Consumer Health Data Privacy Policy — NutriCitadel
Effective and last updated: 21 October 2026
This policy describes the consumer health data that the NutriCitadel app handles, as required by Washington's My Health My Data Act (RCW 19.373) and Nevada's consumer health data law (NRS 603A.400 to 603A.550). NutriCitadel is published by NewEvolve.
In short: almost everything stays on your phone and we never receive it. These can reach us: a meal photo you choose to send for an estimate, an email you choose to write to us and, on Android, a photo result you choose to report. We do not sell consumer health data, and nobody receives it for their own use.
1. What we collect, where it comes from, and why
Kept on your phone — we never receive it
The law's definition of "collect" includes processing data in any manner, so we list this even though we never receive it:
- Food diary: what you ate, when, the meal, the amount and its nutrition figures.
- Body details: sex, age, height, weight and activity level, if you enter them, used to calculate your daily calorie target.
- Weight entries, water intake and your fasting timer, if you use them.
- Daily step count, read from your phone's motion sensor on iPhone or from Health Connect on Android, if you allow it.
- Food you describe by voice: your phone turns speech into text on the device, and only the text is used, to find the food.
Source: you, and your phone's step sensor or Health Connect. Purpose: to show you your diary, your targets and your progress.
A meal photo you choose to send
- What: the photo of your meal, and the estimate that comes back (the food's name and nutrition), produced by Google's Gemini model. A random ID created on your phone travels with the photo. Because it is a persistent identifier, the law treats it as personal information, and so do we. If you subscribe, the App Store's signed record of your subscription travels with it too.
- Source: you, when you press the button. The app asks you before the first photo is sent.
- Purpose: to estimate the food and its nutrition, and to count how many photos that phone sent today so the daily limit works. For subscribers, to confirm the subscription so it has its own daily allowance. Nothing else.
- What we keep: not the photo, and not the subscription record. Our server checks the request's shape and forwards the photo unchanged. It keeps only a counter row (the ID — or, for subscribers, a one-way code made from the subscription's App Store transaction number — the date and the number of photos that day), which is deleted automatically 7 days after that date.
- Your internet address: the server, operated by Cloudflare, has to see your IP address to deliver the request. We have turned request logging off, so we do not keep it.
A photo result you choose to report (Android only)
- What: the reason you pick and the estimate the AI model returned for that photo (the food names, grams and calories). It carries no photo, device ID, subscription record or anything you type.
- Source: you, when you tap Report this result and pick a reason.
- Purpose: to find and fix wrong or inappropriate photo estimates. Nothing else.
- What we keep: the report and its date, deleted automatically 90 days after the day it arrives. It is not linked to any ID, so we cannot tell who sent it, and we do not try to find out.
An email you choose to write to us
- What: your email address and whatever you write. If you mention your weight, what you eat or a health condition, that becomes consumer health data we have received. We never ask for it, and you do not need to include it to get help.
- Source: you.
- Purpose: only to answer you. We do not add you to any list and do not use your message for anything else.
- How long: we delete the conversation within 90 days of our last reply, or sooner if you ask.
2. Who else receives it
We do not sell consumer health data, and we do not give it to anyone for their own use. No third party collects data about you over time or across websites or apps through NutriCitadel: there are no ads, no analytics and no tracking code.
It reaches only the companies that run the services described above, and only so that they can run them:
- Google (Gemini) receives the meal photo to produce the estimate. We use Google's paid API tier. Under it, Google states that it does not use the photo to improve its products, and that it logs it for a limited time, only to detect misuse of its service and for legally required disclosures. policies.google.com/privacy
- Google (Gmail) hosts our mailbox, so it holds the emails you send us. policies.google.com/privacy
- Cloudflare operates the server that forwards the photo and stores the counter rows and reports. cloudflare.com/privacypolicy
3. Your rights
You can do the following at any time, free of charge:
- Confirm and access. Everything kept on your phone is visible and editable in the app, and About → Export a backup gives you a copy. If you have emailed us, ask and we will tell you what we hold, give you a copy, and tell you which of the companies above it reached.
- Correct. Edit or delete any entry in the app.
- Withdraw consent. Tap Turn off meal photo analysis in About. Nothing else in the app changes.
- Delete. On your phone, delete entries, or delete the app to delete everything it kept there. With us, ask and we will delete your emails and ask any company above that still holds them to delete them too.
Photo counter rows carry no name, email address or IP address, so we cannot tell which one is yours from a request. They delete themselves 7 days after the date they refer to. Reports carry none of these either and delete themselves 90 days after the day they arrive. Cloudflare's database keeps an automatic recovery history for up to 30 days, so deleted rows can remain there until it expires.
How to make a request
Email growevolve.business@gmail.com with the subject "Health data request". There is no account, and you will never need to create one. To confirm the request is yours, we may ask you to write from the address you used before. We act on every request within 45 days of receiving it. If we need more time (at most 45 more days), we will tell you why within the first 45 days. We complete a deletion within 30 days of confirming the request is yours.
If we say no
Reply with the subject "Appeal". We will answer in writing within 45 days and explain our decision. If we still say no, our answer will tell you how to contact the Washington State Attorney General (atg.wa.gov/file-complaint) or the Nevada Attorney General to submit a complaint.
4. Changes
We will not collect a new category of consumer health data, or use it for a new purpose, without first telling you and asking for your consent. When this policy changes, the date at the top changes and the new version appears in the app.