Privacy Policy

1. Introduction

This policy applies to your use of the Pallas website. We may update it from time to time; if we make material changes, we'll notify you and update the date at the top of this page.

2. Who we are

Pallas is operated by Ketopallas LTD ("Pallas", "we", "us"), a company registered in England and Wales (company number 17489071), with its registered office at 4th Floor Office, 205 Regent Street, London, England, W1B 4HB, contactable at hello@ketopallas.com. We are the data controller responsible for your personal data.

3. Personal data we collect from you

• Account information: your email address and password (stored as a secure hash, never in plain text) when you create an account.
• Health data: blood glucose and ketone readings, body composition readings (weight, BMI, body fat), and menstrual cycle tracking data. This is a special category of personal data under GDPR, and we only process it with your explicit consent. We treat menstrual cycle data with particular care given its sensitivity; it is never used for any purpose beyond the tracking and insight features you actively use, and is never shared with third parties for their own purposes.
• Data you import: readings you choose to bring in from a CSV export of your meter or scale.
• AI feature inputs: if you use a feature powered by artificial intelligence, such as our weekly menu generator, certain inputs — your macro targets, ingredient list, meal preferences, and language — are sent to our AI provider, Google (Gemini), to generate the output. We do not send your blood glucose, ketone, body composition, or cycle data to this provider.
• Usage information: basic technical and session information needed to operate the website and keep it secure, such as log-in timestamps and session identifiers.
• Analytics and session data: if you consent via our cookie banner, usage analytics and session replay (a recording of your on-screen interactions, such as taps and page views) collected through our analytics provider, PostHog. This is only collected with your consent, which you can withdraw at any time by changing your cookie preferences.
• Payment and billing information: if you subscribe to a paid feature, your billing address and your card's issuing country — collected by our payment processor, Stripe, at checkout. We never see or store your full card details ourselves. We also log the IP address used at checkout, to help verify the correct country for tax purposes.

4. How we use your data

• To provide core features: we use your health readings to calculate insights such as GKI and show them to you. Legal basis: your explicit consent.
• To generate AI-assisted content: we send the inputs described in Section 3 to our AI provider to generate content such as recipes, and store the result in your account so you can view and use it. Legal basis: performance of a contract.
• To manage your account: we use your email and password to create, secure, and authenticate your account. Legal basis: performance of a contract.
• To keep the Services secure: we monitor for misuse and technical issues using the usage information described in Section 3. Legal basis: legitimate interest — specifically, our interest in preventing fraud, abuse, and service disruption, balanced against your right to privacy.
• To communicate with you: we send account-related emails, such as email verification and password resets. Legal basis: performance of a contract.

We do not sell your data, and we do not use your health data for advertising, employment decisions, insurance eligibility assessments, or any purpose beyond providing the Services to you.

5. Your privacy rights

• Access: request a copy of the personal data we hold about you.
• Rectification: ask us to correct inaccurate or incomplete data.
• Erasure: ask us to delete your data — you can also delete your account at any time.
• Restriction: ask us to limit how we use your data in certain circumstances.
• Portability: receive your data in a structured, commonly used format, or have it transferred to another service.
• Objection: object to processing based on legitimate interest.
• Withdraw consent: withdraw consent for the processing of your health data at any time, without affecting processing carried out before withdrawal.

To exercise any of these rights, contact us at hello@ketopallas.com. We will respond within 30 days of receiving your request.

If you're not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.

6. Who we share your data with

We share data only with the service providers that help us run Pallas — such as our email delivery, database hosting, and (where you've consented) analytics providers — under agreements that require them to protect your data and prohibit them from using it for their own purposes. Our payment processor is Stripe, which handles billing for paid features. Our analytics and session-replay provider is PostHog. Our AI feature provider is Google, which powers AI-assisted features such as our weekly menu generator through its Gemini model. We do not sell your data, and we do not share it with advertisers or data brokers. A list of our current service providers is available on request at hello@ketopallas.com.

7. Retention of your data

We keep your data for as long as your account is active. If you delete your account, we delete or anonymize your personal data within 30 days, including data held in backup systems, which may take slightly longer to fully clear. We may retain limited data beyond this where required by law, such as for legal claims or compliance obligations. Where we retain anonymized or aggregated data (which can no longer identify you) for product improvement purposes, this is not personal data and is not subject to these retention limits.

Where you make a payment, we are legally required to retain your billing country, your card's issuing country, and records of the transaction for 10 years to meet UK and EU VAT obligations. Legal basis: legal obligation — this retention applies regardless of whether you delete your account, and does not depend on your consent.

Our AI provider, Google, separately retains the inputs and outputs of AI-assisted features (such as our weekly menu generator) for up to 55 days to detect and prevent misuse, regardless of when you delete your account. This data does not include your name, email, or other identifiers, and cannot be linked back to a specific deleted account.

8. Security of your data

We use technical and organizational measures to protect your data, including encrypting data in transit and at rest, hashing passwords, and restricting access to what's needed to operate the Service.

If a data breach affecting your personal data occurs, we will notify the relevant supervisory authority and/or affected users as required by law.

9. Children's privacy

You must be at least 18 years old to use Pallas. We do not knowingly collect personal data from anyone under this age, and our sign-up process requires confirmation of age.

10. Communication with you

We may email you about your account, such as verification and password reset messages — these are necessary to provide the Service. If we ever send optional updates about Pallas, you'll be able to unsubscribe at any time.

11. Cookies and analytics

We use strictly necessary cookies on our website, required for it to function — such as remembering your session and login state. These do not require your consent under the ePrivacy Directive.

With your consent, given via the cookie banner shown on your first visit, we also use PostHog, a product analytics and session-replay tool, to understand how Pallas is used and to improve it. PostHog may set cookies and record on-screen interactions such as taps, clicks, and page views; by default, the text you type into input fields is masked in these recordings and is not visible in session replay. No analytics or session-replay data is collected until you accept; if you decline or later withdraw consent, this collection stops. PostHog processes this data on servers located in the European Union.

12. International data transfers

If your data is transferred outside the European Economic Area (EEA) or UK, we ensure it remains protected through appropriate safeguards, such as Standard Contractual Clauses or an adequacy decision. A list of the countries your data may be transferred to, and the safeguard used in each case, is available on request at hello@ketopallas.com.

13. Automated processing

Pallas calculates metrics such as GKI directly from the data you provide, using fixed, transparent formulas. This does not involve automated decision-making that produces legal or similarly significant effects on you, and no decision about you is made without the ability for you to review the underlying data yourself.

Some features, such as our weekly menu generator, use a third-party AI model (currently Google's Gemini) to generate content like recipes based on inputs you provide. This content is a suggestion only, may contain errors, and does not involve automated decision-making that produces legal or similarly significant effects on you.

14. Changes to this policy

We may update this policy from time to time. If we make material changes, we'll notify you and update the date at the top of this page.

15. Contact us

Questions about this policy? Reach out at hello@ketopallas.com.