Privacy Policy

Effective date: 2026-09-30

Last updated: 2026-09-30

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

Contact: privacy@devxgroup.io

App: Nutrify.AI (Apple App Store ID io.devxgroup.nutrifyai)

This is the per-app addendum to the shared DevX Group 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 and workouts from Apple Health or Health Connect), 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 you can turn them off 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 and we do not use it to train third-party AI models. 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 (the speech-to-text feature converts voice to text on-device or via Apple SpeechFramework before any text leaves the device), social-graph data, or anything from Apple Health or Health Connect beyond the sleep and workouts in section 2a, and those only after you connect.

Notifications. If you allow them, we send reminders and nudges through Apple Push Notification service (Android will use Google's push service when the Android app ships). 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 and workouts from Apple Health on iPhone, or 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. This feature shipped in app version 1.4.0.

What we read.

• Sleep sessions: when you went to bed, when you woke up, how long you slept, and the minutes of light, deep, and REM sleep when your device records them.
• Workouts: the type, the start and end time, the duration, the calories your device counted, and the ID your phone gave the workout, so we never import the same one twice.

On Android, reading a workout from Health Connect also reads the distance, total calories, and steps recorded during that workout. We read those three only inside each imported workout's time window, to complete that workout record. They are never read outside a workout and never stored separately.

What we do not read. Heart rate, location, medical records, steps, distance, or calories outside an imported workout, or anything else in Apple Health or Health Connect. We never write anything back into either one.

What happens to it. When you connect, we read the last 30 days. After that we read new entries each time you open the app or tap Sync now. Imported sleep and workouts 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 on failover) when the coach, 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 and Google do not receive your Nutrify.AI data through this feature: the read happens on your phone.

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 and workouts 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.

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.

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.

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. By using Nutrify.AI you consent to international transfer of your data, including, where applicable, transfer outside the European Economic Area, the United Kingdom, or other jurisdictions, under the EU Standard Contractual Clauses or equivalent legal mechanism.

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.

Write to privacy@devxgroup.io for our current Article 27 representation arrangements, and 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 → Account → "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)
• 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 anonymous analytics". Flip it off and we stop collecting product-usage events right away.
• Children's data: Nutrify.AI is not directed to children under 16. We do not knowingly collect data from anyone under 16. 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 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

The app is rated 16+ on the App Store given the scope of AI conversations on health topics. We do not market to children and do not collect data from anyone under 16.

11. Changes to this policy

If we materially change how we collect or use data, we will (a) update this Markdown file, (b) update the hosted 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. 2026-09-30: 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