Privacy Policy
Effective Date: March 6, 2026 | Version 2.0
1. Introduction and Acceptance
This Privacy Policy ("Policy") describes how Shellel ("we", "us", "our") collects, uses, stores, shares, and otherwise processes personal data and information ("Data") in connection with your use of the Shellel mobile application and any related services (collectively, the "Service"). This Policy forms part of and should be read alongside our Terms of Service.
BY ACCESSING OR USING THE SERVICE IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND UNCONDITIONALLY CONSENT TO THE COLLECTION, PROCESSING, USE, DISCLOSURE, AND RETENTION OF YOUR DATA AS DESCRIBED IN THIS POLICY. If you do not agree, you must immediately discontinue use of the Service and delete your account.
We reserve the right to modify this Policy at any time. Your continued use of the Service after any modification constitutes your binding acceptance of the revised Policy. It is your sole responsibility to review this Policy periodically.
2. Data Fiduciary
Shellel operates as the Data Fiduciary in respect of your personal data as defined under the Digital Personal Data Protection Act, 2023 ("DPDP Act"). Our contact for data-related matters is support@shellel.com. Shellel processes Data on servers located within India in accordance with applicable data localisation requirements.
3. Data We Collect
3.1 Data You Provide
- Google Account Information: Your name, email address, and profile picture as provided by Google Sign-In upon authentication.
- Health & Nutrition Data: Dietary goals, food preferences, allergies, intolerances, health objectives, meal logs, and any other health-related information you choose to provide, which constitutes Sensitive Personal Data or Information ("SPDI") under the IT (SPDI) Rules, 2011.
- User-Generated Content: Any additional information, preferences, feedback, or content you voluntarily submit through the Service.
3.2 Data Collected Automatically
- Device identifiers, operating system version, application version, and device type
- IP address, approximate geolocation derived from IP, and network information
- Usage patterns, feature interactions, session duration, navigation paths, and in-app behaviour
- Crash logs, diagnostic data, and performance metrics
The categories of automatically collected data may expand as the Service evolves. By continuing to use the Service, you consent to collection of any additional categories of data reasonably necessary for the operation and improvement of the Service, provided we update this Policy accordingly.
3.3 Data from Third Parties
We may receive Data about you from third-party sources including Google (via Sign-In), analytics providers, crash reporting tools, and other service partners. Such third-party data may be combined with data we collect directly from you.
4. How We Use Your Data
- Providing, operating, maintaining, and improving the Service and its features
- Generating AI-powered personalised nutrition recommendations and meal plans
- Developing, training, testing, and enhancing our AI models and algorithms using aggregated and anonymised data
- Analysing usage trends, user behaviour, and Service performance
- Communicating with you regarding your account, service updates, and policy changes
- Enforcing our Terms of Service, preventing fraud, abuse, and illegal activity
- Complying with applicable legal obligations under Indian law
We expressly reserve the right to use anonymised, aggregated, or de-identified data derived from your use of the Service for any purpose, including commercial purposes, without restriction and without compensation to you. Such de-identified data is not subject to this Policy.
5. Disclosure of Data to Third Parties
5.1 Service Providers
- Google LLC: Authentication services via Google Sign-In. Your use of Google Sign-In is additionally governed by Google's Privacy Policy.
- OpenAI: We transmit relevant contextual data including your dietary goals, preferences, and meal information to OpenAI's API to generate nutrition recommendations. We do not transmit your name, email, or Google account identifiers to OpenAI. OpenAI's processing is governed by OpenAI's Privacy Policy.
- MongoDB Atlas: Your data is stored on MongoDB Atlas infrastructure with encryption at rest and in transit.
- Analytics and Diagnostics Providers: We may use third-party analytics, crash reporting, and performance monitoring tools that collect and process usage data on our behalf.
5.2 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of assets, your Data may be transferred to the acquiring entity. You consent to such transfer. We will notify you of any such change via the Service or by email.
5.3 Legal and Regulatory Disclosure
We may disclose your Data without notice to the extent required or permitted by applicable law, including in response to court orders, lawful requests by government or regulatory authorities, and requirements under the IT Act 2000, DPDP Act 2023, or any other applicable Indian law.
5.4 No Sale of Personal Data
Shellel does not sell your identifiable personal data to third parties for monetary consideration. However, we may share anonymised, aggregated, or de-identified data with third parties without restriction.
6. Third-Party Services — Limitation of Liability
THE SERVICE IS DEPENDENT ON THIRD-PARTY INFRASTRUCTURE, PLATFORMS, AND APIs THAT ARE OUTSIDE SHELLEL'S OWNERSHIP, OPERATION, OR CONTROL. Shellel makes no representation or warranty regarding the security, availability, accuracy, or privacy practices of any third-party service. Shellel accepts no liability for:
- Any data breach, unauthorised access, loss, corruption, or unavailability of your Data arising from third-party service providers
- Any change in the data practices, terms, or privacy policies of third-party providers
- Any processing of your Data undertaken by third parties beyond the scope of Shellel's instruction
- Any disruption to the Service caused by the unavailability or failure of third-party infrastructure
7. Data Security
Shellel implements and maintains reasonable technical and organisational security measures designed to protect your Data, including encrypted database connections and encryption at rest and in transit.
However, no data transmission over the internet and no storage system is guaranteed to be 100% secure. You acknowledge that you transmit your Data to the Service at your own risk. You are responsible for maintaining the security of your Google account credentials.
8. Data Retention
We retain your Data for as long as your account remains active and for such further period as may be necessary to:
- Comply with applicable legal obligations under Indian legislation
- Resolve disputes, enforce our Terms of Service, or protect Shellel's legal interests
- Prevent abuse of free account features
Upon deletion of your account, your identifiable personal data will be scheduled for deletion within 30 days. Anonymised or aggregated data may be retained indefinitely. Backup systems may retain data for up to 90 days following scheduled deletion due to standard backup rotation cycles.
Free accounts inactive for 12 consecutive months may be deleted following the notice procedure set out in the Terms of Service. Paid accounts will not be deleted for inactivity while an active subscription is in force.
9. Children's Privacy
The Service is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided personal data to us, please contact us at support@shellel.com and we will take reasonable steps to delete such data.
Users between 13 and 17 years of age may only use the Service with verifiable parental or legal guardian consent as required under the DPDP Act, 2023. The parent or guardian assumes full responsibility for the minor's use.
10. Your Rights Under Applicable Law
Subject to the provisions of the DPDP Act, 2023 and other applicable Indian law, you have the following rights:
- Right to Access: You may request a summary of the personal data we hold about you and the purposes for which it is processed.
- Right to Correction: You may request correction of inaccurate or incomplete personal data. Correction of data within third-party platforms (such as Google) must be addressed directly with those providers.
- Right to Erasure: You may request deletion of your personal data by visiting the account deletion page or contacting support@shellel.com. Erasure is subject to our retention obligations described in Section 8.
- Right to Grievance Redressal: You may raise a grievance with our designated Grievance Officer at support@shellel.com. We will acknowledge within 48 hours and endeavour to resolve within 30 days.
- Right to Withdraw Consent: You may withdraw your consent to processing at any time by deleting your account. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
- Right to Nominate: In accordance with the DPDP Act, 2023, you may nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity.
- Revoke Google Access: You can revoke Shellel's access to your Google account through your Google Account settings.
11. Consent and Legal Basis for Processing
By registering for and using the Service, you provide free, specific, informed, and unambiguous consent to the processing of your personal data, including Sensitive Personal Data, for the purposes described in this Policy, as required under the DPDP Act, 2023 and the IT (SPDI) Rules, 2011.
Where we process your data on the basis of consent, you may withdraw that consent at any time. However, withdrawal of consent will result in your inability to use the Service.
12. Cookies, Tracking, and Analytics
The Service may use cookies, local storage, device identifiers, and similar tracking technologies to enhance your experience, maintain session state, and collect usage analytics. By using the Service, you consent to the use of such technologies. You may disable cookies through your device or browser settings, but doing so may impair the functionality of the Service.
13. Cross-Border Data Transfers
While Shellel stores your primary personal data on servers within India, the operation of the Service requires transmission of certain data to third-party service providers whose infrastructure may be located outside India, including OpenAI (United States). By using the Service, you acknowledge and consent to the transfer of data to OpenAI's infrastructure outside India solely for the purpose of generating your nutrition recommendations.
14. Changes to This Policy
Shellel reserves the right to amend this Policy at any time. Changes will be effective from the date they are posted with an updated effective date. Your continued use of the Service after any change constitutes your unconditional acceptance of the revised Policy. Where changes are material, we will make reasonable efforts to notify you via the app or email.
15. Governing Law
This Policy and all matters arising from it are governed by the laws of India, including the Information Technology Act, 2000, the IT (SPDI) Rules, 2011, and the Digital Personal Data Protection Act, 2023. Any dispute arising out of this Policy shall be subject to the dispute resolution mechanism set out in the Terms of Service.
16. Contact and Grievance Officer
For any questions, concerns, or requests relating to this Policy or the processing of your personal data:
Shellel — Privacy and Data Grievances
Email: support@shellel.com
Website: https://shellel.com
Grievance Officer: support@shellel.com
By using Shellel, you confirm that you have read, understood, and consented to this Privacy Policy in its entirety.