Legal · VitalDiet for iOS

Privacy Policy

1. Who we are

The VitalDiet mobile application (the “App”) is provided by:

Where this policy refers to “we”, “us” or “Vitalverse”, it means the business named above. To the extent we process any personal data (see sections 4.8 and 4.10), we act as the data controller within the meaning of the EU General Data Protection Regulation 2016/679 (“GDPR”). We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 GDPR. For any privacy matter, please write to [email protected].

2. Scope of this policy

This policy explains what happens to information when you use the App on iPhone, what (very limited) information may leave your device, who receives it and what rights you have. It applies to users worldwide, including users in the European Economic Area (EEA), the United Kingdom and the United States. It does not cover the websites or services of third parties you reach from the App (for example Open Food Facts, Apple or an AI provider); their own privacy policies apply to them.

3. Our core principle: your data stays on your device

VitalDiet is designed as an on-device app. It does not require registration, does not create a user account and does not send your diary or health information to any server operated by us. We do not have a back-end that stores user data, so we cannot see, access, read, analyse, export or delete the information you keep in the App. Because of this, we are also unable to restore your data if you lose your device or delete the App – please use the backup feature described in section 4.7.

4. What data is processed, where and by whom

4.1 Data stored locally on your device

Everything you enter or create in the App – meals and food diary entries, products and recipes, nutrition and water targets, meal plans, fasting sessions, weight and body measurements, progress data, notes and posts, your profile name and photo, and your preferences – is saved in the App’s private storage on your iPhone. This information is protected by the security mechanisms of iOS (including device encryption when a passcode is set). It is not transmitted to us.

4.2 Apple Health (HealthKit)

If you grant permission, the App can read data from and write data to Apple Health (for example weight, body measurements, dietary energy, macronutrients, water or activity data). This is health data, a special category of personal data under Article 9 GDPR. All HealthKit data is read and written exclusively on your device; it is never sent to us or to any third party, and it is never used for advertising, marketing or data mining, in line with Apple’s HealthKit rules. You can change or revoke HealthKit permissions at any time in the iOS Settings app or in the Health app. Data the App has written to Apple Health remains there until you delete it in the Health app.

4.3 Device permissions

The App asks for iOS permissions only when a feature needs them: the camera (to scan barcodes or photograph a meal), the photo library (to pick a meal or profile photo) and notifications (for example fasting or reminder alerts, which are scheduled locally on your device). Photos and images remain on your device unless you explicitly send one to an AI provider (section 4.5). You can manage permissions in iOS Settings at any time.

4.4 Open Food Facts product search

When you scan a barcode or search for a product, the App sends the barcode number or your search phrase to the public Open Food Facts database, operated by the non-profit association Open Food Facts (France), and downloads the matching product information. As with any internet request, Open Food Facts technically receives your device’s IP address and basic technical information (such as the app identifier). The request does not contain your name, diary, health data or any identifier created by us. Processing by Open Food Facts is governed by its own privacy policy.

4.5 Optional cloud AI assistant (bring your own key)

The App offers an optional AI feature that can estimate the nutritional content of a meal from a text description or photo. This feature is switched off by default and works only if you (a) enter your own API key from a provider of your choice and (b) give your consent in the App (“Allow sending text and photos I choose to analyse”). Supported providers currently include Anthropic (Claude), OpenAI, Google (Gemini) and Abacus.AI, as well as a custom endpoint that you configure yourself.

• Only the text or photo you choose to analyse is sent – directly from your device to the selected provider. No name, Apple Health data or diary history is sent.
• The request goes directly to the provider; it does not pass through any server of ours, and we do not receive or store its content or the response.
• Your API key is stored only in your iPhone’s Keychain and is sent only to the provider it belongs to.
• The relationship between you and the provider is governed by your agreement with that provider and its privacy policy. Usage costs are charged to your provider account; we recommend setting a monthly spending limit in the provider’s console.
• You can withdraw consent at any time by switching the toggle off or removing your API key. This does not affect the lawfulness of earlier processing.

Please do not include in photos or descriptions any information you do not wish to share with the provider (for example faces, documents or other people).

4.6 Subscriptions and purchases

Premium subscriptions and other in-app purchases are sold and processed by Apple through the App Store and StoreKit. Apple handles payment, billing and your Apple Account data under the Apple Privacy Policy. We do not receive or process your payment card details, name or Apple Account e-mail. The App only checks on your device whether an active entitlement exists. Apple provides us with aggregated sales and financial reports that do not identify you.

4.7 Backups

You can export a backup file of your App data and save it where you choose, for example in the Files app or iCloud Drive, and import it later. The backup is created and stored by you; we never receive a copy. If you use iCloud Drive or iCloud Backup, Apple stores that data under its own terms. Please keep your backup files secure, as they contain your diary and body data.

4.8 Contacting us

If you write to us by e-mail (for support, questions or to exercise your rights), we process your e-mail address, name (if given) and the content of your message, solely in order to reply and handle your request. Apart from showing ads in the free version (section 4.10), this is the only situation in which we, as Vitalverse, process your personal data.

4.9 Diagnostics provided by Apple

The App does not include any third-party analytics or crash-reporting SDK (the Google ad SDK described in section 4.10 is used only for ads in the free version). If you have chosen in iOS settings to share analytics with app developers, Apple may provide us with crash reports and aggregated usage statistics. Apple anonymises this information before sharing, and we use it only to fix errors. You can turn this off in Settings › Privacy & Security › Analytics & Improvements.

4.10 Ads in the free version (Google AdMob)

The free version of the App is funded by ads. A banner ad is shown on the main screens and, after some logged meals, an occasional full-screen ad (with limited frequency). Ads are provided by Google AdMob, a service of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) and Google LLC (USA). If you have Premium, the App shows no ads and does not start the Google ad SDK at all.

• What Google receives. When requesting and showing an ad, the Google SDK may process: your IP address and the approximate location derived from it, device and system information (model, iOS version, language, settings), the App identifier, device identifiers (Apple’s advertising identifier – IDFA – only if you allow tracking), ad impressions and clicks, and ad diagnostics and performance data.
• What Google never receives. Your food diary, Apple Health (HealthKit) data, body measurements, photos, meal descriptions, API keys or information about what you do in the App are never passed to Google or used for ads. Ad requests contain no keywords, content categories or user attributes.
• Consent in the EEA, UK and Switzerland. Before ads are shown for the first time, the App displays Google’s consent form (User Messaging Platform, IAB TCF compliant). You can accept personalised ads, decline, or choose detailed settings. Without consent Google may show only non-personalised or limited ads, based for example on context and approximate location. You can change or withdraw your choice at any time in the App: More › Ad privacy choices.
• Tracking (Apple App Tracking Transparency). The App asks, with the iOS system prompt, whether you allow tracking. Only with your permission does Google receive the IDFA advertising identifier, which enables ad personalisation across apps and websites. You can change this in iOS Settings › Privacy & Security › Tracking.
• Google’s role. For data processed for advertising, Google generally acts as an independent controller under its own data protection terms and the Google Privacy Policy. More on how Google uses data from partner apps: policies.google.com/technologies/partner-sites. We receive from Google only aggregated reports (for example impressions and revenue) that do not identify you.
• How to avoid ads completely. Get Premium – ads disappear and the ad SDK is not started.

5. Purposes and legal bases

Because the data you keep in the App never reaches us, we do not process it within the meaning of the GDPR. For the limited data flows described above, the following legal bases apply:

6. How long data is kept

• Data stored in the App remains on your device until you delete it in the App or delete the App. Deleting the App permanently removes its local data from the device (copies may persist in your own device backups or exported backup files until you delete them).
• Apple Health data stays in the Health app until you delete it there.
• Open Food Facts and AI providers retain request data according to their own policies; we have no influence over or access to it.
• Google (ads) retains advertising data according to its own retention rules (policies.google.com/technologies/retention). Your choice in the consent form is stored locally on your device until you change it or delete the App.
• E-mail correspondence is kept for as long as necessary to handle your matter and then for up to 3 years for the purpose of possible claims, unless a longer period is required by law.

7. Recipients and third parties

We do not sell or rent your personal data. Data leaves your device only towards the following independent third parties, and only when you use the relevant feature – or, for ads, when you use the free version:

We may disclose the limited data we hold (e-mail correspondence) to public authorities only where required by applicable law.

8. Transfers outside the EEA

We do not transfer personal data outside the European Economic Area ourselves. A transfer can occur when you use the ad-supported free version (Google may process advertising data in the United States; Google LLC participates in the EU–US Data Privacy Framework and uses Standard Contractual Clauses) or when you activate the optional AI feature and select a provider based outside the EEA (in particular in the United States). In that case your device sends the selected content directly to that provider under your own agreement with it. Such providers typically rely on the European Commission’s adequacy decision for the EU–US Data Privacy Framework (where the provider is certified) or on Standard Contractual Clauses approved by the European Commission. Please review the chosen provider’s privacy policy for details. Apple may process data in the United States under its own safeguards.

9. Automated decision-making and profiling

We do not carry out automated decision-making producing legal or similarly significant effects within the meaning of Article 22 GDPR, and we do not profile users ourselves. If, in the free version, you consent to personalised ads or tracking, Google may build an interest profile to select ads; this has no legal effect on you and you can withdraw consent at any time (section 4.10). Calculations in the App (for example calorie or macronutrient targets, or AI-generated nutrition estimates) are performed for you as informational tools; they are suggestions you are free to accept, edit or ignore.

10. Your rights under the GDPR

If you are in the EEA or the UK, you have the right to:

• access your personal data and receive a copy (Art. 15);
• rectification of inaccurate data (Art. 16);
• erasure (“right to be forgotten”) (Art. 17);
• restriction of processing (Art. 18);
• data portability (Art. 20);
• object to processing based on legitimate interest (Art. 21);
• withdraw consent at any time, without affecting the lawfulness of processing before withdrawal (Art. 7(3));
• lodge a complaint with a supervisory authority – in Poland the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl), or the authority in your country of residence or work.

Because data stored in the App is under your sole control, you can exercise most of these rights directly on your device: view and edit entries in the App, delete them or delete the App, and export your data with the backup feature (portability). For data we do hold (e-mail correspondence), contact us at [email protected]. We will respond within one month, which may be extended by two further months in complex cases. Requests concerning data held by Apple, Google, Open Food Facts or an AI provider should be addressed to them. You can withdraw ad consent directly in the App (More › Ad privacy choices) or with the iOS Tracking setting.

11. Privacy rights for California and other US residents

This section applies to residents of California under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”), and, where applicable, to residents of other US states with comprehensive privacy laws. We provide this information voluntarily and to the extent these laws apply to us.

• Categories collected. In the free version, the Google AdMob SDK collects identifiers (IP address, device identifiers, IDFA only with tracking permission), internet activity (ad impressions and clicks) and approximate geolocation derived from the IP address, to serve and measure ads. When you contact us we also process identifiers and communications (your e-mail address and message content), solely to respond to you. Health, biometric, precise geolocation and other sensitive personal information is not collected.
• Sale and sharing. We do not sell personal information for money. If you allow tracking in the free version, disclosing data to Google for personalised ads may constitute “sharing” for cross-context behavioural advertising under the CCPA. You can opt out by declining the iOS tracking prompt or turning tracking off in Settings › Privacy & Security › Tracking; Premium removes ads entirely. We have no actual knowledge of selling or sharing personal information of consumers under 16.
• Sensitive personal information. We do not use or disclose sensitive personal information for purposes requiring a right to limit.
• Your rights. You have the right to know what personal information we have collected, to request deletion and correction, to opt out of sharing for cross-context behavioural advertising (as described above) and not to be discriminated against for exercising your rights.
• How to exercise them. E-mail [email protected]. You may use an authorised agent. Because we hold almost no data, verification will usually involve confirming control of the e-mail address in question.
• Do Not Track / Global Privacy Control. These are web-browser signals that an iOS app does not receive. Their iOS equivalent is the Tracking setting, which we respect: without your permission Google does not receive the advertising identifier.

12. Minimum age

The App is intended for persons aged 16 or older. It is not directed at children, and we do not knowingly process personal data of anyone under 16. If you believe a child under 16 has contacted us and provided personal data, please write to us and we will delete it.

13. Security

Your data is protected by the security features of iOS: sandboxed app storage, device encryption and the Keychain for your API key. Connections to Open Food Facts, AI providers and Google (ads) use encrypted HTTPS. We encourage you to protect your device with a passcode or Face ID / Touch ID and to store backup files in a secure location.

14. Medical disclaimer

15. Changes to this policy

We may update this policy, for example when the App gains new features or when the law changes. The current version is always available at www.vitalverse.life/aplikacje/privacy and in the App. We will inform you of material changes in the App or on our website before they take effect. The effective date at the top of this page shows when the policy was last updated.

16. Contact

For all questions about this policy or your data, contact Vitalverse – Janusz Magerramow, Wysłouchów 29/47, 30-611 Kraków, Poland, e-mail [email protected].

See also our Terms of Service.