1. What Data We Collect

When you register and use NUTBOM, we collect the following categories of personal data:

• Identity data: full name, job title
• Contact data: work email address, phone number
• Business data: company name, subscription plan
• Usage data: login activity, feature usage, system logs
• Customer-entered content: recipes, formulations, ingredient lists, prices (these remain your exclusive property)

2. Lawful Basis for Processing

2.1 Contractual Necessity: The Company processes Personal Data on the basis of contractual necessity (Performance of a Contract) to provide the NUTBOM service — including account authentication, billing, and customer support.

2.2 Legitimate Interests: We may also process data based on our legitimate business interests, such as improving the System using aggregated and anonymized usage statistics. Your individual recipes and formulations are never used for this purpose.

2.3 Consent: With your explicit consent, we may send you marketing communications and product updates. You may withdraw this consent at any time.

3. Your Rights Under GDPR

As a data subject, you have the following rights regarding your personal data:

To exercise any of these rights, contact our Data Protection Officer (DPO) at: hello@foodnet.co.il

4. Data Processing Addendum (DPA)

4.1 Insofar as the Customer processes the Personal Data of EU residents within the System, the parties shall execute a Data Processing Addendum (DPA) as required by Article 28 of the GDPR, which shall form an integral part of this agreement.

4.2 In this arrangement, the Customer acts as the Data Controller and NUTBOM acts as the Data Processor.

5. International Data Transfers

5.1 Personal Data transferred outside the European Economic Area (EEA) will be protected using EU-approved mechanisms, such as Standard Contractual Clauses (SCCs) or an Adequacy Decision.

5.2 NUTBOM implements appropriate Technical and Organizational Measures (TOMs) to protect your data at rest and in transit, including encryption and access controls.

6. Data Retention

We retain your personal data for as long as your account is active, or as necessary to provide services. Upon account deletion:

• You may export all your data in JSON/CSV format within 30 days
• After this period, we delete all copies from active servers
• We retain only data required by law (tax, billing, regulatory records)

7. Third-Party Data (End-Customer Data)

If you collect information about end consumers through NUTBOM features (e.g., online menus, QR code scans), you act as the Data Controller for that data, and NUTBOM acts as the Data Processor. You are responsible for ensuring that such collection is lawful and properly disclosed to your end customers.

8. Data Breach Notification

In the event of a Data Breach affecting Personal Data, NUTBOM will notify you without undue delay and within the timeframe stipulated by GDPR (72 hours from discovery).

9. AI and Your Recipe Data

NUTBOM uses AI models for features such as OCR text recognition, ingredient auto-fill, and marketing text generation. Your recipes, formulations, and trade secrets are never used to train external public AI models. AI outputs are recommendations only — you retain full verification responsibility.

10. Contact Us

For any privacy-related inquiries, GDPR requests, or to contact our Data Protection Officer: