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Privacy Policy

Splot is a food journal. You record meals, foods and nutrition targets, and you can connect an AI assistant such as ChatGPT to read and update your journal. This policy explains what information that involves and what we do with it. It applies to the Splot app, the website at splot.health, our sign-in and account pages, and assistant connections (together, the “Services”).

Summary

1. Who we are

Splot is operated by Konrad Dębiec Cloud&ML Services, Szlak 77/222, 31-153 Kraków, Poland, NIP 9482637969, registered in CEIDG (the Polish business register) (“Splot”, “we”, “us”). We are the controller of the personal information described in this policy.

We may later transfer Splot to a company we set up to run it. If that happens, we will tell you in advance, name the new operator, and the new operator will be bound by this policy.

Contact us about privacy at privacy@splot.health.

2. Information we collect

Account information. You sign in with Apple or Google. We receive your email address and, if the provider shares it, your name. If you choose Apple’s “Hide My Email”, we receive a relay address instead of your own. With Google, we also receive a link to your Google profile picture. We keep that link with your sign-in details, and the app uses it to show your avatar. The picture itself stays on Google’s servers. Your device loads it from there and may keep a temporary copy in the app’s cache, but it is never sent to Splot. We also keep an account identifier, the display name you set, and when your account was created.

Your journal. This covers what you save in Splot, directly or through an assistant:

Your nutrition profile. Daily calorie and macronutrient targets, unit preference, weight, height, age, sex and activity level.

Product corrections. Sometimes you change a product that comes from our shared food catalogue, such as its name, brand, barcode, nutrition values, portion sizes or composition. We keep a record of the change so we can review it for the shared catalogue (section 6). Notes, photos and your own portions are never part of a correction.

Assistant connections and API keys. When you connect an assistant, we keep a record of the authorization and of which assistant created or changed each record. If you create personal API keys, we keep each key’s name, permission, expiry and last-use time. We store only a one-way hash of each key, never the key itself.

Subscription information. If you subscribe to Splot Pro, Apple or Google processes the payment. RevenueCat, our subscription provider, tells us your plan, trial and renewal status. We never receive your card details.

Support messages. If you write to us, we receive your email address and whatever you include in your message.

Technical information. Our servers receive your IP address, device and app information, and the requests your device or assistant makes. Our logs record each request’s address, result and duration, which assistant tool was used, and error messages. Error messages can include the name of a food.

Website analytics. When you visit splot.health, PostHog records the pages you view, the links and buttons you click, how far you scroll and where your pointer moves, how quickly pages load, where you came from, and your browser and device type. If you accept analytics cookies, a random identifier lets us recognise your later visits, and PostHog may also record your IP address and the approximate location derived from it. If you don’t, visits are counted without storing anything on your device, and PostHog uses your IP address only to work out a code that changes every day, without keeping the address or deriving your location (section 12). The Splot app and your journal are not part of this.

What stays on your device. Onboarding answers that are not listed above, such as goal weight and pace, stay on your device and are not sent to us. Barcode scanning happens on your device, and only the barcode number is sent to look up the product. Your sign-in session is stored in your device’s secure storage.

We do not collect your precise location, contacts or advertising identifiers. We do not use the location data that photos can carry.

Meals, weight, targets and similar records can reveal information about your health. Many laws, including the EU and UK GDPR and several US state laws, treat such information as sensitive. We handle all of it as health information.

When you create your account, Splot asks for your explicit consent to process this information to provide the Services. This consent is separate from accepting the Terms of Use. Without it, Splot cannot store your journal. Sharing your records with an assistant needs a second, separate consent, given on the connection screen when you connect it (section 5).

You can withdraw your consent at any time by deleting your account, or by writing to privacy@splot.health. Withdrawing does not affect processing that took place before.

4. How we use your information

Purpose Information used Legal basis (EEA, UK and Switzerland)
Create and secure your account; sign you in Account information, technical information Contract
Store, calculate and show your journal and nutrition profile Journal, nutrition profile Explicit consent (health information); contract
Carry out requests from assistants and API keys you authorize Journal, nutrition profile, connection records Explicit consent (health information); contract
Search the food catalogue and review product corrections Search terms, barcodes, corrections Contract; legitimate interest in an accurate shared catalogue
Manage Splot Pro subscriptions and trials Subscription information Contract; legal obligation (tax and accounting records)
Answer support and privacy requests Support messages, account information Contract; legal obligation (privacy requests)
Keep the Services running and secure; investigate errors and abuse Technical information Legitimate interest in a reliable and secure service
Understand how people use our website Website analytics Consent (analytics cookies); legitimate interest (counting visits without cookies)
Comply with the law and defend legal claims Information relevant to the matter Legal obligation; legitimate interest

We do not:

To improve Splot, we use technical information, website analytics and feedback you send us, not the contents of your journal.

5. AI assistants

Splot can connect to ChatGPT and other AI assistants that support the Model Context Protocol. Connecting one is always your choice, and you approve it on a connection screen that lists what the assistant will be able to do.

A connected assistant can read your meals, foods, photos, nutrition targets and unit preference, and your account’s name and email address. It can log, plan, change and delete meals and foods, and change your targets. Splot does not limit a connection to particular records.

The assistant’s provider receives what it reads and handles it under its own terms and privacy policy, as a separate controller. That provider decides how long it keeps conversations and whether it uses them to train models. Our commitments in this policy do not bind it. Check the provider’s settings before you connect.

To stop an assistant’s access, disconnect Splot in that assistant’s settings, or delete your account. Disconnecting stops future access. It does not delete copies the provider already holds; ask the provider to delete those.

Estimates the assistant makes, such as calories read from a photo, are the assistant’s. Splot does not analyse photos or estimate nutrition itself.

6. Sharing your information

We share personal information only as described here.

Service providers. These companies process information on our behalf under contracts that limit them to providing their service to us:

Provider Role Location
Supabase Database, sign-in and photo storage Ireland; read replicas in the United States
Vercel Backend hosting Ireland for processing; request logs and parts of its platform in the United States
Cloudflare Website hosting Global network
PostHog Website analytics European Union
RevenueCat Subscription status United States
Our email provider Receives and stores messages sent to our contact addresses EU or United States

Companies you choose to use. Apple and Google sign you in and process payments under their own terms and privacy policies. The same applies to an assistant you connect (section 5).

The shared food catalogue. If we accept one of your product corrections, the corrected product details become part of the catalogue that all Splot users see. We never publish your identity with it.

Legal reasons. We may disclose information if a valid legal request requires it, or to protect the safety of people or the Services. We share only what is necessary, and we assess requests involving health information with particular care.

A change of operator. If Splot is transferred to a new operator, including a company we set up, your information moves with it under the terms of this policy. We will tell you before that happens.

7. How long we keep information

Information How long
Account, journal, nutrition profile, photos Until you delete them or your account
Earlier versions of a meal Until you delete the meal or your account
A photo you remove from a meal Deleted when you remove it, unless another meal or food still uses it
A food you delete Removed from My foods straight away, and kept out of sight for the meals and recipes that used it until you delete your account
Product corrections Until you delete your account. An accepted correction stays in the shared catalogue without your identity.
Assistant authorizations Until you disconnect the assistant or delete your account
API keys Until they expire (at most one year), you revoke them, or you delete your account
Backups Up to 30 days, after which they are overwritten
Server and sign-in logs Up to 30 days
Website analytics Up to 1 year
Support messages Up to 2 years after the conversation ends
Subscription and transaction records As long as tax and accounting law requires, usually 5 years after the end of the year of the transaction

We never restore deleted information from a backup into normal use. If we ever have to restore a backup, we delete again anything that had already been deleted.

8. Where your information is processed

We store your account and journal in Ireland. Some information is also processed in the United States:

Our providers may also give technical support from other countries.

When personal information from the EEA, UK or Switzerland is transferred to a country without an adequacy decision, we rely on the EU–US Data Privacy Framework where the recipient is certified, and otherwise on the European Commission’s Standard Contractual Clauses and their UK and Swiss equivalents. You can ask us for a copy of these safeguards at privacy@splot.health.

9. Security

We protect your information with these measures:

Access by people who run Splot is limited to what support, security and our legal obligations require. Splot is not end-to-end encrypted, because our servers must process your records to provide the Services.

If a security breach affects your information, we will notify you and the authorities where the law requires. This includes the EU and UK GDPR and the US Federal Trade Commission’s Health Breach Notification Rule.

10. Your choices and rights

In Splot or through a connected assistant.

Deleting your account. In the app, tap your avatar, open your account and choose Delete account, or sign in at app.splot.health/account and choose Delete account. This deletes your journal, nutrition profile, photos, corrections, consents, assistant authorizations and API keys. Signing out or uninstalling the app does not delete anything. See Deleting your account for details.

By writing to us. Email privacy@splot.health from the address on your account to:

We may ask you to confirm that the account is yours. We never ask for more health information to do that.

We respond within one month, or sooner where your law requires. If a request is complex, we may extend this where the law allows and will tell you why. We will not treat you differently for exercising your rights.

EEA, UK and Switzerland. You have the right to:

You can complain to your local data protection authority. Our lead authority is Poland’s President of the Personal Data Protection Office (UODO), uodo.gov.pl. We would appreciate the chance to resolve your concern first.

United States. Depending on your state, you may have the right to:

To appeal, reply to our decision with “Appeal” in the subject line. If you disagree with the outcome, you can contact your state attorney general. We do not sell personal information or share it for targeted advertising, so there is nothing to opt out of. Residents of Washington, Nevada and other states with consumer health data laws can also read our Consumer Health Data Privacy Policy.

11. Age requirement

Splot is only for people aged 18 and over. We do not knowingly collect information from anyone younger. If you believe someone under 18 has an account, contact privacy@splot.health and we will delete it.

12. Cookies and similar technologies

Our sign-in and account pages use cookies that keep you signed in and protect the sign-in process. If you choose a light or dark theme on these pages or on our website, a splot-theme cookie remembers it on both; it holds only that choice, and we don’t record it. The Splot app keeps your session in your device’s secure storage. Our website sets analytics cookies only if you accept them, and you can change your choice with Cookie settings at the bottom of every page. We do not use advertising cookies. See our Cookies Policy for the public website.

13. Changes to this policy

We will update the date at the top whenever we change this policy. For a significant change, we will tell you in the app or by email before it takes effect. We will never use your health information for a new purpose without asking for your consent first.

14. Contact