Privacy Policy

Fennla — a calorie-tracking Telegram bot · Last updated: 19 September 2026

This policy explains what personal data Fennla (“we”, “the bot”) collects when you use it, why we use it, who receives it, and the choices you have. Fennla estimates the calories and macronutrients of meals you log.

Not medical advice. Fennla provides calorie estimates for information only. It is not a medical device and does not diagnose, treat, or prevent any condition. If you are pregnant, managing a health condition, or have had a difficult relationship with food or numbers, please talk to a doctor or a registered dietitian.

1. Who is responsible for your data

Individual Entrepreneur Stanislav Tibilius
Registration / ID number: 304651124 (LEPL National Agency of Public Registry, Georgia)
Registered address: Georgia, Tbilisi, Krtsanisi District, Ponichala 3, Building 5, Floor 4
Data-request contact: fennla@proton.me

2. What we collect

DataHow it reaches us
Your Telegram user id, first name and language codeTelegram sends them when you interact with the bot
Meal photosYou send them in the chat; Fennla downloads each image for analysis but stores neither the image nor its Telegram file reference
Meal descriptions and barcodesYou type or scan them to log or look up food
Your food diary: meals, calories, macronutrients and timestampsCreated as you log meals
Optional daily calorie or protein targetYou set it directly in the bot. If you use the optional calculator, age, sex, height, weight and activity are processed only on your device; Fennla receives and stores only the final targets

We do not ask for your phone number, email address or payment details to use the bot.

3. Why we use it and our legal basis

You can withhold or withdraw consent without losing any right you already had. To withdraw it, clear all your data in Settings and stop sending new meal data, or contact us. Withdrawal does not affect processing that was lawful before withdrawal.

4. Who receives data and international transfers

Running the bot means some data is processed by these recipients and may be processed outside Georgia.

RecipientWhat they receive and why
TelegramYour messages and photos pass through Telegram, the platform on which the bot runs.
Google (Gemini API)Your meal photos and descriptions are sent to Gemini to estimate the food. We use a paid API tier whose terms say prompts, images and responses are not used to train Google’s models; Google may keep logs for a limited time for abuse detection, security and legal obligations.
Hetzner (Germany)Hosting for the bot, its database and operational logs.
PostHogProduct analytics. It receives event names, a pseudonymized token and limited properties such as interface language, acquisition source, action and input type; it does not receive your Telegram id, photos, free-form meal text or absolute nutrition values.
Open Food FactsAn open food database queried for barcode and product data. If the local copy does not contain an ingredient, Open Food Facts may receive that ingredient's search term without your Telegram id. Product data is used under the Open Database License (ODbL).

We do not sell your data or share it with advertisers.

5. How analytics protects your identity

Before an analytics event is sent to PostHog, your Telegram id is replaced with a pseudonymized token using a secret held on our server. PostHog cannot use that token to identify your Telegram account. We can relate it back only when needed to answer a data request.

6. How long we keep data

7. Your rights and choices

Depending on the law that applies to you, you may ask to access, correct, delete, restrict or object to processing, receive a portable copy, or withdraw consent.

You may also lodge a complaint with the data-protection authority that has jurisdiction where you live.

8. Children

Fennla is not intended for minors. You must be at least 18 years old to use it. We do not knowingly collect data from anyone under 18.

9. Changes

If this policy changes, we will update this page and its “Last updated” date. If a change affects the consent you gave, the bot will ask you again before further health-data processing.

10. Contact

Questions or requests about your data: fennla@proton.me