Privacy Policy

Effective date: 2026-10-24

Last updated: 2026-10-24

Operator: DevX Group LLC ("we", "us")

Contact: privacy@devxgroup.io

App: Nutrify.AI (Apple App Store ID 6763514365, bundle and Google Play ID io.devxgroup.nutrifyai)

This is the per-app addendum to the shared DevX Group LLC corporate privacy policy at devxgroup.io/privacy. The corporate-wide sections (who we are, governance, cookie practices, your global rights) live on the parent page; this addendum covers what is specific to Nutrify.AI.

1. Plain-language summary

Nutrify.AI is a personal nutrition, exercise, sleep, and lab-data assistant. We collect what you tell us and what you log (and, only if you connect it, sleep, workouts and daily heart and fitness summaries from Apple Health or Health Connect, plus workouts you record with the Nutrify.AI Apple Watch app), store it in your account, send a bounded slice to third-party AI providers when you ask the AI for help, and use it to generate personalized recommendations only inside your account. We also use first-party product analytics (PostHog) to see how people use the app so we can fix problems and improve it. Analytics records that you opened a screen or created a log, tied to your account ID. It never records the contents: not the food, not the number on the scale, not a lab value, not a journal entry. Analytics also includes session replay on the paywall screens only, with all text and images masked, so we can see where the purchase flow confuses people without ever capturing your health or nutrition content; it runs under the same analytics toggle. Because knowing that you uploaded a lab report is itself health information, we treat these events as health data too: they stay first-party, they are never used for advertising, they are never shared with an advertising or data-broker network, and they are off unless you allow them: the app asks once, and you can change your answer any time in Settings then Support. Separately from the app, our public marketing page at nutrilogical.co runs a Meta advertising pixel so we can tell which ads bring people to the page. It only ever records that a browser opened a marketing page, it is not on any of our legal or account pages, and it never sees your account or anything you log. §4a has the detail. We do not sell your data. We do not use your data for advertising. We do not use your personal data to train AI models, including large language models, and our AI providers (Google Gemini and Anthropic Claude) do not train on it either under their commercial API terms. Every AI request is processed for that single response and not retained for training by our providers under their commercial API terms. You can delete everything from inside the app at any time.

2. What we collect

We do NOT collect: precise location, contacts, browsing history outside the app, microphone audio (voice input uses your phone's own speech recognition, Apple's on iPhone and Google's on Android, which may turn your voice into text on the phone or on Apple's or Google's servers under their own terms; Nutrify.AI only ever receives the finished text), social-graph data, or anything from Apple Health or Health Connect beyond what section 2a lists, and those only after you connect.

Notifications. If you allow them, we send reminders and nudges through Apple Push Notification service on iPhone. On Android, reminders are scheduled on your phone itself; we do not use Google's push service. The notification text never contains a lab value, a weight, or anything else you logged, so nothing sensitive shows on your lock screen. Turn them off any time in your device settings or in Settings then Notifications inside the app. Notifications are optional and the app works without them.

2a. Apple Health and Health Connect (optional)

Nutrify.AI can read sleep, workouts and daily heart and fitness summaries from Apple Health on iPhone, or sleep and workouts from Health Connect on Android. This is off until you turn it on in Settings, then Wearables, then Connect, and confirm on the permission screen your phone shows. Data from an Apple Watch, or from any other watch or ring that saves to Apple Health or Health Connect, arrives the same way.

What we read: sleep sessions (when you went to bed, when you woke up, how long you slept, and your light, deep and REM stages when your device records them, which we use only to work out your time asleep; we store your bedtime, wake time and time asleep, not the stages) and workouts (the type, the start and end time, the duration, the calories your device counted, on iPhone the distance, and the ID your phone gave the workout so we never import the same one twice).

On Android, for each imported workout we also read the active calories that the same app recorded during that workout, so the workout shows how many calories it burned. We read them only inside that workout's time window, never outside a workout, and never store them separately.

On iPhone we also read one daily summary each for resting heart rate, heart rate variability, blood oxygen, breathing rate, VO2 max, steps, and active calories. Apple Health calculates each day's number on your phone, and we receive only that one number per day. For these daily health summaries, we do not import the underlying individual readings.

Nutrify.AI Apple Watch app: if you start a workout in it, your watch measures heart rate, active calories and distance during that workout through Apple Health. During that workout the watch checks your latest heart rate every few seconds. It uses those readings on the watch to show your live heart rate, a short heart-rate chart and your heart-rate zones. While your iPhone is nearby, the watch also sends your current heart rate, calories and distance to it every few seconds so the iPhone can show the workout live; your iPhone does not store these live readings. While the workout runs, Apple Watch itself saves the heart rate, active calories and distance it measures to Apple Health, the same way it does for every watch workout. When you end the workout, the watch app saves the workout itself to Apple Health, linked to those readings, and sends a summary to the Nutrify.AI app on your iPhone: the workout type, start and end time, average and highest heart rate, time in each heart-rate zone, active calories, and distance. Only that summary is stored: your iPhone stores it in your account. The watch never sends anything to our servers by itself; if your iPhone is out of range, the summary waits on the watch until it is back. To work out your heart-rate zones, the watch reads your date of birth from Apple Health and uses it on the watch only; it is never sent to your iPhone or our servers.

What we do not read: location, medical records, your date of birth on iPhone, your heart rate at any time other than during a workout you record with the Nutrify.AI Apple Watch app (the daily resting heart rate summary above is a single daily number), steps, distance, or calories outside an imported workout on Android, or anything else in Apple Health or Health Connect. The Nutrify.AI iPhone app never writes to Apple Health. The only thing Nutrify.AI writes is from its Apple Watch app, and the only write permission it asks for is to save workouts: when you end a workout there, the watch saves it to Apple Health, together with the heart rate, calories and distance Apple Watch recorded during it, so it counts like any other watch workout. We never write anything into Health Connect.

What happens to it: when you connect, we read the last 30 days (for daily summaries, starting at midnight on the day 30 days ago). After that, each time you open the app or tap Sync now, we read from one day before your last sync, so nothing is missed. Imported sleep, workouts and daily summaries are stored in your account on Supabase next to what you log by hand, marked as imported, and every section of this policy treats them as health data. They show in your charts and, like anything you log, they can be part of the bounded slice sent to Google Gemini or Anthropic Claude (each is the backup for the other: daily insights and meal photos go to Claude first, everything else goes to Gemini first; section 4) when the coach, your daily insights, the sleep insights, or the morning brief run for you. They are never used for advertising or marketing, never sold, never given to a data broker, never used for data mining, never stored in iCloud, and never shared with anyone except the processors in section 4. Apple, as the maker of Apple Health, and Google, as the maker of Health Connect, do not receive your Nutrify.AI data through this connection: the read happens on your phone. Google's Gemini AI service is a separate processor, covered in section 4.

Turning it off: Settings, then Wearables, then Disconnect stops new imports. You can also take away Nutrify.AI's access inside the Apple Health app or the Health Connect app. Sleep, workouts and daily summaries already imported stay in your history until you delete them one by one or delete your account.

3. How we use your data

Most of what you log with Nutrify.AI is health data. Under the GDPR that is "special category" data and it gets extra protection, so we ask for your explicit consent before we process any of it, separately from your agreement to the Terms. You give that consent at sign-up and you can withdraw it at any time by emailing privacy@devxgroup.io or by deleting your account in Settings. Withdrawing stops all future processing. It does not undo processing we already did while your consent was in place.

In the app this health-data consent is its own box during onboarding, separate from the Terms box at sign-up. It starts empty, and that one box covers both our collection of your health data and our sharing of it with the processors in section 4. To withdraw it, delete your account in Settings (Delete Account is at the bottom of the screen) or email us. To stop only the Apple Health or Health Connect import, go to Settings, then Wearables, then Disconnect.

If you withdraw consent, Nutrify.AI cannot do the thing it exists to do, so withdrawing also ends your ability to use the health features.

Anything the AI writes in the app (coach replies, meal analysis, insights, plans, recipes) is labelled “Generated by AI”.

We do NOT use anything in your account for: advertising, cross-app or cross-company tracking, behavioral profiling that follows you outside Nutrify.AI, model training (third-party or our own), or sale to data brokers. Nothing you log in the app, and no event describing what you did in the app, ever reaches an advertising network. We do use first-party, in-product analytics (PostHog) to understand how people use the app and improve it; that data stays first-party, is never used for advertising, and is described in the rows above and §4. Our public marketing page at nutrilogical.co is a separate surface with its own rules, and it does carry an advertising cookie: §4a says exactly what it does and what it cannot see.

4. Third-party processors

We share data only with the processors strictly required to operate the app, each under a written data-processing agreement.

Sub-processors of these vendors (e.g., AWS, GCP) operate under each vendor's published sub-processor list. We update this table whenever a primary vendor changes.

Apple Health and Health Connect are not processors. When you connect them (section 2a), the read happens on your phone. Apple and Google never receive your Nutrify.AI data through that connection. A workout you record with the Nutrify.AI Apple Watch app, and the heart rate, calories and distance measured during it, are saved into Apple Health on your own devices, where they sit like any other watch workout under your Apple Health settings.

Food databases. When you scan a barcode or log a food, our server looks up nutrition facts in the U.S. Department of Agriculture's FoodData Central and in Open Food Facts. The request carries only the barcode number or food description, never your name, account ID, or any other personal data.

4a. The website (nutrilogical.co)

Everything above is about the app. This section is about the public web pages, which are a separate surface with separate data.

What runs on the marketing page. Our home page carries two things: Vercel Web Analytics, which counts page views with no cookie and no identifier, and the Meta Pixel. A pixel is a small piece of an advertiser's code, plus a cookie, that reports back to the advertiser that a browser opened the page. We run Meta's because when we pay for an ad on Instagram or Facebook, it is the only way to know whether that ad brought anyone to the site instead of burning the money.

What it sends. One event, called PageView, meaning "a browser loaded this page". With it Meta receives what any web request carries: your IP address, your browser and device type, the page address, and Meta's own cookie if you are signed in to Facebook or Instagram in that browser. We do not send Meta your name, your email, or your account ID, and we have deliberately not added the extra events an advertiser normally adds next, such as one that fires when you tap a download button, because those describe what you were interested in.

Where it is not. The pixel is on the marketing page only. It is deliberately absent from this Privacy Policy page, the Terms, the Consumer Health Data notice, the account deletion page, and the password reset page. Reading one of those says something about your health or your account, and we are not willing to hand that to an ad network. The pixel cannot see that you came here, and it cannot see that you deleted your account.

What it can never reach. The pixel runs in your browser on a public page. It has no connection to the app, no access to your Nutrify.AI account, and no way to see a meal, a lab value, a weight, a sleep record, or a journal entry. Those live behind your sign-in, and no advertising network touches them, as §3 says.

How to stop it. Any tracker blocker, private browsing in Safari or Firefox, or the ad-measurement controls in your Meta account settings will stop it, and so will browsing with JavaScript off. Nothing on the site breaks if you block it, and blocking it has no effect on the app.

5. Where your data is stored

Primary storage is Supabase US-East. Processing for AI inference happens on the AI vendor's infrastructure (Google US, Anthropic US). Crash diagnostics live on Sentry US. For people in the European Economic Area, the United Kingdom and Switzerland, each transfer to the United States relies on the EU-U.S. Data Privacy Framework (with its UK Extension and the Swiss-U.S. Data Privacy Framework) where the receiving processor is certified under it, and otherwise on the European Commission's Standard Contractual Clauses (with the UK International Data Transfer Addendum) in that processor's data-processing agreement. Health data is sent only with your explicit consent (section 3). Email privacy@devxgroup.io for a copy of the safeguards that apply.

5a. EU and UK residents: Article 27 representation

DevX Group LLC is established in the United States and offers Nutrify.AI to users in the European Economic Area and the United Kingdom, so Article 27 of the GDPR and of the UK GDPR applies to us and we treat it as binding.

Our EU and UK representative under Article 27 is being appointed and will be named here. Until then, contact privacy@devxgroup.io for anything you would otherwise raise with a representative: access, correction, erasure, objection, restriction, portability, withdrawal of consent, or a complaint. Requests from the EEA and the UK are handled by us directly, on the timelines in §7, so nothing is lost in a hand-off.

None of this narrows your rights. You can always complain to your own supervisory authority (in the EEA, your national data protection authority; in the UK, the Information Commissioner's Office) without contacting us first.

6. How long we keep your data

7. Your rights

Regardless of jurisdiction, you can:

• Export your data: Settings → Support → "Export My Data" gives you a JSON archive of your data on the spot, right in the app. You can also email privacy@devxgroup.io from the address on your account and we will send the archive within the windows described under "How long we take" below.
• Correct your data: edit any log directly in the app; the underlying row updates immediately
• Delete your data: Settings, scroll to the bottom, "Delete Account". This hard-deletes your row in auth.users and cascade-deletes every child table including journal entries, lab files, and chat history within minutes (your analytics identity is erased at PostHog in the same pass; other vendor copies expire on their documented windows)
• Disconnect Apple Health or Health Connect: Settings → Wearables → "Disconnect", or take away Nutrify.AI's access in the Apple Health or Health Connect app. New imports stop right away (section 2a). Workouts the Nutrify.AI Apple Watch app saved to Apple Health stay in Apple Health; you manage them in the Health app
• Object / restrict / portability (GDPR / UK GDPR): email privacy@devxgroup.io
• Opt out of sale (CCPA, CPRA): we do not sell. There is nothing to opt out of.
• Turn off analytics: Settings → Support → "Share usage analytics". Flip it off and we stop collecting product-usage events right away.
• Children's data: Nutrify.AI is for adults 18 and over. We do not knowingly collect data from anyone under 18. If you believe a child has provided data, email us and we will delete it.

If you live in the EEA, UK, or Switzerland, you may also lodge a complaint with your national data-protection authority.

How long we take. We confirm we got your request within 10 days and answer it within 45 days. If it is complicated we may take another 45 days, and we will tell you before the first 45 are up. There is no charge unless a request is repetitive or excessive, and we will tell you before charging anything.

Someone acting for you. You can authorize another person or a service to make a request on your behalf. Send us written proof that you authorized them. We may still check with you directly before acting.

If we say no. We will tell you why in writing. You can appeal by replying to that email with the word "appeal". A different person reviews it and answers within 45 days. If we still say no, you can complain to your state attorney general, or, in the EEA, UK, or Switzerland, to your national data-protection authority.

No retaliation. We will never give you a worse price, a worse service, or a worse experience because you used one of these rights.

7a. Washington and Nevada consumer health data

If you live in Washington State or Nevada, you have extra rights over the health data you give us. We publish those rights in a separate Consumer Health Data Privacy Policy, linked from the home page and from Settings inside the app, as those laws require.

The short version: we collect your consumer health data only after you agree to it at sign-up, we never share or sell it, and you can ask us to delete it by emailing privacy@devxgroup.io or by deleting your account in Settings. We respond to a deletion request within 30 days: your live data is hard-deleted immediately, your analytics identity and events are erased at PostHog, and remaining processor copies expire on their documented windows (Sentry diagnostics and our encrypted backups within 90 days). Nobody at DevX Group LLC can access your health data except to fix a problem you have reported to us or to keep the service running, and that access is logged.

8. Security

In transit: TLS 1.2+ on every API call. Authentication: Supabase Auth + Apple/Google OAuth + Sign-in-with-Apple. Authorization: Postgres row-level security: every read/write is scoped to your auth.uid(); this is enforced in the database, not the application. Storage: Apple-managed iCloud-encrypted on device; Supabase-managed encryption at rest in the cloud (AES-256). API secrets: never embedded in the app binary; all AI keys live server-side in Supabase Edge Function environment variables.

We are a small team. We will not promise SOC 2 today; we will tell you the truth: we follow the same practices SOC 2 demands (least-privilege access, encrypted at rest and in transit, audit logs, password rotation, deny-by-default RLS) but we are not externally audited yet.

8a. If something goes wrong

If your health data is ever exposed to someone who should not have it, whether through a security incident or through a disclosure we did not have your permission to make, we will email you at the address on your account without unreasonable delay and no later than 60 days after we find out. The notice will say what happened, what data was involved, what we have done about it, and what you can do. Where the law requires it we will also notify the US Federal Trade Commission, the relevant data-protection authorities, and, for large incidents, the media.

9. Health-data disclaimer

Nutrify.AI is not a medical device. The advice, summaries, and recommendations the app produces are general wellness information, not medical diagnosis or treatment. Always consult a licensed clinician before changing your diet, exercise, supplementation, or medication.

HIPAA does not apply here. DevX Group LLC is not a HIPAA covered entity and not a business associate of one. Nutrify.AI is a consumer wellness app, not a healthcare provider, health plan, or clearinghouse. The lab reports and health data you put into it are not protected health information under HIPAA. They are protected by this policy, by the state and national privacy laws described in §7 and §7a, and by the security measures in §8, but not by HIPAA. If you want your doctor's copy of your records to stay under HIPAA, keep it with your doctor.

10. Children and parental control

Nutrify.AI is for adults 18 and over and is set to 18+ in the App Store and Google Play. Our AI provider's terms do not allow apps likely to be used by people under 18, and the app discusses health topics with an AI coach. We do not market to anyone under 18 and do not knowingly collect data from anyone under 18. If the app learns from your phone (Apple's Declared Age Range or Google Play Age Signals) or your profile that you are under 18, its AI features are turned off.

11. Changes to this policy

If we materially change how we collect or use data, we will (a) update this page and the in-app copy, (c) bump the "Last updated" date, and (d) announce the change prominently in the app before it takes effect. Non-material clarifications (typo fixes, layout changes) update silently.

Recent changes. 2026-10-24: the summary now says plainly that we do not use your personal data to train AI models, including large language models, and that our AI providers do not train on it either under their commercial API terms (this restates the existing practice); Nutrify.AI is for adults 18 and over (it was 16), and a person the app learns is under 18 has its AI features turned off; product analytics is off for everyone until you allow it; section 5 names the transfer mechanism (EU-U.S. Data Privacy Framework where the processor is certified, otherwise Standard Contractual Clauses); section 5a says our Article 27 representative is being appointed; AI-written content is labelled “Generated by AI”; the policy date is the day app version 1.6.1 went live. Also 2026-10-24: section 3 now says that a meal photo is used only to recognize food, with no face detection and no biometric identifier created or kept, and spells out how the separate health-data box at onboarding works and how to withdraw it. These are clarifications of how the app already works, not new data uses. 2026-10-22: sections 2a, 3 and 4 now say which AI service goes first for each feature (Anthropic Claude for daily insights and meal photos, Google Gemini for everything else, each the backup for the other), where before they said Claude was only a backup, and section 3 gains rows for meal photos and Apple Ads; starting with app version 1.6.1, on iPhone and only if you allow analytics, the app gives the Apple Ads attribution token to RevenueCat, which asks Apple which ad campaign, if any, led to the install (section 2); the company is named DevX Group LLC throughout. Also 2026-10-22, matching the app as it is: Discord is added to section 4 (it delivers in-app feedback to our team); Sentry crash reports carry your account ID; voice input uses Apple's or Google's own speech recognition; Android reminders are scheduled on the phone, with no Google push service; a photo that turns out to be a lab report can go to Anthropic Claude when Gemini is busy; the delete path is Settings, then Delete Account at the bottom; and the App Store ID is corrected. Also 2026-10-22: section 2a says exactly how watch workouts reach Apple Health (Apple Watch saves the heart rate, calories and distance while the workout runs; the Nutrify.AI watch app saves the workout itself when you end it, and asks to write workouts only); the optional Product emails switch in Settings is now listed in sections 2 and 3, with Hostinger, which hosts our own mailboxes, in section 4. 2026-10-01 (app version 1.5.0): section 2a now covers one daily summary each for resting heart rate, heart rate variability, blood oxygen, breathing rate, VO2 max, steps, and active calories, read on iPhone only, and workouts recorded with the Nutrify.AI Apple Watch app (average and highest heart rate, time in each heart-rate zone, active calories and distance). The watch saves those workouts, and the heart rate, calories and distance measured during them, to Apple Health; that is the only thing Nutrify.AI writes, and the iPhone app never writes to Apple Health. During a watch workout your iPhone shows your heart rate live and does not store those live readings. On Android we now read less: only the active calories inside each imported workout, no longer the distance, total calories, and steps described in the 2026-09-30 entry. 2026-09-30: disclosed that on Android, importing a workout from Health Connect also reads the distance, total calories, and steps recorded inside that workout's time window, only to complete that workout record (never read outside a workout, never stored separately; heart rate is still not read), and disclosed the once-per-install read of how you found the app (the Google Play install referrer on Android, and on iPhone only whether an Apple Search Ads attribution token exists), under the same analytics opt-out. 2026-09-18: added the optional profile setup answers to section 2, namely health conditions you want us to keep in mind, whether you are pregnant or breastfeeding, alcohol use, nicotine use, and your usual sleep schedule. Every one of those questions is optional, and the answers are used only to personalize your wellness guidance and keep our suggestions safe for you. 2026-08-30: added Resend, Inc. to the processor table (it sends the account deletion confirmation and support replies), matching the in-app policy screen. 2026-08-30: disclosed that PostHog derives an approximate location (country, region, city, postal code, coordinates) from your IP address for country-level product statistics, and that PostHog discards the IP address itself right after. 2026-08-27: added section 2a for the optional Apple Health and Health Connect import that shipped in app version 1.4.0, and removed the earlier line that said Apple HealthKit was not integrated. 2026-08-08: disclosed masked paywall session replay and the in-app feedback relay.

12. Contact

privacy@devxgroup.io. Typical response within 5 business days.
DevX Group LLC, PO Box 5010, PMB 76, Rancho Santa Fe, CA 92067