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Privacy Policy

Last updated: October 3, 2026

In plain language: what data Imperia The1 collects, why, who it goes to and how to delete it. We do not sell data. The ad networks Meta and TikTok receive only events such as an app install or a subscription start — to measure advertising, and only within your choices (section 9).

1. Who is responsible for your data

The data controller is Aram Elbakyan (Aramayis Elbakyan), a private individual, Dubai, UAE, who is also the seller of the IMPERIA THE1 app on the App Store. For any question about data: [email protected].

The service is intended for people aged 18 and over. We do not knowingly collect data from minors; if such an account comes to light, we delete it.

2. What data we collect

3. Health data — separate consent

Measurements, body and food photos, lab results, heart rate, sleep and everything you tell the mentor about how you feel are health data, a special category. We process them only on the basis of your explicit consent (GDPR Art. 9(2)(a)).

You give that consent with a separate checkbox at sign-up — separate from accepting the terms — and you may decline it: the platform still works, only the AI mentor is switched off. You can withdraw it at any time in the same place you gave it: your account → "My data". Withdrawal switches off the chat and the transfer of data to Anthropic and leaves the rest of your subscription untouched. It applies going forward and does not undo processing that has already happened.

Sharing Apple Health / Health Connect metrics with the mentor, and writing your meals back into Health, are separate toggles that are off by default. Until you turn them on, that data never reaches the AI.

4. Why we use data, and on what legal basis

We do not make automated decisions with legal effects: the AI produces training and nutrition recommendations, not refusals of service.

5. Who we share data with

We do not sell data. Access is limited to the services the platform cannot run without and to ad networks, within the limits described below and in section 9:

We also disclose data where required by law, a court, or a competent authority.

6. International transfers

The platform runs on a server in Germany (Hetzner). Some of the services in section 5 are outside the EU and the UAE — chiefly in the USA. For those transfers we rely on the EU Standard Contractual Clauses in our agreements with them, and for health data additionally on your explicit consent. Paying with a Russian card means payment data goes to Russia: that is your choice of payment method, and you can always use a card or crypto instead.

7. Retention, and what survives deletion

Data is kept while your account is active. You can delete it yourself: your account → "My data" → "Danger zone", confirmed with a code sent to your email. In the same place you can end all sessions if you suspect someone else has signed in.

What actually happens on deletion:

8. Your rights

We answer requests within 30 days. We verify identity with a code sent to the email linked to the account, so that nobody else receives your data.

9. Cookies, analytics, pixels and in-app advertising

In the web account, cookies and localStorage are purely technical: they keep your session and remember settings and progress. There is no analytics and there are no advertising pixels in the account area.

On the public site — the landing page, the blog, these pages — a banner appears on your first visit. Until you press "Accept", no third-party script loads at all: no pixel, no counter. After consent, these are enabled:

These services receive your IP address, a browser identifier and the pages you viewed, and process them under their own policies — Meta, Google and Yandex respectively. You can withdraw consent by clearing site data in your browser: the banner reappears and you can choose again.

The iPhone app. The app includes the Meta SDK and the TikTok Business SDK. They send Meta and TikTok app events — install, launch, registration, trial start, subscription start and renewal — together with technical device data (model, iOS version, language, IP address). This tells us which ads bring people in, so the budget is not wasted. Purchases are processed by Apple; neither we nor Meta nor TikTok receive card details.

After the questionnaire the app shows Apple's system prompt "Allow tracking?" once. If you tap "Allow", the SDKs receive the device advertising identifier (IDFA). If you tap "Ask App Not to Track", the IDFA is not shared and iOS blocks data from reaching Meta's and TikTok's tracking domains; advertising gets only Apple's anonymised statistics (SKAdNetwork). You can change your mind at any time: iPhone Settings → Privacy & Security → Tracking. Health data, photos, lab results and your chat with the coach are never shared with Meta or TikTok.

10. How we protect data

Connections are encrypted (HTTPS) and server access is by key and limited to a small circle. We store no passwords at all: you sign in with an email code or through Google, Apple or Telegram. Backups live in private storage with key-based access. No protection is perfect, which is what section 11 is for.

11. If there is a breach

If personal data is breached, we notify the supervisory authority within 72 hours of becoming aware (GDPR Art. 33) and the UAE Data Office without undue delay under the PDPL. If the breach puts you at real risk, we write to you personally — by email and in your account: what happened, which data is affected, what we are doing and what you should do.

12. Changes and contact

We update this policy as the product changes. We will notify you of material changes by email. Questions and data requests — [email protected].