Your privacy,
in plain words.

1. Who is responsible?

Praelion Ltd is the proposed controller for Gutbean. Contact support@praelion.com about privacy or your rights. The company’s registered address, company number and other required controller details must be added before launch.

2. Your diary stays on your device

Meals, symptoms and check-ins are stored locally on your phone. There is no Gutbean account or routine upload of your diary to our servers. Backups and exports you choose to make may contain sensitive information; where you save or share them is your choice. Device or operating-system backups may also apply.

3. Optional AI processing

With your explicit consent, meal text or photos you select are sent through our server to OpenAI. Text may include symptoms and other health information. Text requests also include local time and time zone. Voice is intended to be transcribed on your device; audio is not sent to the AI proxy.

We use consent under UK GDPR Article 6(1)(a) and explicit consent under Article 9(2)(a) for this optional health-data processing. You can decline or withdraw without losing the non-AI diary. Read what AI sends and how to withdraw.

Praelion does not save AI request content, photos or results on its servers or in application logs. OpenAI may retain abuse-monitoring content for up to 30 days by default, or longer for legal or safety reasons, including applicable image-review exceptions. Zero Data Retention has not been assumed or confirmed.

4. The small cloud records we need

A random app identifier links consent receipts, subscription checks and daily AI limits. App Attest keys and counters help us verify genuine app requests and prevent replay. A random identifier is still personal data when it can be linked to a person or device.

Subscription checks are needed to provide paid features. Security and abuse-prevention records are intended to rely on legitimate interests, subject to the final assessment. Consent records help us demonstrate compliance with our legal duties. We do not use these records to build an advertising profile. If you contact support, we receive your email and the information you choose to send. Necessary support is intended to rely on contract or legitimate interests; any intentional collection of health information needs a separate appropriate condition. Local diary processing and any health implications of security or consent records also require a documented legal assessment.

5. Service providers

The planned providers include Vercel for hosting, Neon (via the Vercel Marketplace) for the cloud database, OpenAI for optional AI processing, RevenueCat for subscription management, and Apple for purchases, distribution and device-attestation services. Some providers act independently for their own purposes, under their own privacy terms.

Barcode and product search use Open Food Facts. Requests can expose a barcode or search query, network address and standard connection information to that service; they do not require sending your diary.

6. International transfers

The API is planned for London and the database for a UK or EU region. Other processing, including OpenAI processing, can occur in the US or other countries. Actual provider contracts and transfers must be checked before launch, using applicable adequacy arrangements or appropriate safeguards such as the UK IDTA or UK Addendum, with the necessary transfer assessment.

7. How long records remain

Your local diary remains until you delete it or remove the app, subject to copies in your backups and exports. Praelion does not retain AI content. Provider retention is described above.

The proposed schedule, subject to legal review and implementation, is: consent receipts while current and for 24 months after withdrawal or replacement; daily quota records for 35 days; attestation keys until 12 months of inactivity; entitlement cache for about five minutes; operational metrics for 30 days; and support correspondence for 12 months after closure. Supplier logs and backup expiry still need verification. Withdrawal stops future AI processing; it does not automatically erase all compliance or security records.

8. Your choices and rights

Depending on the circumstances, you can ask to access, correct or erase your personal data, restrict or object to processing, and receive portable data. You can withdraw consent at any time without affecting the lawfulness of earlier processing.

We may need limited information to locate your random app identifier and verify your request. We cannot retrieve a diary that only exists on your device. Contact support@praelion.com. We normally respond within one month, subject to lawful extensions and exceptions. Uninstalling the app or cancelling a subscription does not automatically withdraw consent or delete server records. You can also complain to the Information Commissioner’s Office.

9. This website and changes

No advertising or analytics tools are included in this website’s current implementation. Hosting providers may process network and security information when you visit. Provider settings and any cookies must be checked before publication.

The intended age group and any child-access controls remain subject to owner and legal review. Material changes to optional AI processing will need updated information and, where required, fresh consent. This draft will be replaced with the reviewed policy before the service launches.