Privacy.

1. Who We Are

NutraSafe is a product of NutraSafe Nutrition Ltd, a company registered in England and Wales (company number 16813697, registered office 52 Tarvin Road, Chester, United Kingdom, CH3 5DZ). Founded and led by Aaron Keen. "NutraSafe", "we", "us" and "our" mean NutraSafe Nutrition Ltd.

Contact: contact@nutrasafe.co.uk

3. Data We Collect

Provided by you

• Account details: email (required for login).
• App content: food logs, reactions, allergens, expiry-tracking entries, and optional photos.
• Health and fitness data: nutrition goals, weight, height, age, gender, workout activity (if you use the AI Coach feature).
• Apple Health (optional): if you connect Apple Health, we read your workouts, activity summary, steps, active energy, resting energy, heart rate, walking and running distance and body weight, and we write back the foods you log as dietary entries, plus workouts, body weight, active energy, distance and heart rate recorded in the app. Values we import, such as a weight or a workout, become part of your NutraSafe data and sync to your account like anything else you log. If you use the AI Coach, the weigh-ins, water, daily step totals and daily energy totals (resting and active) we take from Apple Health are part of what it reads (see Section 7a). We do not send any other Apple Health data to Google Gemini, and none to the search service. You can disconnect Apple Health at any time in the iOS Health app or Settings.
• AI Coach conversations: messages you send to the AI Coach (if you use this feature).
• Support messages you send to us.

Automatically collected

• Device and app information (e.g., IP address, device model, OS version, app version).
• Notification token (if you enable push notifications).
• In-app searches and barcode scans: the words you type into food search and the barcodes you scan, together with whether we found a match, which result you picked, and whether you gave up and created the food yourself. These are recorded against your account so we can find and fix gaps in our food database. We use them to improve search results and to decide which foods to add next. The raw records are deleted after 30 days (see Section 8).

Passwords are handled securely by Firebase Auth and are never visible to us.

Website visit counts. On our website we count anonymous page visits to understand how many people reach each page. This uses no cookies and stores no personal data: your IP address is turned into a one-way daily code on our server and is never stored, so visits cannot be linked back to you or across days. We record only the page visited and the site that referred you. This is separate from Google Analytics, which runs only after you accept the cookie banner.

4. How We Use Your Data

• To provide and personalise your NutraSafe account.
• To sync, back up, and display your entries.
• To provide AI-powered coaching (see Section 7a below for full details).
• To troubleshoot, secure, and improve the service.
• To reply to support requests.
• To work out, in aggregate across all users, which foods are missing from our database and where search is failing, so we can fix both (see Section 5).

We do not use your data for advertising or profiling.

5. Access and Storage

Your data is stored with Google Firebase (Google LLC), which encrypts all data in transit (TLS) and at rest (AES-256).

As the data controller, NutraSafe Nutrition Ltd (acting through its founder Aaron Keen and any authorised staff) may technically access user data through the Firebase Console solely for:

• Bug investigation
• User support
• Maintaining database integrity and security
• Producing aggregate statistics that describe how the app is used as a whole

Aggregate statistics never single you out. Before any such analysis your account identifier is replaced with a one-way code, results are only ever reported as totals and averages across many people, and no individual record appears in them. Typical examples are which meal of the day is logged most often, how many foods are missing from our database, and how often a search returns nothing.

We do not use your data for advertising, profiling, or building a picture of you as an individual.

6. Legal Basis (UK GDPR)

• Contract (Art. 6(1)(b)) to deliver the app and its features.
• Legitimate Interest (Art. 6(1)(f)) to maintain reliability and security, and to produce the aggregate, non-identifying statistics described in Section 5 so we can improve the food database and the app. You can object to this at any time using the contact details in Section 13.
• Consent (Art. 6(1)(a)) for optional features such as notifications, camera access, AI Coach data sharing with Google Gemini, and the photo scanning features described in Section 7a, which send a photo to Google Gemini only when you take or choose one for them.

7. Data Sharing and Transfers

Data is shared only with:

• Google Firebase (hosting, authentication, storage).
• Google Gemini (third-party AI service for AI coaching, see Section 7a).
• Meilisearch, hosted for us on Fly.io (Fly.io, Inc., United States), the search service that powers food search in the app. Food records are copied to this service so they can be searched quickly. When you search, the app sends the words you type, or the barcode you scanned, directly to that service, and like any internet request that carries your device's IP address. When you create your own food, its copy carries the account identifier that marks it as yours, which is what keeps your personal and restaurant foods visible only to you. No email address, name, diary, or health data is sent.
• Authorities or law enforcement if legally required.

Where data is processed outside the UK/EU, Firebase relies on Standard Contractual Clauses. Fly.io stores and processes data in the United States and is certified under the EU-U.S. Data Privacy Framework and its UK Extension (see Fly.io's privacy statement).

We never sell, rent, or trade data.

7a. AI Coach and Photo Scanning, Third-Party AI Data Sharing

NutraSafe includes an optional AI Coach feature powered by Google Gemini, a third-party AI service provided by Google LLC. This feature is entirely opt-in, you must give explicit consent before any data is shared.

Photos you scan

Three optional features send a photo to Google Gemini so it can be read: the AI meal scan (a photo of your plate), the pack scanner (photos of a product's label, ingredients list or nutrition table) and recipe import from a photo. The photo is sent for that one request, to produce the result you asked for, and nothing is sent unless you take or choose a photo for one of these features. Text you type or dictate into recipe import is sent the same way. Google does not use this data to train its models.

What data is sent to Google Gemini

• Your nutrition goals and progress
• Your food diary: foods, amounts, nutrients and additives
• Weigh-ins and water, including any from Apple Health
• Daily step totals and daily energy burned (resting and active) from Apple Health
• Workouts, fasts and reactions you log
• Basic profile information (height, weight, age, sex, activity, and your first name if you have set one)
• Photos you attach in a coaching conversation
• Your coaching conversation messages

What we never send to Google Gemini

• Your name or email address
• Photos, other than the ones you take or choose for the scanning features above or attach in the coach
• Apple Health data other than weigh-ins, water, and daily step and energy totals
• Payment or financial information

How your data is protected

• Data is processed by Google Gemini in real-time only to generate coaching responses.
• Your data is not used by Google for AI model training.
• All data is encrypted in transit (TLS).
• Google LLC provides equivalent data protection as described in their Privacy Policy and Gemini API Terms of Service.

Your consent and control

• Before using the AI Coach, you are asked to review what data will be shared and give explicit consent.
• You can revoke AI data sharing consent at any time in Settings → Data & Privacy.
• Revoking consent immediately stops all data sharing with Google Gemini.
• You can continue using all other NutraSafe features without the AI Coach.

8. Retention Periods

• Active accounts: data retained while the account remains active.
• Deleted accounts: data removed or anonymised within 30 days; backups purged within 90 days.
• Support emails: kept up to 24 months for audit and dispute resolution.
• Raw search and scan logs: deleted after 30 days. Only aggregate totals (how often a search returned nothing, which foods are missing) are kept beyond that.

9. Your Rights

Under UK GDPR you can request to:

• Access your personal data
• Correct inaccurate information
• Delete your data ("Right to be Forgotten")
• Restrict or object to processing
• Receive a portable copy of your data

Contact contact@nutrasafe.co.uk to exercise these rights.

You may also contact the Information Commissioner's Office (ICO) at ico.org.uk.

10. Security

We use industry-standard security controls (encryption, access restrictions, monitoring). No system is 100% secure; please keep your device updated and use a strong password.

11. Children

NutraSafe is not intended for use by anyone under 16. If we learn we hold data for a child under 16 without consent, we will delete it promptly.

12. Changes to This Policy

We may update this policy periodically. Updates will be posted in-app and on our website with a new effective date. Material changes will be clearly communicated before they take effect.