Privacy Policy

This policy explains what personal data the Sugar Lens app and the website sugarintaketracker.com handle, why, and what you can do about it. We have tried to keep it short and plain. If anything is unclear, email support@sugarintaketracker.com.

Sugar Lens is our sugar-tracking app for iPhone. On the App Store it is listed as "Sugar Tracker: Food Scanner". The website is called Sugar Intake Tracker.

The short version

• Sugar Lens has no accounts. The app never asks for your name or email address. Age, gender and a daily goal are optional and stay on your iPhone.
• Your sugar log, food thumbnails, profile and settings are stored on your iPhone, and we have no server that receives them. Only the food thumbnails can end up in your own iCloud or computer backups (section 2).
• When you tap Analyze sugar, the app sends the food photo (and a nutrition-label photo, if you add one) through our relay on Cloudflare to OpenAI, whose AI model estimates the sugar. Nothing from your log or profile is sent with it. OpenAI doesn't use it to train its models and may keep it for up to 30 days to detect abuse. You can always type the grams yourself instead.
• To handle Sugar Lens Plus, the app contacts our subscription provider RevenueCat each time it starts, using a random ID and basic device details. Apple handles all payments.
• The app shows no ads and contains no analytics, crash-reporting or advertising software. It doesn't use your phone's advertising ID, and it sends no notifications.
• The website uses one analytics tool, Fathom, which sets no cookies and doesn't identify you. There is no Google Analytics, no Meta (Facebook) Pixel and no other tracking or advertising tool on the website. Blog posts with a video load YouTube's player (section 9).
• We don't sell personal data. You have rights over your data, including the right to object to the processing we base on our legitimate interests, and you can use them by emailing us.

Contents

1. Who we are
2. App: what stays on your iPhone
3. App: food photo analysis (AI)
4. App: purchases and Sugar Lens Plus
5. App: permissions and other connections
6. Website: hosting and server logs
7. Website: analytics (Fathom only)
8. Website: cookies and browser storage
9. Website: blog, videos and images
10. App Store links
11. When you email us
12. No selling of data, no ads
13. Why we use data (legal bases)
14. How long we keep data
15. Who receives data
16. Transfers outside the EU
17. Security
18. Children
19. Your rights
20. Complaints
21. Changes to this policy
22. Contact us

1. Who we are

Sugar Lens and Sugar Intake Tracker are made by Iaroslav Morgunov, an individual sole trader in Portugal who trades as Last Stand Studio (laststand.studio). In this policy, "we", "us" and "our" mean him. He is the data controller for the personal data described here.

• Name: Iaroslav Morgunov, trading as Last Stand Studio
• Address: Rua Alfredo Keil 571, 4150-047 Porto, Portugal
• Email (privacy, support and everything else): support@sugarintaketracker.com
• Phone: +351 924 331 054
• Tax number (NIF): 310038588

We have not appointed a data protection officer, because the law does not require one for a business like ours. You can contact us directly about anything in this policy.

This policy covers:

• the app: Sugar Lens for iPhone, including when it runs on a Mac with Apple silicon;
• the website: sugarintaketracker.com, including its blog and the pages that open inside the app.

Sugar Lens is available only on the App Store. There is no Android version. If we release one, we will update this policy first.

Sections 2 to 5 are about the app. Sections 6 to 10 are about the website and our App Store links. Sections 11 onwards apply to both.

2. App: what stays on your iPhone

Sugar Lens has no accounts and no sign-up. The app does not ask for your name, email address, location or contacts, and it does not read Apple Health.

Everything you enter is saved in the app's own storage on your iPhone:

• your sugar log: for each entry, the food or drink, the portion, the grams of sugar, when you had it and whether it came from a photo or you typed it. For photo entries it also keeps the AI's estimate details (the foods it recognised, the sugar range, how confident it was and its notes);
• a small thumbnail (640 pixels wide) of the food photo for each photo entry you confirm;
• your profile, if you give it: age (13 to 120), gender (female, male, non-binary or "prefer not to say") and a daily sugar goal. All three are optional;
• your settings: measurement system (U.S. or metric), language and appearance;
• a record that you finished the introduction and that you agreed to photo analysis, with the date and time you agreed (section 3).

We have no servers that receive this data, and we can't see it. A sugar log can say something about your diet and health. That is why it stays with you. Your log, age, gender and goal are never sent with your photos.

Photos. When you take a photo in the app, it is not saved to your photo library. When you choose a photo, you use Apple's photo picker, so the app sees only the photo you pick and not the rest of your library. The app works with a temporary copy and deletes it when you confirm the entry, discard it or leave the screen. Nutrition-label photos and analyses you discard are never kept. Only the thumbnail of a confirmed food photo stays.

Deleting. Deleting an entry also deletes its thumbnail. Settings > Delete all tracker data removes your whole log, all thumbnails, your age, gender, measurement system and goal. It leaves your language and appearance settings, the record that you finished the introduction and agreed to photo analysis, and the purchase details that RevenueCat's software keeps on your phone (section 4). Deleting the app removes all of them.

iPhone backups. The app has no sync of its own. Your log, profile and settings are marked so that they are left out of iCloud Backup and of backups to a computer. The food thumbnails are not left out, so if you back up your iPhone, the backup includes them. Apple stores iCloud backups under your agreement with Apple and Apple's Privacy Policy. You control iCloud Backup in the iOS Settings app.

3. App: food photo analysis (AI)

Sugar Lens can estimate the sugar in a meal from a photo. This is the only time the app sends content you create off your iPhone.

What is sent. Only when you tap Analyze sugar, the app sends:

• the food photo, and the nutrition-label photo if you added one. Before sending, the app resizes each photo to 1,280 pixels wide and saves it as a new JPEG image. The new image does not carry the original photo's location or camera details;
• a fixed instruction for the AI, which includes your measurement system (so portions come back in U.S. or metric units) and your app language (so the answer is in your language).

Nothing else is sent: not your log, age, gender, goal or name, and no ID for you or your device. Without an internet connection, nothing is sent. A photo shows whatever is in the frame, so please photograph only the food and its label, not people, documents or screens.

How it travels.

1. The request goes to a small relay (a Cloudflare Worker) that we run on the network of Cloudflare, Inc. (USA). The relay adds our OpenAI access key and passes the request on to OpenAI. It does not store your photos or the result. To stop abuse, it can count requests per IP address, and each count deletes itself after 2 minutes. The relay passes on the request's technical details, so OpenAI may also receive details such as the app and iOS version and, possibly, your IP address.
2. OpenAI runs its AI model (currently GPT-5 nano) on the photos and returns an estimate. For us, as a business in the EU, the OpenAI company is OpenAI Ireland Ltd., which uses OpenAI's systems in the USA. OpenAI processes the request for us, as our processor, under its API terms. It does not use this data to train its models. It may keep requests for up to 30 days to detect and prevent abuse, and then deletes them, unless the law requires it to keep them longer. We don't ask OpenAI to store requests. See OpenAI's API privacy commitments.
3. The app shows you the estimate. It is added to your log only if you confirm it, and you can change the numbers first.

Your agreement. Before you can use the tracker, the app explains what happens to your photos and asks you to agree ("Agree and continue"). The app saves this, with the date and time, on your iPhone. To take it back, go to Settings > Reset onboarding. The app then clears your agreement and shows the introduction again. Because photo analysis is built into the tracker, the tracker opens again only after you agree. You never have to analyse a photo: you can add any entry by typing the grams yourself, and then no photo leaves your iPhone.

Is a food photo health data? On its own, a photo of a meal usually says nothing about your health. It reaches OpenAI without your name or any ID, and we don't use photos to learn anything about you. But because Sugar Lens is a sugar tracker, a photo could sometimes hint at your diet or a health condition, and data protection law gives health data extra protection. For any health information a photo might reveal, we rely on your explicit consent (GDPR article 9(2)(a)): the agreement you give in the app, together with your choice to tap Analyze sugar for each photo. You can withdraw it at any time by not analysing photos and by taking back your agreement as described above. Withdrawing doesn't affect analyses done before.

The estimate is produced automatically and is only an approximate guide for general wellness. It is not medical advice and must not be used for insulin dosing, diagnosis or other medical decisions. See our Terms of Use.

4. App: purchases and Sugar Lens Plus

Sugar Lens is free to download, but the tracker needs Sugar Lens Plus. Plus is sold as a monthly auto-renewing subscription (with a free trial when the App Store offers you one) or as a one-time Lifetime purchase. The details are in our Terms of Use.

Payments. Apple handles all payments through the App Store. We never see your card or bank details, and we don't receive your Apple Account name or email address. In the EU, the seller of in-app purchases is Apple Distribution International Ltd. in Ireland. Apple processes payment data under its own privacy policy. You manage and cancel subscriptions with Apple (Settings > Manage subscription in the app opens Apple's screen). If you share a Lifetime purchase through Apple's Family Sharing, Apple handles that too. Apple also gives us sales reports, such as which products were bought, when, at what price and in which country.

RevenueCat. We use RevenueCat, Inc. (USA) to check purchases and manage subscriptions. RevenueCat processes this data on our behalf, as our processor. It also shows us overall figures, such as how many subscriptions were started, renewed or cancelled. Each time the app starts, it contacts RevenueCat to check whether you have Plus and to load the current plans and prices. This happens for everyone, including people who have never bought anything. Buying and restoring purchases also go through RevenueCat.

RevenueCat receives:

• a random, anonymous ID that RevenueCat's software creates in the app (we don't link it to your name, email address or Apple Account);
• purchase information from Apple: receipts and transaction IDs, which product you bought, the price and currency, purchase and expiry dates, whether you used a free trial, and whether Plus is active;
• your device model, iOS version, app version, language settings, and the country of your App Store account;
• Apple's "identifier for vendor": an ID that iOS gives to all of our apps on your iPhone. It is not the advertising ID, and iOS changes it if you delete all of our apps;
• when the app last contacted RevenueCat;
• your IP address, as with any internet connection.

RevenueCat does not receive your photos, your log or your profile, and the app sends it no advertising or ad-attribution data. RevenueCat stores data on Amazon Web Services servers in the USA. RevenueCat's software also saves the anonymous ID and your purchase status on your iPhone, so the app knows your plan. See RevenueCat's privacy policy.

5. App: permissions and other connections

Permissions

• Camera: the app asks the first time you choose to take a photo. If you say no, you can still choose a photo or type your entries.
• Photos: the app uses Apple's photo picker, so it doesn't need access to your photo library and sees only the photos you pick.

The app does not use your microphone, location, contacts or Apple Health, and it doesn't collect your advertising ID. It never shows the "Allow apps to request to track" prompt, because it doesn't track you.

Other connections from the app

• No notifications. Sugar Lens sends no notifications, so it has no push token.
• No analytics or ads. Apart from the photo analysis (section 3) and RevenueCat (section 4), the app contains no analytics, crash-reporting or advertising software.
• No over-the-air updates. App updates come only through the App Store.
• Web pages inside the app. Support, Terms of Use and this Privacy Policy open inside the app as pages from sugarintaketracker.com. From there you can also browse the rest of the website. These pages work like the website in a browser, as described in sections 6 to 9.
• Crash reports from Apple. If you chose in your iPhone's settings to share analytics with app developers, Apple may give us crash reports and combined usage statistics through App Store Connect. You control this in Settings > Privacy & Security > Analytics & Improvements.

6. Website: hosting and server logs

The website is hosted by Vercel Inc. (USA). When you open a page, Vercel receives your IP address, browser and device details, the page address, the page you came from and the time. Vercel keeps these request logs for a limited time under its own settings. We use them only to run the site and keep it secure. Vercel does not set cookies for us. Blog pages also pass through Cloudflare (section 9).

The website has no accounts, sign-up forms, newsletter, comments or contact form.

7. Website: analytics (Fathom only)

The only analytics tool on our website is Fathom Analytics. We don't use Google Analytics, Google Tag Manager, the Meta (Facebook) Pixel or any other tracking or advertising tool.

Provider: Conva Ventures Inc. (Canada), as our processor. Fathom counts page views and records the page address, the site you came from, campaign tags in the address, and general browser, device and country information. We haven't set up any event tracking, so Fathom doesn't record clicks or what you do on a page. It counts every page of the site, including the blog and the pages that open inside the app.

Fathom does not use cookies or save anything on your device, and it doesn't build a profile of you or follow you to other websites. It turns your IP address and browser details into a scrambled code (a hash) that changes every day, and it doesn't keep your raw IP address in its analytics. For visitors in the EU, this step happens on servers in the EU. Fathom says it keeps raw data for no longer than 24 hours. We only see combined statistics, such as how many people viewed a page. See Fathom's privacy policy.

Our pages are about sugar and diet, so the page address Fathom counts shows which pages were visited, but not by whom. Our tools run entirely in your browser. What you type into them is not sent to us and is not added to the page address.

Our tool pages also offer code that other websites can use to embed a tool. If an embedded tool loads on another website, Fathom counts it in the same way.

If you don't want to be counted, you can use a content blocker, most of which block Fathom, or email us to object (section 19).

8. Website: cookies and browser storage

Our website sets no cookies, and neither do Fathom, Vercel or Cloudflare. (YouTube's video player may store data in your browser; see section 9.)

Browser storage. Only one tool saves anything: the Sugar-Free Streak Tracker keeps your streak start date and your best streak in your browser's local storage, so they are still there next time. Its "Reset all data" button deletes them. All other tools keep what you enter only while the page is open. This data stays in your browser, and we never receive it. You can also clear it at any time in your browser settings.

9. Website: blog, videos and images

• Blog. Our blog at sugarintaketracker.com/blog is published with our blogging tool, Lunroo. Its pages, images and styles are stored and delivered by Cloudflare, Inc. (USA). When you open a blog page, Vercel passes your request on to Cloudflare, including the page address and your browser details, and possibly your IP address. No cookies are set.
• YouTube videos. Our blog posts include a YouTube video, shown in YouTube's privacy-enhanced mode (youtube-nocookie.com). The player loads by itself when you scroll near it, before you press play. When it loads, your browser sends Google your IP address and browser details, and the player may store data in your browser. If you press play, YouTube also records what you watch. Google handles this under Google's Privacy Policy.
• Other images. All other images on the site are our own files, delivered by Vercel. The site loads no external fonts.
• Other websites. Links to other websites, such as sources in our articles, are covered by those websites' own policies.

10. App Store links

Our App Store buttons link to the Sugar Lens page on the App Store. The links carry no campaign tags and nothing about you. Because of our site settings, Apple sees only that you came from sugarintaketracker.com, not which page. On an iPhone, Safari may show a banner for the app at the top of our pages. Safari handles this banner itself, and we receive nothing from it. What happens on the App Store is covered by Apple's Privacy Policy.

11. When you email us

If you email support@sugarintaketracker.com, we receive your email address, your name if your email shows it, your message, any attachments (for example a screenshot) and the time you sent it. We use this only to reply and help you, and to spot common problems. Your emails are stored by the email provider that runs our mailbox, which processes them for us as our processor.

Please don't send more personal or health details than you need to. We keep support emails for up to 2 years after our last exchange, then delete them. We keep an email longer only if we need it for a legal claim or the law requires it.

12. No selling of data, no ads

• We don't sell personal data, and we don't pass it to data brokers.
• The app shows no ads and contains no advertising or analytics software. It doesn't use your phone's advertising ID and doesn't track you across other companies' apps and websites.
• Your food photos are used only to estimate sugar for you. We don't keep them, look at them or use them for anything else.
• Apart from the YouTube player in blog posts (section 9), the website runs no advertising or tracking tools.

13. Why we use data (legal bases)

Data protection law (the GDPR) says we need a legal basis for each use of personal data. Here are ours.

Where we rely on legitimate interests, you have the right to object (section 19).

Do you have to give us data? No law requires you to give us personal data, and you can use Sugar Lens without an account. But the tracker needs Sugar Lens Plus, and the app needs the RevenueCat connection in section 4 to know your plan, so it happens whenever you use the app. To buy or restore Plus, purchase data has to pass through Apple and RevenueCat. Without it, we can't deliver Plus. The app also asks you to agree to photo analysis before the tracker opens, but agreeing sends nothing by itself. Analysing a photo is your choice each time: without it, you type the grams yourself. Age, gender and a goal are optional, and so is emailing us.

Automated decisions. The sugar estimate is produced automatically by an AI model, but it is only a suggestion that you can check, change or discard, and it has no legal or similarly significant effect on you. We don't make decisions about you based only on automated processing, including profiling.

14. How long we keep data

When we stop using a service listed here, we delete our data held with it, unless the law requires us to keep it.

15. Who receives data

We share data only with the companies below, and only for the purposes in this policy. Processors act on our instructions. Independent controllers decide for themselves how they use data, under their own privacy policies.

Each processor works under a data processing agreement, usually part of its standard terms. The agreement lets it use the data only to provide its service to us, and requires it to keep the data confidential and secure as the GDPR requires, giving it the same protection this policy describes. Apart from our website pages that open inside it (section 5), the app shares data only with Cloudflare and OpenAI (for photo analysis), RevenueCat (for purchases) and Apple (the platform it runs on).

We may also share data:

• if the law requires it, for example with a court, the tax authority or another public authority;
• with professional advisers, such as an accountant or a lawyer, only as far as they need it and under a duty of confidentiality;
• if Sugar Lens is sold or passed to someone else. The new owner would receive only the data we hold (such as support emails and purchase records at RevenueCat) and would have to follow this policy. We will tell you on the website before this happens.

16. Transfers outside the EU

Some recipients are outside the European Economic Area (EEA). When data goes there, it is protected as follows.

Apple handles transfers of the data it controls under its own terms.

The EU-US Data Privacy Framework is currently being challenged in court. If it stops applying, we will rely on the Standard Contractual Clauses instead. You can ask us for a copy of the safeguards for any transfer by emailing support@sugarintaketracker.com.

17. Security

• The best protection is not collecting data in the first place. Your log and profile never reach our systems, and we don't keep your photos.
• Data on your iPhone is protected by your phone's own security, such as your passcode and device encryption.
• Photos travel over encrypted connections to our relay and from there to OpenAI. Our OpenAI access key is kept on the relay, not in the app.
• The app talks to RevenueCat over encrypted connections, and RevenueCat encrypts data in transit.
• The website works only over HTTPS. It uses HSTS and other security headers, and it blocks access to your camera, microphone and location.
• Access to our service accounts (Cloudflare, OpenAI, RevenueCat, analytics and email) is limited to the developer.

No system is perfectly secure. If a data breach puts your rights at risk, we will tell you and the authorities as the law requires.

18. Children

Sugar Lens is rated 4+ on the App Store. That rating describes the app's content. The app is meant for people aged 13 and over. If you enter an age, it must be between 13 and 120, but the age is optional and stays on the iPhone. The app never asks anyone for a name, email address or contact details. If a child uses the app, a parent should make sure the photos show only food.

In Portugal, children under 13 can't give valid consent to online services by themselves (Lei n.º 58/2019, article 16). Where we rely on consent, including the photo-analysis agreement in section 3, a parent or guardian has to give it for a child under 13. Other EU countries set this age between 13 and 16. If you are under that age where you live, please ask a parent or guardian before you use Sugar Lens or email us.

Purchases go through Apple. Parents can use Apple's Ask to Buy to approve purchases. The website's kids' sugar calculator is meant for parents and caregivers. If you think a child has sent us personal data, email us and we will delete it.

19. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you and get a copy;
• correct data that is wrong;
• delete your data;
• restrict how we use it;
• data portability: receive data you gave us in a common machine-readable format, where we use it based on consent or contract;
• withdraw consent at any time, where we rely on it. This doesn't affect what happened before you withdrew;
• not be subject to decisions based only on automated processing that have legal or similarly significant effects (we don't make any).

How to use your rights

Email support@sugarintaketracker.com. It's free. We answer within one month. If a request is complex, we may need up to two more months, and we will tell you why. We may ask for information to confirm the request is yours.

Because Sugar Lens has no accounts, we often can't link data to a person. For example, to find your purchase record at RevenueCat, we will usually need the order ID from your Apple receipt. Photo requests sent to OpenAI carry no ID for you, so we can't find or delete a single one; OpenAI deletes them within 30 days (section 14). If we can't identify you, we will tell you. In that case the law doesn't require us to act on the request unless you give us details that let us find your data.

Data we don't hold

Most Sugar Lens data never reaches us, so you control it directly:

• On your iPhone: edit or delete entries in the app, or use Settings > Delete all tracker data. Deleting the app deletes all of its data on the phone.
• iPhone backups: manage or delete them in the iOS Settings app (iCloud Backup) or on the computer you back up to.
• Purchases: Apple holds your payment and purchase history. Contact Apple for its records.
• Website: use the streak tracker's "Reset all data" button, or clear browser storage for sugarintaketracker.com in your browser settings.

UK and US users

If you are in the UK, you have the same rights under the UK GDPR, and you can complain to the Information Commissioner's Office (ico.org.uk).

If you live in a US state with a privacy law, such as California, you can ask to know, correct or delete your personal data by emailing us. We don't sell personal data. We won't treat you differently for using your rights.

20. Complaints

We would like to hear from you first at support@sugarintaketracker.com, so we can try to fix the problem. You also have the right to complain to a data protection authority, in particular in the EU country where you live, work or where the problem happened. Our lead authority is the Portuguese one:

• Comissão Nacional de Proteção de Dados (CNPD)
• Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, Portugal
• Phone: +351 213 928 400
• Email: geral@cnpd.pt
• Website: www.cnpd.pt
• Complaint form: www.cnpd.pt/cidadaos/participacoes

21. Changes to this policy

We will update this policy when the app, the website or the law changes. The date at the top shows the latest version. If we make important changes, we will point them out on the website or in the app's update notes. Before we use your data for a new purpose, we will tell you first.

22. Contact us

Iaroslav Morgunov, trading as Last Stand Studio
Rua Alfredo Keil 571, 4150-047 Porto, Portugal
Email: support@sugarintaketracker.com
Phone: +351 924 331 054
NIF: 310038588

You can also reach us through our support page.