Privacy Policy

Last updated 18 October 2026 · Draft pending legal review

In short:

1. Who is responsible

The controller of your personal data is Gustav Littau, Skovfyrvangen 6, 5270 Odense N, Denmark. Contact for all privacy questions and requests: getrawly@gmail.com.

2. What we collect and why

DataWhyLegal basis (GDPR)
Account: email address, password (stored only as a secure hash), or your Apple sign-in identifier and the email Apple shares (which may be a private relay address)To create your account, sign you in and send account emails such as 6-digit codesContract
Profile: first name, the answers you give in onboarding (such as goals and quiz results), time zone and regionTo personalise Rawly and count your diary days in your own time zoneContract
Health-related data: allergens, diets and ingredients to avoid, for you and your household membersTo check products against themExplicit consent (Art. 6(1)(a) and 9(2)(a))
Household members: a nickname, an age band and allergens (and diets for adults only)To check products for the people you shop forExplicit consent
Diary: products you choose to log, when, for whom, their Rawly Score and number of flags; your daily averages and weekly cardsTo show your diary, averages, streaks and weekly cardContract
Package photosTo read the label and identify the productConsent
Barcodes and searches you look upTo find productsContract
Subscription: your plan, its status and renewal dates (not your payment details, which only Apple sees)To give you access to Rawly PremiumContract
Notifications: a device token and your notification settingsTo send the notifications you turned onConsent
Consent records: what you agreed to or withdrew, which version and whenTo prove and respect your choicesLegal obligation
Security data: counters of how many lookups and photos an account makes, and basic request logsTo prevent abuse and keep costs fairLegitimate interests

Scanning a product doesn't save anything to your diary: only products you choose to log are stored. Recently viewed products, recent searches and cached product data stay on your device.

3. Health data and consent

Allergies, intolerances and diets can reveal information about your health or beliefs. Rawly asks for explicit, separate consent before storing them, records that consent with its date and version, and deletes this data at once if you withdraw consent (Profile → Privacy). Rawly works without it, but can't then check products for allergens and diets.

4. Children

Rawly is for people aged 16 and over and is not directed at children. A parent or guardian can add a child as a household profile with the minimum data: a nickname, an age band and allergens. We don't store diets, photos or any other details about children, never share children's data, never include it in shareable weekly cards, and never use it for analytics or marketing.

5. AI photo identification

When you photograph a package, Rawly first shrinks the photo and removes all metadata (including location) on your phone. Only after you've agreed is it sent, through our server, to Anthropic's Claude AI service, which reads the text on the label. The result is checked by our server and shown to you, labelled as read from your photo. Photos are not stored by Rawly; they exist only while the request is processed. Anthropic processes them under its commercial terms, which do not allow using them to train its models. Please photograph only the packaging, not people.

6. Who processes your data

We use these service providers (processors). Each processes data only on our instructions, under a data processing agreement:

ProviderPurposeLocation of processing
Supabase, Inc.Database, sign-in and server functionsEU (Ireland)
Anthropic, PBCReading package photos (only with your consent)United States
RevenueCat, Inc.Managing subscription statusUnited States
Resend, Inc.Sending account emails such as codesEU (Ireland)
Apple Inc.Sign in with Apple, App Store payments and push notificationsApple's infrastructure
Cloudflare, Inc.Hosting this websiteGlobal network

Product data comes from Open Food Facts. When you're signed in, our server looks products up for you, so Open Food Facts doesn't see who you are. If you look up a barcode while signed out, your phone contacts Open Food Facts directly, which then sees your IP address.

We don't sell your personal data, share it for targeted advertising, or let anyone use it for their own purposes. We may disclose data if the law requires it.

7. International transfers

Our database is in the EU. When a provider processes data outside the EU/EEA, such as in the United States, we rely on the European Commission's Standard Contractual Clauses or another lawful transfer mechanism, together with additional safeguards where needed.

8. How long we keep data

DataKept
Account, profile, health data, household, diary and subscription statusUntil you delete them or your account
Consent recordsWhile your account exists, as proof of consent
Weekly cards2 years
Notification device tokensUntil you turn notifications off, Apple rejects the token, or 1 year without use
Lookup and photo counters2 days
Package photosNot stored
Record that an account was deleted (no content)2 years
Encrypted backupsOverwritten within 30 days

Automated jobs delete data when these periods end.

9. Your rights

You can:

Email getrawly@gmail.com for anything you can't do in the app. We answer within one month and may need to confirm it's really you. You can also complain to a data protection authority: in Denmark, Datatilsynet, or the authority where you live or work.

10. Security

Data is encrypted in transit and at rest. Each person's data is separated in the database so that only they can reach it. Sign-in tokens are stored in your iPhone's Keychain, and access to our systems is limited and logged. No system is perfectly secure; if a breach affects you, we will tell you and the authorities as the law requires.

11. No tracking

Rawly doesn't track you across other companies' apps or websites, doesn't show ads and doesn't use advertising identifiers. The Rawly score and flags are automated assessments of products, not decisions about you.

12. Region-specific information

United Kingdom

The UK GDPR gives you the same rights as above. You can complain to the Information Commissioner's Office.

United States

Under the California Consumer Privacy Act and similar state laws, you have the right to know, access, correct and delete your personal information, and not to be discriminated against for using these rights. In the last 12 months we collected the categories in section 2 (identifiers, account and profile information, sensitive information about allergies and diets with your consent, and app activity) for the purposes in section 2, from you and your device. We have not sold or shared personal information for cross-context behavioural advertising, and we use sensitive personal information only to provide the service you asked for. Washington and Nevada residents: see our Consumer Health Data Privacy Policy.

Canada

Gustav Littau is responsible for protecting personal information under PIPEDA and Quebec's Law 25 and can be reached at the address above. Some providers store data outside Canada (see section 6), where it may be accessible to authorities under local law. You may complain to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d'accès à l'information.

Australia

We handle personal information in line with the Australian Privacy Principles. Some data is stored outside Australia (see section 6). If you're not satisfied with our response to a complaint, you can contact the Office of the Australian Information Commissioner.

Brazil

Under the LGPD you have the rights in section 9, including confirmation of processing and information about sharing. You can complain to the Autoridade Nacional de Proteção de Dados (ANPD).

13. This website

getrawly.app uses no cookies, analytics or trackers. Our hosting provider, Cloudflare, processes technical data such as IP addresses to deliver and protect the site.

14. Changes

We'll update this policy when Rawly changes and show the date at the top. If a change affects how we use data you've already given us, we'll tell you in the app first and, where needed, ask for your consent again.