will not share, sell, or rent Personal Information with anyone without your permission or unless ordered by a court of law.

Foodzilla works with third-party services in Singapore, New Zealand, Europe and the USA that we allow access to Personal Information, and may use it on our behalf strictly for the purposes for which they are engaged. We minimise the amount of personal data that is utilised by these services, and we have ensured that these services process your data in accordance with the appropriate regulations. A full list of our third-party service providers is available in Section 10 below.

In rare circumstances, we may be obliged to disclose Personal Information if disclosure is required to comply with the law, if we believe our Terms of Service, located at https://foodzilla.com/terms, have been violated, if we believe it is necessary to protect our rights, or if the ownership and assets of Zilla Technologies were to be transferred to another party.

If you contact Foodzilla's customer support, your information will be shared with Help Scout (the third-party provider that Foodzilla uses to facilitate customer support operations). By using Foodzilla and its customer support service, you agree to sharing your name and email address with Help Scout. Your information is only used to identify your account within our service and to help you resolve any issues you have with the service.

Foodzilla uses Postmark as its email service provider to send transactional and system emails (such as account notifications, password resets, and subscription confirmations). By using Foodzilla, you agree that your name and email address may be shared with Postmark solely for the purpose of delivering these emails. Postmark does not use your information for any other purpose. Emails sent through Postmark are permanently deleted after 45 days. Foodzilla does not store the content of these emails in our systems.

SECTION 4 - THE SECURITY OF YOUR PERSONAL INFORMATION

Data transfer is encrypted with SSL and WSS, stored in state-of-the-art facilities, access is restricted to those who have a need to know, and we regularly review our technology to maintain security.

Personal Information is also encrypted at rest in our hosted database and in every backup we hold. Administrative access to production systems requires multi-factor authentication and is logged and reviewed. Details of where your data is hosted are set out in Section 6 below.

The No-PHI plan (formerly called the HIPAA plan) provides access to core features only, including foods, recipes, and meal plan templates. It does not include any client-facing features such as client management, messaging, food diaries, or any other functionality designed for the storage or processing of Protected Health Information (PHI) as defined under HIPAA. We do not accept PHI on the No-PHI plan, and Customers on that plan agree not to enter PHI into the Service, and we will provide a no-PHI addendum that records this. A Business Associate Agreement (BAA) is not included with the No-PHI plan or any other plan. A Customer who needs a BAA must contact us before entering any PHI, and a BAA applies only once it has been agreed in writing and signed by us. Customers should not rely on the Service for the storage or processing of PHI unless such a BAA is in place.

If there is a data breach that affects Personal Information, we act straight away to contain it and assess the risk of harm. We then notify as each law requires:

• Australia: we assess a suspected breach within 30 days. If it is an eligible data breach under the Notifiable Data Breaches scheme, we tell the affected people and the Office of the Australian Information Commissioner as soon as practicable.
• New Zealand: if a breach has caused or is likely to cause serious harm, we tell the Privacy Commissioner and the affected people as soon as practicable.
• Canada: if a breach of security safeguards creates a real risk of significant harm, we report it to the Office of the Privacy Commissioner of Canada and tell the affected people as soon as feasible. We keep a record of every breach for at least 24 months.
• EU, EEA and UK: we tell the supervisory authority within 72 hours of becoming aware of a breach where the law requires it, and the affected people without undue delay where the risk to them is high.
• Client information: we tell the Customer (the practitioner) without undue delay, with what we know about the breach, so that they can meet their own duties. Where the law makes the Customer responsible for telling their Clients, we help them to do it.

When we notify you, we tell you what information is at risk, what we have done and are doing about it, and what you can do to protect yourself.

We keep an access log of who opened Client records and when, for 12 months, to detect misuse and to answer requests about who has seen a record. The log does not store the content of the record.

To find and fix errors, our self-hosted error monitoring (Sentry) records some Customer sessions in the Foodzilla platform. Text that can show Client information is masked in these recordings, and booking and video call pages are never recorded. Our support and engineering staff can see these recordings.

In the Foodzilla apps, health data kept on the phone is encrypted or held in memory only, and it is removed when you sign out.

SECTION 5 - ACCESSING YOUR PERSONAL INFORMATION

You can request access to the Personal Information you have provided to us through our privacy request form or by email to privacy@foodzilla.com. This enables you to receive a copy of the data and to check that we are lawfully processing it. If you are in the EU, EEA or UK, you can also make this request through our representative's GDPR request portal (see Section 12).

If you think there’s a problem with the Personal Information we hold about you, you will either have the tools available to make these changes, or you can request a correction. This enables you to have any incomplete or inaccurate data we hold about you corrected (though we may need to verify the accuracy of the new data you provide to us).

If you want to delete your Personal Information, we'll take all reasonable steps to do so unless we are required to keep it for legal reasons, which will be notified to you, if applicable, at the time of your request. As we only collect information that is required, it is likely that revoking your consent will limit the functionality of your Foodzilla account. You can request deletion through our privacy request form or by email, and Clients can also delete their account from Settings in the Foodzilla mobile app. If you are in the EU, EEA or UK, you can also request deletion through our representative's GDPR request portal (see Section 12). We log every request and confirm once it has been actioned.

Should you require to move your data to another service, you may request the transfer of your data (including Personal Information) to you or to a third party. We will provide to you, or a third party that you have chosen, your data in a structured, commonly used, machine-readable format.

You may withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. This will be notified to you at the time of your request if applicable.

We answer a request to see or correct your Personal Information within 30 days, or within 20 working days if you are in New Zealand. If we need more time, or we cannot do what you ask, we tell you why and how you can complain. We do not charge for a request. If you are a Client, your practitioner controls your record, so we pass your request to them and help them to answer it (see "If your practitioner uses Foodzilla" above).

SECTION 6 - INTERNATIONAL DATA TRANSFERS AND LOCAL PRIVACY LAWS

Foodzilla is a worldwide service, and we acknowledge that Personal Information about clients, patients, and the obligations of health professionals relating to them, may be subject to access and privacy laws in the country of residence of those patients and/or clients.

WHERE YOUR DATA IS HOSTED

Our primary data hosting is in Singapore. Customer and Client data — including account details, client records, meal plans, food diaries, messages, and health data — are stored in a MongoDB Atlas database cluster located in the Asia Pacific (Singapore) region. Backups of that data are encrypted and retained as described in Section 8 below.

In order to operate the Service, your Personal Information may also be transferred to and processed in other countries outside your country of residence, including New Zealand (where we are based), the United States, and countries within the European Union, where our third-party service providers are located. Section 10 below lists each provider and the region it processes data in, and the sub-processor table in our Data Processing Agreement lists the providers that process Client information on a Customer's behalf, with the region of each. We ensure that appropriate safeguards are in place for these transfers, including data processing agreements with our providers.

TRANSFERS FROM THE UNITED KINGDOM AND THE EUROPEAN ECONOMIC AREA

Singapore is not covered by UK adequacy regulations or an EU adequacy decision. Where we transfer Personal Information out of the United Kingdom or the European Economic Area, including to our primary hosting location in Singapore, we rely on the following transfer mechanisms:

• Transfers from the UK — the Standard Contractual Clauses approved by the European Commission, together with the International Data Transfer Addendum (the "UK Addendum") issued by the UK Information Commissioner's Office under section 119A of the Data Protection Act 2018, or the UK International Data Transfer Agreement (IDTA) where a provider offers it in place of the Standard Contractual Clauses.
• Transfers from the EEA — the Standard Contractual Clauses approved by the European Commission.
• Adequacy — for transfers to New Zealand, where we are based, we rely on the UK adequacy regulations and the EU adequacy decision recognising New Zealand as providing an adequate level of protection.

These contractual mechanisms sit alongside the technical safeguards described below and in Section 4. Where required, we carry out a transfer risk assessment before relying on them. You can request details of the transfer mechanism that applies to your data by emailing privacy@foodzilla.com.

AUSTRALIAN PRIVACY PRINCIPLE 8 - CROSS-BORDER DISCLOSURE

Where we disclose Personal Information about Australian individuals to an overseas recipient, including our primary hosting provider in Singapore, we take reasonable steps — as required by Australian Privacy Principle 8 and section 16C of the Privacy Act 1988 (Cth) — to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information. Those steps include:

• Contractual obligations — binding data protection terms with every overseas provider that require standards of protection at least equivalent to those required of us under the Australian Privacy Principles, restrict use of the information to the services we engage the provider for, and prohibit any secondary use or disclosure.
• Encryption — Personal Information is encrypted in transit using TLS/SSL (and WSS for real-time connections) and encrypted at rest in the hosted database and in all backups.
• Access controls — access to Personal Information is restricted to authorised personnel on a need-to-know basis, administrative access requires multi-factor authentication, and access is logged and reviewed.
• Provider assurance — we favour providers that hold recognised independent security certifications (such as ISO 27001 or SOC 2), and we review the security and privacy practices of our providers regularly.
• Breach cooperation — our provider agreements require prompt notification of any security incident affecting Personal Information, so that we can meet our obligations under the Notifiable Data Breaches scheme.

We'll take all reasonable steps to comply with local access and privacy laws, to the extent consistent with legal obligations we have under New Zealand law, where we are based.

CANADA: CROSS-BORDER TRANSFERS (PIPEDA)

If you are in Canada, your Personal Information is stored and processed outside Canada, mainly in Singapore and also in the other countries listed in Section 10. While it is there, it may be accessed by the courts, law enforcement and national security authorities of those countries. We stay responsible for it, and our contracts with providers require a comparable level of protection. You can ask our privacy officer about how we handle cross-border transfers at privacy@foodzilla.com.

NEW ZEALAND: HEALTH INFORMATION PRIVACY CODE 2020

In New Zealand, health information about Clients is covered by the Health Information Privacy Code 2020 (the Code) as well as the Privacy Act 2020. Your practitioner is the health agency that collects and holds this information. We hold it for them as their agent, and we protect it to the standard the Code sets for them. In practice:

• Collection (rules 1 to 4). Your practitioner decides what health information to collect and why. The privacy notice you agree to in the Foodzilla app, the client portal or a form helps them tell you.
• Security (rule 5). We protect health information with the safeguards in Section 4. Only staff who need it to run or support the Service can get to it, and that access is logged.
• Access and correction (rules 6 and 7). You can ask your practitioner to see your health information or to correct it, and they must answer within 20 working days. If you ask us, we pass your request to them and help them to answer it.
• Retention (rule 9). Practitioners in New Zealand must keep health records for at least 10 years after the last service, under the Health (Retention of Health Information) Regulations 1996. That's why we keep a New Zealand practice's data for 10 years after its last activity before we delete it (Section 8).
• Use and disclosure (rules 10 and 11). We use and disclose health information only to provide the Service to your practitioner, as this policy describes. We don't use it for our own purposes.
• Overseas storage (rule 12). Health information is stored in Singapore, and some of our providers are in other countries (Sections 6 and 10). They hold it only to provide the Service, under contracts that require safeguards comparable to New Zealand law.

If you're unhappy with how your health information has been handled, talk to your practitioner first. You can also contact us (Section 12) or complain to the Privacy Commissioner at privacy.org.nz.

SECTION 7 - LEGAL BASIS FOR PROCESSING (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your Personal Information on the following legal bases:

• Contractual necessity — To provide the Service to you as a registered Customer, including account management, billing, and delivering the platform features you have subscribed to.
• Legitimate interest — To operate, improve, and secure the Service, to prevent fraud and abuse, and to communicate with you about your account. We balance our interests against your rights and only rely on this basis where the impact on you is minimal.
• Consent — For sending promotional emails and for the use of non-essential cookies and tracking technologies. You may withdraw consent at any time.
• Legal obligation — To comply with applicable laws, regulations, or lawful requests from public authorities.

These legal bases cover the information we hold as a controller, such as Customer accounts, billing and our website. For Client information, the Client's practitioner decides the legal basis, and we process the information for them as their processor.

SECTION 8 - DATA RETENTION

We retain your Personal Information for as long as your account is active or as needed to provide the Service to you.

Following cancellation or deactivation of your account, if we have no instruction to delete it, Foodzilla keeps your data in an inactive state for up to 7 years after the last account activity, or up to 10 years if your practice is in New Zealand. This supports the legal duty of health professionals to keep health records (in New Zealand, 10 years after the last service), and lets you reactivate your account without loss of information. If your practice is in New Zealand and you see a client outside Foodzilla after your account becomes inactive, you're responsible for keeping their records for 10 years after that service, so export them before we delete your data. When that period ends, we delete the data automatically. We send a notice to the account email at least 30 days before deletion, and if you sign in during that time, we keep your data. You can delete your data at any time, yourself in the Service or by request, and we will action a request promptly across our live systems, with residual backup copies removed within our three month backup cycle.

Your data is not used by Foodzilla for any purpose while your account is inactive, except as required by law or to resolve disputes. Deletion requests can be made through our privacy request form or sent to privacy@foodzilla.com, and we will confirm once the request has been actioned. If you are in the EU, EEA or UK, you can also send a deletion request through our representative's GDPR request portal (see Section 12). We may retain information where retention is required by law.

BACKUP RETENTION

Foodzilla maintains encrypted backups for disaster recovery purposes. Backups are retained for up to three months, after which they are permanently and automatically deleted. When you request deletion of your data, it is removed from our live systems promptly, and any copies persisting in backups are erased within this three month window.

Transaction and billing records may be retained for up to 7 years to comply with tax and accounting obligations, even after a deletion request.

Anonymised or aggregated data about Customers and website visitors that can no longer identify you may be retained indefinitely for analytical purposes. We don't make this data from Client information.

SECTION 9 - CHILDREN'S PRIVACY

Foodzilla is designed for use by nutrition and health professionals. The Service is not directed at children under the age of 16, and we do not knowingly collect Personal Information from children. If a health professional uses Foodzilla to manage information about a minor client or patient, the professional is responsible for obtaining appropriate parental or guardian consent as required by applicable law.

If we become aware that we have inadvertently collected Personal Information from a child under 16 without appropriate consent, we will take steps to delete that information as soon as possible. If you believe we may have collected information from a child, please contact us at privacy@foodzilla.com.

SECTION 10 - THIRD-PARTY SERVICE PROVIDERS

Foodzilla uses the following third-party service providers to operate and improve the Service, and the region each one processes data in. Each provider only receives the minimum data necessary to fulfil its purpose:

• MongoDB Atlas: Primary database hosting and storage. Asia Pacific (Singapore).
• Cloudflare: Hosting of our API (Cloudflare Workers), storage of uploaded files and images (Cloudflare R2), content delivery, DNS, security, real-time video consultations (Foodzilla Meet, not recorded), call transcripts and AI-generated call summaries, food photo and nutrition label reading, food diary reading, and translating meal plan names and notes and collection names in PDFs, using open-source models on Workers AI. Cloudflare does not use this content to train AI models. Global edge network.
• Stripe: Payment processing and subscription management. United States.
• OpenAI: Powers non-client-data features only, such as translating recipes and grocery lists in PDFs. We do not send it Client personal information or health data. A food name, amount and unit can be sent to convert it to grams, with nothing that identifies the person. No data is used for model training. United States. (A Client who connects their own ChatGPT account through Autopilot sends their information to OpenAI themselves, as described in Section 11. OpenAI is not our sub-processor for that.)
• Ory: Authentication and identity management. United States, with data hosted in the EU region.
• Help Scout: Customer support and communication. United States.
• Google Ads (Google tag): Advertising measurement and conversion tracking. Google processes this data for us to measure our ads, and acts as an independent controller only where it uses the data for its own advertising purposes, under its own terms. United States.
• Microsoft Advertising (Bing UET): Advertising measurement and conversion tracking. United States.
• Rewardful: Affiliate referral tracking, on our website only. When a referred visitor signs up, the referral ID is passed to Stripe so that the affiliate is credited. United States.
• Meta Pixel: Advertising measurement and conversion tracking. United States.
• Datafast: Privacy-focused website and platform analytics. Singapore and United States. Not used for users in the European Union, European Economic Area, United Kingdom or Switzerland, and never used in client-facing apps or with client data.
• DigitalOcean: Analytics infrastructure, including our self-hosted, cookieless website analytics (Plausible), customer support services, and self-hosted error monitoring and session recording (Sentry). United States.
• Amazon Web Services: Secure database access service between our API and the primary database. Asia Pacific (Singapore).
• Postmark: Transactional and system email delivery. United States.
• Mailcoach: Product news and marketing emails to Customers. It receives the Customer's name, email address and business name. Never used for Client information. Customers can unsubscribe from any of these emails. Stored in the European Union (Finland). The emails are sent through Postmark in the United States.
• OneSignal: Push notifications to the Foodzilla mobile apps. United States.
• Replicate: Recipe image generation. No client personal information or health data is sent. United States.

We regularly review our third-party providers to ensure they meet our security and privacy standards. This list may be updated from time to time as we add or remove providers.

Advertising and affiliate tags never load in the Foodzilla apps, the client portal, or any page a Client uses (such as stores, bookings, forms, invoices and video calls). In the Foodzilla platform, they load only on the sign-up page and for Customers who have not chosen a plan or whose plan has ended. Visitors in the EU, the EEA, the UK and Switzerland are asked first, and the tags load only if they accept. Anyone can change this choice in our cookie settings, and Customers can also change it in Profile, Preferences.

A Customer can also connect their own Google Calendar, Microsoft Outlook or Zoom account to Foodzilla Bookings. Foodzilla then writes each booking to that account: the appointment type, the Client's name, the Client's email address as the invitee, and the Client's phone number for a phone appointment. The Customer chooses these accounts and has their own agreement with each company, so these companies are not our sub-processors.

SECTION 11 - FOODZILLA AUTOPILOT (AI ASSISTANT CONNECTIONS)

Foodzilla Autopilot lets a Customer, and a Client of that Customer, connect their Foodzilla account to an AI assistant such as Claude or ChatGPT. The connection uses the Model Context Protocol (MCP) and runs over our server at https://api.foodzilla.io/mcp. This section explains what that connection reaches, what we store about it, and how to end it. Everything else in this Privacy Policy still applies.

HOW THE CONNECTION IS AUTHORISED

Connecting uses OAuth 2.1. You sign in to Foodzilla on a Foodzilla page, and you then see a consent page that names your account and lists what the connection can and cannot do. Nothing connects until you confirm on that page.

The assistant never receives your Foodzilla password. It receives a token that is limited to one account and to one role, either Customer or Client. A token issued to a Client cannot reach anything belonging to their Customer or to another Client.

CLIENT CONNECTIONS

Autopilot for Clients is off until the Customer turns it on, for their whole team or for one Client. A Client can connect only when it is on for them, and only after they have agreed to their Customer’s privacy notice in the Foodzilla app. If the Client withdraws that agreement, their connection stops working.

Before a Client connects, the consent page tells them that their health information will go to the company that runs their assistant (Anthropic for Claude, OpenAI for ChatGPT), that this company can be outside their country, mainly in the United States, and that the usual protections for information sent overseas will not apply to it. The Client must tick a box to agree. We keep a record of the words they saw, the assistant they connected and when they agreed, and their Customer can see this record.

A Client asks for this disclosure, and it rests on their express consent: Article 9(2)(a) and Article 49(1)(a) of the GDPR and the UK GDPR, Australian Privacy Principle 8.2(b), and Information Privacy Principles 11 and 12(1)(a) of the New Zealand Privacy Act 2020. A Client can stop at any time by disconnecting Foodzilla in their assistant. The Customer decides whether their Clients can use Autopilot, so we handle a Client connection for the Customer, as their processor. We ask for the Client's consent on the Customer's behalf and keep the record for them.

WHAT A CONNECTION CAN REACH

A Customer connection can read and write the Customer’s own working data. That is their account and profile, their recipes and foods, their meal plan templates, their collections, their forms, their booking availability and appointment types, their content posts, their client-facing store and plans, their invoice settings, and their subscription and plan details.

A Client connection reaches that Client’s own data only. It can add to and change their diary, meaning their food, water, exercise, sleep and weight entries. It can read, but not change, the meal plan and daily targets their Customer set for them, their recent foods, and their own profile.

A connection cannot send messages on your behalf, and a Client connection cannot change their meal plan or their targets.

WHAT WE STORE ABOUT A CONNECTION

For each assistant you connect we record the assistant’s name, the identifier its developer registered with us, when it was first connected, when it last signed in, and how many times it has connected. If you disconnect it, we record when. We also count how many requests a connection makes each week, so we can apply fair use limits and show you your own usage as a percentage. These counters are keyed by account and by week.

For security, our access log records each request to the connection: the account, the Client where there is one, the tool the assistant called, and the time. It does not record what the request contained. We keep the access log for 12 months.

We do not store the conversation you have with your assistant. We process the content of a request only to carry it out and to return the answer. Our server logs do not carry names, email addresses or phone numbers.

THE ASSISTANT YOU CONNECT

The assistant is chosen by you and is not operated by us. Anything you type to it, and anything our server returns to it, is processed by that assistant’s provider under that provider’s own privacy policy and terms. We have no control over that processing and we cannot delete data held there.

This matters if you handle health information. If you are a Customer who is subject to HIPAA or a comparable law, you are responsible for deciding whether to send information about a Client to an assistant, and for having whatever agreement with that provider your obligations require. Our agreement with you does not cover the assistant.

Inside Foodzilla, the third-party providers listed in Section 10 are the same ones that serve the rest of the Service. Generation features reached through a connection use OpenAI on the same terms described there.

YOUR CONTROL

• Disconnect an assistant. A Customer can do this from Profile, then Autopilot. This withdraws the consent, so the assistant must sign in again to reconnect. It can take up to a minute to take effect everywhere.
• End every browser sign-in. The connection flow remembers your sign-in for up to 30 days. Signing out everywhere ends all of those, which matters on a shared or public computer. Assistants that are already connected keep working.
• Turn Autopilot on or off for Clients. Autopilot for Clients is off until a Customer turns it on. A Customer can turn it on or off for their whole team, or for one Client, under Clients, then App Experience. A Client whose Customer has not turned it on cannot connect, and turning it off stops a connected Client’s assistant from reaching their data.
• Delete your data. The rights in Section 5 apply to connection records and usage counts in the same way as to the rest of your data.

RETENTION

We keep a connection record while your account is open, so that you can see what is connected and disconnect it. Weekly usage counters are kept only as long as we need them for fair use limits and our own capacity planning. Both are removed with the rest of your data when your account is deleted, as described in Section 8. When a Client closes their account and their Customer keeps the Client record, we still delete the Client’s connection records and usage counters.

If you join the Autopilot waiting list, we keep your email address for 12 months after your last attempt to connect, and then delete it.

SECTION 12 - QUESTIONS OR COMPLAINTS

If you have any questions or complaints about our Privacy Policy or the way we handle your Personal Information, you can contact our privacy officer at privacy@foodzilla.com. This is our preferred method of contact. You can also write to us at:

Privacy Officer
Zilla Technologies Limited
12 Shankill Place
East Tamaki
Auckland 2013
New Zealand

If you are in the EU, EEA or UK, you can also contact our GDPR representative, using the details below.

We confirm that we have received a complaint within 5 working days, and we aim to answer it in full within 30 days. If you are a Client, we may also pass your complaint to your practitioner, who is responsible for your record.

If you are not satisfied with our answer, you can complain to the privacy regulator where you live:

• Australia: the Office of the Australian Information Commissioner, oaic.gov.au.
• New Zealand: the Office of the Privacy Commissioner, privacy.org.nz.
• Canada: the Office of the Privacy Commissioner of Canada, priv.gc.ca.
• EU and EEA: the data protection authority in your country.
• United Kingdom: the Information Commissioner's Office, ico.org.uk.

EU/EEA AND UK GDPR REPRESENTATIVES (ARTICLE 27)

If you are located in the EU or UK and have questions or concerns regarding your personal data, you may contact our appointed GDPR representative:

EU Representative:
Euverify Limited (Ireland)
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork
T23 AT2P
Ireland
Email: gdpr@euverify.com

UK Representative:
Euverify Ltd (UK)
3rd Floor
86-90 Paul Street
London
EC2A 4NE
United Kingdom
Email: gdpr@euverify.com

To submit a Data Subject Access Request (DSAR), data deletion request, or any other GDPR-related inquiry, please use our secure portal at:
https://gdpr.euverify.com/verify/56b42128-056f-452b-bb8d-1b25bfdb2068

This link allows you to verify our appointed representative and submit GDPR requests directly. Requests submitted through this portal are logged and tracked to ensure timely response and compliance.