The controller responsible for the processing of personal data described in this Privacy Policy is an individual operator based in Germany:
No separate Data Protection Officer (DPO) has been appointed. [PLACEHOLDER — CONFIRM WHETHER DPO REQUIRED UNDER GDPR ART. 37]
As the controller is established in Germany, the GDPR applies in full to all processing described in this Policy.
This Privacy Policy applies to the GutWell iOS application ("App") and website ("Site").
We collect and process only the personal data reasonably necessary to provide the features requested by the user, comply with legal obligations, protect the service, and improve its reliability.
A German-language version will be made available before publication in German-speaking markets. [PLACEHOLDER — GERMAN TRANSLATION TO BE ADDED]
GutWell is not intended for use by anyone below the minimum age required by applicable law for consent-based data processing. [PLACEHOLDER — MINIMUM AGE TO BE CONFIRMED. UNDER GDPR ART. 8, THE DEFAULT IN GERMANY IS 16 YEARS. LEGAL REVIEW REQUIRED.]
If we become aware that data has been collected from a person below the applicable minimum age, we will delete it promptly. Contact [PLACEHOLDER — SUPPORT EMAIL] if you believe this has occurred.
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Email address; submission timestamp | To send a single notification when GutWell launches on the App Store. No other use. | Consent (Art. 6(1)(a) GDPR). Withdraw at any time by contacting us. |
| Server request logs (IP address, browser type) via Vercel | Standard technical operation and security of the website | Legitimate interests (Art. 6(1)(f) GDPR) |
The website does not load fonts from external servers. No third-party font requests are made when you visit the Site.
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Email address; hashed password; display name (optional) | Account creation and authentication | Performance of contract (Art. 6(1)(b) GDPR) |
| Onboarding responses: gut concern, goal, symptom frequency, daily life context (if provided) | Configuring the initial app experience to reflect your stated preferences | Performance of contract (Art. 6(1)(b) GDPR) |
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Stool type (Bristol Scale 1–7); bloating, pain, and energy levels (1–5); mood (1–5); water intake; optional free-text note; timestamp | Computing your daily Gut Score; displaying your health patterns over time | Explicit consent (Art. 9(2)(a) GDPR) for special-category health data; Art. 6(1)(a) for general processing |
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Meal name; meal type; timestamp | Recording food history; connecting meals to check-in data for pattern review | Explicit consent (Art. 9(2)(a) GDPR) where linked to health data; Art. 6(1)(a) otherwise |
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Meal photograph; meal description (if typed); current symptoms; gut profile context (conditions, gut score, supplements); approximate location (only if explicitly enabled) | Generating a personalised AI meal analysis via Google Gemini | Explicit consent (Art. 9(2)(a) GDPR) where symptom data is included; Art. 6(1)(a) for general processing. Consent given at point of submitting the photo. |
Photograph handling: Your meal photograph is transmitted to Google's Gemini API and processed there to generate an analysis. It is not stored on GutWell's servers after the request completes. The analysis text is stored in your account history and locally on your device. Google's handling of data submitted to the Gemini API is governed by Google's API terms of service. [PLACEHOLDER — VERIFY CURRENT GEMINI API TERMS INCLUDING: DATA RETENTION, TRAINING USE, CONTRACTING ENTITY, AND TRANSFER MECHANISM — LEGAL REVIEW REQUIRED]
You may optionally provide your current physical state (such as bloating, stomach pain, low energy, or nausea) and your planned activity after eating (such as working, studying, driving, travelling, exercising, attending a social event, managing a stressful day, or resting).
These inputs are:
Legal basis: Explicit consent (Art. 9(2)(a) GDPR) where current physical state is included; Art. 6(1)(a) GDPR otherwise.
The text result of each meal analysis is stored in your account history on GutWell's servers and locally on your device. If you correct the AI's output or ask follow-up questions, your corrections and the revised analysis are stored as part of that meal history entry.
GutWell does not intentionally use submitted content or corrections to train its own general-purpose AI model. Processing by third-party AI providers depends on the provider configuration, contractual terms, and data-processing arrangements in place at the time. [PLACEHOLDER — VERIFY GEMINI API TERMS ON MODEL TRAINING — LEGAL REVIEW REQUIRED]
Legal basis: Performance of contract (Art. 6(1)(b) GDPR).
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Crash reports and error logs via Sentry — device type, OS version, app version, stack traces. Not linked to your identity or health data. | Diagnosing and resolving technical errors | Legitimate interests (Art. 6(1)(f) GDPR) |
| Pseudonymous usage events via PostHog — e.g. "check-in completed" — linked to your Supabase user UUID (a pseudonymous identifier), not your name or email. No health values are transmitted. | Understanding aggregate usage patterns to improve the app | Legitimate interests (Art. 6(1)(f) GDPR). [PLACEHOLDER — CONFIRM WHETHER TDDDG §25 CONSENT REQUIRED FOR POSTHOG DEVICE ACCESS — LEGAL REVIEW REQUIRED] |
| Push notification token (if notifications enabled) | Delivering daily check-in reminders you have opted into | Consent (Art. 6(1)(a) GDPR) |
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Subscription status received from Apple via RevenueCat. Full payment card details are not received or stored by GutWell. | Verifying and managing your premium subscription | Performance of contract (Art. 6(1)(b) GDPR) |
GutWell can optionally adapt meal guidance to your real-life situation. When you provide information about your current state or planned activities — such as working, studying, driving, travelling, exercising, attending a social event, managing a stressful day, or preparing for sleep — this information is included in the analysis request sent to Google's Gemini API to make the guidance more relevant.
This guidance uses cautious, non-prescriptive language such as "may feel more comfortable" and does not make guarantees. Context inputs are not stored as a permanent profile in GutWell's database. See Section 4.6 for the legal basis.
We use personal data solely for the purposes described in Section 4. We do not use your data for advertising. We do not sell personal data. We do not share health data with employers, insurers, government bodies, or data brokers.
Several processors are based outside the EEA, primarily in the United States. Where personal data is transferred outside the EEA, we rely on appropriate safeguards under GDPR Chapter V, such as Standard Contractual Clauses (SCCs). [PLACEHOLDER — CONFIRM TRANSFER MECHANISM FOR EACH NON-EEA PROCESSOR — LEGAL REVIEW REQUIRED]
GutWell uses third-party AI services, including services provided by Google, to generate meal analyses. AI-generated analyses are informational suggestions only — not medical advice, clinical assessments, or diagnoses. The AI may make mistakes, misidentify foods, or produce guidance unsuited to your circumstances. You are always free to challenge, correct, or disregard any AI-generated output.
GutWell does not intentionally use submitted content or corrections to train its own general-purpose AI model. Processing by third-party AI providers depends on the provider configuration, contractual terms, and data-processing arrangements in place at the time. [PLACEHOLDER — VERIFY GEMINI API TERMS ON TRAINING AND RETENTION — LEGAL REVIEW REQUIRED]
GutWell aims to comply with applicable transparency obligations under the EU AI Act (Regulation (EU) 2024/1689) as relevant provisions come into effect. [PLACEHOLDER — CONFIRM SPECIFIC OBLIGATIONS AS PROVISIONS TAKE EFFECT — LEGAL REVIEW REQUIRED]
Contact us at [PLACEHOLDER — SUPPORT EMAIL] to exercise any of the following rights. We will respond within one month (extendable by two further months in complex cases with notice).
You have the right to lodge a complaint with the competent supervisory authority. As the controller is established in Germany, the lead supervisory authority is: [COMPETENT GERMAN DATA PROTECTION SUPERVISORY AUTHORITY — TO BE CONFIRMED BASED ON OPERATOR'S FEDERAL STATE OF RESIDENCE]
You also retain the right to seek judicial remedy under Art. 79 GDPR.
We implement appropriate technical and organisational measures including: passwords stored via cryptographic hashing; data encrypted in transit using TLS; row-level security ensuring each user accesses only their own data; API keys stored server-side only; and access controls on backend systems.
While we use appropriate technical and organisational safeguards, no system can guarantee absolute security.
The GutWell app does not use browser cookies. The website uses only technically necessary server-side handling via Vercel. No third-party advertising or tracking cookies are set on the website.
The GutWell app uses local device storage (AsyncStorage) to retain session data, user preferences, and locally cached analysis history. This is necessary for the app to function.
[PLACEHOLDER — CONFIRM WHETHER POSTHOG IN THE APP ACCESSES DEVICE STORAGE IN A WAY REQUIRING CONSENT UNDER TDDDG §25 — LEGAL REVIEW REQUIRED]
We will provide reasonable advance notice of material changes via in-app notification or email before they take effect. Where applicable law requires your express consent to a change, we will request it. If you do not agree, you may stop using the App and delete your account.