This Policy explains how Integrated Nutrition Solutions Establishment collects, uses and protects your data in the Dietitian app, in line with the Saudi Personal Data Protection Law (PDPL) and its regulations.

1. Controller

Integrated Nutrition Solutions Establishment, CR 7053878596, Makkah. Contact our Data Protection Officer in the app or at +966545209769.

2. Data we collect

We do not ask for your national ID number, and we do not access your precise location or contacts. We access the camera or photos only when you use meal capture and your device grants permission.

3. Purposes

• Running your account and providing features: meal analysis, needs calculation, behaviour analysis, chat, suggested plan.
• Linking your account to a Specialist you choose and showing you their plan — with your consent at linking.
• Managing subscriptions, billing and support.
• Service security, fraud prevention and bug fixing.
• Improving model accuracy from your data and corrections — only with separate consent.
• Marketing messages and tips — only with separate consent.
• Legal compliance and lawful requests from competent authorities.

We do not sell your data, use your health data for targeted advertising, or share it with insurers or employers.

4. Legal basis

5. Consent to health data

• We ask for your explicit consent to process health data through a separate checkbox at sign-up, distinct from accepting the Terms, and we keep a documented record of it.
• You can withdraw any consent at any time (Settings → Privacy) and we will stop processing without undue delay. Withdrawing consent to health data means the features that depend on it stop working.
• Declining model improvement or marketing does not affect your access to the Service.

6. AI and automated analysis

• Meal photos, chat messages and the data needed for your plan are sent over encrypted connections to AI providers (section 9), who process them only on our behalf.
• Our contracts with them prohibit using your data to train their own models.
• Behaviour analysis and suggested plans are non-binding automated recommendations with no legal effect on you. You may ask for an explanation of their basis or correct the data they rely on.

7. Specialists

• No Specialist sees your data until you accept their invitation or link your account to them. Before linking, we show you exactly what they will see so you can agree explicitly.
• Once linked, the Specialist sees your measurements, goals, food log and behaviour analysis. They do not see your chats with the AI assistant unless you share them.
• The Specialist is an independent party and is responsible for how they process your data in their own practice and outside the app. They are bound by us to confidentiality and to use your data only to follow you.
• You can unlink at any time and their access stops immediately. Plans they added stay in your account unless you delete them.

8. Disclosure

We disclose only the minimum necessary data to:

• The Specialist you link to (section 7).
• Processors acting on our behalf under written contracts (section 9), whose compliance we assess periodically.
• Apple or Google to complete in-app purchases.
• Competent government authorities when legally required.
• Any other party only with your explicit consent.

9. Providers and transfers outside the Kingdom

We rely on these categories of providers: cloud hosting and storage, AI processing, analytics and crash reporting, electronic payment, and email. We will send you their names and processing countries on request.

Where processing happens outside Saudi Arabia, we transfer only the minimum necessary data and comply with the Regulation on Personal Data Transfer Outside the Kingdom. We rely on appropriate safeguards such as SDAIA's standard contractual clauses, and we carry out a risk assessment before transferring health data. We stop the transfer immediately if the safeguards no longer hold.

10. Retention and destruction

After that, data is destroyed or anonymised so that it can no longer identify you.

11. Your rights

Under the PDPL you have the right to:

• Be informed of the purpose and legal basis of processing.
• Access your data and receive a copy in a readable electronic format.
• Correct inaccurate or incomplete data, and have processing restricted while a correction is reviewed.
• Request destruction of your data.
• Withdraw your consent at any time.
• Lodge a complaint with the Saudi Data & AI Authority (SDAIA).

Send requests in the app or by phone at +966545209769. We respond within 30 days, which may be extended by 30 more days in specific cases with notice of the reason. We may verify your identity first.

12. Users under 18

• We do not accept users under 13.
• For users aged 13–17, we process health data only after explicit consent from their guardian, verified by a confirmation link sent to the guardian's email or mobile.
• The guardian exercises the rights in section 11 on the minor's behalf, approves any link to a Specialist, and may request deletion at any time.
• We do not send marketing to minors or use their data for model improvement.
• If we learn data was collected without these conditions, we destroy it immediately.

13. Security and breaches

• We use encryption in transit and at rest, need-based access controls, access logs and periodic reviews. No method is completely secure.
• If a breach may harm you or your data, we notify SDAIA within 72 hours of becoming aware and notify you without undue delay, in clear language, with steps you can take.

14. Marketing

We send marketing only with your consent, and every message includes a way to unsubscribe. Essential service messages (invoices, material changes, breaches) are always sent.

15. Changes

We will notify you of material changes through the app or by email. Any new purpose for processing health data requires your new consent.

16. Contact

Integrated Nutrition Solutions Establishment — +966545209769

By registering for or using the Dietitian app, you agree to these Terms. If you do not agree, do not use the app. Processing of your health data is governed by the Privacy Policy and requires your separate, explicit consent.

1. Definitions

• Establishment / we: Integrated Nutrition Solutions Establishment (مؤسسة حلول التغذية المتكاملة).
• App / Service: the Dietitian mobile app, its website and all of its features.
• User / you: anyone who creates an account or uses the Service.
• Specialist: an independent dietitian or health practitioner who uses the app to follow their clients.
• Specialist Plan: any plan, advice, instructions or content a Specialist adds for you in the app.
• Guardian: the parent or legal guardian of a user under 18.
• Generated Content: any output produced by AI: meal analysis, eating-behaviour analysis, chat replies or a suggested plan.

2. Operator

• Name: Integrated Nutrition Solutions Establishment
• Commercial Registration: 7053878596
• Address: Makkah, Kingdom of Saudi Arabia
• Phone: +966545209769

3. The Service

Dietitian is an AI-powered nutrition wellness app that provides:

• Food tracking with calorie and macronutrient estimates from photos, text or manual entry.
• Estimated daily needs based on your age, height, weight, activity level and goal.
• Eating-behaviour analysis: patterns and timing of meals, with insights and alerts.
• Chat with an AI assistant on general nutrition topics.
• A suggested complete meal plan based on the information you provide.
• Linking your account to a Specialist you choose, who can add their plan and follow your log.

Some features are free and others require a paid subscription; details are shown in the app before purchase.

Intended use:

• Dietitian is a nutrition wellness and healthy-lifestyle product. Its intended use is to help you track your food and improve your general eating habits. It is not intended to diagnose, treat, prevent or clinically monitor any disease.
• The Establishment does not present or market the app, in app stores, on its website or in any promotional material, as a means of treating or clinically managing disease.
• If you indicate that you have a chronic condition (such as diabetes or kidney disease), the app will not automatically generate a therapeutic meal plan. It will limit itself to general content and suggest linking your account to a licensed Specialist who can prepare your plan.
• If the Saudi Food and Drug Authority considers any feature of the app to be a medical device, the Establishment will obtain the required regulatory authorisation, modify that feature, or withdraw it.

4. Eligibility and users under 18

• The minimum age is 13.
• Accounts of users aged 13–17 are activated only after documented consent from their guardian to these Terms and to the processing of their health data. The guardian may withdraw consent and request account deletion at any time.
• The guardian is responsible for supervising the minor's use, for any paid subscription made in the minor's name, and for choosing any Specialist linked to the account.
• We may restrict certain features for users under 18, such as automatically generated weight-loss plans or low calorie targets, to protect healthy growth.
• If we learn that a user is under 13, or under 18 without guardian consent, we will close the account and destroy its data.

5. Your account

• Provide accurate information and keep it up to date; the accuracy of recommendations depends on it.
• You are responsible for keeping your login credentials confidential and for all activity under your account. Notify us immediately of any unauthorised use.
• You can delete your account in the app (Settings → Account → Delete Account) or by contacting us. Deleting your account does not cancel Apple or Google subscriptions; cancel those in the store.

6. AI and its limitations

• Generated Content is an estimate and may be wrong about the food, portion size or nutritional value. Review and correct results before relying on them.
• The AI assistant is not a human dietitian, and the chat says so clearly.
• Automated plans and behaviour analysis are built from the data you provide and are not reviewed by a human specialist.
• You may ask for an explanation of the basis of any automated recommendation, and you may ignore or change it.

7. Specialist Plans and advice

• Specialists are fully independent. They are not employees, agents or partners of the Establishment. Our role is technical only: providing the tool through which a Specialist uploads their plan and you see it.
• The Specialist alone is professionally and legally responsible for their plan, advice, assessment and follow-up, and for its suitability for your health.
• The Establishment does not review, approve or guarantee Specialist Plans or their results. Every Specialist Plan is labelled with the Specialist's name and shown separately from Generated Content.
• The professional and financial relationship between you and the Specialist is direct, and any fees you agree belong to that relationship unless the app states otherwise.
• To the extent permitted by law, the Establishment bears no liability for any harm or outcome arising from a Specialist's plan, advice, errors or delays in follow-up, nor for any dispute between you and the Specialist.
• Complaints about professional practice go to the Specialist or to the Saudi Commission for Health Specialties. You may report any violating content to us; we may remove it or suspend the Specialist's account, without this creating any duty to monitor.
• You can unlink your account from a Specialist at any time in Settings, and their access to your data stops immediately.

8. Health disclaimer

• Dietitian is a wellness and healthy-lifestyle tool. It does not diagnose or treat any disease and does not replace a doctor.
• Consult a professional before following any plan if you are pregnant or breastfeeding, have a chronic condition (such as diabetes or kidney disease), take medication, have a history of eating disorders, or are under 18.
• In an emergency call 997 or go to the nearest emergency department. Do not use the app for urgent situations.
• We do not guarantee any health outcome or specific change in weight.

9. Acceptable use

You must not: use the Service unlawfully; upload offensive or indecent content; impersonate others; attempt to hack or reverse engineer the app; scrape data; or try to make the AI assistant produce harmful content.

10. Subscriptions, payment and refunds

• Prices are shown in the app before payment, including 15% VAT, together with the subscription period and how it renews. An invoice is issued after payment.
• Apple or Google: subscriptions renew automatically unless cancelled at least 24 hours before the end of the period. Cancellation and refunds are handled through the store under its policies.
• Website: you may cancel and receive a full refund within 7 days of purchase if you have not used the paid features, in line with the Saudi E-Commerce Law. Send requests in the app or by phone at +966545209769.
• After that, cancelling stops future renewals only; features remain available until the end of the paid period, unless the law requires otherwise.
• We will give at least 30 days' notice of any price change, and it will not apply to your current paid period.

11. Intellectual property

The app, its design, trademarks, food database, models and educational content are owned by or licensed to the Establishment. We grant you a personal, non-exclusive, non-transferable licence for non-commercial use. Copying, modifying or reselling without written permission is prohibited. Specialist Plans remain the property of the Specialist.

12. Your content and data

• You keep ownership of your meal photos, entries and chats.
• You grant us a limited licence to process them only as needed to provide the Service to you, ending when you delete them or your account.
• We do not use your identifiable data to train or improve models without a separate consent you can withdraw.

13. Third-party services

We rely on providers for cloud hosting, AI processing, payments and email, described in the Privacy Policy. Links to external sites are subject to those sites' terms.

14. Limitation of liability

To the extent permitted by Saudi law:

• The Service is provided "as is", without guarantee of uninterrupted or error-free availability.
• The Establishment is not liable for health decisions made on the basis of Generated Content without consulting a professional, for Specialist Plans and advice (section 7), or for indirect damages.
• The Establishment's total liability does not exceed the amount you paid it in the 12 months before the claim.
• This clause does not limit any right that cannot be waived by law, nor liability for fraud, gross negligence or breach of the Personal Data Protection Law.

15. Suspension and termination

We may suspend or terminate an account that breaches these Terms, after notice unless the breach is serious. If we discontinue the Service permanently we will give 30 days' notice, let you download your data and refund the unused paid period.

16. Changes to these Terms

We will notify you of material changes through the app or by email at least 15 days before they take effect. Continued use afterwards means acceptance. Any change that expands the use of your health data takes effect only with new consent.

17. Governing law and disputes

These Terms are governed by the laws of the Kingdom of Saudi Arabia, including the E-Commerce Law and the Personal Data Protection Law. We will first try to resolve any complaint amicably within 30 days; after that the Saudi courts have jurisdiction. You keep your right to complain to the Ministry of Commerce or to SDAIA.

18. Contact

+966545209769

Appendix: Specialist Terms of Use

These terms apply to every Specialist who uses Dietitian to follow their clients, in addition to the Terms & Conditions and the Privacy Policy. They must be accepted before a Specialist account is activated.

1. Nature of the relationship

• The Establishment is a technology provider only, supplying a tool to upload plans and follow clients.
• The Specialist is independent; no employment, agency or partnership relationship arises with the Establishment.
• The Specialist must not present themselves as representing the Establishment or attribute their plans to it.

2. Licensing and eligibility

• The Specialist confirms they are licensed and classified by the Saudi Commission for Health Specialties, or otherwise legally qualified for what they provide, and that their licence is valid.
• They must enter and keep updated their professional classification number, and notify the Establishment immediately if it expires or is suspended.
• The Establishment may verify the licence, without this being a guarantee of the Specialist's qualifications or the quality of their work.

3. Professional responsibility

• The Specialist alone is responsible for assessing their client and for their plan, advice and follow-up, and for its suitability for the client's health, in line with professional standards and health regulations.
• Automated content in the app (meal, behaviour and needs analysis) is an estimate. A Specialist who relies on it is responsible for reviewing it first.
• The Establishment does not review or approve plans and bears no liability for them or their results.
• The Specialist should hold professional liability insurance where the law requires it.

4. Client data

• The Specialist accesses only the data of clients who have linked their accounts to them with consent.
• They must comply with the Personal Data Protection Law and professional confidentiality, and use the data only to follow that client.
• Copying client data outside the app, sharing it or using it for marketing is prohibited without the client's separate consent. Anything the Specialist keeps outside the app is their sole responsibility.
• They must notify the Establishment within 24 hours of any suspected account compromise or data breach.
• When a client unlinks, the Specialist's access to their data stops immediately.

5. Specialist content

• The Specialist keeps ownership of their plans and grants the Establishment a limited licence to display and store them for their clients.
• They must not add misleading or unlawful content, or recommend products in which they have an interest without disclosing it.
• The Establishment may remove any violating or reported content.

6. Financial relationship with the client

Fees between the Specialist and their client are a matter between them. The Specialist is responsible for invoicing and tax obligations, unless the Establishment agrees otherwise in writing.

7. Indemnity

The Specialist will indemnify the Establishment against any claim, fine, damage or cost (including reasonable legal fees) arising from their plan or advice, practising without a valid licence, or breach of these terms or of the Personal Data Protection Law.

8. Suspension

The Establishment may suspend or terminate a Specialist account immediately if the licence expires, serious complaints are received, or these terms are breached. Linked clients will be notified, and their data remains in their accounts.

9. Governing law

These terms are governed by the laws of the Kingdom of Saudi Arabia. Disputes go to the Saudi courts after an attempt at amicable resolution within 30 days.