Privacy Policy

Your Data.
Your Device. Always.

Log & Grow — Personal Health & Nutrition Coach

📅 Effective: May 25th, 2026 📋 Version 1.0
⚕️
Medical Disclaimer

Log & Grow provides general health and nutrition information for educational and informational purposes only. It is not a substitute for professional medical advice, diagnosis, or treatment. Always consult a qualified healthcare professional before making any changes to your diet, exercise routine, or health management. Never disregard professional medical advice or delay seeking it because of information provided by this application.

✦ Last updated May 25th, 2026 — Version 1.0

Contents

Section 01

About This Policy

This Privacy Policy describes how Invictus Publishing Ltd. ("we", "our", or "us"), trading as Log & Grow, collects, uses, and protects information in connection with the Log & Grow mobile application ("the App"). It applies to all users of the App and has been prepared in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR").

We are committed to protecting your personal data and to being fully transparent about how we handle it. Please read this policy carefully before using the App.

Section 02

Who We Are

The data controller responsible for your personal data is:

Invictus Publishing Ltd.

🏷️ Trading as: Log & Grow
📧 Privacy enquiries: Contact Us menu option in the app
⏱️ Response time: within 30 days of receipt
Section 03

Minimum Age Requirement

🔞 The App is intended for use by adults aged 18 and over only.

We do not knowingly collect personal data from individuals under the age of 18. If you are under 18, please do not use the App or provide any personal data through it.

If we become aware that we have inadvertently collected personal data from a person under 18, we will take immediate steps to delete that information. If you believe we may have collected data from a minor, please contact us at the Contact Us menu option directly in the app.

Section 04

Our Core Privacy Principle

🔐 Your personal health data is stored exclusively on your own smartphone using strong encryption. We do not operate a central database of user health records.

We do not sell, share, rent, or trade your personal data with third parties for their own purposes.

When you use features powered by artificial intelligence — such as personalised health coaching or meal recognition — your data is transmitted to third-party AI services solely to generate a response. That response is returned to your device and stored locally. The third-party services do not retain your data beyond the processing of each individual request, in accordance with their respective data processing terms.

Section 05

What Data We Collect and Why

5.1 Data You Provide Directly

When you use the App, you may choose to enter the following personal and health data. All data is stored exclusively on your device in an encrypted database:

The legal basis for processing this data is your explicit consent (GDPR Article 6(1)(a)) and, for health-related data, your explicit consent for the processing of special category data (GDPR Article 9(2)(a)). You may withdraw consent at any time via App Settings.

5.2 Data Collected Automatically

The App uses Firebase Authentication (Google Ireland Limited) to assign an anonymous identifier to your device session. This identifier:

The App uses Firebase Crashlytics for crash reporting services, resolving technical issues and bugs.

The App does not use analytics tools or any advertising identifiers beyond what is described in this policy.

5.3 Environmental Data

Where you have provided a location in your profile, the App may retrieve local environmental data including outdoor temperature, humidity, and air quality measurements (NO₂, O₃, SO₂, PM₂.₅, PM₁₀, NH₃, CO). This data is fetched via our secure server-side functions and stored locally on your device alongside your health records.

5.4 Contact Form Data

If you use the "Contact Us" feature, you may provide your email address and a message. This is transmitted solely to allow us to respond to your enquiry. We do not add you to any mailing list without your explicit consent.

Section 06

How We Use Your Data

We use the data described in Section 5 for the following purposes only:

We do not use your data for advertising, profiling for third-party commercial purposes, or any purpose not listed above.

We do not use your data for training AI models, all AI services are enterprise paid services from top providers within the EU and USA which adhere to strict data protection standards.

Section 07

Data Transmitted to Third-Party Processors

When you use AI-powered features, selected health data is transmitted securely to the following third-party providers solely to generate a response, these are enterprise AI services governed by strict data protection standards, your data is not used at any point for AI training purposes. Providers do not store your personal data beyond processing each individual request.

AI Google LLC — Gemini AI
LocationMountain View, CA, USA
PurposeHealth coaching analysis and meal recognition
Data sentAnonymised health metrics, meal data, personal profile
SafeguardEU Standard Contractual Clauses
AI Mistral AI SAS
LocationParis, France (within EEA)
PurposeHealth and nutritional AI analysis
Data sentAnonymised health metrics, meal descriptions, personal profile
SafeguardWithin EEA — no international transfer
AI OpenAI, L.L.C.
LocationSan Francisco, CA, USA
PurposeHealth and nutritional AI analysis
Data sentAnonymised health metrics, meal descriptions, personal profile
SafeguardEU Standard Contractual Clauses
Auth Google LLC — Firebase
LocationMountain View, CA, USA
PurposeAnonymous user authentication and secure function execution
Data sentAnonymous device session token only — no health data stored
SafeguardEU Standard Contractual Clauses
Billing RevenueCat, Inc.
LocationSunnyvale, CA, USA
PurposeSubscription management and entitlement verification
Data sentAnonymous Firebase user ID and Google Play subscription receipt
SafeguardEU Standard Contractual Clauses

All data transmitted to third-party processors is sent over encrypted connections (HTTPS/TLS). Providers located outside the EEA process data under EU Standard Contractual Clauses approved by the European Commission.

Section 08

Data Storage and Security

🛡️ All personal health data is stored exclusively on your device in an encrypted SQLite database using AES-256 encryption via SQLCipher, with keys managed by the Android Keystore system.

We do not operate or maintain any central server database containing your personal health records. The only data that exists on external servers at any point is transient data being processed in real time by our third-party AI providers as described in Section 7, and the anonymous session identifier managed by Firebase Authentication.

You are responsible for maintaining the security of your own device, including its screen lock and operating system updates. If your device is lost or stolen, your encrypted data cannot be accessed without your device's authentication credentials.

Section 09

Data Retention

Your health data is retained on your device for as long as you choose to keep the App installed. The App is designed to support up to ten years of historical health data to enable meaningful long-term trend analysis.

You may delete all data at any time by uninstalling the App, which removes the encrypted database from your device. You may also export all your data at any time using the Export My Data feature in App Settings.

Your anonymous Firebase Authentication session is retained for as long as your App installation exists. Firebase automatically clears inactive anonymous sessions after an extended period of inactivity in accordance with Google's standard retention practices.

Section 10

Your Rights Under GDPR

As a data subject under GDPR, you have the following rights with respect to your personal data:

👁️
Right of Access (Article 15)

Access all your health data directly through the App at any time, or export a complete copy using the Export My Data feature in Settings.

✏️
Right to Rectification (Article 16)

Correct or update your personal data at any time through the App's Home screen and Profile screen.

🗑️
Right to Erasure (Article 17)

Uninstalling the App constitutes complete erasure of your personal health records. Contact us to request deletion of your anonymous authentication identifier from Firebase using the Contact Us menu option in the app.

⏸️
Right to Restriction (Article 18)

Restrict AI processing at any time by revoking the privacy agreement in App Settings. All outbound API calls are disabled immediately.

📦
Right to Data Portability (Article 20)

Export all your health data in machine-readable JSON format at any time via Export My Data in Settings. Delivered as a ZIP archive.

🚫
Right to Object (Article 21)

Object to any processing of your personal data at any time by contacting us at the Contact Us menu option in the app or revoking the in-app privacy agreement.

↩️
Right to Withdraw Consent

Withdraw consent at any time via App Settings. This does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, contact us at the Contact Us menu option in the app. We will respond within 30 days and may ask you to verify your identity before processing certain requests.

Section 11

Right to Lodge a Complaint

If you believe that we have processed your personal data in a manner that does not comply with GDPR, you have the right to lodge a complaint with the relevant supervisory authority. As we are based in the Czech Republic, the competent supervisory authority is:

Úřad pro ochranu osobních údajů (UOOU)
Full nameOffice for Personal Data Protection
AddressPplk. Sochora 27, 170 00 Prague 7, Czech Republic
Phone+420 234 665 111

You may also lodge a complaint with the supervisory authority of the EU member state where you reside or work if different from the Czech Republic.

Section 12

Health Data — Special Category Data

The App processes health-related data including body weight, blood pressure, pulse rate, symptoms, and meal nutritional information. Under GDPR Article 9, this constitutes special category data and is subject to enhanced protections.

We process this data solely on the basis of your explicit consent, provided when you accept the in-app privacy agreement. This consent is entirely voluntary. The App remains partially functional (manual data logging and historical report viewing) even if you decline AI processing. You may withdraw your consent for AI processing at any time via App Settings without losing access to your locally stored data.

Section 13

Automated Decision-Making and Profiling

The App uses AI to generate personalised health and nutrition coaching reports based on your health data. This constitutes automated analysis of personal data. However, these reports are informational and advisory in nature only. They do not produce legal effects or similarly significantly affect you.

⚕️
Important

AI-generated reports are not a substitute for professional medical advice, diagnosis, or treatment. Always consult a qualified healthcare professional before making changes to your diet, exercise routine, or health management based on information provided by the App.

Section 14

Children's Privacy

The App is not directed at children under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe your child has provided personal data through the App, please contact us immediately at the Contact Us menu option in the app and we will take prompt steps to delete that information.

Section 15

International Data Transfers

Some of our third-party AI service providers are located outside the European Economic Area (EEA), specifically in the United States. When your data is transmitted to these providers for AI processing, it is transferred outside the EEA. We ensure that such transfers are protected by appropriate safeguards as required by GDPR Chapter V:

You may request a copy of the relevant transfer safeguards by contacting us at the Contact Us menu option in the app.

Section 16

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the App's functionality, or applicable law. When we make material changes, we will notify you through the App with a prompt to review and re-accept the updated policy. The effective date at the top of this document will be updated accordingly.

Your continued use of the App after the effective date of a revised policy constitutes your acceptance of the changes. If you do not agree to the revised policy, please stop using the App and contact us at the Contact Us menu option in the app to request deletion of your authentication data.

Section 17

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Get in Touch

🏢 Invictus Publishing Ltd., trading as Log & Grow
📧 Use the Contact Us feature inside the app
⏱️ We aim to respond within 30 days of receipt