Privacy policy

Last updated: October 20, 2026

1. Controller

PebbleByte GmbH
Mittelgasse 4/13
1060 Vienna, Austria
Phone: +43 676 59 40 027
Email: office@pebblebyte.com
App support: service@pebblebyte.com

This policy covers the AI Calorie Count app (iOS and Android) and the website ai-calorie-count.com. See the imprint for more company details.

2. Account and sign-in

You need an account for every feature of the app. You sign in with “Sign in with Apple” or “Sign in with Google”; there is no separate password. Apple or Google then gives us a unique identifier and your email address. With Apple, you can choose an anonymous relay address instead of your email address. We don’t store a name or profile picture.

On our server we store for your account: the internal account ID, the sign-in provider and its identifier, your email address, when the account was created and last signed in, and the Premium details from section 3. Your diary, your profile (e.g. height, weight, goal) and health data are not part of it. We use your email address only for messages about your account and purchases, never for advertising.

Legal basis: Art. 6(1)(b) GDPR (providing the app and your account). Apple and Google process the sign-in as independent controllers under their own privacy policies.

3. Premium, purchases and Premium codes

You buy Premium through the Apple App Store or Google Play. We don’t receive payment details. To unlock Premium, we store for your account the store, the product purchased (monthly or yearly), the start, expiry and status of the subscription, and the store’s transaction ID. Our server verifies purchases directly with Apple or Google and receives notifications from them about renewals, cancellations and refunds.

When you redeem a Premium code, we store the code, when it was redeemed and when the Premium period ends for your account, so each code can only be used once.

Legal basis: Art. 6(1)(b) GDPR (performing the Premium contract) and Art. 6(1)(f) GDPR (preventing misuse of purchases and codes).

4. Data stored only on your device

The app stores the following data only locally on your device (in a database, with meal photos as files in app storage): profile details (e.g. name, date of birth, height, weight, goal, calorie budget), meals and nutrition, activities, weight history, meal photos, settings, reminder times and your photo- and text-upload consent. This data is not transferred to us, is not synced with your account and is excluded from device backups (iCloud/Android backup).

If you export a backup, the app creates a file with your diary and meal photos on your device. You decide where to save or share it; we don’t receive a copy.

5. AI analysis of photos and text

AI analysis is a Premium feature and works in German and English. When you analyze a photo or describe a meal, the app sends the photo (downscaled) or the text, plus the app language, to our server (api.ai-calorie-count.com). The request includes a sign-in token so our server can check that your account has Premium. The server forwards the input to OpenAI, adds matching entries from our food database and returns the result. We ask for your consent before the first photo upload and before the first text analysis.

• Our server does not store photos or text and does not link them to your account. To prevent abuse, we only count how many analyses an account requests in a period. Your diary, profile and health data are not sent.
• OpenAI processes the input as our processor to produce the analysis. OpenAI receives neither your email address nor your account ID. Requests are sent with storage disabled (store: false); according to OpenAI, API data is not used for training but may be retained for up to 30 days for abuse monitoring.
• Legal basis: your consent (Art. 6(1)(a) GDPR and, where inputs may reveal information about your health, Art. 9(2)(a) GDPR). You can withdraw consent at any time by not starting analyses or by deleting your data in the app. Manual entry works without any upload. For counting requests: Art. 6(1)(f) GDPR (preventing abuse).

Results are estimates. The app makes no decisions about you; you review and confirm every meal yourself.

6. Food search and barcode scanning

Search terms, scanned barcodes and the app language are sent to our server to find matching foods. If a barcode isn’t in our database, our server asks Open Food Facts; only the barcode is sent, not your IP address. We don’t store search terms or link them to your account; retrieved product data is cached without any link to you. Legal basis: Art. 6(1)(b) GDPR (providing the requested feature).

7. Apple Health and Health Connect

You can connect Apple Health (iOS) or Health Connect (Android) without Premium. The app only reads data if you have Premium or a valid Premium code and have allowed it: steps, active calories and weight, to calculate your calorie budget and weight progress on your device. When Premium ends, the app stops reading new data; values already imported stay on your device until you delete them. The app never writes health data.

Health data is not transferred to us, to OpenAI or to any other third party, and is never used for advertising or marketing. No health data is sent to check your Premium status. Legal basis: Art. 9(2)(a) GDPR. You can revoke access at any time in the Health app or in Health Connect.

Use of information received from Health Connect adheres to the Health Connect Permissions policy, including the Limited Use requirements.

8. Other permissions

• Camera and photos: to take or choose meal photos and scan barcodes. Only photos you select are used.
• Microphone and speech recognition: to dictate a meal for AI text entry. Speech is converted to text on your device; audio is not uploaded.
• Notifications: for local reminders scheduled on your device. We don’t use push servers.

9. Hosting and website

Our website and server run on Cloudflare, Inc. (USA), which also hosts the database with the account data from sections 2 and 3. When you connect, Cloudflare processes technically necessary connection data such as IP address, time and requested URL to deliver content and protect against attacks. We have not enabled our own access logs and only record anonymous totals (count, errors, duration) for search requests. The website sets no cookies; your chosen language is stored only locally in your browser. Legal basis: Art. 6(1)(f) GDPR (secure and stable operation).

10. Contacting us by email

If you email us, we use your message and email address only to answer your request and delete them once no longer needed, unless legal retention obligations apply. Legal basis: Art. 6(1)(b) or (f) GDPR.

11. Recipients and international transfers

Recipients are limited to the providers named above: Cloudflare (hosting and account database) and OpenAI (AI analysis), both of which are based or process data in the USA, and Open Food Facts (barcodes only, no personal data). Transfers to the USA are based on EU Standard Contractual Clauses and, where the provider is certified, the EU-U.S. Data Privacy Framework. Apple and Google process sign-in, download and purchase data as independent controllers under their own privacy policies.

12. Retention

We keep account data for as long as your account exists. If you delete your account, we delete it within 30 days at the latest; anything we must keep for legal reasons is restricted until the retention period ends. Redeemed Premium codes are then only kept as “used”, with no link to you. Local data stays on your device until you delete it. Our server does not store analysis inputs; see section 5 for OpenAI’s retention. We delete emails once your request is resolved.

13. Your rights

You have the right to access, rectification, erasure, restriction of processing, data portability, objection, and to withdraw consent with effect for the future. Under Settings → “Delete account” you delete your account on our server and all data on your device. Cancel any running subscription in the App Store or Google Play as well. Because we don’t store your diary on our servers, you can exercise most rights directly in the app. To request a copy of your account data, or for anything else, email us. You can also lodge a complaint with a data protection supervisory authority. In Austria, this is the Austrian Data Protection Authority (Datenschutzbehörde), Barichgasse 40–42, 1030 Vienna, dsb@dsb.gv.at, www.dsb.gv.at.

14. Data security

All connections between the app, the website and our server are TLS-encrypted. Your sign-in token is kept in your device’s protected keychain or keystore, and the local database in its protected app storage. Protect your device with a screen lock, as anyone using your unlocked device can see your diary.

15. Children and teenagers

The app is intended for people aged 14 and over; anyone younger may not use it. If you are between 14 and 17, you may only use the app if a parent or legal guardian has fully agreed to this privacy policy and the terms of use. This expressly includes the account (section 2), the AI analysis of photos and text (section 5) and access to health data (section 7). The app asks for this consent during setup. Parents and legal guardians can delete the account and data in the app at any time or contact us with questions.

16. Changes

We update this policy when the app or the law changes. The version published here applies.