Moku — Privacy Policy

Last updated: 25 May 2026 Effective date: [TO BE SET WHEN PUBLISHED]

1. About this policy

This Privacy Policy explains how Moku ("Moku", "we", "us", or "our") handles your personal information when you use the Moku mobile application (the "App") and any related services (together, the "Service").

We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). For users outside Australia, additional rights may apply under the EU/UK General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA/CPRA) — see §13.

This Privacy Policy is incorporated into our Terms of Service.

2. What we collect

We collect only what we need to make the App work. There are four buckets:

2.1 Information you give us directly

What Source Required?
Apple user ID Sign in with Apple Required after 5 anonymous scans
Email address (often a private Apple relay) Apple shares this if you allow it Optional
Display name Apple shares this on first sign-in if you allow it Optional
Health goal (e.g. "Eat healthier", "Blood sugar", "Pregnancy") Onboarding Required to personalise output
Dietary restrictions (e.g. "Gluten", "Dairy") Onboarding Optional
Pregnancy details — region (AU/UK/US), trimester, due date Pregnancy mode only Required if you select Pregnancy mode

2.2 Food images

When you scan a food, the image is transmitted to Google's Gemini API for AI analysis and a result is returned. We do not retain the food image on our servers. See §4.2 for what Google does with it.

2.3 Information we generate when you use the App

What Purpose
Scan results (food name, "Go for it"/"Maybe not" decision, glucose impact, AI explanation, tags) Saved to your history (local + cloud sync if signed in)
Scan timestamp History ordering, daily limit enforcement
Goal active at scan time So your history shows context
Device timezone (X-Client-Timezone header) To apply the daily 5-scan limit on your local calendar day
Subscription status To know whether to show the paywall
Anonymous device identifier (Apple's identifierForVendor) For analytics — see §2.4
Session token (JWT) Stored in iOS Keychain so you stay signed in

2.4 Anonymous usage analytics (Statsig)

We use Statsig to track aggregate, anonymous events about how the App is used:

These events are tied to an anonymous device identifier, not your name or email. We use them to improve the App.

2.5 Crash and performance diagnostics

We use Sentry, a crash reporting service, to capture crash logs and basic performance metrics so we can fix bugs faster. This data is:

2.6 What we do NOT collect

3. Why we collect it (legal basis)

Under Australian law, we collect personal information because it is reasonably necessary to provide the App and the Service you've requested (APP 3).

For users in the EU/UK, our legal bases under GDPR Art. 6(1) are:

Purpose GDPR basis
Providing the core App (auth, scans, sync, history) Contract (Art. 6(1)(b))
Subscription billing and fraud prevention Contract + legitimate interests (Art. 6(1)(b), (f))
Anonymous analytics to improve the App Legitimate interests (Art. 6(1)(f))
Complying with legal obligations (e.g. tax, breach notification) Legal obligation (Art. 6(1)(c))

For sensitive pregnancy data (Art. 9 GDPR / sensitive information under the Privacy Act), our basis is your explicit consent when you select Pregnancy mode.

4. Who we share information with

We do not sell your personal information. We share it only with the following service providers, each acting as our processor:

4.1 Apple (Sign in with Apple, App Store, in-app billing)

4.2 Google (Gemini API)

4.3 RevenueCat (subscription management)

4.4 Cloudflare (backend infrastructure)

4.5 Statsig (anonymous analytics)

4.6 Sentry (crash reporting)

4.7 Other circumstances

We may also disclose personal information: - To comply with a law, court order, or lawful government request - To investigate suspected fraud, security incidents, or breaches of our Terms - In connection with a sale, merger, or restructure of Moku (we will notify you and your data will remain protected under terms no less protective than this Policy)

We will not sell or rent your personal information for marketing purposes.

5. Cross-border data transfers (APP 8)

Because the third parties above operate globally, your personal information is processed in countries other than Australia, including the United States and other regions where our providers operate.

Under APP 8.1, we take reasonable steps to ensure overseas recipients handle your information consistently with the APPs. We do this by:

You consent to these cross-border transfers when you use the App. By doing so, you acknowledge that overseas privacy regimes may differ from the Privacy Act, and that we may not be accountable under the Privacy Act for an act or practice of an overseas recipient where you have consented to the disclosure (APP 8.2(b)).

6. How long we keep your information

Data Retention period
Account profile (goal, restrictions, pregnancy details) While your account exists. Deleted on account deletion.
Scan history While your account exists. Capped at 50 most recent items locally; full history in the cloud while signed in. Deleted on account deletion.
Subscription records While your account exists + 7 years after for tax/accounting (Australian Taxation Office requirement)
Webhook events from RevenueCat 90 days (audit log)
Anonymous analytics (Statsig) Per Statsig's retention policy. Not linkable to your identity.
Crash and performance logs Per the crash reporting provider's retention policy. Not linkable to your identity.
Food images sent to Gemini Not retained by us. Google's retention per its API terms.

When you delete your account (Profile → Delete account in the App, or via trymoku.ai/delete-account), we delete: - Your user record - All profiles linked to your account - All scan history - Your subscription record

Cascading deletion is enforced at the database level. Records held by Apple, RevenueCat, and Google remain subject to their own retention policies.

7. How we protect your information

No system is 100% secure. We do our best, but cannot guarantee against all risks.

8. Your rights

8.1 Under the Australian Privacy Act (APPs 12 & 13)

You have the right to: - Access the personal information we hold about you - Correct information that is inaccurate, out of date, incomplete, irrelevant, or misleading - Opt out of direct marketing (we don't currently send marketing — see §10) - Complain about how we handle your information (see §14)

To exercise these rights, email [email protected]. We will respond within 30 days.

8.2 Under GDPR (EU/UK users)

In addition to the above, you have the right to: - Erasure ("right to be forgotten") - Data portability — receive your data in a machine-readable format - Restriction of processing in certain circumstances - Object to processing based on legitimate interests - Withdraw consent at any time (where processing is based on consent) - Lodge a complaint with your local data protection authority

8.3 Under CCPA/CPRA (California users)

You have the right to: - Know what personal information we collect and how we use it - Delete your personal information - Correct inaccurate information - Opt out of "sale" or "sharing" of personal information (we do not sell or share) - Non-discrimination for exercising your rights

8.4 How to delete your data the fast way

The fastest way to delete everything we have on you is in-app: Profile → Delete account → Confirm. This is a one-tap permanent deletion. No email required.

9. Data breach notification

If we suffer a data breach that is likely to result in serious harm to any individual, we will: - Notify the Office of the Australian Information Commissioner (OAIC) as required by the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act - Notify affected users as soon as practicable

For EU/UK users, we will also notify the relevant data protection authority within 72 hours where required under GDPR Art. 33.

10. Direct marketing

We do not currently send marketing emails. If we ever do, it will only be to users who have signed in and provided an email, and you will be able to opt out at any time via an unsubscribe link.

We will never share your contact details with third-party advertisers.

11. Children's privacy

The App is intended for users 17 years and older. We do not knowingly collect personal information from anyone under 17.

If you believe a child under 17 has used the App, please contact [email protected] and we will delete the account.

We do not target advertising to children and do not collect data triggering COPPA (US Children's Online Privacy Protection Act) obligations.

12. Cookies and tracking

The App is a native iOS app and does not use browser cookies.

We do not use third-party advertising trackers or share data with data brokers. The App does not currently implement Apple's App Tracking Transparency (ATT) prompt because we do not track you across other companies' apps or websites.

13. International users

The App is operated from Australia. If you access the App from outside Australia, you consent to the transfer of your personal information to Australia (and to the third-party countries listed in §4).

13.1 European Economic Area / UK / Switzerland

Where we transfer your personal data outside the EEA, UK, or Switzerland, we rely on appropriate safeguards including Standard Contractual Clauses (SCCs) and the EU-US Data Privacy Framework where applicable. You can request a copy of these safeguards by emailing [email protected].

13.2 California

We do not sell or share personal information as those terms are defined under the CCPA/CPRA. We have not done so in the past 12 months. To exercise your CCPA rights, email [email protected] with the subject "CCPA Request".

14. Complaints

If you believe we have breached the Australian Privacy Principles or mishandled your personal information:

  1. Contact us first at [email protected] with the subject "Privacy Complaint". We will acknowledge within 7 days and respond substantively within 30 days.
  2. If unresolved, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
  3. Website: oaic.gov.au
  4. Phone: 1300 363 992
  5. Post: GPO Box 5288, Sydney NSW 2001

15. Changes to this Policy

We may update this Policy from time to time. When we do: - We will update the "Last updated" date at the top of this page - For material changes affecting how we use your data, we will notify you in-app or by email (where we have one) at least 14 days before the change takes effect - Continued use of the App after the effective date constitutes acceptance

16. Contact

Email: [email protected] Web: trymoku.ai/support Operator: Moku, located in New South Wales, Australia

© 2026 Moku. All rights reserved.