Legal

Privacy Policy

Effective from: 2026-11-02
Last updated: 2026-11-02

Who we are

This Privacy Policy describes how MACKRO LTD ("Mackro", "we", "us", "our") collects, uses, and shares personal data when you use the Mackro mobile app (iOS and Android) and the website at mackro.co.uk (together, the "Service").

MACKRO LTD is a private company limited by shares registered in England and Wales under company number 17243600, with its registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. We are registered with the UK Information Commissioner's Office (ICO) under registration number ZC256962.

We are the data controller for personal data processed in connection with the Service.

If you have any questions about this Privacy Policy or your personal data, contact us at privacy@mackro.co.uk.

In short

What data we collect

We collect data in three ways: data you give us, data generated as you use the Service, and data we receive from third parties (limited).

Data you give us

Account data

Profile and onboarding data (clients)

Logged food data

Activity from Apple Health or Health Connect (optional)

Messages

Payment data (limited)

Coaching plans and payment records

Coaching leads (coaches)

Support data and reports

Launch mailing list (website)

Data generated as you use the Service

Usage analytics

Error, crash and performance reports

Network and device metadata

Cookies and similar technologies

Data we receive from third parties

We do not buy data from data brokers. We do not enrich your profile from third-party sources.

How we use your data (lawful basis under UK GDPR)

What we doCreate and maintain your accountWhy we do itTo provide you with the Service you signed up forLawful basisContract
What we doSend you service emails when the Service requires it (e.g. password-reset emails, billing receipts, and other account-related notices).Why we do itTo run the ServiceLawful basisContract
What we doProcess your food logs, photos and macrosWhy we do itTo provide the core feature of the ServiceLawful basisContract
What we doShare your logged data with your linked coach (clients)Why we do itRequired for the core coach-client feature; you opt in by linking a coachLawful basisContract + consent
What we doProcess paymentsWhy we do itTo collect subscription feesLawful basisContract
What we doKeep a coach's plans and payment records for their clients, and remind clients when a payment is dueWhy we do itSo the coach and the client can both see what is owed and what has been paid (Mackro does not handle the money)Lawful basisContract
What we doStore the leads a coach addsWhy we do itSo coaches can manage enquiries from prospective clients and invite them to MackroLawful basisLegitimate interests (helping coaches run their coaching business; we never contact leads or use their details for anything else)
What we doDetect and prevent fraud, abuse, and security incidentsWhy we do itTo protect the Service and our usersLawful basisLegitimate interests
What we doReview reports of messages and AI coach repliesWhy we do itTo act on offensive or harmful content and improve the AI coach's safeguardsLawful basisLegitimate interests
What we doDiagnose crashes, errors and slow performance (Sentry), linked to your account IDWhy we do itTo keep the app working and fix problems for the people they affectLawful basisLegitimate interests
What we doSend what an AI feature needs to Google Gemini when you use itWhy we do itTo provide the AI features (logging, chat, recipes, plans, meal ideas, and your coach's AI tools)Lawful basisExplicit consent, which you give in the app before the first AI use and can withdraw in Settings (UK GDPR Articles 6(1)(a) and 9(2)(a))
What we doRead steps, active energy and exercise minutes from Apple Health / Health ConnectWhy we do itTo show your activity, and your coach if you have oneLawful basisExplicit consent, which you give when you connect it (UK GDPR Articles 6(1)(a) and 9(2)(a))
What we doImprove the Service via aggregated analyticsWhy we do itTo understand how the Service is used and prioritise improvementsLawful basisLegitimate interests
What we doComply with legal obligations (e.g., tax record-keeping, responding to lawful requests)Why we do itTo meet our legal dutiesLawful basisLegal obligation
What we doSend marketing emailsWhy we do itTo tell you about new features (only if you opted in)Lawful basisConsent
What we doKeep the launch mailing list and email the people on itWhy we do itTo tell you when Mackro launches and, if you signed up on the page for coaches, to contact you about setting up your coaching accountLawful basisConsent, which you give by submitting the form

You can withdraw consent at any time for marketing emails by clicking unsubscribe at the bottom of any marketing email. Withdrawing consent does not affect the lawfulness of processing before withdrawal.

How coaches and clients share data

This is the core of how Mackro works, so it deserves its own section.

When a client uses an invite code to link to a coach, the client consents to share with that coach:

Some of this is health-related data. Where you link with a coach, we process it on the basis of your explicit consent (UK GDPR Article 9(2)(a)), which you give in the app at the moment you link. You can withdraw it at any time by unlinking your coach.

The coach sees this data through the Mackro platform. From the coach dashboard they can also download it: a full export of one client's records (food, weight and body logs, notes, goals and workouts), and summary spreadsheets of their client list (name, email, recent logging, weight trend and attention flags). Our Terms and Acceptable Use Policy require coaches to keep what they download confidential and not to share it with anyone outside the platform without your explicit consent.

A client can unlink from a coach at any time. Once unlinked:

If a coach blocks or removes a client, the same applies in reverse — the client retains their own data but loses access to that coach.

We are the data controller for client data throughout this flow. Coaches use the data through us and within the bounds of these terms; they are not separate data controllers, and they may use the data, including anything they download, only to coach you.

How we use AI (Google Gemini)

Mackro's AI features run on Google's Gemini models (currently Gemini 3.5 Flash, falling back to Flash-Lite when it is busy), through Google's paid Gemini API. They are optional, and the app asks your permission, naming Google Gemini and the data below, before any of your data is sent. You can turn AI features off at any time in Settings → AI features.

When you use a feature, we send Google what that feature needs:

We never send your email address or account ID. Data from Apple Health or Health Connect is never sent to Gemini.

Important things to know:

You can use Mackro without AI. Every food can be logged manually, and turning AI off or saying “Not now” changes nothing else.

Subprocessors (third parties we use)

We rely on a small set of trusted third parties to run the Service. Each is bound by a data processing agreement that requires them to handle your data only on our instructions and to apply appropriate security.

SubprocessorSupabasePurposeDatabase and file storageData sharedAll account, profile, log, message and photo dataLocationEU (Frankfurt, Germany)
SubprocessorRenderPurposeHosting for the Mackro API, the servers the app and coach dashboard talk toData sharedAll app data, while it is being processedLocationEU (Frankfurt, Germany)
SubprocessorGoogle Gemini APIPurposeAI features (photo and text logging, chat, recipes, plans, meal ideas, coach AI tools), only after you allow themData sharedWhat you give a feature, plus the profile and log details it needs (see How we use AI). Never your email address or account IDLocationGoogle global
SubprocessorStripePurposePayment processing for coach plansData sharedBilling email, name, payment card (held by Stripe, not us)LocationUK + US
SubprocessorApple App Store / Google PlayPurposeIn-app purchases for PremiumData sharedApple ID / Google Account email, paymentLocationApple/Google global
SubprocessorRevenueCatPurposePremium subscription and entitlement managementData sharedYour Mackro account ID, purchase and entitlement statusLocationUS
SubprocessorExpoPurposePush notifications (passed on to Apple or Google for delivery, below) and app updatesData sharedDevice push token and notification content; device and network details when the app checks for updatesLocationUS
SubprocessorApple Push Notification service (Apple)PurposeDelivers push notifications to iPhones, passed on by ExpoData sharedDevice push token and the notification content, such as a new coach message (the sender's name and the start of the message)LocationApple global
SubprocessorFirebase Cloud Messaging (Google)PurposeDelivers push notifications to Android phones, passed on by ExpoData sharedDevice push token and the notification content, such as a new coach message (the sender's name and the start of the message)LocationGoogle global
SubprocessorSentryPurposeError, crash and performance monitoringData sharedYour Mackro account ID (a pseudonymous number) with crash, error and performance reports. No names, email addresses or food logsLocationEU (Frankfurt)
SubprocessorPostHogPurposeProduct analyticsData sharedYour Mackro account ID, plan, and feature-usage eventsLocationEU (Frankfurt)
SubprocessorResendPurposeTransactional emailsData sharedEmail address, message contentLocationUS
SubprocessorZohoPurposeEmail for our support@ and privacy@ mailboxesData sharedEmails you send us and our repliesLocationEU
SubprocessorVercelPurposeHosting for mackro.co.uk and the coach dashboard (coach.mackro.co.uk)Data sharedSite visit metadata; for the coach dashboard, the coach's session and the client data shown to themLocationUS
SubprocessorFasthostsPurposeDNS for mackro.co.ukData sharedStandard DNS lookup metadata only (no personal data processed)LocationUK

A current version of this list is also available at mackro.co.uk/subprocessors. We will update this list when subprocessors change.

We will give you reasonable notice (typically 30 days) before adding a new subprocessor that materially changes how we process your data.

International transfers

Some of our subprocessors are based outside the UK or process data in the United States or other regions. When personal data leaves the UK we ensure an appropriate transfer mechanism is in place, such as:

Copies of the relevant agreements are available on request from privacy@mackro.co.uk.

How long we keep your data

Data typeAccount data while account is activeRetention periodFor the lifetime of the account
Data typeAccount data after deletion requestRetention periodPermanently deleted within 30 days (see Account deletion below)
Data typeLogged food, photos, messagesRetention periodFor the lifetime of the account; deleted with the account
Data typePayment records (Stripe-side, RevenueCat-side)Retention periodPer Stripe / Apple / Google retention; we hold only the customer ID
Data typeCoaching plans and payment recordsRetention periodUntil the coach deletes them, or until the coach's or the client's account is deleted
Data typeCoaching leadsRetention periodUntil the coach deletes the lead, or until the coach's account is deleted (or, for a lead who became a client, that client's account)
Data typeReports you make (of a message or an AI coach reply)Retention periodFor the lifetime of the account; deleted with the account
Data typeTax records (invoices, VAT records once registered)Retention period6 years from end of accounting period (UK statutory)
Data typeSentry crash, error and performance reportsRetention period90 days
Data typePostHog analytics eventsRetention period12 months
Data typeServer access logs (with IP)Retention period30 days
Data typeSupport correspondenceRetention period24 months
Data typeMarketing email contact (if opted in)Retention periodUntil you unsubscribe
Data typeLaunch mailing list entry (email, form used, sign-up time, IP address)Retention periodUntil you ask us to delete it. Unsubscribing stops the emails at once; we keep a note that the address unsubscribed so it is not emailed again

If you ask us to delete your account before the retention periods above expire, we will delete the data on the schedule described in Account deletion below.

Account deletion

You can delete your account from inside the app at any time:

Mobile app: Profile → Settings & account → Delete account. You can also start it on the web at mackro.co.uk/delete-account.

When you request deletion:

  1. Your account is immediately marked for deletion and you are signed out on every device. Your progress photos are deleted straight away. If you signed in with Apple, we revoke Mackro's access to your Apple ID. If you are a coach paying for a plan by card, it stops renewing.
  2. There is a 30-day grace period, to protect against accidental or coerced deletion requests. During it you can cancel the deletion by signing back in and choosing to keep your account, or by emailing privacy@mackro.co.uk.
  3. After 30 days, your account, all logged data, all photos, and all messages are permanently deleted from our production systems.
  4. Backups containing your data are rotated within a further 60 days. After this period, no copy of your data exists in our systems.

We retain only:

If you delete your account as a coach, your linked clients are notified and they can choose to either (a) link to a new coach using a new invite code, or (b) continue with a standalone account.

If you delete your account as a client, your linked coach loses access to all your data. Any messages you sent to the coach are deleted from the coach's view as well.

Your rights under UK GDPR

You have the following rights:

To exercise any of these rights, email privacy@mackro.co.uk. We will respond within one calendar month. We may ask you to verify your identity before acting on the request.

If you are not satisfied with our response, you can complain to the UK Information Commissioner's Office at ico.org.uk or by phone on 0303 123 1113.

Security

We take security seriously. The measures we use include:

No system is completely secure. If we ever detect a personal data breach that is likely to result in risk to your rights, we will notify the ICO within 72 hours and notify affected users without undue delay.

Children

The Service is intended for users aged 16 and over. We do not knowingly collect personal data from anyone under 16. If we become aware that we have collected personal data from someone under 16, we will delete it promptly. If you believe we may have collected such data, contact privacy@mackro.co.uk.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the most recent change. If we make material changes (for example, adding a significant new use of your data, or adding a subprocessor that materially changes how we process your data), we will notify you in advance — typically 30 days — by email or through an in-app notice.

The latest version is always available at mackro.co.uk/privacy.

Contact us

For privacy questions, data subject requests, or to report a concern:

Email: privacy@mackro.co.uk
Post: Privacy, MACKRO LTD, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

For complaints, you can also contact the UK Information Commissioner's Office:

Web: ico.org.uk
Phone: 0303 123 1113