1. Who we are
The data controller for Zerotox is Illia Vinivitin, operating the Zerotox product (“Zerotox”, “we”, “us”, “our”).
Contact for privacy requests: hello@zerotox.app
Website: https://zerotox.app
App: Zerotox for iOS (bundle ID app.zerotox.ios)
If you later incorporate under a company name, we will update this Policy and the in-app notice with the new legal entity details.
2. Scope
This Policy applies to:
- the Zerotox iOS application;
- our website at zerotox.app (including this page);
- backend services we operate to analyze labels and manage accounts (Supabase-hosted infrastructure).
Apple’s Sign in with Apple, App Store billing, and private iCloud (CloudKit) are provided by Apple under Apple’s terms and privacy policy. We do not operate Apple’s systems.
3. What we process
3.1 Data that stays on your device (and your private iCloud)
Depending on how you use the app, the following may be stored locally with SwiftData and optionally synced through your private iCloud via Apple CloudKit:
- display name and avatar;
- dietary / avoidance preferences you select;
- scan history and analysis results you keep in the app;
- app settings (for example language and consent flags).
We do not upload your full profile or scan history to Zerotox servers as a personal dossier. Private iCloud sync is between your devices and Apple; we do not host that database.
3.2 Data sent for label analysis
When you choose to analyze a label, the app transmits:
- one or more re-encoded JPEG images of the label (stripped of EXIF/GPS metadata);
- preference identifiers (for example
gluten_free) — not your display name; - response language for the result text;
- an authentication token (Sign in with Apple → our auth system) used to authenticate the request and enforce fair-use / rate limits.
Ingredient text extracted from the image is processed to return your result. We do not store label photos or full ingredient lists as your personal scan history in our application database.
3.3 Account identifiers
If you sign in with Apple, we create or use an account identifier (for example a Supabase Auth user UUID) so we can authenticate API calls, enforce quotas, restore Premium entitlements, and honor delete-account requests. We do not require you to share your email with us; Apple may provide a relay or hide-my-email address depending on your Apple choices. Any name/email Apple returns to the device for local profile display is kept on-device / private iCloud and is not sent to Zerotox servers as profile data.
3.4 Purchases and subscriptions
Premium purchases are processed by Apple (StoreKit / App Store). We use Adapty to manage subscription entitlements (whether your account has Premium access). Purchase handling occurs through Apple; we do not receive your full payment card details.
3.5 Technical / security data
We may retain minimal technical records needed to operate the service securely, such as:
- authenticated request metadata for rate limiting (for example user ID, endpoint, timestamp);
- short-lived operational logs from our edge functions (which may incidentally include request diagnostics).
We do not use third-party advertising, analytics, or crash SDKs such as Facebook SDK, Firebase Analytics, AppsFlyer, or similar trackers.
3.6 Data we do not collect for advertising
- precise or coarse location for ads;
- contacts;
- device advertising identifier (IDFA) for tracking;
- browsing history outside the app.
4. Why we process data (purposes & legal bases)
If the GDPR / UK GDPR applies to you, we rely on the following bases:
| Purpose | Examples | Legal basis |
|---|---|---|
| Provide the core product | OCR + AI analysis of a label you submit; return a result matched to preference IDs | Contract / steps at your request (Art. 6(1)(b)); where needed for sensitive preference signals you actively choose to apply, your consent (Art. 6(1)(a) / Art. 9 where applicable) |
| Account, security, abuse prevention | Sign-in, JWT validation, rate limits, fraud / quota enforcement | Legitimate interests (Art. 6(1)(f)); contract (Art. 6(1)(b)) |
| Subscriptions | Unlock Premium features via App Store + Adapty entitlements | Contract (Art. 6(1)(b)) |
| On-device personalization | Local preferences, history, profile you manage in the app | Contract; your control of device / iCloud data |
| Legal compliance & requests | Responding to rights requests; mandatory disclosures | Legal obligation (Art. 6(1)(c)); legitimate interests |
Before the first label analysis, the app asks you to confirm consent (including age confirmation). You can withdraw analysis consent in Settings; withdrawing does not affect the lawfulness of processing before withdrawal.
5. Service providers (processors / subprocessors)
We use carefully limited providers to run Zerotox. They process data only to provide their service to us:
| Provider | Role | Typical data |
|---|---|---|
| Supabase | Auth, edge functions, rate/quota storage | Auth UUID, JWT validation, request timestamps; analysis request handling |
| Mistral (OCR) | Optical character recognition of label images | Label image / derived text for the request |
| Cerebras | Ingredient analysis / AI response generation | Label-derived content, preference IDs, response language |
| Pinecone | Shared ingredient knowledge retrieval (not a per-user profile store) | Ingredient-related query embeddings / matches for analysis |
| Adapty | Subscription entitlement management | Purchase / entitlement status tied to the app user |
| Apple | Sign in with Apple, App Store billing, private iCloud | As determined by Apple and your Apple ID settings |
We do not sell personal information and do not share label photos with data brokers or advertising networks.
6. International transfers
When you request a label analysis, request data may be processed in more than one country:
- Supabase — auth, edge functions, and rate/quota storage (our backend currently runs with US-region infrastructure, including
us-west-2); - Mistral — OCR may be processed in the EU / France (or other regions Mistral operates);
- Cerebras — AI analysis may be processed in the United States;
- Pinecone — ingredient knowledge retrieval may be processed in the United States (or the region configured for our index);
- Adapty — subscription entitlement checks may involve processing outside your country;
- Apple — Sign in with Apple, App Store, and private iCloud follow Apple’s regional systems.
Where personal data is transferred from the EEA/UK (or another region with similar rules) to a country without an adequacy decision, we rely on appropriate safeguards offered by those providers (for example Standard Contractual Clauses) and on the fact that the transfer is necessary to provide the analysis you requested. By using analysis features, you understand that the label image and related request data are transmitted to those processors to generate your result.
7. Retention
- Local / private iCloud data: retained until you clear history, delete the data in-app, delete your account, or remove the app / iCloud data.
- Label photos & ingredient text for analysis: processed to return your result; not kept as your personal scan history in our application database.
- Auth account & rate-limit records: kept while your account exists and as needed for security / abuse prevention; deleted or anonymized when you delete your account, subject to short technical backups.
- Operational logs: retained for a limited period according to our hosting provider’s log retention (used for debugging and security, not for advertising).
8. Your rights
Depending on where you live (for example EEA/UK, Switzerland, California, and other regions), you may have rights to:
- access personal data we hold about you;
- correct inaccurate data;
- delete data (“right to be forgotten”);
- restrict or object to certain processing;
- data portability;
- withdraw consent where processing is consent-based;
- lodge a complaint with a supervisory authority.
In the Zerotox app you can typically:
- withdraw analysis consent;
- clear local scan history;
- edit preferences and profile fields stored on-device;
- delete your account (removes server-side auth / associated quota records we control, and clears local app data as implemented in the current version).
For other requests, email hello@zerotox.app. We may need to verify the request. We will respond within the time required by applicable law.
9. Do Not Sell or Share My Personal Information
Under the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA), you have the right to know whether we “sell” or “share” personal information for cross-context behavioral advertising.
We do not sell or share personal information for cross-context behavioral advertising, and we do not sell personal information to data brokers. Categories we process (for example identifiers, photos/user content for label analysis, and purchase entitlements) are used for app functionality as described in this Policy.
Because we do not sell or share personal information in this sense, there is no opt-out toggle to enable. If you have questions about this notice, email hello@zerotox.app with the subject “Do Not Sell or Share”.
10. Children
Zerotox is intended for users 18 years of age or older. This matches our App Store age rating (18+). You must confirm you are 18+ in the app before label photos are sent for analysis. We do not knowingly provide the service to children under 18. If you believe we have processed data from a minor, contact us and we will take appropriate steps to delete it.
11. Security
We use industry-standard protections appropriate to a small consumer app: transport encryption (HTTPS/TLS), authenticated API access, least-privilege secrets on the server, and on-device storage via Apple platforms. No method of transmission or storage is 100% secure; please protect your device passcode and Apple ID.
12. AI-generated analysis (important)
Analysis results are generated with AI assistance and are provided for informational preference-matching only. They are not medical, allergic, dietary, or safety advice, and not a diagnosis. Always verify ingredients against the physical label and consult a qualified professional for health decisions.
13. Changes to this Policy
We may update this Privacy Policy as Zerotox evolves. The “Last updated” date at the top will change when we do. Material changes will also be reflected in the in-app legal document where practical. Continued use of analysis features after an update means you acknowledge the revised Policy.
14. Contact
Privacy questions and requests:
hello@zerotox.app
Controller: Illia Vinivitin · Brand: Zerotox · https://zerotox.app