Privacy Policy & Data Rights.
How ellara collects, protects, processes, and respects your personal health, nutrition, and device data across our platform and applications.
Transparency and User Control
This privacy policy (“Policy”) was last changed on July 2nd, 2026. We may occasionally make changes to the Policy. If we do, we shall notify either by sending you an e-mail or sending you a notification through our mobile application (“App”). Please make sure to read such notices carefully.
We hold the sincere belief that you should always know what data we collect from you, the purposes for which such data is used, and that you should have the ability to make informed decisions about what data you want to share with us.
This is why we want to be fully transparent about: (i) how and why we collect, store, share and use your personal data through the various capacities in which you interact with us; and (ii) the rights that you have to determine the parameters of this interaction.
While we would strongly advise you to read the Policy in full, the following summary will give you a scanshot of the salient points covered herein:
- This Policy details the critical aspects governing your personal data relationship with ‘ELLARA’ App which is owned and operated by Converse Global Consulting FZE, a company incorporated under the laws of United Arab Emirates, and having its registered office at FBC 40243, Compass building, Al Shohada Road, Al Hamra industrial zone-FZ, Ras Al Khaimah, UAE;
- Your personal data relationship with ELLARA varies based on the capacity in which you interact with us/avail of our products and services (“Services”). You could be: (i) a visitor to https://www.ELLARA.ai (“Website”) or any pages thereof (“Visitor”); or (ii) a person who has an account with ELLARA App to avail our Services (“Registered User”);
- Based on whether you are a Visitor or Registered User, the type of data we collect and the purpose for which we use it will differ and this Policy details such variations;
- This Policy applies to all the Services provided by ELLARA through the Website, App or any other associated website of ELLARA;
- This Policy is a part of and should be read in conjunction with our Terms of Service; and
- This Policy will clarify the rights available to you vis-à-vis the personal data you share with us.
INFORMATION WE COLLECT AND HOW WE USE IT
1. Your IP Address;
2. Your location;
3. How you behave on the Website, (what pages you land on, how much time you spend, etc.);
4. What device you use to access the Website and its details (model, operating system, etc.);
5. Cookies and web beacon data; and/or
1. Your name, age, gender, phone number, e-mail address, mailing address;
2. Your lifestyle, food preferences, medical conditions (if any), health goals or other fitness regimes;
3. Your ethnicity, health
4. Username or other relevant unique identifier;
5. How you behave on the Website, App (what pages you land on, how much time you spend, etc.);
6. Credit card/debit card/other payment mode information to facilitate payments for our Services;
7. Your IP Address;
8. Your location unless you deactivate location services in the relevant section of the Website/App;
9. How you behave in the relevant product environment and use the features;
10. What device you use to access the Website/App and its details (model, operating system, etc.);
11. Cookies and web beacon data.;
12. Photos containing food items ("Food Photos”) that you scan, upload through our [Scan feature];
We use this information to analyse and identify your behaviour and enhance the interactions you have with the Website.
If you submit your details and give us your consent, we may use your data to send you e-mails/newsletters, re-target ELLARA advertisements or re-market our Services using services from third-parties like Meta and Google.
The Food Photos will be collected, stored and processed in terms of Section 2 below.
We collect this data in order to help you register for and facilitate provision of our Services.
We use this data to show age appropriate content and advertisements.
We use this data to track your nutrition needs, health goals.
We use the data from the device you access our Website/App to identify the login information of multiple users from the same device.
We use this data to help you with clear insights on ingredients, allergens and personalized nutrition based on you and your family’s health goals.
We use this data to enable you to make payments for our Services. We use a third-party service provider to manage payment processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of payment processing on our behalf
We use this data for processing your requests, enquiries and complaints, customer services and related activities.
We use this data to communicate about existing or new offers, content, advertisements, surveys, key policies or other administrative information.
We also use this data to provide you with informative features and services that are developed by us from time to time.
We also use this data for providing, testing, improving, or recommending the Services.
We also use this data for analytics and reviews to improve the Services.
We also use this data to provide support to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law or anti-fraud activities/systems.
If you give us your consent, we may send you newsletters and emails to market other products and services we may provide.
The Food Photos will be collected, stored and processed in terms of Section 2 below
SPECIAL CATEGORIES OF DATA
PERSONAL DATA
We may collect and process ‘special categories of personal data’ such as ethnic origin or health which are considered sensitive. We use this special category of personal data, for example to help you identify food products that best fit your ethnicity, dietary needs, lifestyle and health goals. We require your explicit consent to collect and process special categories of personal data. You may refuse or revoke your consent at any time, please see the section about 'Your Rights & Preferences As A Data Subject In The EU' below. A limited number of our personnel will have access to special categories of personal data provided by you.
FOOD PHOTOS – SCAN feature
With your prior consent, the following activities may be undertaken with respect to your Food Photos:
The Food Photos will be analyzed on your device (i.e., without storing them on our servers) to check the type of data contained therein. Using our AI technology, we will, to the extent possible, blur any and all contents other than food.
Thereafter, such Food Photos will be stored in our servers to help you track your nutrition and achieve your health goals. When you give us permission to access your photo gallery, we will only collect and store the Food Photos you choose to track on our App. We will not upload any other photos or data from your device. To provide more nuance, we would like to clarify that the decision to classify photos as food or non-food is made by algorithms, not through human review. Furthermore, this algorithm operates solely on the device, and no photo is transferred to our server unless the algorithm determines that it is a food photo. It is important to understand that the algorithm may occasionally misclassify non-food photos as food photos. While we are constantly reviewing and improving our code to reduce such occurrences, there is still a chance that your photo may be uploaded even if it is not a food photo. If you are registered with us and intend to use the ‘auto-scan’ feature, please note that you can decide if we can access the photos in your gallery, and we're open about how we use them.
We analyze the Food Photos using our proprietary technology as well as trusted third-party AI service providers (as detailed in Section 11) to determine the nutritional content of your meals/snacks and provide personalized insights. We do not sell your Food Photos or share them with third parties for independent marketing purposes.
We take the security of the Food Photos seriously and have implemented industry-standard security measures to protect such data from unauthorized access or disclosure. All data is encrypted and stored on secure servers that are regularly monitored and updated.
Food Photos, text prompts submitted to our AI features, and generated chat responses are retained on our secure servers for as long as your account remains active or as needed to provide tracking and personalized recommendation services, after which they are securely deleted. You may also manually delete Food Photos or chat history from your account settings at any time.
If no consent is provided by you, we will not analyze or collect any Food Photos. You will still be able to avail of the other functionalities of our App.
Features and Services
The ELLARA App is designed as a personalized nutrition platform. To deliver and continually improve your experience, we may introduce new features, services, integrations, and technologies over time, including but not limited to wearable device connectivity, health and fitness platforms, smart watches, AI-powered insights, online shopping, coaching tools, and other digital services.
Where you choose to enable these optional features, we may collect, process, and use the information necessary to provide the requested functionality, personalize your experience, improve our services, and develop new products and features. Any optional integration that requires access to additional personal data or device permissions will only be activated with your consent where required by applicable law.
Unless a new feature materially changes how your personal information is collected, used, or shared, the introduction of additional features or integrations will be governed by this Privacy Policy without requiring a revision each time a new capability is launched.
USE OF AGGREGATED, DE-IDENTIFIED DATA
FOR THE AVOIDANCE OF ANY DOUBT, WE SHOULD CLARIFY THAT IN THE EVENT WE ANONYMIZE AND AGGREGATE INFORMATION COLLECTED FROM YOU, WE WILL BE ENTITLED TO USE SUCH ANONYMIZED DATA FREELY, WITHOUT ANY RESTRICTIONS OTHER THAN THOSE SET OUT UNDER APPLICABLE LAW.
We may use your data in aggregate form for research purposes, based on our legitimate interest in generating non-personally identifiable insights to enhance our services, provide reports to third parties, and promote our business. All such research utilizes data that is de-identified, ensuring no individual user can be identified. This may include analysis of trends, user behavior, and other patterns for inclusion in scientific publications, presentations, or reports, while maintaining user anonymity.
YOUR RIGHTS & PREFERENCES AS A DATA SUBJECT IN THE EU
It might have come to your attention that a new law was passed in the European Union (EU) called the General Data Protection Regulation (GDPR). The GDPR gives certain rights to individuals who are EU data subjects, in relation to their personal data.
Subject to the GDPR and applicable law’s limitations, the rights afforded to you if you are an EU data subject are:
RIGHT TO BE INFORMED
You have a right to be informed about the manner in which any of your personal data is collected or used which we have endeavored to do by way of this Policy.
RIGHT OF ACCESS
You have a right to access the personal data you have provided by requesting us to provide you with the same.
RIGHT TO RECTIFICATION
You have a right to request us to amend or update your personal data if it is inaccurate or incomplete.
RIGHT TO ERASURE
You have a right to request us to delete your personal data.
RIGHT TO RESTRICT
You have a right to request us to temporarily or permanently stop processing all or some of your personal data.
RIGHT TO OBJECT
You have a right, at any time, to object to our processing of your personal data under certain circumstances. You have an absolute right to object to us processing your personal data for the purposes of direct marketing.
RIGHT TO DATA PORTABILITY
You have a right to request us to provide you with a copy of your personal data in electronic format and you can transmit that personal data for using another third-party’s product/service.
RIGHT NOT TO BE SUBJECT TO AUTOMATED DECISION-MAKING
You have a right to not be subject to a decision based solely on automated decision making, including profiling.
In case you want to exercise the rights set out above you can contact our Grievance Officer whose details are set out in Section 16 below.
The data provided by you as a Visitor, or when you sign up as a Registered User for our Services will be processed by us for the purpose of rendering Services to you or in order to take steps prior to rendering such Services, at your request. Where such data is not being used by us to render Services to you, we shall explicitly seek your consent for using the same. You can choose to withdraw this consent at any time by writing to us at contactus@ELLARA.ai Additionally, we may process your data to serve legitimate interests.
Accordingly, the grounds on which we can engage in processing are as follows:
If you believe we have used your personal data in violation of the rights above or have not responded to your objections, you may lodge a complaint with your local supervisory authority.
PUBLISHED CONTENT
Any success stories, comments, messages, blogs, scribbles etc. posted/ uploaded/ conveyed/ communicated by you on the public sections of the Website/App becomes published content. We may publish such published content on our Website/App so long as you consent. You may request that such published content be taken down at any time and we shall remove such published content. However, we are not responsible for any actions taken by third-parties with respect to such published content.
INFORMATION WE GET FROM OTHERS
We may receive data about you from other sources i.e., expert calls, smart watch, surveys, and such data may be added to our Website/App from time to time. Such data may include your behavior towards various content posted on our Website/App from other sources. We use the data collected from other sources to prepare specific insights on ingredients, allergens, personalized nutrition for you. This helps you make smarter, faster food choices that fit well with your ethnicity, dietary needs, lifestyle and health goals. We also use this data for providing, testing, improving, or recommending the Services.
RETENTION OF PERSONAL INFORMATION
We will store any personal data we collect from you as long as it is necessary in order to facilitate your use of the Services and for ancillary legitimate and essential business purposes – these include, without limitation, for improving our Services, attending to technical issues, and dealing with disputes.
Your personal data will primarily be stored in electronic form. We may enter into agreement with third parties to collect, store, process your personal data but under full compliance with applicable laws. In the event, you have any telephonic interactions with our customer representatives, the call data is recorded and stored on the Amazon Web Services (AWS) for training and quality purposes.
We may need to retain your personal data even if you seek deletion thereof, if it is needed to comply with our legal obligations, resolve disputes and enforce our agreements.
If you are a Registered User, please be advised that after you terminate your usage of a Service, we may, unless legally prohibited, delete all data provided or collected by you from our servers.
TRACKING BY OUR ADVERTISEMENT PARTNERS
Upon receiving your specific consent, we may share the data we collect from cookies or web beacons with our advertisement partners to track your visits, establish your non-personal identity and present you with targeted advertisements about our Services.
COMPLIANCE WITH CHILDREN’S ONLINE PRIVACY PROTECTION ACT
Our Services are intended exclusively for adult users. We do not knowingly collect, store, or process personal data from children under 18 years of age. Individuals under the age of 18 are not permitted to register for an account or submit personal information through our Website or App without verified parental or legal guardian consent. If we become aware that we have collected personal data from a minor without verified authorization, we will take immediate steps to delete such information.
TRANSFER OF INFORMATION
In the ordinary course of business, we may employ other companies and people to assist us in providing certain components of our Services in compliance with the provisions of this Policy. To do so, we may need to share your data with them.
Where applicable – if the entities to which these transfers are effected are not situated in countries deemed ‘adequate’ by the European Commission or are not registered under the EU-US Privacy Shield framework, we shall enter into appropriate Data Protection Addendums with the transferee parties that comprehensively protect your data. We shall also put in place industry-standard technical and organizational measures (including robust data handling policies) to ensure that such transfers are completed in accordance with applicable laws.
Some of the examples of where we may sub-contract processing activities to third parties include—record keeping, data analysis, marketing assistance, processing payments, and providing customer service.
ELLARA uses artificial intelligence (“AI”) technologies, including third-party AI service providers, to power certain features within the App, including but not limited to nutrition analysis, food (meal/snacks) recognition, recommendation of healthier food alternatives, health tips, health insights, chat functionality, and personalized recommendations.
11.1 Data Sent to AI Service Providers
When you use AI-powered features, the following categories of data may be transmitted securely to our third-party AI processing providers:
- Text inputs you submit (e.g., chat messages, queries)
- Food (meal/ snacks/ packaged food) photos
- Selected health and fitness data necessary to generate insights (e.g., Allergens, health goals, health issues, logged nutrition data)
- Limited device and usage metadata required to process your request.
We only transmit the data necessary to provide the requested functionality. We do not transmit personal identifiable user information.
11.2 Purpose of Processing & Medical Disclaimer
Your data is transmitted to third-party AI providers solely for generating personalized nutrition estimates, health insights, and tracking personal lifestyle goals.
Disclaimer: AI-generated outputs, nutritional breakdowns, and suggestions are provided for informational and educational purposes only and do not constitute medical advice, diagnosis, or treatment. Always seek the advice of a physician or other qualified health provider with any questions you may have regarding a medical condition.
11.3 Third-Party AI Providers and Data Protection
We share data with trusted third-party AI service providers that act as our data processors. These providers:
- Process data solely on our behalf and according to our instructions
- Are contractually required to provide privacy and security protections equal to or greater than those described in this Privacy Policy
- Are not permitted to use your personal data for independent marketing purposes
ELLARA does not sell your personal or health data.
THIRD PARTY LINKS
We may display links to third-party websites or applications on our Website or App for advertising or providing you with relevant content. We will not be responsible for such third-party websites or applications if you choose to access them. If you provide any data to such website/application, please ensure you read their policies given that you will no longer be bound by this Policy in doing so.
We may receive data whenever you visit a third-party link through our Website/App which includes the date and time of your visit to the third-party website, the web address or URL, technical information about the IP address, browser and the operating system you use and, if you are logged into ELLARA, your username.
INTEGRATION WITH GOOGLE – LIMITED USE POLICY
We have integrated the App with services provided by Google to: (a) enable you to sign in to the App using your existing Gmail ID; and/or (b) provide insights and analysis of your health. To this end, please note that any collection, storage, use and/or transfer of your data that is received from:
1. Google API will, at all times, adhere to Google API Services User DataPolicy, including the limited use requirements prescribed therein; and
To summarize, ELLARA's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the concerned Limited Use requirements.
INTEGRATION WITH APPLE – LIMITED USE POLICY
We have integrated the App with services provided by Apple to: (a) enable you to sign in to the App using your existing Apple Account. To this end, please note that any collection, storage, use and/or transfer of your data that is received from Apple services will be handled in accordance with the applicable Apple Developer policies and guidelines.
1. Sign in with Apple will always adhere to Apple’s applicable requirements for user authentication, privacy and data handling, including the requirements prescribed for Sign in with Apple; and
To summarize, ELLARA’s use and transfer to any other app of information received from Apple services will adhere to Apple’s applicable policies and guidelines, including the requirements governing the use of Sign in with Apple data.
For more information, please refer to the Apple Developer Documentation.
COMPELLED DISCLOSURE
In addition to the purposes set out in the Policy, we may disclose any data we collected or processed from you if it is required:
- under applicable law or to respond to a legal process, such as a search warrant, court order, or subpoena;
- to protect our safety, your safety or the safety of others or in the legitimate interest of any party in the context of national security, law enforcement, litigation, criminal investigation or to prevent death or imminent bodily harm;
- to investigate fraud, credit risk or violation of our Acceptable Use Policy;
- in connection with legal proceedings brought against ELLARA, its officers, employees, affiliates, customers or vendors;
- to establish, exercise, protect, defend and enforce our legal rights; or
- when we do a business deal or negotiate a business deal, or our assets are merged or acquired by the other business entity, or during restructuring of business or re-organization, we may have to share information provided by you with the other business entities.
SECURITY OF YOUR PERSONAL INFORMATION
We implement industry-standard technical and organizational measures by using a variety of security technologies and procedures to help protect your data from unauthorized access, use, loss, destruction or disclosure. When we collect particularly sensitive data (such as a credit card number or your geo-location), it is encrypted using industry-standard cryptographic techniques including but not limited to PBKDF2, AES256, TLS1.2 & SHA256.
The collection, storage, usage, and sharing of your data by the Company shall be in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws.
Your password is your first line of defense once you set up a ELLARA account, we recommend that you set a strong password which you never share with anyone.
We have taken appropriate steps for the security and protection of all our digital platforms including internal applications, however, we shall not be responsible for any breach of security or the disclosure of personal data for reasons outside our control, such as hacking, social engineering, cyber terrorism, espionage by third parties, or any events by way of force majeure such as sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war or acts of government.
ACCESS, CORRECTION & DELETION
You may request access, correction or updation, and deletion of the data by contacting contactus@ELLARA.ai You may note that deletion of certain data or withdrawal of consent may lead to cancellation of your registration with us or your access to our Services.
Based on technical feasibility, we will provide you with access to all your personal and sensitive personal data that we maintain about you. We will perform verification before providing you access to this data.
You may opt out of our marketing emails by clicking on the ‘opt-out’ link provided in the emails. However, we may still send you non-marketing emails about your accounts or any other transactions with you.
GRIEVANCE OFFICER
If you have any queries, requests or complaints, you may reach out to our Grievance Redressal Officer using the contact information below: