Last Updated: April 23, 2026 Effective Date:
TBD · To be updated upon App Store approval
1. Introduction
This Privacy Policy describes how Unreal Technology Limited (“we,”
“us,” or “our”) collects, uses, and protects your information when you
use NomLens (the “App”), a mobile application for AI-powered food
calorie tracking and nutrition logging.
By downloading, installing, or using NomLens, you agree to the
practices described in this Privacy Policy. If you do not agree with
this policy, please do not use the App.
Data Controller: Unreal Technology Limited Hong Kong
Contact: iossupport@unrealtechai.com
When you use NomLens, you may voluntarily provide the following
information, all of which is stored locally on your
device:
- Profile Information: Name, age, gender, height,
weight, activity level, and health goals (used to calculate your
personalized Basal Metabolic Rate and nutrition targets)
- Food Diary Entries: Photos of meals, food
descriptions, portion sizes, meal times, and notes you add
- Favorite Foods: Custom food items you save for
quick logging
- Water Intake: Daily water consumption logs
- Body Measurements: Weight entries for progress
tracking (optional)
Storage: All of the above data is stored locally on
your device using Apple’s SwiftData framework. This data is not
transmitted to our servers.
2.2 Camera and Photo Library
Access
NomLens requests permission to access your device’s camera and photo
library for the following purposes:
- Camera: To capture photos of your meals for
AI-powered food recognition and to scan product barcodes
- Photo Library: To select existing photos of meals
for AI analysis
Data Flow: - Photos you capture or select are
processed on your device and may be sent to OpenAI for AI-powered food
recognition (see Section 3.1) - Barcode images are processed locally by
Apple’s AVFoundation framework; only the decoded barcode number (not the
image) is used to query Open Food Facts (see Section 3.2) - Photos are
not uploaded to our servers or stored in our
backend
2.3 Apple HealthKit
Integration (Optional)
If you grant permission, NomLens reads the following data from Apple
Health:
- Step Count: Daily steps walked
- Active Energy Burned: Estimated calories burned
from physical activity
Purpose: To provide context for your daily calorie
intake (calories in vs. calories out).
Storage: HealthKit data is read on-demand and
displayed within the App. We do not store, copy, or
transmit this data to any external servers. HealthKit data remains
exclusively in Apple’s secure Health database on your device.
Your Control: You can revoke HealthKit access at any
time via iOS Settings → Health → Data Access & Devices →
NomLens.
If you subscribe to NomLens Premium, we use Apple’s In-App Purchase
system and RevenueCat for subscription management. The following
information is collected:
- Subscription status (active / expired / trial)
- Subscription plan (monthly / annual)
- Purchase receipt (processed by Apple)
- Anonymous subscriber ID (generated by RevenueCat)
Payment Information: NomLens does
not collect, access, or store your credit card, debit
card, or any payment information. All payments are processed directly by
Apple through the App Store.
2.5 Anonymous Usage Analytics
We use Mixpanel to collect anonymous usage analytics to improve the
App. This includes:
- Feature usage patterns (which screens are visited, how often
features are used)
- App performance metrics (crash reports, load times)
- Anonymous device identifier (generated by Mixpanel, not linked to
your identity)
- App version, iOS version, device type (e.g., iPhone 17 Pro)
We do not collect: - Your name, email, or any
personally identifiable information - The content of your food entries
or photos - Your precise location
2.6 Diagnostic and Crash Data
If the App crashes or encounters an error, we may collect:
- Crash logs (via Apple’s built-in crash reporting or Sentry, if
enabled)
- Device model and iOS version
- Stack traces (technical error information)
This data is used solely to diagnose and fix bugs.
3. Third-Party Services
NomLens uses the following third-party services. Each service has its
own privacy policy that applies when your data is shared with them:
3.1 OpenAI (Food Recognition)
- Purpose: AI-powered food identification and
nutrition estimation from photos
- Data Shared: Meal photos (when you use the photo
scan feature)
- Data Retention: OpenAI processes images per their
API data retention policy. As of this writing, OpenAI does not use API
data for model training and retains data for abuse monitoring for up to
30 days.
- Privacy Policy:
https://openai.com/policies/privacy-policy
3.2 Open Food Facts (Barcode
Database)
- Purpose: Product information lookup by barcode
number
- Data Shared: Barcode numbers only (no user
identifiers, no photos)
- Data Retention: Query logs per Open Food Facts
public API terms
- Privacy Policy:
https://world.openfoodfacts.org/cgi/privacy.pl
3.3 RevenueCat (Subscription
Management)
- Purpose: Manage subscription state across devices
and platforms
- Data Shared: Anonymous subscriber ID, subscription
status, purchase receipts
- Data Retention: Per RevenueCat data retention
policy
- Privacy Policy:
https://www.revenuecat.com/privacy
3.4 Mixpanel (Product
Analytics)
- Purpose: Anonymous usage analytics to improve the
App
- Data Shared: Anonymous usage events (no PII)
- Data Retention: Per Mixpanel data retention
policy
- Privacy Policy:
https://mixpanel.com/legal/privacy-policy/
- Purpose: App distribution, In-App Purchase,
HealthKit, iCloud (if user enables)
- Data Shared: Per Apple’s standard platform
services
- Privacy Policy:
https://www.apple.com/legal/privacy/
We use the collected information for the following purposes:
- Provide Core Functionality: Display your food
diary, calculate nutrition totals, track progress toward your goals
- AI Food Recognition: Process meal photos via OpenAI
to identify foods and estimate nutrition
- Personalization: Customize nutrition targets based
on your profile (age, weight, activity level)
- Subscription Management: Process and validate your
subscription status
- App Improvement: Analyze anonymous usage patterns
to improve features
- Bug Diagnosis: Investigate crashes and errors to
improve stability
- Customer Support: Respond to your inquiries (only
when you contact us)
We do not use your information for: - Advertising or
ad targeting - Selling data to third parties - Training AI models (our
integration with OpenAI is per-request and does not contribute to model
training) - Cross-device tracking for marketing
5. Data Storage and Security
5.1 Local Storage
The majority of your data is stored locally on your device:
- Food diary entries, favorites, water intake, body measurements:
SwiftData database on device
- Profile information and preferences: iOS UserDefaults on device
- Photos: Not stored by NomLens (only processed via OpenAI API, which
does not retain long-term)
5.2 iCloud Sync (Optional,
Future Feature)
Future versions of NomLens may offer iCloud sync for cross-device
data backup. If enabled, your data will be stored in your personal
iCloud account, controlled by Apple’s security and privacy standards.
This feature is not currently active in the initial
release.
5.3 Security Measures
We implement industry-standard security practices:
- API keys for OpenAI and other services are stored securely using iOS
Keychain (when applicable)
- Network communications use HTTPS/TLS encryption
- No personal data is transmitted in plain text
- Access to our infrastructure follows principle of least
privilege
However, no system is 100% secure. If we become aware of a data
breach that affects you, we will notify you in accordance with
applicable law.
6. Your Rights
Depending on your location, you may have the following rights:
6.1 GDPR Rights (European
Economic Area, UK)
If you are located in the EEA or UK, under the General Data
Protection Regulation (GDPR), you have the right to:
- Access: Request a copy of the personal data we hold
about you
- Rectification: Correct inaccurate or incomplete
data
- Erasure: Request deletion of your data (right to be
forgotten)
- Restriction: Limit how we process your data
- Portability: Receive your data in a
machine-readable format
- Object: Object to our processing of your data
- Withdraw Consent: Withdraw previously given consent
at any time
To exercise any of these rights, contact us at
iossupport@unrealtechai.com.
Since most data is stored locally on your device, you can also
exercise many rights directly by: - Deleting entries within the App -
Uninstalling the App (deletes all local data) - Revoking HealthKit
permission in iOS Settings
6.2 CCPA Rights (California
Residents)
Under the California Consumer Privacy Act (CCPA), California
residents have the right to:
- Know what personal information is collected
- Request deletion of personal information
- Opt-out of the sale of personal information (Note: We do
not sell your personal information)
- Non-discrimination for exercising your rights
6.3 Other Jurisdictions
Residents of other jurisdictions may have similar rights under local
privacy laws. Contact us at iossupport@unrealtechai.com to learn
more.
7. Children’s Privacy
NomLens is not intended for use by children under 13 years of
age (or under 16 in the EEA/UK).
We do not knowingly collect personal information from children. If we
learn that we have collected information from a child without parental
consent, we will delete that information promptly. If you believe your
child has provided us with information, please contact
iossupport@unrealtechai.com.
The App is rated 12+ on the App Store based on
references to health and fitness topics that may not be suitable for
young children.
8. Data Retention
- Local Device Data: Retained until you delete
individual entries or uninstall the App
- Photos Sent to OpenAI: Not retained by us; subject
to OpenAI’s retention policy (typically up to 30 days for abuse
monitoring, not used for training)
- Subscription Records: Retained by Apple and
RevenueCat per their respective policies
- Analytics Data: Retained by Mixpanel per their data
retention policy (typically 1-5 years)
- Support Communications: Retained for up to 2 years
after the last interaction
9. International Data
Transfers
If you are located outside the United States or the European Union,
please be aware that your data may be transferred to and processed in
countries where our third-party service providers operate (primarily the
United States).
We ensure appropriate safeguards are in place through: - Standard
Contractual Clauses (SCCs) with service providers - Service providers
certified under relevant frameworks (e.g., EU-US Data Privacy Framework
where applicable)
10. Cookies and Tracking
Technologies
NomLens is a mobile application and does not use web
cookies. However, it does use:
- Anonymous Device Identifiers: Generated by Mixpanel
for analytics (not linked to your Apple ID)
- iOS Advertising Identifier (IDFA): Not
used by NomLens
11. Changes to This Privacy
Policy
We may update this Privacy Policy from time to time to reflect
changes in our practices or legal requirements. When we make
changes:
- We will update the “Last Updated” date at the top of this
policy
- For material changes, we will notify you via in-app notification or
email (if we have your email)
- Continued use of the App after changes indicates your acceptance of
the updated policy
If you have any questions, concerns, or requests regarding this
Privacy Policy or our data practices, please contact us:
Unreal Technology Limited Hong Kong Email:
iossupport@unrealtechai.com
For privacy-specific inquiries (GDPR / CCPA):
iossupport@unrealtechai.com For general support:
iossupport@unrealtechai.com
Last Updated: April 23, 2026 Version:
1.0