Privacy Policy

1. Introduction

Luonio (the “App”) is a mobile application developed and operated by Airat Bakhteev, an independent developer (“Luonio,” “we,” “us,” or “our”). This Privacy Policy explains how information is collected, used, stored, protected, and disclosed when you use the App and the related cloud-based functionality, support, and services (collectively, the “Services”).

Luonio helps users understand food products by analyzing food labels, ingredient lists, nutritional information, and related product information using image processing, optical character recognition (“OCR”), and other automated analysis technologies.

By accessing or using the Services, you acknowledge that you have read this Privacy Policy. This Privacy Policy is a notice about our information practices; it is not a contract for the Services. If you do not agree with these practices, please discontinue use of the Services.

The English version is the controlling version of this Privacy Policy. Translations may be provided for convenience; where permitted by law, the English version will prevail if there is an inconsistency.

2. Who We Are

The controller or business responsible for the information described in this Privacy Policy is Airat Bakhteev, acting as an independent individual developer and operator of Luonio. Luonio is a product name and is not represented in this Privacy Policy as a separate incorporated entity.

Contact details are provided in Section 19. Depending on applicable law, some third-party providers may act as our processors or service providers, while others may act as independent controllers for their own processing activities.

3. Scope of This Privacy Policy

This Privacy Policy applies to the App and the Services that link to it. It does not govern third-party websites, applications, payment systems, or services that have their own privacy notices, even if they are accessible through or used in connection with Luonio.

The Services are offered worldwide. Additional or different rights may apply based on your location. Where applicable law provides stronger protections than this Privacy Policy, those protections apply.

4. Information We Collect

The information we collect depends on how you use Luonio. We seek to collect only information reasonably necessary to provide, maintain, secure, support, and improve the Services. You are not required to create a traditional account using your name, email address, or phone number.

4.1 Information You Choose to Provide

Depending on the features you use, you may choose to provide or create the following information:

• Photographs of food labels or product packaging selected from your photo library or captured with your device camera.
• Text recognized from food labels through optical character recognition (“OCR”).
• Product barcodes submitted for product lookup and analysis.
• Optional comments, the relevant scan result, and, where applicable, the associated label image submitted through the scan error reporting feature.
• Messages and information you send when contacting customer support or otherwise communicating with us.

During the ordinary image-scanning flow, the App processes the selected or captured image on the device to recognize text. The recognized text and related product information may then be transmitted to our Services for cloud-based analysis. The original image is not transmitted as part of the ordinary OCR analysis flow.

If you voluntarily submit a scan error report, the associated label image, generated scan result, optional comment, and relevant technical information are transmitted to our Services so that we can investigate the reported issue.

Please do not include unnecessary personal, confidential, or sensitive information in label images, comments, error reports, or support messages.

4.2 Anonymous Account and Installation Identifiers

When you first use the App, Firebase Authentication generates an anonymous user identifier for the anonymous account used by the Services. This identifier supports authentication, continuity across sessions, cloud-based functionality, subscription entitlement management, supported synchronization, account deletion, and security.

The App also generates a separate random installation identifier. This identifier is stored in the device Keychain and is used to enforce free-scan limits, determine eligibility for trials or promotional allowances, prevent repeated use or circumvention of those limits, and protect the Services against fraud or abuse.

The installation identifier is not an advertising identifier, is not used for third-party advertising, and is not used to track you across apps or websites owned by other companies. It may remain available after the anonymous account is deleted and may persist after the App is reinstalled, subject to the behavior of the device operating system and Keychain.

Although these identifiers do not directly contain your name, email address, or phone number, account-level and device-level identifiers may be treated as personal data under applicable law.

4.3 Subscription and Purchase Information

If you purchase Luonio PRO, Apple and RevenueCat may provide limited purchase information, such as product or entitlement status, subscription status and expiration, and transaction identifiers used to validate and manage access. Payments are processed by Apple. We do not receive or store your payment card number or banking details.

4.4 Technical and Diagnostic Information

The App and its service providers may process limited technical and diagnostic information necessary to provide, secure, troubleshoot, and maintain the Services. This information may include:

• App version and build number.
• Operating-system version and platform information.
• Device language and selected App language.
• Network and request information, which may include an IP address.
• Anonymous account and installation identifiers.
• Request timestamps, response status, service errors, and technical logs.
• Diagnostic information submitted with a voluntary scan error report.
• Information about the type and origin of a scan, such as whether it was created from a camera image, a photo-library image, or a barcode.

We use this information for App functionality, service security, troubleshooting, customer support, fraud prevention, and reliability. We do not use it for third-party advertising or cross-app tracking.

4.5 Scan Content, Results, and Generated Information

For an ordinary image scan, the App performs OCR processing on the device and may transmit the recognized label text and related product information to our cloud-based Services. The Services use this information to identify ingredients, nutritional information, product characteristics, warnings, explanations, product scores, and other analysis results.

For a barcode scan, the App may transmit the scanned barcode to Open Food Facts to retrieve available product information. Relevant barcode and product information may then be transmitted to our cloud-based Services for analysis.

Generated scan information may include recognized text, product names, ingredients, nutritional information, product categories, explanations, warnings, scores, analysis-quality information, and related metadata. This information may be stored locally and may also be associated with the anonymous account or installation identifier in cloud-based caches and usage records.

4.6 Information We Do Not Intentionally Request

Unless you voluntarily include it in content or communications, Luonio does not intentionally request your legal name, postal address, telephone number, precise location, contacts, unrelated photo-library content, payment-card details, biometric information, or government identification. Selecting an image does not give Luonio access to unrelated photo-library content beyond the access permitted by your device settings.

5. How We Use Information and Our Legal Bases

We use information for the purposes described below. For users in the European Economic Area, the United Kingdom, and other jurisdictions that require a legal basis, the applicable basis depends on the context.

Where we rely on legitimate interests, we consider the nature and necessity of the processing and its potential impact on users. We do not use information for automated decision-making that produces legal or similarly significant effects about you.

6. Anonymous Accounts

Luonio primarily uses anonymous authentication. An anonymous account is designed to avoid requiring direct identity details, but it is still an account-level record. It may be linked to Services data such as cached scan results, usage limits, and subscription entitlements. Do not share device access or authentication credentials with others.

If the anonymous account or App data is lost, deleted, or replaced, we may not be able to restore data that cannot be reliably associated with the new anonymous identifier. Apple may separately retain purchase records and allow eligible purchases to be restored through its systems.

7. Local Storage and Scan Cache

Luonio stores certain information locally on your device to provide a faster and more convenient experience. Depending on your use, this may include settings, language preferences, favorite products, custom product names, notes, product photographs, scan results, and locally cached analysis data.

Luonio may also maintain a cloud-based cache associated with your anonymous account to improve performance, avoid unnecessary repeated processing, support continuity across sessions, and provide supported synchronization. Removing the App may delete local data but does not necessarily delete cloud data or cancel a subscription. Cached information is not used for third-party advertising or sold.

8. Food Label Images, OCR, and Automated Analysis

When you capture or select a food-label image for an ordinary scan, the App processes the image on the device to perform optical character recognition. The App may transmit the recognized text and related product information to our cloud-based Services for automated analysis. The original image is not transmitted as part of the ordinary OCR analysis flow.

Images may be stored locally on your device when required to provide App features, such as saved product photographs or temporary report preparation. Locally stored product photographs are not transmitted solely because they are saved in the App.

If you voluntarily submit a scan error report relating to an image-based scan, the App transmits the associated label image together with the generated scan result, your optional comment, and relevant technical information. We use this information to investigate the reported problem, improve reliability, provide support, and prevent similar errors.

User-submitted images, recognized text, scan results, and other content are not used by Luonio to train general-purpose artificial-intelligence models. If this practice changes, we will update this Privacy Policy and provide any notice or obtain any consent required by applicable law before the new use begins.

Automated analysis may be inaccurate, incomplete, or outdated because of image quality, OCR errors, damaged or incomplete packaging, recipe changes, regional product variations, and other technical or factual limitations.

9. Voluntary Scan Error Reports

The App includes an optional feature that allows you to report an incorrect or unsatisfactory scan result.

When you submit an image-based scan error report, we may receive:

• The associated food-label or product-packaging image.
• The generated scan result and analysis snapshot.
• Your optional comment.
• Information about whether the image originated from the camera or photo library.
• App version, build number, operating-system information, language information, and other relevant client metadata.
• Authentication, request, and technical information generated while submitting and processing the report.

When you submit a barcode-based scan error report, we may receive the barcode instead of an image, together with the generated scan result, optional comment, and relevant technical information.

Submitting an error report is voluntary. We use report information to investigate the reported result, troubleshoot technical or analysis problems, improve reliability and quality, respond to support issues where possible, and prevent similar errors.

Please review the image and comment before submitting a report and avoid including faces, documents, addresses, payment information, or other unnecessary personal or sensitive information.

10. Third-Party Services and Disclosures

Luonio uses third-party providers to operate the Services. These providers currently include:

• Apple, for App Store distribution, in-app purchases, subscription processing, and platform services.
• Google Firebase and Google Cloud, for anonymous authentication, cloud functions, backend processing, storage, hosting, security, and related service infrastructure.
• RevenueCat, for subscription offering, purchase-status, transaction, and entitlement management.
• Open Food Facts, for retrieving available product information associated with a scanned barcode.

When you perform a barcode lookup, the scanned barcode is transmitted to Open Food Facts. As with ordinary internet requests, Open Food Facts and its infrastructure providers may also receive standard network information, such as an IP address and request metadata. Open Food Facts processes information under its own terms and privacy practices.

We disclose information to these providers only as reasonably necessary for the functions described in this Privacy Policy. Depending on the circumstances and applicable law, providers may act as processors, service providers, or independent controllers for certain processing activities.

Some providers may independently process transaction, security, network, device, or service information for their own lawful purposes. Their processing is also governed by their respective terms and privacy notices.

We may additionally disclose information where reasonably necessary to comply with law, respond to valid legal process, protect users or the Services, investigate fraud or abuse, or establish, exercise, or defend legal claims.

11. No Sale, Advertising, or Tracking

Luonio does not sell or rent personal information, use personal information for third-party advertising, build advertising profiles, or share personal information for cross-context behavioral advertising. Luonio does not use user-submitted images or scan content for advertising. If applicable law defines “sale” or “sharing” more broadly, you may contact us to exercise any relevant right.

11.1 Free-Scan Limits, Fraud, and Abuse Prevention

Luonio may provide a limited number of free scans, trials, promotional allowances, or introductory benefits. To determine eligibility, enforce applicable limits, and prevent repeated use or circumvention, the Services process a random installation identifier together with limited anonymous-account, usage, transaction, and technical information.

The installation identifier is stored in the device Keychain. Deleting the anonymous account, reinstalling the App, resetting local App data, or receiving a new Firebase anonymous user identifier does not necessarily reset eligibility for free scans, trials, promotional allowances, or introductory benefits.

Limited identifiers and eligibility records may be retained after account deletion where reasonably necessary to prevent fraud, abuse, or repeated use of promotional benefits. They are not used for advertising or cross-app tracking and are not sold.

12. Data Retention

We retain information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the Services, maintaining security and integrity, resolving disputes, and meeting legal obligations. Retention varies by category and context.

For ordinary image scans, the original label image is not transmitted to our cloud-based analysis Services. Recognized OCR text, product information, generated analysis results, and related cache records may be retained for as long as reasonably necessary to provide the Services, improve performance, maintain scan continuity, enforce usage limits, and satisfy security or legal requirements.

Images and related information voluntarily submitted through the scan error reporting feature may be retained for a reasonable investigation and support period and then deleted or anonymized when they are no longer reasonably necessary for troubleshooting, service improvement, security, legal compliance, or the establishment or defense of legal claims.

The random installation identifier and limited usage or eligibility records may remain after deletion of the anonymous account where reasonably necessary to enforce free-scan limits, prevent circumvention, and protect the Services from fraud or abuse.

Purchase and subscription records controlled by Apple or RevenueCat may be retained independently under their own legal obligations and privacy practices.

Local information generally remains under your control until you remove it, reset App data, or uninstall the App. Security and technical records may be retained for a limited period appropriate to security, abuse prevention, troubleshooting, and legal compliance.

When information is no longer needed, we delete, anonymize, or securely dispose of it where reasonably practicable. Backups may persist for a limited period before routine deletion or overwrite.

13. International Data Transfers

Luonio is available worldwide, and information may be processed in countries other than your country of residence. Those countries may have different data-protection laws. Where required, we use appropriate safeguards for transfers, which may include contractual protections, adequacy decisions, or other lawful transfer mechanisms. You may contact us for additional information about safeguards relevant to your data.

14. Data Security

We use reasonable technical and organizational measures designed to protect information from unauthorized access, alteration, disclosure, misuse, or destruction. Measures may include encrypted network communications, authentication, access controls, provider security features, and operational monitoring. No electronic transmission or storage system is completely secure; therefore, we cannot guarantee absolute security.

15. Children’s Privacy

Luonio is not directed to children under 13, and we do not knowingly collect personal information from children under 13. Higher minimum ages or parental-consent requirements may apply in some jurisdictions. If you believe a child has provided personal information through the Services, contact privacy@luonio.com. We will investigate and take appropriate action, including deletion where required.

16. Your Privacy Rights

Depending on your location and applicable law, you may have rights to request access, correction, deletion, restriction, objection, portability, or a copy of relevant information; to withdraw consent where processing relies on consent; and to complain to a competent data-protection authority. These rights may be subject to legal conditions, limitations, and exceptions.

Because Luonio primarily uses anonymous accounts, we may need information reasonably necessary to locate and verify the relevant account or records. We cannot provide or delete information that we cannot reasonably identify as relating to the requester, and we will not weaken security or disclose another user’s information to fulfill a request. Contact privacy@luonio.com to submit a request. We may ask for reasonable verification and will respond within the period required by applicable law.

17. Account Deletion

You can initiate deletion of the current anonymous account from within the App. When deletion is completed, the Firebase anonymous authentication account and associated account data controlled by Luonio are deleted or scheduled for deletion in accordance with our retention processes.

A new anonymous account may be created automatically if you continue using the App after deletion.

Account deletion does not necessarily remove:

• The random installation identifier stored in the device Keychain.
• Limited usage, eligibility, transaction, security, or fraud-prevention records that we reasonably need to retain.
• Records that must be retained for legal compliance, transaction reconciliation, security, dispute resolution, or legal claims.
• Information controlled independently by Apple, RevenueCat, Open Food Facts, or other third-party providers.

Deleting the account, reinstalling the App, resetting App data, or receiving a new anonymous account does not reset eligibility for free scans, trials, promotional allowances, or introductory benefits.

Account deletion does not cancel an active App Store subscription. You must manage or cancel the subscription through your Apple Account subscription settings.

18. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to the Services, our practices, legal requirements, or operational, technical, and security needs. We will revise the “Last Updated” or “Effective Date” above. Where required by law, we will provide additional notice in the App or by another appropriate method and obtain consent if required. The updated policy applies from its stated effective date.

19. Contact Us

For questions, privacy requests, or concerns about this Privacy Policy, contact:

20. Important Notice Regarding Food Analysis

Luonio provides automated analysis of food labels and related information for general informational purposes only. Food products, packaging, ingredient lists, allergen statements, and nutritional information can change over time and may vary by country, manufacturer, production batch, or packaging version. Results may be incomplete, inaccurate, or outdated.

Always review the original, current product packaging and, when appropriate, verify information with the manufacturer before making purchasing, dietary, allergy-related, or health-related decisions. Do not rely on Luonio as the sole method of determining whether a product is safe or suitable for you.

Luonio is not a medical device and does not provide medical advice, diagnosis, treatment, nutritional counseling, or allergy verification. If you have an allergy, medical condition, dietary restriction, or other health concern, consult an appropriately qualified healthcare professional.

Appendix A — Summary of Information We Collect

This summary is provided for convenience. The full Privacy Policy controls if there is any inconsistency.