Privacy Policy

1. Introduction

Atom Digital Group Ltd (Company Number: SC866714) ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use the PantryAI mobile application ("App").

We are the data controller responsible for your personal data and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

2.1 Information Collected Automatically

• Device Identifier: Unique ID to manage your account and usage limits (Legitimate interests)
• Platform Device Identifier: Your device's own identifier (Apple's Identifier for Vendors, or the Android ID). We use it only as a one-way hash, and only to stop free-tier limits being reset by deleting an account or signing out and starting again (Legitimate interests)
• Device Information: Operating system, device type, app version for compatibility (Legitimate interests)
• IP Address: Used to keep our systems secure and prevent abuse, such as rate limiting and detecting fraudulent or automated access (Legitimate interests)
• Approximate Location: A country, region, and city estimated from your IP address, used to understand where our users are based and to meet regional legal obligations. This is not GPS or precise location (Legitimate interests)
• Usage Data: Feature usage, scan counts, recipe searches for service delivery (Contract performance)
• Crash Reports and App Diagnostics: Technical errors, device and app-version details, and breadcrumbs recording which screens you moved between, so we can find and fix faults. Unless analytics is enabled for you (see 2.4), this runs in a reduced "errors only" mode — no session recordings and no performance traces (Legitimate interests)
• App Update Checks: Each time the App starts, it asks our update service whether newer app code is available. This involves your IP address, your platform, and app and update version numbers (Legitimate interests)
• Analytics Data: Pseudonymous usage patterns, linked to your app-install identifier, to improve the App (Legitimate interests)

2.2 Information You Provide

• Photographs: Processed by AI to identify ingredients (Contract performance)
• Barcodes: When you scan a product, the barcode is sent to us and looked up against the Open Food Facts product database (Contract performance)
• Pantry Items: Stored to manage your ingredient inventory (Contract performance)
• Saved Recipes: Stored to provide recipe book functionality (Contract performance)
• Subscription Status: To provide appropriate service tier (Contract performance)
• Account Details (optional): If you create an account, your email address and a password we store only as a one-way hash; if you sign in with Apple or Google, your email address and an account identifier they provide (Contract performance)
• Synced Data (account holders): While you are signed in, your pantry items, saved recipes, staples list, and cooking history are stored on our servers to back them up and keep your devices in sync (Contract performance)

2.3 Pantry Usage Insights

When you use the App, we collect records of pantry activity — such as item barcodes, item names, categories, and whether an item was added, removed, or used — to analyse product trends and improve the App. These records are linked to your app install identifier, so they are not anonymous. We rely on our legitimate interest in understanding usage and improving the App. You can opt out at any time in Settings → Data & Privacy ("Pantry insights"); collection then stops, and the pantry-activity records we already hold for you are deleted.

2.4 Information We Collect With Your Consent

The following are collected only where you have turned the relevant option on, or where your region's default allows it and you have not opted out (see 2.6). You can change these choices at any time in Settings → Data & Privacy.

• Extended Diagnostics: Where analytics is enabled, our error-monitoring provider also records app session information, performance traces, and session replays of your app screens. Replays are captured with all text, images, and graphics masked, so the contents of your pantry and recipes are not readable in them (Consent)
• Consent Records: We keep a record of the choices you make, including the date and the version of this Policy in effect at the time, so we can honour your preferences and demonstrate compliance (Consent / legal obligation)

2.5 Information We Do NOT Collect

• We do not collect your name or physical address
• We only collect an email address if you choose to create an account (see section 2.2); you can use the App without one
• We do not collect payment card details (payments are processed by Apple/Google)
• We do not collect precise or GPS-based location data
• We do not collect contacts, calendar, or other device data
• We do not send push notifications and do not collect a push notification token — expiry and meal reminders are scheduled and shown by your own device

2.6 How Your Region Affects These Choices

We estimate which privacy regime applies to you from the approximate location described in 2.1, and apply that region's defaults:

• United Kingdom, EEA, and anywhere we cannot confidently place you: analytics and extended diagnostics do not run at all. In the UK and EEA you will also see Google's consent message for advertising
• United States "opt-out" states: analytics may run by default, and you can switch it off at any time with the "Pantry insights" control in Settings → Data & Privacy

Wherever you are, a Global Privacy Control signal switches everything to off-by-default; this signal is sent by web browsers, so it applies when you use the App on the web. Crash reporting in its reduced "errors only" mode runs in every region, because we rely on legitimate interests to keep the App working.

3. How We Use Your Information

We use your information to:

• Provide and operate the App's features
• Process photographs for ingredient identification
• Look up scanned barcodes against a product database
• Manage your subscription and usage limits
• Generate personalised recipe suggestions
• Create and secure your optional account, back up and sync your data across your devices, and send you service emails such as password-reset codes
• Understand where our users are based (approximate location only)
• Collect pantry usage insights (linked to your install) to analyse product trends and improve the App
• Display advertisements (Free tier only; always non-personalised)
• Deliver over-the-air updates to the App
• Improve and optimise the App
• Detect, prevent, and address technical issues
• Prevent abuse of free-tier usage limits
• Comply with legal obligations

4. Your Privacy Choices

Settings → Data & Privacy is where you control what we collect:

• "Pantry insights" — controls the pantry-activity records described in section 2.3, and, in regions where analytics runs by default, whether analytics and extended diagnostics run at all. Turning it off stops collection going forward and deletes the pantry-activity records we already hold for you

Your region sets the starting position of this control — see section 2.6.

Withdrawing consent stops the related collection going forward and does not affect processing that already took place. Ads on the Free tier are always non-personalised. Turning this control off does not switch off basic crash reporting, which we run under legitimate interests so that the App keeps working — you can object to it at any time using the contact route in section 13.

5. Third-Party Services

We share data with the following third-party service providers:

5.1 International Transfers

Your core account data is hosted on secure infrastructure located in the European Union (EU). Because the EU benefits from UK "adequacy" status, no additional safeguards are required for this data to move between the UK and the EU.

Some of our other third-party providers listed above are based outside the UK and EU. Where data is transferred to those providers, we rely on appropriate safeguards such as Standard Contractual Clauses.

6. Data Retention

• Device Identifier: Retained until you request deletion; it may remain on our servers after you uninstall the App unless you ask us to delete it
• Authentication Tokens (stored only as a one-way hash): Retained until you request deletion of your data or your account is deleted
• Account Details (email address, hashed password, Apple/Google sign-in identifiers): Until you delete your account
• Synced Data (pantry items, saved recipes, staples list, cooking history): Until you delete it or delete your account
• Pantry Items: Until you delete them or request account deletion
• Saved Recipes: Until you delete them or request account deletion
• Pantry Usage Insights: Until you turn "Pantry insights" off or delete your account — either one deletes the records we hold
• AI Usage Records: Technical logs of each AI request (feature used, model, and processing cost — never the content of your photographs): until you delete your account
• Approximate Location: Stored on your account record and updated periodically; retained until you request deletion
• Consent Records: Retained for the life of your account and a reasonable period afterwards, as a record of the choices you made. When you delete your account these records are kept, but the link between them and you is removed
• Photographs: Processed immediately and not permanently stored
• Password-Reset Codes (stored only as a one-way hash): Single-use and valid only briefly, then discarded
• Security & Rate-Limit Records (including IP address): Short-lived; each record is tied to a limited time window and is automatically purged once that window expires
• Post-Deletion Abuse-Prevention Tombstone: When you delete your account, your personal account data is removed immediately. To prevent abuse of free-tier limits, we retain a one-way hashed fraud-prevention fingerprint — which includes a hashed device identifier (such as the iOS Vendor ID or Android ID) and a hashed network address, and is not restorable personal data — for 180 days, then automatically delete it. The same hashed record is written when you sign out of an account, for the same reason
• Crash Reports: 90 days
• Analytics Data: Held by our analytics provider no longer than is necessary to analyse product trends, and deleted on request (see section 13)

7. Data Security

We implement appropriate technical and organisational measures to protect your data, including:

• Encrypted data transmission (HTTPS/TLS)
• Secure API authentication using per-install tokens stored only as one-way hashes
• Account passwords stored only as strong one-way hashes — we never see or keep your actual password
• Regular security assessments
• Access controls limiting who can access data

However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

8. Your Rights

We store only a minimal amount of technical data on our servers: a device identifier, a one-way hashed authentication token, your usage counts and subscription tier, an approximate location, your consent choices, and short-lived IP-based security records. If you create an account, we also store your email address, a hashed password or sign-in identifier, and the synced data described in section 2.2. We hold this data to operate the App, keep our systems secure, prevent abuse, and honour your privacy choices. We do not sell it to third parties.

Under UK GDPR you have the right to access, correct, or request deletion of your personal data, to object to or restrict its processing, to withdraw consent, and to data portability. You can delete your account and its data yourself, at any time, from inside the App — section 9 explains exactly how, what is removed, and what is kept. To exercise any of the other rights, contact us using the route in section 13; we will respond within one month.

8.1 Right to Complain

If you have concerns about how we handle data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Telephone: 0303 123 1113

9. Deleting Your Account and Data

You can delete your account and its data at any time, directly in the App. You do not need to contact us first, and you do not need to give a reason.

9.1 How to Delete Your Account in the App

1. Open the App and go to Settings (the gear icon)
2. Tap "My Account"
3. Scroll to "Delete Account & Data"
4. Tap "Delete account & data"
5. Read the confirmation, then tap "Delete permanently"

Deletion happens straight away — there is no waiting period and no recovery window, so please be sure before you confirm. This works whether or not you ever created an account: if you have only ever used the App anonymously, the same option deletes the install record we hold for your device.

9.2 What Deleting Removes

Deleting removes, immediately and permanently, the account record we hold for you and everything stored against it on our servers:

• Your account details — email address, hashed password, and any Apple or Google sign-in identifier
• Your device identifier, subscription tier, usage counters, consent flags, and approximate location
• Your pantry items, saved recipes, staples list, and cooking history — including the cloud backup used for multi-device sync
• Your earned badges, pantry-activity records, AI usage records, and cached AI results
• Your authentication tokens, so every device signed in to the account is signed out

It also wipes the App's data on the device you deleted from — your local pantry, saved recipes, staples list, cooking log, notification and expiry preferences, and stored sign-in token — and cancels any reminders the App had scheduled. Deleting from one device removes the server-side data for every device.

9.3 What We Keep After Deletion, and Why

• A one-way hashed abuse-prevention record (see section 6) for 180 days, so free-tier limits cannot be reset by repeatedly deleting and recreating an account. It contains only hashes — it cannot be turned back into your data, and it is deleted automatically after 180 days. A practical consequence is that if you use the App again on the same device within that window, your previous month's usage counts carry over
• Your consent records, kept as an audit trail of the choices you made, with the link between them and you removed
• Short-lived security and rate-limit records, which expire on their own shortly afterwards

We keep nothing else. If you would rather we did not keep the hashed abuse-prevention record either, contact us using the route in section 13.

9.4 Things Deleting in the App Does Not Do

• It does not cancel a paid subscription. Subscriptions are billed by Apple or Google, so cancel yours in your App Store or Google Play account settings — deleting your PantryAI account does not stop future charges
• It does not remove records held by Apple, Google, or our subscription provider RevenueCat about purchases you made; they keep those for their own billing, tax, and fraud purposes
• It does not automatically erase copies held by our analytics and crash-reporting providers. Ask us using the route in section 13 and we will have those deleted too
• Uninstalling the App, or clearing its data through your device settings, only removes the copy on your device. It does not delete anything from our servers — use the in-app deletion in 9.1, or ask us, if that is what you want

9.5 Deleting by Request Instead

If you cannot use the in-app option — for example you have uninstalled the App, lost access to the device, or want copies held by our providers erased as well — contact us at https://pantryai.io/contact and ask us to delete your data. Tell us the email address on your account if you had one. We will confirm and complete the deletion within one month.

10. Children's Privacy

The App is not intended for children under 13 years of age. We do not knowingly collect personal data from children under 13. If you believe we have collected data from a child under 13, please contact us immediately at https://pantryai.io/contact and we will delete it.

11. Cookies and Similar Technologies

The App may use local storage and similar technologies to:

• Store your preferences
• Maintain session information
• Track usage for analytics

You can manage these through your device settings, though this may affect App functionality.

11.1 Our Website (pantryai.io)

Our website uses a small number of cookies. Strictly necessary cookies, such as the one that remembers your cookie choices (zaraz-consent), are always on. Analytics cookies are off until you accept them in the cookie banner, wherever you are. Because they are optional, we rely on your consent.

• Google Analytics: counts visits and shows us which pages are used, so we can improve the website. It sets cookies such as _ga. Provided by Google; see how Google uses data
• Microsoft Clarity: records how visitors interact with pages (clicks, scrolling, mouse movement), shown to us as heatmaps and session recordings, to help us find confusing parts of the website. It sets cookies such as _clck and _clsk. Provided by Microsoft; see the Microsoft Privacy Statement

If you decline, neither service runs. You can change your choice at any time with the "Cookie Settings" link in the footer of every page; we also load this banner everywhere except the legal pages, so you can read them before deciding. We do not use advertising cookies on the website.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes through the App. Your continued use of the App after changes are posted constitutes acceptance of the revised Policy.

The "Last Updated" date at the top of this Policy indicates when it was last revised.

13. Contact Us

For any questions about this Privacy Policy or our data practices, or to exercise any of your rights under section 8, contact us at https://pantryai.io/contact.