Privacy policy

Version 1.14 · updated 2026-10-24

This is an English translation for your convenience. The Lithuanian version is the legally binding one; if they differ, the Lithuanian text applies.

In short

• Without an account (the website, calculators, the quiz) everything stays on your device only – we can't see it.
• With an account (the app, invite-only for now) your plan, food diary and weight are stored encrypted on our server in the EU – only with your explicit consent, so that you can see them on all your devices.
• We never send your health quiz answers (conditions, the eating and sleep questionnaires, pregnancy) anywhere – not even if you have an account.
• No advertising, no ad pixels and no visitor tracking.
• We only get your email address if you join the waitlist yourself or write to us.
• When you scan a barcode, only the code number is sent to Open Food Facts.
• “Calories from a photo” (Plus): only when you tap and agree, the photo is sent to an AI model for one answer. We don't keep the photo itself; a dish you log is saved under “Mine”, and only a small picture stays with it.
• “My recipes”: your recipes are kept like your diary; a recipe's photo stays on your phone, only a small thumbnail goes with your account. Reading a recipe with AI (Plus) – only when you tap and agree, the photo or text is sent for one answer and not kept.
• “Check with AI” at the end of the quiz: only when you tap and agree, your sex, age, height, weight, target weight, goal and activity level go to an AI model – not your health answers. We don't keep them.
• Phone notifications – only if you turn them on: we keep your phone's notification address, time zone and reminder times. None of your data is inside a notification.
• In the apps, Apple or Google take the subscription payment – we never get your card details. RevenueCat tells us which plan to switch on.

Who we are

Data controller: Travel Solutions Inc., company code 306998943, registered office V. Nagevičiaus g. 3, LT-08237 Vilnius. Email for privacy questions: labas@dumpli.app, phone: +370 641 40294. We process health data (a special category) only for account holders and only with their explicit consent, but not on a large scale, so we have not appointed a data protection officer for now.

What stays on your device only

The app calculates and stores your nutrition quiz answers – age, height, weight, health conditions, answers to the eating and sleep questionnaires, pregnancy – and calculator data only in your browser or on your phone. Progress photos also stay on your device only. None of this is sent to our servers – not even if you have an account. The only exceptions are what you choose to send: a photo for an estimate (see “Calories from a photo”) and a few body numbers for a plan check (see “Check with AI”). Health conditions, the eating and sleep questionnaires and pregnancy never leave your phone.

Without an account, your food diary, weight and plans also stay on your device only. You can delete them yourself: in the app, “Me” → “Delete all my data”, or by clearing the site data in your browser or deleting the app.

The App Store and Google Play app without an account

You can use the app from the store without an email address or a password. When you first open it, a device record is created on our server: a random number, when it was created and until when your free time runs, and – if you accept the terms or buy a subscription – those facts too. It holds no health data: your diary, weight and plan stay on your phone only until you choose “Save my data” and give your explicit consent as described under “Your account”. The number is needed for purchases to work (RevenueCat receives it, see “Subscriptions in the apps”) and for the Plus features that need our server. Legal basis: performing the contract (GDPR Art. 6(1)(b)). A record that nobody has used for 90 days and whose subscription has ended is deleted automatically; you can also delete it yourself: “Me” → “Delete all my data”. Without an email address we can't send renewal reminders – the plan screen says so before you buy.

Your account: what is stored on our server

For now the app opens by invitation, and it works with an account. When you create an account, you give your explicit consent in a separate tick box (GDPR Art. 9(2)(a)) for us to store your app record: your plan settings (goal, calorie and protein targets, allergies, dietary choices and, if the quiz said not to show numbers, only a “numbers hidden” flag so that another device hides them too – without the reason: only the phone with your quiz answers knows why), your food diary, water, movement, sleep, weight, saved recipes, shopping list and your family members' allergies.

• The record is stored encrypted (AES-256) on our server in Germany (Hetzner). We don't store your password – only its hash (scrypt), from which the password can't be recovered.
• The encryption key is kept on the same server, so this protects against stolen disks or copies, but not against us – we're telling you this openly. We don't read your record unless you ask us for help.
• Your login is kept in a secure cookie (180 days). We don't store IP addresses.
• To look after the service and what it costs, we count how you use the app – as numbers only: when you last opened it, how many times your record synced, how many photos we estimated and what that cost us, and how many times you looked up a barcode in the shared product database. What you ate, weigh or photographed is not part of these numbers. Only we see them; they are deleted with your account and are in your “Download everything we store” file. Daily totals with no names or emails are kept for up to 400 days. Legal basis: legitimate interest (GDPR Art. 6(1)(f)).
• You can withdraw your consent at any time: “Me” → “Delete account”. Your account and record are deleted from the server immediately; they disappear from backups within 14 days. When you delete your account, we also ask RevenueCat to delete its customer record. Apple and Google keep their own purchase records, which we can't delete.
• You can download all the data we hold at any time: “Me” → “Download everything we store”.

What we process and why

Giving your email address is optional – Dumpli works exactly the same without it. We store waitlist email addresses on our own server in the EU (Hetzner) – only the email address, the time of consent and the page where you signed up, with no IP address and no quiz answers. We use Google Search Console only for summary information about how the website appears in search – it tells us nothing about individual visitors.

Subscriptions in the apps

If you buy a subscription in the App Store or Google Play, Apple or Google handle the payment as independent controllers – we never receive your card or bank details. RevenueCat, Inc. (USA, processor) links purchases to your Dumpli account: it receives a random account number (not your email) and the store's purchase information, and like any online service its servers see your IP address. Our server keeps only what's needed to switch your plan on: which subscription, which store, whether it renews, until when and, if the store tells us, the price – so that we can email you the date and the amount about 3 days before a monthly and 7 days before a yearly payment. Legal basis: contract (GDPR Art. 6(1)(b)). Kept while you have an account; when you delete it, we also ask RevenueCat to delete its record of you. Apple and Google keep their own purchase history under their own rules. Transfers to the USA rely on standard contractual clauses.

Barcode lookup

When you look up a product by its barcode, the app contacts the open product database Open Food Facts (France, EU). Only the code number is sent. As when visiting any website, their server sees your IP address. Open Food Facts is an independent data controller, not our processor.

Check with AI (at the end of the quiz)

If you tap “I agree, check with AI” at the end of the quiz, we send once, through our server, your sex, age, height, weight, target weight, goal (lose, keep, build muscle), activity level and our own formula's result to an AI model (Anthropic Claude). We don't send health conditions, the eating and sleep questionnaires, pregnancy, waist size, your name or email. The model suggests daily calories and macros; our safety limits always win over its answer, and you choose which numbers to use. We don't keep the request or the answer – we only count how many checks you used (up to 3 in 30 days). Legal basis: your consent.

Calories from a photo (Dumpli Plus)

If you photograph a meal or a product label in the app and tap “I agree”, the photo is made smaller on your phone and sent once through our server to an AI model (Anthropic Claude), which answers what's in it and roughly how many calories. Only the app language is sent with it – not your name, email or health data. We don't keep the photo – not on the server, not in logs; we only count how many photos you've used today (up to 10 a day). The only exception: when you log a dish from a photo to your diary, it is saved under “Mine” with a small picture (about 120 × 120 pixels) so you recognise it quickly. It is kept with your food diary – on your phone and, if you have an account, encrypted on our server – and deleted when you delete the dish or your account. It is never sent to the AI model. The legal basis is your consent, which you can withdraw at any time simply by not using the feature. Please don't photograph people or documents.

Estimate with AI (your own entry). If you tap “Estimate with AI” in a “Your own” entry and agree the first time, what you typed under “What was it?” (e.g. “dumplings with sour cream”) is sent once through our server to the same AI model, which estimates the calories and nutrients. Only the app language is sent with it. We don't keep the text – not on the server, not in logs; we only count how many times you've used it today (up to 30 a day). The entry itself stays in your diary like any other. The legal basis is your consent. Please type only food – no names or other personal things.

My recipes. Your recipes (name, portions, ingredients, notes) are kept like your diary – on your phone and, with an account, encrypted on our server. A recipe's photo stays on your phone only; the recipe keeps just a small thumbnail (about 160 × 160 pixels) so you recognise it on another phone. Delete the recipe or your account and they go too. Reading a recipe with AI (Plus). If you tap “Photograph a recipe” or “Paste the text” and agree the first time, the recipe photo (shrunk on your phone) or the pasted text is sent once through our server to the same AI model, which reads the ingredients and amounts. Only the app language is sent with it. The model doesn't count calories – the app does, from its own food table. We don't keep the photo or the text – not on the server, not in logs; we only count how many times you've used it today (up to 10 a day). The legal basis is your consent; withdraw it under “Me” → “Privacy and consents”. Please photograph only the recipe – no people or documents.

Shared product database. If you photograph the label of a product we couldn't find by its barcode, the numbers read from it (barcode, name, calories and nutrients per 100 g) are saved in the shared Dumpli database, so the same barcode is recognised straight away for others. This is information about a package, not about you: others can't see who added it, and we keep that link only to fix mistakes. If you delete your account, the product stays but is no longer linked to you. “Numbers don't match” reports are anonymous to others too.

Phone notifications

If you turn on notifications in the app, your phone (strictly, its browser) creates a notification address at its maker's push service (Apple, Google, Mozilla or Microsoft). Our server keeps that address with its encryption keys, your time zone, language, the reminders you chose and their times (e.g. “lunch 13:00”), and the day each was last sent. The notification text is only our short reminder (“☀️ Time for lunch”) – no name or health data. In browser notifications it's encrypted so that only your phone can read it – the push service only sees the address and when it was sent (for the store apps, see below). The basis is your request (contract): you turn it on and off yourself. Turn notifications off on your phone or delete your account and the address and times are deleted; addresses the service no longer recognises, we delete ourselves.

In the App Store and Google Play apps, notifications are delivered by Google Firebase Cloud Messaging (Google Ireland Limited and Google LLC, processor), and to iPhones through Apple's push service. For this the phone gets a notification number (FCM token), which we keep with your time zone, language and reminder times. Unlike browser notifications, these are not end-to-end encrypted – Google and Apple can technically see the text. That's why it is always just our short, generic reminder, never your name or health data.

Apple Health and Health Connect

In the App Store and Google Play apps you can, if you want, let Dumpli read your steps, active calories, pulse and workouts from Apple Health (iPhone, including Apple Watch data) or Health Connect (Android). We read only these for the last 7 days and keep only day totals, the steps and average pulse for each hour (for the day chart), one resting-pulse number a day and each workout's time with its average and highest pulse – not single pulse readings. We show them on the “Move” and “Today” screens. You can allow or refuse pulse separately. We never write to Apple Health or Health Connect, never pass this data on and never use it for advertising. It is kept in your account with the rest of your data, based on your explicit consent (GDPR Art. 9(2)(a)). You can turn it off in the app (Me → Phone and watch – the imported data is deleted) and take the permission back in your phone's health app settings.

Who receives data

• Cloudflare, Inc. – domain name system (DNS) (data processor). Data may be transferred to the USA under the EU-US Data Privacy Framework and standard contractual clauses.
• Zoho Corporation B.V. – our mailbox (data processor); data is stored in an EU data centre. This is where the emails you write to us end up.
• Hetzner Online GmbH (Germany) – the server that runs the website and the app and stores the waitlist, accounts and messages (data processor, EU data centre).
• Anthropic, PBC (USA) – the AI model that estimates photos you choose to send with “Calories from a photo”, meal descriptions with “Estimate with AI” and recipes you send to be read in “My recipes” (data processor). It doesn't use API data to train models. Data is transferred to the USA under standard contractual clauses.
• Phone push services (Apple, Google, Mozilla or Microsoft – depending on your phone and browser) – only if you turn on notifications. They deliver the encrypted notification to your phone and can't see what's in it. They are independent services your phone uses for all notifications.
• Email sending service – to be added when we start sending emails.
• Google Ireland Limited / Google LLC – Firebase Cloud Messaging for notifications in the App Store and Google Play apps (processor). EU-US Data Privacy Framework and standard contractual clauses. We don't use Google Analytics or any other Firebase analytics tools.
• RevenueCat, Inc. (USA) – subscription status in the apps (processor). Standard contractual clauses.
• Apple and Google – only if you buy a subscription in their stores (independent controllers).

We don't pass data to anyone else, and we never sell it.

Cookies and device storage

We don't use advertising, analytics or tracking cookies. The only cookie is the login cookie, if you have an account. Fonts are loaded from our own website, not from third parties. Your device stores only the data without which the features you use wouldn't work (quiz answers, the app's food diary, photos, working offline). That's why we don't show a cookie banner. If we ever wanted to add visitor statistics, we would first describe it here and ask you.

Automated decisions

The quiz and the calculator give suggestions calculated on your device using publicly described formulas. We make no automated decisions with legal or similarly significant effects, and we don't build profiles for advertising.

Age

Dumpli is meant for adults (18+). Teenagers should discuss a meal plan with their parents and a doctor. We only accept people aged 18 or over on the waitlist.

Your rights

You can ask to access your data, correct it, delete it, restrict its processing, object to processing, receive it in a portable format, and withdraw your consent at any time (every email has an unsubscribe link). Write to labas@dumpli.app – we'll reply within a month, free of charge. We'll check your identity only when it's really necessary.

How to delete your account yourself, and what stays afterwards: How to delete your Dumpli account.

If you think your rights have been violated, you can contact VDAI (the State Data Protection Inspectorate of Lithuania; L. Sapiegos g. 17, LT-10312 Vilnius, ada@ada.lt, vdai.lrv.lt) or the supervisory authority in your own EU country. We'd be grateful if you wrote to us first.

Security

The website works only over a secure connection (HTTPS), with security headers and without third-party scripts. We collect as little as possible. Account records are encrypted, passwords are stored only as hashes, and the number of password-guessing attempts is limited. Data on your device is only as secure as the device itself – use a screen lock.

Changes

Every version has a number and a date. We'll tell waitlist members about significant changes by email in advance. See also the terms of use.