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

• Photographs of food labels or product packaging submitted for analysis.
• Optional comments and the relevant scan data submitted with a scan error report.
• Messages and information you send when contacting support or otherwise communicating with us.

Please do not submit unnecessary personal, confidential, or sensitive information in images, comments, or support messages.

4.2 Anonymous Account and Identifiers

When you first use the App, Firebase Authentication may generate an anonymous user identifier associated with your App installation or anonymous account. The identifier supports continuity across sessions, usage limits, subscription entitlements, cloud-based cache functionality, synchronization of supported data, account deletion, and fraud or abuse prevention. Although it does not directly reveal your name, an account or device identifier may still 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 Services and their providers may process limited technical information required for functionality, security, troubleshooting, and performance, such as App and operating-system versions, device language, network and request information (which may include an IP address), service-generated identifiers, diagnostic records, and technical logs associated with requests, error reports, or support. The precise information depends on the feature and provider used.

4.5 Scan Results and Generated Information

Luonio generates information from submitted food-label content, including recognized text, ingredients, nutritional information, product characteristics, explanations, product scores, and other analysis results. These results may be stored locally and may be associated with the anonymous account in a cloud-based cache.

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 and Automated Analysis

Luonio processes submitted images to recognize text, identify ingredients and nutritional information, generate analysis, provide explanations, and operate or improve the requested scan functionality. Images may be transmitted to and temporarily processed or cached by the Services and their providers. Unless an image is included in an error report or otherwise needs to be retained for the stated operational purposes, it is not retained longer than reasonably necessary for those purposes.

User content is not used to train general-purpose artificial-intelligence models by Luonio. If this practice changes, this Privacy Policy will be updated before the new use begins where required by law.

Automated analysis can be inaccurate, incomplete, or outdated because of image quality, missing or damaged labels, OCR errors, packaging or recipe changes, country-specific formulations, and technical limitations. Section 20 provides an important notice about relying on results.

9. Error Reports

If you voluntarily submit a scan error report, we may receive the associated label image, generated scan results, your optional comment, and technical information necessary to investigate the issue. We use this information to debug problems, improve the reliability and quality of Luonio, respond where possible, and prevent similar issues. Please do not include unnecessary personal information in an error-report comment.

10. Third-Party Services and Disclosures

Luonio uses third-party providers to operate the Services. Based on the current architecture described to us, these include Apple (App Store purchases and platform services), Google Firebase and Google Cloud (anonymous authentication, databases, server functions, file storage, and hosting or processing infrastructure), and RevenueCat (subscription entitlement and purchase-status management).

We disclose information to these providers only as reasonably necessary for the described functions. Their processing is governed by applicable terms, data-processing arrangements, and privacy notices. Some providers may independently process service, security, transaction, or device information for their own lawful purposes. We may also disclose information when reasonably necessary to comply with law, respond to valid legal process, protect users or the Services, investigate abuse or fraud, or establish, exercise, or defend legal claims.

If the ownership or operation of Luonio changes through a business transfer, information may be transferred as part of that transaction, subject to applicable law and continued protection under an appropriate privacy notice.

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 Fraud and Abuse Prevention

Luonio provides a limited number of free scans or may offer trials, promotional allowances, or introductory benefits. To prevent repeated use or circumvention of those limits, the Services may process and retain limited account, device, usage, transaction, and technical signals reasonably necessary to identify prior use, enforce eligibility rules, and protect the Services from fraud or abuse. We do not disclose the precise operation of these safeguards where doing so could undermine their effectiveness.

Deleting an account, reinstalling the App, resetting App data, or receiving a new anonymous identifier does not reset eligibility for free scans, trials, promotional allowances, or introductory benefits. Fraud-prevention information is not used for advertising and is retained only for as long as reasonably necessary for these purposes, subject to applicable law.

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:

• Local information generally remains under your control until you remove it, reset App data, or uninstall the App.
• Cloud-cached scan results and account-associated records may remain while reasonably needed to provide functionality and until deletion under our retention processes.
• Error reports may be retained for a reasonable period to investigate, resolve, document, and prevent similar issues.
• Subscription and transaction records may be retained as necessary to validate entitlements, reconcile transactions, prevent fraud, or comply with law.
• Security and technical records may be retained for a limited period appropriate to security, abuse prevention, troubleshooting, and legal compliance.
• Limited identifiers, usage records, transaction records, or fraud-prevention signals may be retained after account deletion where reasonably necessary to prevent repeated use of free scans or promotional benefits, detect circumvention, enforce eligibility rules, and protect the Services. These records are kept separate from ordinary account functionality where reasonably practicable and are not retained longer than necessary for those purposes.

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 delete the current anonymous account from within the App. When deletion is initiated, the authentication account is removed and associated information is deleted or scheduled for deletion in accordance with our retention practices. A new anonymous account may be created automatically if you continue using the Services.

Deleting an account, reinstalling the App, resetting App data, or creating or receiving a new anonymous account does not create a new entitlement to free scans, trials, promotional allowances, or introductory benefits. To prevent abuse and repeated use of such benefits, Luonio may retain limited identifiers, usage records, transaction records, or fraud-prevention signals after account deletion for as long as reasonably necessary.

Certain records may also be retained where reasonably necessary for legal compliance, security, transaction reconciliation, or legal claims. Account deletion does not cancel an App Store subscription and does not delete records controlled independently by Apple. Manage or cancel active subscriptions through your Apple Account 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.