Privacy Policy

Last Updated: March 10, 2026

This Privacy Policy describes and governs the manner in which Future Artifact Labs Limited, a company incorporated in Hong Kong (“we”, “us”, “our” or the “Company”) collects, uses, maintains and discloses information about you when you visit our website and use our mobile application and other online services (the “Services”).

Please read this Privacy Policy carefully before you start to use the Services. By accessing and/or using the Services, you accept and agree to be bound by and abide by this Privacy Policy, and our terms of use available at https://doc.peakwatch.co/en/service/terms-of-use.html (the “Terms of Use”), which are incorporated herein by reference, and to comply with all applicable laws, rules and regulations (collectively, “Applicable Law”). If you do not want to agree to this Privacy Policy and the Terms of Use, you must not access or use the Services.

Personal Information

We may collect personal information from you in a variety of ways, including the following key categories and types of personal information:

Contact information: Name, username, email address and phone number, as well as any photographs or information you choose to include in your profile..
Health Information: See “Third-Party Health Information” below.
Information about your transaction: We will collect information about any transaction for which you use our Services, including general transaction details and timing.
Geolocation data: The general region or area from which you access our Services.
User-Generated Content: Photos of meals or food items that you upload, and text descriptions of your dietary intake that you input into the Services.
Conversations with PeakWatch AI (if enabled): As further described below.
Inferences: We may make inferences based on the information we collect.

Third-Party Health Information

With your permission, our Services connect to third-party applications and services (the “Third-Party Applications”), which may include Apple Health, laboratory and testing services and other providers for whom you offer us permission to connect our Services. We connect to these Third-Party Applications solely for the purpose of importing certain health information about you. Such health information may include the following: heart rate, sleep information, movement and exercise activity, blood oxygen levels, respiratory rate, height, age, and dietary data (including food types, estimated calorie intake, and macronutr. ient information derived from your photos or text inputs). The various health information you permit us to access in connection with the Services is collectively referred to as “Health Information.” See “Where Your Information Is Stored” below for information regarding where your Health Information is stored.

How We Collect Your Personal Information

We collect personal information from the following sources:

Directly. We collect personal information directly from you. When you register for the Services, submit information in an online form, request information from us, or otherwise communicate with us or our support personnel, you may provide us with information, for example, your name, email address, phone number.
Third-Party Import. We also collect Health Information about you by importing information from the Third-Party Applications (see above). Imported Health Information is generally stored and processed locally on your device, except where you opt in to features (such as PeakWatch AI) that require cloud processing.
By providing us with this information or allowing us access to the Third-Party Applications, you consent to your information being collected, used, disclosed, processed and stored by us in accordance with this Privacy Policy.

Where Your Information Is Stored

Note: Imported biometric Health Information you permit us to access from the Third-Party Applications (such as heart rate, sleep, blood oxygen, and respiratory rate) is, by default, stored and processed locally on your device. Unless you enable PeakWatch AI, we do not store or access such imported biometric Health Information in the ordinary course of providing the Services. When PeakWatch AI is enabled, such information is transmitted only as described in the “PeakWatch AI & Third-Party Artificial Intelligence Technology” section below.

If you enable the optional PeakWatch AI feature, certain biometric Health Information may be transmitted through third-party cloud hosting and artificial intelligence (“AI”) technology providers in order to generate AI-powered responses and guidance. Only the minimum relevant information necessary to generate a response will be transmitted.

PeakWatch AI does not access or process reproductive health information. If this were to change in the future, we would update this Privacy Policy and obtain your explicit consent before processing such data.

We store your non-health personal information on secure servers in Asia and may transfer your information to our service providers who may reside in other countries.

By using the Services or otherwise providing information to us, you understand and consent to having any personal information transferred to and processed in Asia or other regions. If you reside in the European Union (the “EU”), we will transfer your personal information pursuant to EU data protection laws. You understand that data protection and other relevant laws in other jurisdictions may not provide the same level of protections as the laws in your country. In certain circumstances, law enforcement or regulatory agencies, courts or security authorities in other jurisdictions may be entitled to access your personal information.

How We Use Collected Information

We may collect and use your personal information for the following purposes:

To provide the Services. We use your imported Health Information and user-provided dietary data for purposes of providing our Services, including analyzing food images to estimate nutritional content and tracking your caloric intake over time.
To perform analysis. In the ordinary course of providing the Services, your imported Health Information is processed locally on your device and is not analyzed or processed by us in the cloud. Analysis involving Health Information occurs only when you explicitly initiate optional features that require cloud-based processing, such as PeakWatch AI, and is limited to generating insights for you.
To provide and improve customer service. We use your contact information to answer your questions and respond to your requests and inquiries, notify you of changes to the Services and improve and maintain functionality of our Services.
For analytical purposes. We may also use your activity on our Services in an anonymized and aggregate way in order to improve our Services. We may also use your information to protect the Company, our Services and our website, and to prevent fraud, theft and misconduct.
Restrictions. We do not use Health Information for advertising or marketing purposes.
To support PeakWatch AI functionality. PeakWatch AI is an optional feature that you may choose to enable. If enabled, we may use conversations with PeakWatch AI to provide continuity, context, and user-requested functionality, subject to your ability to review and delete AI conversation memory within the app.

With service providers who do things on our behalf. For example, we will share information with vendors and contractors who conduct email marketing for us or who assist us with developing and providing the Services and customer support. Such service providers may reside outside Asia and in countries that may not provide the same level of protections as the laws in your jurisdiction. If you choose to enable PeakWatch AI, we may also share certain Health Information with third-party cloud hosting providers and AI technology providers (including large language model partners) solely to generate AI-powered responses and guidance. Except as described above, we do not share your Health Information with third parties. When shared, Health Information is limited to what is reasonably necessary to provide the feature or service, and, where possible, is anonymized or de-identified.
With partners for research and data purposes in connection with developing and improving the Services. We may share your information with third-party partners who help us in developing and improving the Services. Information shared for such purposes shall be anonymized and the third parties with whom we share it shall be subject to non-disclosure obligations.
With third parties as directed by you or to support transactions you engage in via the Services. We may share your information with third parties with your consent or as requested by you, or in connection with a transaction you engage in through the Services.
In accordance with applicable law. We may share your information with the appropriate authorities if we believe disclosure is in accordance with, or required by, any applicable law, including lawful requests by public authorities to meet national security or law enforcement requirements.
In connection with sale of the Company. In the event of a reorganization, merger, or sale we may transfer your personal information we collect to the relevant third party.

With your consent. We may disclose or share your information with your consent. We may obtain your consent in writing; online, through “click-through” agreements; when you accept the terms of use on our website; orally, either in person or on the phone; or by other means.
In a business transfer. We may disclose or share your information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, where such information could be transferred to third parties as a business asset in the transaction.
To non-affiliated third parties.  We may disclose or share your non-Health Information with certain non-affiliated third parties for a variety of business purposes, including to facilitate your access to and use of our Services. Such third parties may include, but are not limited to, internet service providers and other related professionals, operating systems and platforms, social media networks, and service providers who provide services on our behalf.
Notwithstanding the foregoing, we do not disclose or share Health Information with advertising networks, and Health Information is not used for advertising or marketing purposes. Health Information is only shared with third parties as expressly described in this Privacy Policy, such as when you explicitly initiate optional features that require third-party processing (for example, PeakWatch AI).

With your consent. We may disclose or share your information with your consent. We may obtain your consent in writing; online, through “click-through” agreements; when you accept the terms of use on our website; orally, either in person or on the phone; or by other means.
In a business transfer. We may disclose or share your information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, where such information could be transferred to third parties as a business asset in the transaction.
To non-affiliated third parties.  We may disclose or share your non-Health Information with certain non-affiliated third parties for a variety of business purposes, including to facilitate your access to and use of our Services. Such third parties may include, but are not limited to, internet service providers and other related professionals, operating systems and platforms, social media networks, and service providers who provide services on our behalf.
Notwithstanding the foregoing, we do not disclose or share Health Information with advertising networks, and Health Information is not used for advertising or marketing purposes. Health Information is only shared with third parties as expressly described in this Privacy Policy, such as when you explicitly initiate optional features that require third-party processing (for example, PeakWatch AI).
To subsidiaries and affiliates. We may disclose or share your information with our subsidiaries and affiliates to further facilitate your use of our websites and Services.
For legal process and protection. We may disclose or share your information to satisfy any law, regulation, legal process, governmental request, or where we have a good-faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
- Protect our rights or interests, property or safety or that of others;
- In connection with claims, disputes, or litigation— in court or elsewhere; and
- Protect users of our website and Services and other carriers or providers from fraudulent, abusive, or unlawful use of such Services.

PeakWatch AI & Third-Party Artificial Intelligence Technology

PeakWatch AI is an optional, generative AI feature that is initiated by you and intended to help you understand your health data and provide educational guidance.

When enabled, PeakWatch AI processes Health Information that you authorize us to access, including biometric information from Third-Party Applications. PeakWatch does not upload or store your Health Information on its own servers. In addition, PeakWatch does not access, collect, or process reproductive health information, and therefore no reproductive health data is used or transmitted for AI processing.

PeakWatch AI is an optional, generative AI feature that is initiated by you and intended to help you understand your health data and provide educational guidance.

To provide this feature, we leverage third-party cloud hosting providers and AI technology from our large language model partners. When you initiate an AI interaction, only the minimum Health Information relevant to your specific request is transmitted directly to third-party AI services for real-time processing, and solely for the purpose of generating responses and guidance.

PeakWatch does not store or retain Health Information transmitted for AI processing within its own systems or servers. Such Health Information is processed transiently as part of the AI interaction and is not retained by PeakWatch after a response is generated. Any processing performed by third-party AI or cloud service providers is subject to their respective privacy policies and data handling practices.

PeakWatch AI may maintain conversational memory derived from your interactions with the AI in order to improve continuity, context, and overall user experience. Such AI memory does not include raw Health Information obtained directly from Third-Party Applications. However, it may include health-related information that you voluntarily provide during conversations or that is generated as part of the AI’s responses or summaries based on those conversations.

AI memory may be dynamically created, updated, or deleted based on your interactions. You may review and delete AI conversation memory at any time directly within the PeakWatch app, without needing to contact us.

We take the following steps to protect your privacy:

We transmit only the minimum Health Information necessary to generate a response.
We transmit Health Information in a manner intended to minimize direct identifiability.
We do not use Health Information for advertising and marketing.

Please note that PeakWatch AI generates responses based on your inputs and available Health Information, and such responses may be inaccurate, incomplete, or inconsistent. PeakWatch AI does not provide medical or advice and should never be relied upon as a substitute for professional medical care, diagnosis, or treatment. You should always consult a qualified physician or other licensed healthcare provider with any questions regarding your health, medical conditions, or wellness decisions.

We Do Not Sell Your Personal Information

We do not sell or rent your personal information, and only share your personal data with certain trusted service providers and partners so that we can provide and improve our Services, to provide partner services and other offerings, and to operate our business.

Third-Party Links and Websites

Our Services may contain advertising, links or other content from the websites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties (collectively, the “Third-Party Services”). We do not control the content or links that appear on these Third-Party Services and are not responsible for the practices employed by such Third-Party Services. In addition, these Third-Party Services may have their own privacy policies and customer service policies. Browsing and interacting on any of these Third-Party Services are subject to such Third-Party Services’ own terms and policies.

Our Content on Third-Party Services

Our Services may be provided on or hosted on a third-party platform or otherwise make use of Third-Party Services. We do not control the content or links that appear on these Third-Party Services and are not responsible for the practices employed by such Third-Party Services. Your browsing and interacting on any of these Third-Party Services are subject to such Third-Party Services’ own terms and policies. Any visit you make to those other services is at your own risk. Such third parties’ use of any information you share is governed by the third party’s privacy policy. The Services may also use third-party service remarketing services to advertise to previous visitors to the Services on such Third-Party Services. Such third parties may use tracking technology (e.g., cookies) to serve ads to you based on your past activity on our Services and other websites and applications, subject to their own privacy policies.

Your California Rights

Note: The following only applies to residents of the United States. If you are a California resident, you have a Right to Know, Right to Delete, and a Right to Non-Discrimination, among other rights.

Your Choices

You have certain choices on how we treat your personal information, described below:

Modifications to Personal Information. You may review and request modifications to your personal information by editing your profile directly on our website or by contacting us at hi@PeakWatch.co. Please note that we will retain data for as long as it is reasonably necessary to fulfill the purpose for which it has been collected or as required or permitted by Applicable Law.
Right to Delete. If you are a California resident, you have a right to ask that we delete your personal information, subject to appropriate legal exceptions. You may request that we delete your personal information online. You may designate an authorized agent to submit a request on your behalf.
PeakWatch AI. You can choose whether or not to enable and interact with PeakWatch AI. We will only transmit certain Health Information to our third-party cloud hosting providers/large language model partners that power PeakWatch AI if you enable and engage with the feature. If you no longer wish to use PeakWatch AI, you can simply not interact with the feature, or you can disable the feature entirely from our mobile application by accessing the settings at any time. Please note, however, that any information you previously shared with PeakWatch AI may already have been transmitted to and stored within those third-party systems, and disabling the feature may not delete or retract that past information.
Tracking Technology. You may turn off part or all of our tracking software that has been placed on your computer by following the instructions on your browser. On a mobile device, you may turn off part or all of mobile tracking through your mobile device settings. However, if you prevent the use of tracking software or tracking through your mobile device, it will be more difficult, and may be impossible, for you to use the Service or portions of the Services.
Location and Analytics. If we use Third-Party Services to automatically collect your personal information, such Third-Party Services may offer you a choice to stop the automatic collection of your information. Please see our “How We Collect Your Personal Information” above with respect to our tracking tools.
Cookies. Most web browsers are set by default to accept cookies. You can usually set your browser to remove or reject cookies. Please note if you choose to reject, this could affect the availability and functionality of our Services.
Not Providing Personal Information. You may choose not to provide personal information to us. However, if you do not provide personal information, we may not be able to offer you all or part of our Services.
Right of Non-Discrimination. You have a right to exercise your rights under this section free of discrimination. We will not discriminate against you in any way if you choose to exercise your rights under this section.

Information Security

We use commercially reasonable security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. However, we cannot guarantee the complete safety of your information. It is your responsibility to keep your information confidential.

How Long We Keep Your Information

We retain, store and use your information for the least amount of time necessary to fulfill our relationship with you and to provide you access to our Services and in accordance with data retention policies and Applicable Law.

Our Services Are Not Intended For Children

Our Services are not directed to children under the age of 18. We do not knowingly collect information, including personal information, from children. If we obtain actual knowledge that we have collected such information from children, then we will promptly delete it. If you believe we have mistakenly collected such information from children, please contact us at hi@PeakWatch.co.

Information for European Economic Area Residents

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under applicable law regarding the processing of your personal information. The term “personal information” has the meaning given to it by the European General Data Protection Regulation (“GDPR”). When we process your personal information as described in this Privacy Policy, we will only do so when we have a legitimate interest in processing your personal information (for example, our legitimate interest in providing the Services, responding to your inquiries, or sending you marketing communications), when the processing is necessary for the performance of a contract between you and us, when the processing is necessary for us to comply with the law, or when you give us consent to process your personal information. You have the right to revoke your consent at any time. You also have the right to access personal information we hold about you and to ask that your personal information be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below. If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside.

For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (“CalOPPA”)

Our Service does not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Your California Privacy Rights

If you are a California resident, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes and to opt-out of sharing your personal information with such third parties. To make such a request, please send an email to hi@PeakWatch.co.

Usage and Deletion of Personal Information

You may request what personal information we have collected, used and disclosed about you as well as the identity of the third parties to which we have disclosed your personal information. You may also request deletion of your personal information. Please note that we may not delete all of your information if: (1) we need it to complete a service as requested by you or perform under a contract we have with you; (2) we need such information to repair any errors to our Services or detect data security violations; or (3) we need such information to protect against fraud or illegal activity or to comply with Applicable Law. Please note that if we delete your personal information, we may not be able to provide you the Services with the same functionality.

To make any request for personal information or deletion, please send an email to hi@PeakWatch.co.

Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region. Any disputes relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Hong Kong.

Changes to this Privacy Policy

We have the discretion to update this Privacy Policy at any time. We encourage you to frequently check this page for any changes. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Subject to Applicable Law, your continued use of our Services shall be deemed an acceptance of our revised policy.

You Can Contact Us

If you have any questions about this Privacy Policy, you can email us at hi@PeakWatch.co.