Privacy Policy

1. Who We Are / Data Controller

The controller of personal data processed in connection with FamFish is Andrzej Rybka, operating under the EleaFish brand. We operate the website https://eleafish.com and the FamFish mobile application ('FamFish 1.0').

For any questions, requests, or inquiries regarding data protection and this Privacy Policy, please contact our designated privacy mailbox: contact@eleafish.com.

2. Scope of this Policy

This Privacy Policy applies to personal data collected and processed through the FamFish 1.0 Android application, our web presence at eleafish.com, and related online communication channels. FamFish does not operate an advertising-data sales model. We do not sell, rent, or monetize your personal information.

3. Accounts and Authentication

FamFish uses Supabase Auth for identity management and authentication. User accounts are authenticated exclusively via email address and password. FamFish 1.0 does not use Google Sign-In or Apple Sign-In. When you register, we process your email address, securely hashed password credentials, and unique system user ID (UUID) necessary to establish and authenticate your account session.

4. Family Profiles and Minors

FamFish is a family organization ecosystem designed for multi-member households. Users can create a family workspace or join an existing family via invitation links, invitation codes, or QR codes.

An adult family administrator must be at least 18 years old. Minors under the age of digital consent may join an active family workspace only upon adult administrator invitation and approval. Profile information within a family may include display name, email address, date of birth, name day, avatar image, height, hydration and daily step targets, preferences, notification settings, and assigned family membership role.

5. Family Organization Data

To deliver core family coordination functionality, FamFish processes household content created by members. This includes calendar events, scheduled reminders, shared tasks, habit streak tracking, challenges, journal and list entries, workouts, collaborative projects, budget allocations, logged expenses, and family notes. This content is shared among members of your active family workspace according to family configuration.

6. Messages and Communication

FamFish provides family group chat as well as direct (1:1) chat channels strictly within the active family workspace. Communication features support text messages, attached images, emoji reactions, message replies, and message delivery/read states.

Users can conveniently link or convert chat messages into calendar events, projects, notes, or tasks. Direct 1:1 conversations between family members are accessible only to the participants of that specific conversation; family administrators cannot read private 1:1 direct conversations between other family members. There is no random or public chat functionality in FamFish.

7. Photos and Files

FamFish allows users to capture or select images from their device camera or photo gallery for specific app functions: profile avatars, chat message attachments, and expense receipt images. Access to device camera and photo storage is strictly voluntary and requested only when you trigger an action requiring file upload.

8. Health and Fitness Data

FamFish includes wellness and daily habit features where users may manually enter or synchronize personal fitness metrics. Personal health and fitness data is treated with heightened care and is used strictly to provide personal history and family habit motivation.

9. Android Health Connect

Integration with Android Health Connect is completely optional. FamFish requests read-only access to specific fitness categories only if the user explicitly grants permission in the Android system dialog. FamFish holds zero (0) Health Connect WRITE permissions.

The audited FamFish 1.0 production manifest includes read access for the following 12 health and activity categories:

• Steps
• Active Calories Burned
• Weight
• Body Fat
• Body Water Mass
• Lean Body Mass
• Heart Rate
• Blood Pressure
• Oxygen Saturation
• Hydration
• Body Temperature
• Sleep

Health-related information read from Health Connect may be synchronized to the FamFish backend to maintain continuous history and power app habit insights across sessions. Health Connect data does not remain exclusively on-device.

10. Receipts, OCR and AI Interpretation

FamFish allows users to photograph and upload purchase receipts to organize project expenses and family budgets. Optical Character Recognition (OCR) is performed locally on-device using Google ML Kit. The image itself is processed on your device for text extraction and is not intentionally sent directly to the remote AI model in the currently documented receipt flow.

Extracted receipt text (which may contain merchant names, line items, prices, tax amounts, and dates) may be transmitted through the FamFish backend to configured remote AI providers (such as Google Gemini or OpenAI) for optional automated categorization and item parsing.

11. Notifications

FamFish uses Firebase Cloud Messaging (FCM) and local Android notifications to deliver timely alerts regarding family calendar events, assigned chore reminders, and incoming family chat messages. For push notifications, a unique FCM device registration token is generated and stored in your profile. You can modify notification preferences in app settings or revoke notification permissions entirely in Android system settings.

12. Subscriptions and Purchases

FamFish integrates RevenueCat to synchronize entitlement and subscription status across your family devices. If commercial subscriptions or in-app purchases are enabled, transactions are processed directly by Google Play In-App Billing.

FamFish never receives, processes, or stores your full payment-card number, expiration date, or CVV code. Google Play provides only randomized transaction tokens and purchase status confirmations.

13. Service Providers / Processors

We engage selected technical service providers who act as data processors under binding data processing agreements (DPAs):

• Supabase: Database infrastructure, user authentication, session security, and encrypted storage.
• Google Firebase (FCM): Secure push notification delivery and device token handling.
• Google Play: Secure billing and in-app purchase transaction processing.
• RevenueCat: Subscription lifecycle management and cross-device entitlement validation.
• Google ML Kit: On-device Optical Character Recognition (OCR) for receipt text extraction.
• Remote AI Providers (e.g., Google Gemini, OpenAI): Structured parsing of extracted receipt text when AI expense analysis is initiated by the user.

14. Purposes and Legal Bases for Processing

Under Article 6 of the EU GDPR, we process personal data based on:

• Performance of Contract (Art. 6(1)(b) GDPR): To deliver core services, manage user accounts, coordinate family workspaces, sync schedules, and handle subscriptions.
• Consent (Art. 6(1)(a) & Art. 9(2)(a) GDPR): For optional Android Health Connect synchronization, camera access, and push notifications.
• Legitimate Interests (Art. 6(1)(f) GDPR): To maintain infrastructure security, diagnose technical faults, prevent abuse, and preserve shared family organizational integrity.
• Legal Obligation (Art. 6(1)(c) GDPR): To comply with statutory accounting, taxation, and regulatory reporting requirements.

15. Data Sharing & Family Visibility

Personal data is never sold to third parties. Information is shared strictly inside your active family workspace among invited members (for collaborative calendars, tasks, chats, and projects) and with our vetted infrastructure processors. Health metrics remain personal to your account unless explicitly published to shared family routines.

16. International Data Transfers

Where technical service providers store or process data outside the European Economic Area (EEA), transfers are governed by European Commission Standard Contractual Clauses (SCCs), adequacy decisions, or recognized transfer mechanisms ensuring GDPR-equivalent data protection levels.

17. Data Retention

We apply transparent criteria rather than arbitrary timelines to determine data retention:

• Account & Profile Data: Retained while the account remains active and as required to provide the FamFish service.
• Personal Health & Activity Data: Retained according to active usage and deleted or anonymized upon user request or account deletion.
• Shared Family Content: Maintained while it remains part of active shared family history, or until removed by authorized family members.
• Transaction & Subscription Records: Retained for the duration mandated by applicable commercial, accounting, and tax legislation.
• Security & Technical Diagnostic Logs: Retained only for the minimum duration reasonably necessary to investigate security incidents and resolve system errors.
• Hosting Provider Backups: System backups cycle and expire automatically according to standard cloud hosting retention cycles.

18. Account and Data Deletion

FamFish provides a prominent self-service account deletion path directly within the mobile application: Profile → Settings → Account & Security → Danger Zone → Delete Account. Initiating deletion activates a 14-day grace period during which you can cancel the request. Detailed deletion mechanics are documented on our dedicated Account Deletion page (/account-deletion).

19. User Rights Under GDPR

As an EEA data subject, you hold comprehensive rights under the GDPR:

• Right of Access (Art. 15 GDPR): Obtain confirmation and a copy of your personal data.
• Right to Rectification (Art. 16 GDPR): Correct inaccurate or incomplete profile details.
• Right to Erasure (Art. 17 GDPR): Request permanent deletion of your personal records.
• Right to Restriction of Processing (Art. 18 GDPR): Limit processing in specific circumstances.
• Right to Data Portability (Art. 20 GDPR): Receive your data in a structured, machine-readable format.
• Right to Object (Art. 21 GDPR): Object to data processing based on legitimate interests.
• Right to Withdraw Consent (Art. 7(3) GDPR): Revoke previously given consent at any time without affecting prior lawful processing.
• Right to Lodge a Complaint: Lodge a complaint with a competent supervisory authority (in Poland: Prezes Urzędu Ochrony Danych Osobowych - PUODO).

20. Children and Minors

FamFish supports minors exclusively inside a private family workspace created and managed by an adult administrator (18+). Direct parent/administrator approval is required for minor accounts. We do not engage in behavioral advertising, public profiling, or commercial monetization of children's data. Communication features are strictly confined to the family workspace.

21. Data Security

We enforce industry-standard technical and organizational security controls, including Transport Layer Security (TLS 1.3/1.2) for all data in transit, encrypted storage at rest, database row-level security (RLS) isolating family workspaces, role-based access controls, and regular vulnerability audits.

22. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect app enhancements, infrastructure updates, or legal requirements. Material revisions will be posted on this page with an updated revision date.

23. Contact Us

If you have questions, feedback, or requests regarding this Privacy Policy or your personal data, please reach out to us at: contact@eleafish.com (General Privacy) or support@eleafish.com (Account Support).