NCompanion Privacy Policy

Version 3.0 · Effective: 9 October 2026

This policy applies to the NCompanion app for iPhone, the server that supports it, and the website conelmarketing.com. NCompanion is provided by SIA CONEL MARKETING, Latvia.

The short version

• No account. You do not sign up or sign in. Your food diary, profile, targets and weight entries are stored on your iPhone. We do not keep a copy of them.
• AI analysis only with your permission. When you use an AI feature (a meal photo, a voice note, typed text, a menu or a product tip), the app sends what that request needs to our server in Frankfurt, Germany. From there it goes to OpenAI, which produces the estimate. Nothing is sent until you tap "Allow and continue", and you can switch this off at any time.
• We do not keep your photos or voice recordings. OpenAI may keep request data under its own terms for up to 30 days, and longer in some cases, for example an image that it flags for child-safety review (section 4.5).
• Optional quality copies. Our server keeps copies of some results only if you turn on "Help improve recognition". Copies are kept for 90 days and are linked to a random key on your iPhone. Copies are deleted automatically within a day after the 90 days are up. If a clean-up is delayed by a fault, it is repeated automatically, and our monitoring is set up to alert us. You can delete copies earlier in the app's settings. If you turn the switch off, or turn AI analysis off, no new copies are made and the app asks our server to delete the copies saved from this iPhone (section 4.7).
• Apple Health data is never sent to us, to OpenAI or to anyone else. The app uses it only on your iPhone (section 7).
• No ads, no tracking and no analytics tools in the app. We never sell data.
• Your rights. You can withdraw your consent at any time with the switches in You → Settings → Data & Privacy (section 13.1). In the same place, "Get a copy of saved copies" gives you a copy of the quality copies linked to the keys on your iPhone (section 13.2). You can ask us about your data at [email protected]. You can also complain to the Latvian Data State Inspectorate (section 13).

Contents

1. Who we are
2. What this policy covers
3. The data at a glance
4. What happens to your data, step by step
5. How we use AI
6. Food, weight and health information
7. Apple Health
8. Camera, microphone, photos and reminders
9. Why we use data: purposes and legal bases
10. Who receives data
11. Transfers outside the European Economic Area
12. How long data is kept
13. Your choices and rights
14. Do you have to provide data?
15. How we protect data
16. Children
17. Our website
18. Changes to this policy
19. Contact

1. Who we are

NCompanion is provided by SIA CONEL MARKETING ("we", "us"). The company is registered in the Commercial Register of the Republic of Latvia under registration number 40103478376. Its registered address is Rusonu iela 30 k-1-21, Riga, LV-1057, Latvia.

We decide why and how the personal data described in this policy is processed. Under the EU General Data Protection Regulation (GDPR), that makes us its controller.

• Privacy questions and requests: [email protected]
• Help with the app: [email protected]

A data protection officer (DPO) is not currently appointed. For questions about the processing of personal data, contact [email protected].

We are established in the EU, so we do not have a separate EU representative. Our lead supervisory authority is the Data State Inspectorate of Latvia (Datu valsts inspekcija); see section 13.5.

2. What this policy covers

This policy explains what happens to personal data when you use:

• the NCompanion app for iPhone;
• our server, which handles the app's AI requests, barcode look-ups and optional quality copies;
• our website conelmarketing.com (section 17).

NCompanion is a nutrition diary. It helps you log meals and estimates calories and nutrients. It is not a medical device and does not give medical advice. See our Terms of Use at https://www.conelmarketing.com/terms.

Apple runs the App Store. When you download the app, Apple processes your data under its own privacy policy, not this one.

3. The data at a glance

4. What happens to your data, step by step

4.1 On your iPhone

Everything you log is stored in the app's own storage on your iPhone, and we cannot see it. If you back up your iPhone (to iCloud or to a computer), the backup includes this data. Those backups belong to your Apple account and are governed by Apple, not by us.

• Reset profile & data (You → Settings → Data & Privacy) deletes your profile and personalisation on this iPhone: targets, nutrition focus, Dietary Safety and taste preferences. It does not delete your meal journal, weight entries, water or saved dishes.
• Deleting the app deletes everything in the app's own storage, including the diary, weight entries, water and saved dishes.
• The Keychain is separate. The random app ID and the quality key (sections 4.4 and 4.7) are kept in your iPhone's Keychain. Neither Reset nor deleting the app removes them. The quality key is removed once our server confirms that the copies linked to it are deleted (section 4.7). Otherwise both stay until the iPhone is erased.
• Quality copies are separate. Deleting the app does not delete quality copies on our server, so use "Delete saved copies" first (section 4.7).
• Apple Health. Entries the app has written to Apple Health stay there until you delete them in the Health app.

4.2 Before anything is sent: your consent

Nothing you capture or type leaves your iPhone until you agree. Before the first time, the app shows the screen "Before your first analysis". On a few screens, such as correcting a saved meal, the app instead says that AI analysis is off and asks you to turn it on in You → Settings → Data & Privacy, which shows the same screen. The screen lists:

• what is sent;
• who receives it;
• what is not sent;
• what is kept.

The app sends nothing unless you tap "Allow and continue". If you tap "Not now", nothing is sent, and features that work on your iPhone keep working (for example, saved dishes and repeat meals).

The app checks your choice again before every request. This includes automatic retries and requests that waited on your iPhone while you were offline.

Withdrawing consent. You can withdraw at any time in You → Settings → Data & Privacy by turning off "Send meals for AI analysis". From then on, nothing more is sent for analysis, and the app no longer looks up barcodes. This also turns off "Help improve recognition", and the app asks our server to delete the copies saved from this iPhone (section 4.7).

Changes. If we change what is sent or who receives it, the app asks you again before it sends anything.

The exceptions: requests about your quality copies. The app sends two kinds of request without this consent:

• a request to delete your quality copies. The app sends it when you use "Delete saved copies", when you turn "Help improve recognition" or AI analysis off, and in the other cases described in section 4.7;
• a request for a copy of your quality copies. The app sends it only when you use "Get a copy of saved copies" (section 13.2).

These requests carry no meal content and no app ID, only your quality keys and the app's access code (section 4.3), so that our server can find your copies. They are never passed on to OpenAI.

4.3 What is sent when you use an AI feature

What a request contains depends on the feature:

• Point and Pick: a reduced-size copy of the meal photo you take or choose. Pick shows your recent photos on your iPhone, and a photo leaves your iPhone only when you choose it. The portion size you choose is applied on your iPhone and is not sent. If you add a short spoken detail, it is turned into text as for Say. That text can then be sent as a correction, together with the first result but without the photo.
• Say: a voice note of up to 15 seconds, which is turned into text. To help recognise the speech, the request also carries up to five language codes, taken from the app's language, your iPhone's preferred languages and English.
• Type and corrections: the text you type. For a correction (for example, "the rice was brown rice"), the request also carries the earlier result and, if there is one, the photo, so that it can be corrected.
• Menus and menu suggestions: the text of a menu and where each piece of text sits on the page. Menu photos are read on your iPhone, and only the recognised text and its positions are sent. Each menu request also carries your goal (lose, maintain or gain weight), the meal type (for example, lunch) and, where available, what is left of today's targets for calories, protein, fat and carbohydrates, so that the app can suggest dishes.
• Product tips: the product name, the serving and its nutrients.
• Translation: when you open a meal you logged earlier and the app's language is different from the language its name was saved in, the name that the AI gave the meal, so that the app can show it in the app's current language. A meal you named yourself is never translated.
• Barcodes: the barcode number and the type of barcode (section 4.6).

Requests also carry some technical details, where they apply:

• the meal type (for example, lunch);
• how the meal was entered;
• the app's language;
• a random app ID (section 4.4);
• while "Help improve recognition" is on, a code derived from your quality key (section 4.7);
• the app's access code, which is the same in every copy of the app and says nothing about you.

What the app does not automatically send: your profile name, contacts, weight entries, body measurements or Apple Health data. If you include personal details in a photo, voice note or text (for example, a face in a photo), they are sent with that request. Please leave them out.

4.4 On our server

Our server and its database (Google Firestore) run on Google Cloud in Frankfurt, Germany (region europe-west3). The server receives each request over an encrypted connection, passes the content to OpenAI and returns the answer to the app.

• The request itself exists on the server only while it is processed. That takes seconds, and the service stops any request after 2 minutes.
• Short-lived answers. So that a repeated request can be answered without sending it to OpenAI or Open Food Facts again, the server briefly keeps:
  • recent analysis answers, for up to 90 seconds. To recognise the same request sent twice, for example after a double tap, the server uses a hashed code made from the request, your app ID and, while "Help improve recognition" is on, the code derived from your quality key;
  • tip and menu answers, for up to 10 minutes;
  • barcode product details, for up to 6 hours.

  We keep these answers on the basis of our legitimate interest (section 9, row 11).

• Counters. To protect the service from abuse and overload, the server keeps:
  • request counters per app ID, for about a minute after your last request;
  • counts of requests to the whole service, for up to 6 hours. These are totals for all users together, without any app ID.

  These answers and counters expire automatically.

• The random app ID is created on your iPhone. It is not your name, your e-mail or your Apple ID. We use it only to limit how many requests one copy of the app can send and, in hashed form, to recognise a repeated request (see above). It is not sent to OpenAI and is not stored with quality copies. It is kept in your iPhone's Keychain, so it may stay the same after you reinstall the app.
• We do not store your photos or voice recordings. Apart from the short-lived answers above and the optional quality copies (section 4.7), we keep no copy of your requests or of the answers.
• Your IP address. Google, as our host, sees your device's IP address when the app connects. Google's standard request logs for our service would contain it, but they are not stored.

4.5 At OpenAI

Our server sends the content of your request to OpenAI. OpenAI's AI models recognise foods, estimate nutrients, transcribe voice notes, read menus, write tips and translate dish names.

OpenAI receives the request from our server, not from your iPhone. So it receives neither your IP address nor your app ID.

We use OpenAI's services as a business customer. OpenAI processes this data on our behalf under its Services Agreement and its Data Processing Addendum. Under section 4.1 of that Addendum, OpenAI Ireland Ltd, in the EU, processes our requests (section 11).

What OpenAI keeps, according to OpenAI:

• Stored responses. We switch off OpenAI's optional storage of responses, so none are created.
• Prompt cache. OpenAI states that it may keep encrypted data from a request for up to 24 hours, to speed up similar requests.
• Abuse monitoring. OpenAI states that it may keep request data in its abuse-monitoring logs for up to 30 days. It may keep them longer where the law requires it, or where it is reasonably necessary to protect its services or others from harm.
• Child-safety review. OpenAI states that it checks images for child sexual abuse material. It keeps an image that is flagged as possibly such material for manual review, and gives no time limit for this.

We cannot delete data that OpenAI keeps under these rules.

Training. OpenAI states that it does not use data sent to its API to train its models unless the customer chooses to share it. In our OpenAI organisation, sharing data with OpenAI is switched off.

Where. We use OpenAI's standard processing, not its EU data-residency option. OpenAI may therefore process requests outside the EU, including in the United States (section 11).

4.6 Barcodes and Open Food Facts

When you scan a barcode, our server looks the number up in Open Food Facts (openfoodfacts.org), an independent, openly licensed database of food products.

• What Open Food Facts receives from our server: only the barcode number, with no app ID or other identifier.
• Product pictures: the app loads them directly from Open Food Facts. Open Food Facts then sees your device's IP address and which product's picture is requested, and so which product you scanned. The app sends it no app ID or other identifier. Open Food Facts handles this under its own privacy policy.
• Where the values come from: the values for a scanned product come from Open Food Facts, not from AI.
• Product tip: as soon as a scanned product is shown, and if its calories are known, the app also asks for a short AI tip about it. For this, our server sends OpenAI the product name, the serving and its nutrients, but not the barcode number (sections 4.3 and 4.5). If you change the serving, the app asks again.
• Consent: before the first look-up, the app asks for the same consent as for AI analysis (section 4.2).

4.7 "Help improve recognition": optional quality copies

This switch is off unless you turn it on, either on the consent screen or in You → Settings → Data & Privacy. Agreeing to AI analysis does not turn it on.

Which results are kept. While the switch is on, our server keeps a copy of some analysis results so that we can check how well recognition works:

• results you correct are always kept;
• results the AI was unsure about are always kept;
• of the other results, a random sample of about one in ten is kept.

A copy is kept whether or not you save the meal.

What a copy contains:

• the recognised foods and amounts;
• the estimated calories and nutrients;
• the AI's confidence and its short note;
• the meal type and how the meal was entered;
• the hour of the analysis (not the minute);
• if you corrected the result, what changed;
• two technical details: the version of the copy's format and the time when its 90 days are up.

Food names and the AI's note are based on what you entered, so a copy can repeat how you described a meal.

A copy never contains a photo, a voice recording, your app ID or your IP address.

Technical write times. As a standard technical feature, our database also records the exact time each copy was written. We do not use these times for quality checks or for any other analysis. They are included in the file you can get with "Get a copy of saved copies" (section 13.2).

Copies are not anonymous. Each copy is linked to a random key that the app creates on your iPhone when you turn the switch on. Using an AI feature never creates a key.

• Where the key is kept: in this iPhone's Keychain. It is never synced through iCloud Keychain and never moves to another iPhone. Backups of this iPhone, in iCloud or on a computer, contain it in encrypted form that only this same iPhone can restore.
• What our server stores: only a code derived from the key. This lets the app find the copies saved from your iPhone, to give you a copy of them or to delete them, without an account.
• When the key itself is sent: only to delete copies or to give you a copy of them. To delete copies, it is sent when you use "Delete saved copies", turn "Help improve recognition" off or turn AI analysis off; the app repeats the request until our server confirms it. It is also sent automatically if a backup has brought back a key whose copies you have already deleted, and our server tells the app so. Our server then uses the key only to find and delete those copies and to keep the deletion record (section 4.8). To give you a copy, it is sent only when you use "Get a copy of saved copies", together with any keys still waiting for deletion. Our server then uses the keys only to read what is stored under them, and changes nothing (section 13.2). It does not store or log any key. Analyses carry only a code derived from the key.
• What the key is not: it is not your app ID, your name or your Apple ID.

How we use copies.

• We use them only to check and improve the quality of food recognition, for example to see which foods or portions the AI often gets wrong.
• When you use "Get a copy of saved copies", our server gives you the copies linked to the keys on your iPhone, as they are stored (section 13.2). This is your access to your own data, not a use of the copies for our purposes.
• We use a copy for quality checks only during its 90 days.
• We do not use copies to train AI models, to build a profile of you or for marketing.
• Copies are stored by our infrastructure provider Google on our behalf (section 10). We do not sell them or make them available to other organisations for their own purposes.

How long they are kept. We use a copy for no longer than 90 days. Copies are deleted automatically within a day after the 90 days are up. You can delete them earlier in the app's settings. Until a copy is deleted, it is still stored, so "Get a copy of saved copies" still includes it if this iPhone holds its key, and marks it once its 90 days are up (section 13.2).

The automatic clean-up runs several times a day. If a technical fault holds it up, the clean-up is repeated automatically, and our monitoring is set up to alert us. In the meantime, Google's own expiry mechanism also removes expired copies.

Deleting copies yourself. Go to You → Settings → Data & Privacy → "Delete saved copies", and confirm ("Delete and turn off", or "Delete" while AI analysis is off). If you want a copy of your copies, get it before you delete them or turn either switch off (section 13.2).

• The app first turns saving off. Then it asks our server to delete every copy linked to this iPhone's key.
• It shows "Done" only after our server confirms the deletion, together with the number of copies deleted.
• Until then, the app shows that the deletion has been requested or is in progress, and "Help improve recognition" stays off. If our server cannot be reached or does not confirm, the app tells you and tries again while the app is open and the next time you open it. You can also tap "Try again".

Turning the switch off is withdrawing your consent. When you turn "Help improve recognition" off, or turn AI analysis off, no new copies are made. The app also asks our server to delete the copies saved from this iPhone, in the same way as "Delete saved copies". As with the button, "Done" appears only after our server confirms. If our server cannot be reached or does not confirm, the app tries again as described above.

What the buttons cannot reach.

• Copies from another device, or from before this iPhone's key was lost. This covers copies saved before you erased the iPhone or moved to a new one. This iPhone does not hold their key and we cannot tell which of them are yours, so the app can neither give you a copy of them nor delete them (section 13.2), and they are deleted automatically within a day after their 90 days are up.
• Restoring from a backup, or moving to a new iPhone. A backup can bring back the "on" setting. If it is restored to the same iPhone, it can also bring back the key that was in use when the backup was made. When the app starts after a restore or a move, it checks for this and turns "Help improve recognition" off before sending anything. You then need to turn it on again. If the restored key belongs to copies you have deleted, our server also refuses new copies under that key for 120 days after your last deletion (section 4.8).

4.8 When you delete your copies: the deletion record

After you delete your copies, our server keeps a small technical record for 120 days after your last deletion request.

What the record holds:

• the code derived from your key;
• the hour of the deletion;
• the number of copies deleted;
• the time after which it is deleted automatically.

It holds no meal content and no app ID. Our database also records the exact times the record was created and last changed. We use these times only for the automatic clean-up, and to include them, with the record, in the file from "Get a copy of saved copies" while this iPhone still holds the key (section 13.2).

Why we keep it. The record does two things:

• It stops a request that was still on its way, or an old key brought back by restoring a backup to the same iPhone, from saving a new copy under the deleted key.
• It lets a repeated deletion request report the same result.

120 days is 30 days longer than any copy can be kept.

After a deletion. The app saves nothing until you turn the switch on again. It then uses a new key, unrelated to the old one.

There is one exception. It applies if you restore an older backup to your iPhone and then turn saving on again more than 120 days after the deletion. In that case, new copies can be linked to the key that the backup brought back.

4.9 Logs and alerts

• Service logs record the type, time, duration and outcome of each request as codes. They never record the content, your app ID, your IP address or your key. They are kept for 30 days in Frankfurt.
• Google's request logs would contain IP addresses. They are not stored for our service.
• Administrative audit logs record changes that we or Google make to the service's configuration. Google keeps them for a fixed 400 days. They contain no app requests and no meal content.
• Alerts. Our monitoring is set up to e-mail us if the AI provider stops answering, if the service reaches its request limits or if the clean-up fails. These alerts contain no meal content.

4.10 Test versions before the App Store release

Before NCompanion was released on the App Store, test versions used by our team, testers and Apple's app review ran on a different server. Since 1 October 2026 that server processes no requests: it sends nothing to OpenAI and stores nothing. Some data from that period still exists. A spreadsheet of the old server holds copies of some analysis results; rows saved before 17 August 2026 can also include the text that was typed and the app ID of the installation. OpenAI may still hold some requests and answers that it stored for the old server. On 2 October 2026 we deleted the stored answers that OpenAI still showed us. We plan to delete the spreadsheet permanently once the last test installation has been updated, and we will update this section when this is done. Until then, you can ask us about this data (section 13). Deletion does not remove what our providers keep under their own terms: Google removes deleted files under its own deletion process, and OpenAI keeps abuse-monitoring logs and child-safety review copies as described in section 4.5.

5. How we use AI

What the AI does:

• recognises foods in meal photos and descriptions;
• estimates portions, calories and nutrients;
• turns voice notes into text;
• reads menu text and suggests dishes that fit your goal and what is left of today's targets;
• writes short tips about a product;
• translates the names of meals you logged earlier into the app's language.

Estimates, not facts. AI can get foods and portions wrong. Results are marked "≈ AI estimate", and the app shows them to you for review before you save them. You can correct them or discard them. Values for barcoded products come from Open Food Facts, not from AI.

NCompanion does not give medical advice. If you have a medical condition, an allergy or specific dietary needs, rely on a qualified professional and on product labels.

Who provides the AI. OpenAI (section 4.5).

Training. We do not train AI models with your data, and in our OpenAI organisation, sharing data with OpenAI for training is switched off.

No automated decisions about you. The AI produces estimates and suggestions, and you decide what to do with them. It makes no decision that has legal effects on you or affects you in a similarly significant way (GDPR Art. 22). Menu suggestions use your goal and what is left of today's targets only to answer that one request. We do not build a profile of you.

6. Food, weight and health information

NCompanion is an everyday nutrition diary, not a medical service. It does not ask about illnesses, diagnoses or medication.

EU data-protection law, however, takes a broad view of "data concerning health". What someone eats, and a goal to lose or gain weight, can reveal something about their health, especially over time. So we treat the meal information our server processes as health-related data. We apply the stricter rules that the GDPR sets for such data (Art. 9):

• Only with your explicit consent. You give it by tapping "Allow and continue" on the "Before your first analysis" screen. For quality copies, you give it by turning on "Help improve recognition".
• Easy to withdraw. You can withdraw either consent at any time in the app, as easily as you gave it. Withdrawal does not affect processing that was carried out before you withdrew.
• Kept only as described. We keep on our server only what section 4 describes.
• Never for ads or profiling. We never use it for advertising or marketing, never sell it and never use it to build a profile of you.

The most health-related information in the app stays on your iPhone and is never sent to us. That means your weight entries, your body measurements, the allergies and intolerances you mark, and your Apple Health data.

7. Apple Health

Connecting is optional. iOS asks you which types of data to allow, and you can change your choice at any time.

What the app reads, if you allow it:

• weight and height;
• steps;
• active and resting energy;
• walking and running distance;
• workouts;
• water;
• energy, protein, carbohydrates and fat logged by other apps.

What the app writes, if you allow it:

• the calories, protein, carbohydrates and fat of meals you confirm;
• water you log;
• weight you log in the app, if you allow this separately.

How the app uses it. The app uses this data on your iPhone to show your day, your activity and your energy balance. It can refresh these figures in the background when Apple Health changes.

What the app does not do with it.

• It does not send it to our server, to OpenAI or to anyone else.
• It does not use it for advertising, marketing or data mining.
• It does not share it.

Weight readings in the app. Weight readings that the app reads from Apple Health are also saved in the app's own storage on your iPhone, so that they appear in your weight history. Like the rest of the app's data, they are included in your iPhone's own backups (section 4.1).

To stop access. Use the Health app (your profile → Apps → NCompanion) or iOS Settings (Privacy & Security → Health). Data the app wrote stays in Apple Health until you delete it there.

8. Camera, microphone, photos and reminders

iOS asks your permission before the app can use any of these. You can change your answer in iOS Settings at any time.

• Camera: to photograph meals and menus and to scan barcodes. Barcodes and menu text are recognised on your iPhone.
• Microphone: to record voice notes of up to 15 seconds: in Say, for a short spoken detail in Point and Pick, and for spoken corrections to a meal.
• Photos: Pick shows your recent photos so that you can choose one. They stay on your iPhone until you choose one.
• Notifications: meal reminders are scheduled on your iPhone. We do not run a notification server and receive nothing about your reminders.

The app does not use your location or your contacts.

9. Why we use data: purposes and legal bases

10. Who receives data

We share data only with the service providers and bodies listed below, and only as far as each needs it.

What we never do.

• We do not sell personal data.
• We do not share it for advertising.
• We do not use advertising or analytics tools in the app.
• We do not track you across other companies' apps or websites. That is why the app never asks for tracking permission.

Equal protection. Two service providers process the app's data for us: Google Cloud and OpenAI. Each does so under written data-processing terms that are part of its service agreement with us, as GDPR Art. 28 requires. We confirm that these terms oblige each of them to protect the data at least as well as this policy describes:

• Google Cloud, under its Cloud Data Processing Addendum, which is part of the Google Cloud Terms of Service;
• OpenAI, under its Data Processing Addendum, which is part of OpenAI's Services Agreement.

Open Food Facts is an independent provider, not our processor. We have no data-processing terms with it, so we cannot give this confirmation for it. Our server sends Open Food Facts only a barcode number, with no identifier. When your iPhone loads a product picture, Open Food Facts sees your IP address and which product's picture is requested. Its own privacy policy applies to this.

Our website and our mailbox.

• Cloudflare hosts our website as our processor, under the Cloudflare Data Processing Addendum, which is part of its Self-Serve Subscription Agreement. Under the same agreement, Cloudflare may also use information that it derives from traffic to our website to provide, maintain, develop and improve its own services. If that information includes personal data, Cloudflare has committed to handle it in line with data protection law, but our data-processing terms do not cover this use.
• Inbox.eu (SIA INBOKSS) runs our mailbox. Its terms of service state that it acts as our processor and stores the data in line with Latvian law and the GDPR.

11. Transfers outside the European Economic Area

• Our server and database are in Frankfurt, Germany, inside the EU. Google's Cloud Data Processing Addendum, which is part of the Google Cloud Terms of Service, governs how Google handles this data, including any access from outside the EEA. For transfers to the United States, Google relies on the EU-U.S. Data Privacy Framework, under which Google LLC is certified. The European Commission has decided that this framework gives adequate protection (GDPR Art. 45). For transfers to other countries without such a decision, the Addendum provides for the European Commission's Standard Contractual Clauses between Google and the companies that process data for it (GDPR Art. 46(2)(c)). Google publishes the Addendum, with links to these Clauses, at https://cloud.google.com/terms/data-processing-addendum.
• OpenAI. Under section 4.1 of OpenAI's Data Processing Addendum, our requests are processed by OpenAI Ireland Ltd, in the EU. The Addendum is part of OpenAI's Services Agreement, which applies to our use of OpenAI's API. We use OpenAI's standard processing and not its EU data-residency option. So OpenAI Ireland may pass AI requests to other OpenAI companies and to other providers outside the EEA, including in the United States. Section 4.1 of the Addendum says that it will do this on the basis of agreements that contain the European Commission's Standard Contractual Clauses (GDPR Art. 46(2)(c)), or of a decision by the European Commission that the country gives adequate protection (GDPR Art. 45). These are OpenAI's own agreements. We are not a party to them and do not have a copy of them. Data protection law in those countries may give you less protection than EU law, and authorities there may be able to request access to data. You can ask us at [email protected] for a copy of OpenAI's Data Processing Addendum, which contains this commitment. OpenAI also publishes it at https://openai.com/policies/data-processing-addendum.
• Our website host. Cloudflare, Inc., a US company, delivers our website through its global network. Your IP address and the details of your request may therefore be processed outside the EEA, including in the United States. Cloudflare, Inc. takes part in the EU-U.S. Data Privacy Framework, which the European Commission has decided gives adequate protection (GDPR Art. 45). If its certification lapses or is invalidated, the European Commission's Standard Contractual Clauses in the Cloudflare Data Processing Addendum apply instead (GDPR Art. 46(2)(c)).
• Our e-mail provider. Inbox.eu (SIA INBOKSS) is a Latvian company. It states that it stores e-mail on its servers in Latvia, inside the EU.

12. How long data is kept

We make no backups or exports of our own.

13. Your choices and rights

13.1 Controls in the app

• Stop AI analysis: You → Settings → Data & Privacy → turn off "Send meals for AI analysis". Nothing more is sent for analysis. "Help improve recognition" is turned off with it, as described in the next point.
• Stop quality copies: turn off "Help improve recognition" in the same place. No new copies are made, and the app asks our server to delete the copies saved from this iPhone. It shows "Done" only after our server confirms. If our server cannot be reached, the app tells you and tries again (section 4.7).
• Get a copy of quality copies: "Get a copy of saved copies", in the same place. It covers the copies linked to the keys this iPhone holds, works whether the switches are on or off, and changes nothing (section 13.2).
• Delete quality copies now: "Delete saved copies", then confirm.
• See what is sent, and to whom: "What is sent, and to whom", in the same place.
• Delete data on your iPhone: "Reset profile & data" in You → Settings → Data & Privacy deletes your profile and personalisation. To delete your journal and weight entries, delete the app. Neither removes the random app ID or the quality key from the iPhone's Keychain (section 4.1).
• Apple Health, camera, microphone, photos and notifications: in iOS Settings.

Withdrawing your consent. These two switches are how you withdraw the consents you gave in the app: "Send meals for AI analysis" for AI analysis, and "Help improve recognition" for quality copies. Turning off "Send meals for AI analysis" also stops barcode look-ups. You can turn the switches off at any time, as easily as you gave your consent. Withdrawal does not make the processing carried out before it unlawful.

13.2 Your rights under the GDPR

• Access (Art. 15): to ask whether we hold data about you, and to get a copy. For quality copies, use "Get a copy of saved copies" in the app (see below).
• Rectification (Art. 16): to have wrong data corrected. You can correct everything on your iPhone yourself.
• Erasure (Art. 17): to have your data deleted. Quality copies can be deleted in the app at any time (section 4.7).
• Restriction (Art. 18): to ask us to limit how we use your data, for example while we check a complaint.
• Portability (Art. 20): to receive data you gave us on the basis of consent or contract, in a machine-readable format. The file from "Get a copy of saved copies" is in such a format (see below).
• Objection (Art. 21): see section 13.3.
• Withdrawal of consent (Art. 7(3)): at any time, as easily as you gave it (section 13.1). Withdrawal does not affect processing carried out before it.
• No solely automated decisions (Art. 22): we make none (section 5).
• Complaint (Art. 77): see section 13.5.

What these rights mean in NCompanion. We have no account for you, and your diary is on your iPhone, under your control.

On our server, quality copies are linked only to a key on your iPhone, not to your name, e-mail or app ID. We therefore cannot find them from an e-mail request, and we will not ask you for extra data just to identify you (GDPR Art. 11). The app is the way to reach them, with "Get a copy of saved copies" and "Delete saved copies". Copies we cannot attribute to anyone are deleted automatically after their 90 days.

Getting a copy of your quality copies (Arts. 15 and 20). In the app, go to You → Settings → Data & Privacy and, in the "AI analysis" section, tap "Get a copy of saved copies".

• When you can use it. Whether AI analysis and "Help improve recognition" are on or off. It asks for no new consent, changes no setting and deletes nothing.
• Which keys it uses. The keys this iPhone holds: the key in use and any keys whose deletion is still waiting for our server's confirmation (section 4.7). The request carries these keys and the app's access code, but no app ID and no meal content (section 4.2). If this iPhone holds no key, the app sends nothing and says that there are no saved copies available from this iPhone right now.
• What the file contains. For each key: every copy stored under it, with every field stored in it (section 4.7), its identifier in our database and the exact times our database wrote it and last changed it. If there is a deletion record for the key, the file contains it too, with the exact times our database created it and last changed it (section 4.8). Copies past their 90 days, and deletion records past their 120 days, that the automatic clean-up has not removed yet are included and marked as such. The file leaves out only the internal code derived from your key, which links the copies to it.
• Complete, or an error. The app makes the file only when our server confirms that it has read everything stored under these keys. Otherwise the app shows an error and "Try again". It never shows an error as "no copies", and never passes off part of your copies as all of them. If nothing is stored under these keys, the app says that there are no saved copies available from this iPhone right now.
• The file. The app makes it on your iPhone from our server's answer. It is a JSON file, a common machine-readable format, with explanations, in the app's language, of every field, the units and the time zones. The app opens the iPhone's share sheet, and you decide where to save or send the file. The app does not send it anywhere for you.
• Afterwards. The app deletes the file from its temporary storage when the share sheet closes, whether or not you shared it, or when you leave the screen. If you are no longer on the screen when our server's answer arrives, the app does not make the file. A file left behind, for example because the app was closed, is deleted the next time the app starts. A file you saved or sent is under your control.
• On our server. Our server uses the keys only to read what is stored under them, and changes nothing. It keeps neither the keys nor its answer, and neither our server nor the app keeps the answer in a cache. As for every request, the service log records the request as codes, never the keys or the content of your copies (section 4.9). To protect the service from overload, our server also counts the request, without any identifier (section 4.4).

What the app cannot reach. The app reaches only what is stored under keys this iPhone still holds. It cannot reach copies saved from another device, or before this iPhone's key was lost, for example after you erased the iPhone or moved to a new one (section 4.7). After our server confirms a deletion, the app removes that key, so the deletion record (section 4.8) can no longer be reached from the app either, unless restoring an older backup of this iPhone brings the key back. The app never shows you its keys, and we cannot tell which of these copies or records are yours, so we cannot give you a copy of them. Under GDPR Art. 11(2), your rights of access, rectification, erasure, restriction and portability then apply to them only if you give us additional information that lets us identify them. They are deleted automatically, as described in sections 4.7 and 4.8.

If you believe we hold other data about you, for example e-mails you sent us, write to us and we will help.

13.3 Your right to object

You can object at any time to processing based on our legitimate interest (section 9, rows 5–11). Write to [email protected]. We will stop unless we have compelling legitimate grounds that override your interests, or we need the data to establish, exercise or defend legal claims.

13.4 How to make a request

• Where to write: [email protected]. It is free of charge.
• When we answer: within one month. If a request is complex, or if there are many requests, we may extend this by up to two more months, and we will tell you why within the first month.
• Identity: if we need to confirm that a request comes from you, we will ask only for what is necessary.
• If we cannot help: if we cannot act on a request, we will explain why and tell you about your right to complain.

13.5 Complaints

You can complain to a data-protection supervisory authority. That can be the authority in the EU country where you live or work, or where you think the problem happened. Our lead authority is:

Data State Inspectorate of Latvia (Datu valsts inspekcija)
Elijas iela 17, Rīga, LV-1050, Latvia · [email protected] · +371 67223131 · www.dvi.gov.lv

We would appreciate the chance to sort out your concern first, at [email protected].

14. Do you have to provide data?

No law or contract requires you to give us any data.

• Without consent to AI analysis: features that work on your iPhone keep working, but the app cannot analyse meals, read menus, give tips, translate dish names or look up barcodes.
• "Help improve recognition": optional. Without it, all features work the same, and our server keeps no quality copies of your results.
• Profile details: you enter them to calculate your targets, and they stay on your iPhone.
• Apple Health, camera, microphone, photos and notifications: all optional.

15. How we protect data

• Encrypted connections: all connections between the app, our server, OpenAI and Open Food Facts use encryption (HTTPS).
• Access code: every request to our server must carry the app's access code. The clean-up task uses a separate secret code.
• No names or accounts: we use random identifiers instead. The quality key is stored only in your iPhone's Keychain and, encrypted, in that iPhone's own backups. The app sends the key to our server only to delete your copies or to give you a copy of them (sections 4.7 and 13.2). Our server uses it only for that request and does not store or log it. Our server stores only a code derived from the key.
• Encrypted storage: Google Cloud encrypts stored data by default. Our secret keys are kept in Google Secret Manager, in the EU only.
• Limited access: only the company's owner has access to the production systems.
• Logs without content: logs record codes, not content, and request logs with IP addresses are not stored.
• Checked clean-up: the automatic clean-up repeats itself if it fails, and failure alerts are set up.
• Little data on the server: we keep no photos, voice recordings, diaries or backups of our own on the server.
• Breaches: if a personal data breach puts your rights at risk, we will notify the Data State Inspectorate and, where the law requires, you.

16. Children

NCompanion is not intended for anyone under 16, and our Terms of Use require users to be at least 16. We do not knowingly process children's personal data. Because there are no accounts, we do not know who uses the app. When you set up or edit your profile, the app accepts an age of 16 or over only; it cannot verify the age you enter. The age you enter is used on your iPhone only, to calculate targets.

If you are a parent and think a child has used AI features with "Help improve recognition" turned on, you can delete the copies saved from the child's iPhone. On that iPhone, use "Delete saved copies", or turn "Help improve recognition" off (section 13.1). You can also contact us.

17. Our website

conelmarketing.com is a static website. It has no accounts and no forms. It is hosted and delivered by Cloudflare, our service provider (section 10).

What Cloudflare receives. When you open a page, Cloudflare receives your IP address, the address of the page, the time of the request and technical details of your browser, such as its type and version. On our behalf, Cloudflare uses this data to deliver the pages to you and to protect our website from attacks and abuse. Cloudflare may also use information it derives from traffic on its network, which can include visits to our website, to provide and improve its own services, under its own terms. Cloudflare's network is worldwide, so a request may be handled outside the European Economic Area (section 11).

Network error reports. When Cloudflare delivers our pages, it asks your browser to tell Cloudflare if loading our website fails, for example because the connection breaks or the website returns an error. This is a browser feature called Network Error Logging, and not every browser supports it. Such a report contains details of the failure, such as the page address, the type of error and timings, and Cloudflare receives it from your IP address. No report is sent when a page loads normally. Your browser keeps this instruction for up to 7 days after your last visit. It is not a cookie.

Fonts. The fonts are stored on our own website. Opening a page does not connect your browser to Google or to any other font service.

E-mail addresses on our pages. To hide e-mail addresses from spam robots, Cloudflare scrambles them in the page code. A small Cloudflare script, loaded from our own website, makes them readable in your browser. The script sets no cookie.

No analytics, advertising or tracking. Our website uses no analytics tools and no advertising tools, and it does not track you across other websites.

Cookies. The code of our pages sets no cookies, and in our checks normal visits to the website received no cookie at all. However, Cloudflare's protection can give a short security check to a visit that looks suspicious to it, for example because it seems to come from an automated program. For this check, Cloudflare looks at technical signals from your browser and sometimes asks you to tick a box. If your browser passes, Cloudflare places the cookie "cf_clearance". It records that your browser has passed the check, so that you are not checked again on every page. On our website it is valid for 30 minutes. Cloudflare's check can also place cookies named "cf_chl_rc_i", "cf_chl_rc_ni" or "cf_chl_rc_m", which Cloudflare uses to find technical problems with its checks. Cloudflare describes these cookies as strictly necessary for its services. We do not use them for analytics, advertising or tracking. You can delete or block cookies in your browser settings.

Legal basis. We rely on our legitimate interest in delivering the website and keeping it secure (GDPR Art. 6(1)(f); section 9, row 9). You can object to this (section 13.3).

How long. We keep no logs of website visits ourselves. Cloudflare keeps the data it processes for us, such as its records of requests, only as long as it needs it to provide its service to us, and no longer than our agreement with it lasts unless the law requires otherwise. What it keeps for its own purposes is governed by its own terms. The security cookie and the network error instruction last as described above.

If you e-mail us, we use your message to answer you and to deal with any follow-up on the same matter. We keep it for 12 months after the matter is closed. Our mailbox is run by Inbox.eu (SIA INBOKSS, Latvia) (section 10).

18. Changes to this policy

If we change this policy, we will publish the new version here with a new version number and date, and we will point out important changes in the app or on this website. If a change affects what the app sends or who receives it, the app will ask for your consent again before it sends anything.

Version history

• 3.0, 9 October 2026: This version replaces the policy of 24 August 2026. It describes the server in Frankfurt, the optional quality copies linked to a device key, and how to get a copy of them and delete them in the app.

19. Contact

SIA CONEL MARKETING · registration number 40103478376

Rusonu iela 30 k-1-21
Riga, LV-1057
Latvia

Privacy: [email protected] · Support: [email protected]