Trace Privacy Policy

Version 6 · Takes effect on December 6, 2026
Effective date: December 6, 2026

In short

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Your journal is yours. It stays on your phone, and on iPhone in your own iCloud backup too (section 3.1), unless you give our team a code so we can help you (section 3.17). You don't need an account.
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Trace currently has no ads and no advertising tracking, and we don't sell your personal data.
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What leaves the phone:
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The built-in food search runs on your phone. Food barcode and supplement catalog lookups work without an account on both phones, through Trace's servers. They send the search words, barcode or catalog product identifier needed to find the item, without AI analysis.
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Other supplement and medication searches may contact public databases directly.
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Photo analysis, AI descriptions, cup sizing, AI-assisted product lookups and the larger food database send what that feature needs. On iPhone and Android they can work without an account, within limits. Our servers may keep what they send for a period we set, which may be none, to keep Trace secure, prevent abuse, fix problems and meet legal obligations (section 3.3).
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Android's automatic cup tools use Google services for models and diagnostics. Image cut-outs are processed on your phone; the details are in section 3.7.
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Feedback, and your answer to "How did you find Trace?", when you choose to send them (sections 3.10 and 3.12).
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What Trace keeps on your phone, including your journal, for up to 30 days, only if you ask for help and give our team the code your phone shows (section 3.17).
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Technical information, and safety signals about how the app is used, not what you log (sections 3.7 and 3.16).
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Trace Plus is bought through the App Store or Google Play. We don't receive your payment details. A subscription management provider keeps Plus working under a pseudonymous ID, not your name or email (section 3.8).
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Our team doesn't see your journal unless you give us a code. Under that same ID, it sees your Plus record, when Trace was first and last used, what you choose to send us, such as feedback, and, while we keep it, what your phone sent to Trace's AI features (sections 3.3 and 3.13). If you ask for help and read us the code your phone shows, our team sees what Trace keeps on your phone for up to 30 days, and it's deleted when sharing ends (section 3.17).
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Sharing with our team is off unless you turn it on. If you turn it on, what your phone sends to Trace's AI is kept for up to a year for our team to look at, so we can fix where Trace gets things wrong (section 3.15).
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How Trace is used, not what you log. To protect Trace, for example against scripts and copies, and to test changes, Trace records how it's used, under a scrambled code that our team's website can't connect to you, in a way that doesn't show which health features you use (section 3.16).
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You stay in control. You can export or delete everything in Settings, delete your account in the app, stop using AI features at any time, and ask us to forget what our team keeps about you.
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Wherever you live, you have the rights in section 9. What leaves your phone goes to the United States (section 7).
This summary, like the rest of this policy, describes how Trace works today. We may change our practices; before a change takes effect, we'll update this policy and tell you (section 12).
The rest of this policy gives the details. If you live in Washington or Nevada in the United States, also read our Consumer Health Data Privacy Policy.

1. Who we are

Trace is provided by MySupplements LLC, 108-14 72nd Ave, Forest Hills, NY 11375, USA ("MySupplements", "we", "us"). We are the controller of the personal data described here.
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Privacy contact: support@mysupplementsapp.com
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Privacy officer: Moon Kim, support@mysupplementsapp.com. Moon Kim is also our person in charge of the protection of personal information in Quebec and our data protection officer in Singapore (section 9.2).

2. What this policy covers

Trace is offered in the United States, Canada, Australia, New Zealand, Japan, Singapore and Hong Kong. If we offer it in other countries, we'll update this policy as their law requires. This policy covers the Trace app, its website (trace-api.mysupplementsapp.com/legal) and the services that support them. It does not cover services we don't control, such as the app stores, Apple or Google sign-in, or the public databases Trace looks things up in. Their own policies apply.

3. What we process, and where it lives

3.1 What you log, kept on your device

What you record in Trace is health information. It includes:
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meals, food photos, descriptions and notes;
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drinks of water, and the size of your cup;
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supplements and medications, their doses and schedules, and doses taken or skipped;
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check-ins (sleep, energy, mood), weight and activity;
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your profile: age, sex, height, weight, pregnancy or breastfeeding status, goals and settings.
Your profile can also hold a name for Trace to call you, if you give one.
It is stored on your device. Your device's own backup may also include it (iCloud on iPhone, Google backup on Android), under your device settings. We don't currently receive this journal, except for the pieces a feature sends (3.3), what you choose to send us, such as feedback (3.10), what you share with our team if you turn that on (3.15), and what your phone shares if you give our team a code (3.17).

3.2 Searches and barcode scans

Food searches run on your phone, in a copy of the USDA's food database built into Trace.
Food barcode and supplement catalog lookups go through Trace's servers on iPhone and Android, without an account. Our servers look the item up in food databases and product catalogs, such as Open Food Facts and the MySupplements catalog, and may pass a catalog request on to another catalog service. They send the search words, barcode or catalog product identifier needed, without your account details, and these lookups don't send your photos or journal to AI. Our servers may keep and reuse a lookup's answer for a limited time when the same lookup comes again. Technical information used to protect the service is described in section 3.7.
When you type a search, Trace may also send unfamiliar Korean or Japanese words, with the kind of item you're looking for, to our AI services, which check whether the words are a brand name and translate them into English search terms (section 3.3).
Other supplement and medication searches may send search words directly to public services such as the U.S. National Library of Medicine and National Institutes of Health. Like any website, a service your phone contacts directly can see your device's IP address. Opening a result's image or source link may also contact the site that hosts it. Our Data sources page lists the public databases Trace uses.

3.3 AI features and the larger food database

When you use these features, Trace sends what that feature needs to our servers, and our servers send it on to the service providers that process it for us (section 6). You agree to cloud AI analysis when you continue past setup's "Your data is yours" page, which says under its Continue button that continuing accepts our Terms of Service and this policy, and that AI providers may analyze what you submit. Nothing goes to AI before that, and the app tells you what each feature sends, for example in its first-use guide. You can use these features with an account or, on iPhone and Android, without one, as described below. The account-free database lookups in section 3.2 are separate from these AI-assisted features. Currently, these features are:
Photo analysis
What is sent
The meal photo, and the meal type and time
What happens to it
Analyzed by an AI model to identify foods and amounts; the result returns to your phone
Photo check
What is sent
The meal photo, with small thumbnails of your usual meals
What happens to it
Checked by an AI service for framing and for a match with a usual meal. Kept only as described below the table
Cup sizing (Snap your cup and the camera measure)
What is sent
A photo of your cup, glass or bottle, often with your hand holding it; app language; and, for the camera measure, the phone's own measurements
What happens to it
Read by an AI model to estimate how much it holds. Kept only as described below the table. Cup pictures you choose to save stay on your phone
Say it and AI descriptions
What is sent
The words you typed or spoke
What happens to it
Read by AI to identify foods, amounts and preparation
Fix issue
What is sent
Your correction, the meal's foods and its photo
What happens to it
Read by AI to correct the foods and amounts
AI-assisted product research
What is sent
Product name or description, or a scanned barcode; product category and app language
What happens to it
Our AI service searches official registries, such as Korea's Ministry of Food and Drug Safety and Japan's PMDA, and the web, to find the right product. Facts you confirm may be added to Trace's product catalog, without anything that identifies you
Online food search
What is sent
Your search words and candidate food labels and nutrient summaries
What happens to it
Our servers find candidate foods in the USDA's database and may ask an AI model to rank them
Search-word assistance
What is sent
Unfamiliar Korean/Japanese search words and the food, supplement or medication category
What happens to it
Checked by AI services for brand names and translated into English search terms while you type
Vitamin and mineral estimates
What is sent
The foods and amounts in a meal
What happens to it
Matched to nutrient data
What our servers keep. Our servers keep what your phone sends to Trace's AI features, such as meal and cup photos and the words you type or say, with Trace's answers and your fixes, as long as needed to give you the result. We may also keep it after that, for a period we set and can change, which may be none, as needed to keep Trace secure, prevent abuse, find and fix problems, such as a phone that seems to get wrong answers, and meet legal obligations. When that period ends, we delete it automatically. Access to it is limited to the team members who need it, currently only the person who runs Trace, and each time it's opened, that's recorded. Your journal isn't part of it: it stays on your phone. We keep and open each request on its own, and we don't put what we keep together into your journal or a record of your days; our team sees your journal only if you give us a code for help (section 3.17). We don't use what we keep to build a profile of you, to train AI models or for ads. Deleting your account, or asking us to forget your support ID (section 3.13), deletes it at once. If you turn on sharing with our team, it's kept as section 3.15 describes. How long our AI providers keep what they receive is on the Service providers page.
Lock Screen results on iPhone. If you analyze a meal photo and leave Trace before it's done, your iPhone may give our servers its Lock Screen card's push token and how the card looks. When the analysis finishes, our servers may send the meal's name and calories to that card through Apple's push notification service, and then forget the token. If you come back to Trace first, nothing is sent this way.
When you ask Trace to research a product, our servers keep your request and its result in memory, to return the answer and to reuse it for a short time, including before you confirm it, and may keep it as described above. Facts you confirm may be added to Trace's product catalog, without anything that identifies you.
The phone check, signed in or not. To keep Trace's AI features fair and to stop automated use, your phone may prove to our servers that its requests come from the genuine Trace app, whether or not you're signed in. Your phone makes a key for Trace in its secure hardware. On iPhone, Apple's App Attest confirms the key belongs to a genuine copy of the app. On Android, Google Play Integrity confirms that a genuine copy of Trace from Google Play is running on a device that passes Google's checks; Google processes that check under its own terms. Our servers receive an identifier or the public part of the key, with Apple's confirmation or Google's verdict, and give your phone a short-lived pass. Your phone may get the pass when Trace starts and renew it while you use AI features; on Android, renewing it repeats Google's check.
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The key is for Trace on this phone. It isn't your name, email address, advertising identifier or anything shared across apps, and installing the app again makes a new one.
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The app signs each AI request with the key. What it signs is a fingerprint (a hash) of the request it's sending anyway, so the check itself sends no photos, search words or anything from your journal.
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For a signed-in phone, the check currently stores nothing on our servers: what they need to check a request, such as a one-time code, is held in memory for a short time, currently about ten minutes, and the results are counted without identifiers.
Without an account. The same pass also works as a guest pass, so your phone can use AI features without signing in.
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Each phone has a daily allowance for the phone's own day (see "Usage limits" below). Our servers count its uses in memory, under a number made from the key.
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There's also a monthly limit on the cost of AI use. For it, our database keeps a pseudonymous number made from the key (not the key itself), with how many times each AI feature was used each month and its estimated cost, for a limited time, currently the current and previous month. It holds no content and no internet address.
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When your phone first uses an AI feature, our database also makes a record for it that stays: the key's identifier, the pseudonymous number made from it, which is also your support ID (section 3.8), and when the record was made and last changed. It holds no content and no internet address. It keeps your phone's photos and requests apart from other phones', and we keep it until you ask us to delete it (section 9).
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To protect the service, our servers also limit how often each internet (IP) address can ask, counting for a short time, in memory.
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What your phone sends to Trace's AI features, such as meal and cup photos, is kept under that number and deleted as described above.
Usage limits, for everyone. Trace's AI features have daily and monthly limits, with or without an account and with or without Trace Plus (Terms of Service, section 9). With every AI request, the app sends your phone's time-zone offset from UTC (how many hours it is ahead of or behind), so a daily limit follows your own day. Our servers use the offset for that count, in memory, and may also stop a phone or account that uses far more than its daily allowance within 24 hours. If a phone or account reaches a limit, our database may keep, for a limited time, the days it did and which limit, under the same pseudonymous number and with no content, so we can spot automated use.

3.4 Your account

If you create an account, we process:
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your email address and, if you sign in with Apple or Google, the identifier and any name or email that service shares with us;
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an account identifier and sign-in tokens;
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the proof that your requests come from the genuine app (section 3.3), which our servers check without keeping it;
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records of the features you used, for security and limits.
Accounts are managed by our cloud hosting provider's sign-in service. If you have Trace Plus, its records are described in section 3.8.

3.5 Speech

With "Say it", your phone turns speech into text. On iPhone, this happens on the device. On Android, your phone's speech service, such as Google's, may process the audio under its own terms. Trace receives the text, not the audio.

3.6 Device permissions

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Camera: to take meal photos, scan barcodes, and photograph or measure your cup.
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Microphone and speech recognition: to turn what you say into text for Say it (section 3.5).
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Photos: to pick a photo you choose, such as a meal photo or a screenshot to send with feedback, and to save images you choose to save.
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Notifications: for reminders you set, scheduled on your phone (we don't send them from a server).
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Motion sensors: to tell when the phone is held still for a photo. This stays on the phone.
You can turn each one off in your device settings.

3.7 Technical information

Our servers can record technical information needed to run and protect the service, such as IP address, time, the feature used and the request, app version, device type, status and errors. When we check the quality of meal analysis, these records can also include a meal's name and calorie summary. They can include a record of each AI request without its content, such as when it was made, which feature it was for, which service answered, how it ended, how long it took and what it cost. We keep technical records for a limited time, as long as we need them for these purposes, for example to investigate a security incident or abuse, or as the law requires, and then delete them. What phones send to Trace's AI features is kept as section 3.3 describes.
Android automatic cup tools. Cup fitting and photo cut-outs use Google's ARCore and ML Kit. ML Kit processes images on the phone; it does not send those images or cut-outs to Google. Google services may download models and send identifiers and app/device, usage and performance diagnostics to Google. ARCore may use a Google account identifier or a device identifier for its service analytics. These services operate under the Google Privacy Policy. Cloud AI cup sizing is a separate photo transfer, described in section 3.3.

3.8 Trace Plus

Trace Plus is a subscription you buy in the app through the App Store or Google Play. The store handles payment: we don't receive your card, bank or billing details.
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A subscription management provider keeps Plus working for us (section 6). The app gives it a pseudonymous ID: your account's identifier if you're signed in, otherwise the number our servers know Trace on your phone by (section 3.3), or, before your phone has one, a random number the provider makes. The ID isn't your name or email, and we don't give the provider either. The store shares your purchases and their renewals with the provider, and the provider tells our servers when something changes. Its software in the app also sends technical details such as the platform, app version and language, and the provider records when it first and last saw the ID, with the app version, the platform and the country (section 3.13).
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For Plus, our servers keep, under that ID: whether you have Plus; the plan, the store and the store's country; when it started, renews or ends; and each change, such as a free trial starting or converting, a renewal, a cancellation or expiry with the store's reason, or a billing problem, with the price and currency. They don't include what you eat or take.
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We use these records to give you Plus on your phone and restore it, to answer you when you write to us about a purchase, to keep the financial records the law requires, and to count subscriptions in statistics that don't identify anyone.
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Settings › Trace Plus shows a support ID, the same pseudonymous ID. If you send it to us, we use it to find your purchase and the other records our servers keep under it (section 3.13).
We link the ID to a name or email address when you give us one, for example a first name with feedback (section 3.10), what a sign-in service shares (section 3.4) or the address you write to us from (section 3.9).
You manage or cancel Plus in your App Store or Google Play subscriptions. Refunds are handled by the store.

3.9 Contacting us

If you write to us, we keep your message and our reply for up to 2 years, to help you and to keep records.

3.10 Feedback you send in the app

In Settings › About › Send feedback, you can tell us what you think. You choose what to send:
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stars from 1 to 5, if you want to give them;
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your words;
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a first name, if you leave one in. The app starts with the name you gave Trace on this phone, and you can change it or clear it;
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whether it's OK to quote you;
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a screenshot, if you add one.
With it, the app sends technical details, such as its version, the platform, the app's language and the screen you sent it from.
Your phone's details, unless you turn off Include these details. The page lists them before you send, and they help us find a problem: your phone's model and system version, where Trace came from (such as the App Store, TestFlight or Google Play), your language and region, text size, whether dark mode and a screen reader are on, free storage, and the kind of connection, such as Wi-Fi. They currently include no identifier, carrier, battery level, location or your phone's name. Text size and the screen reader can hint at a disability, so they go only in feedback you see and choose to send, and we use them to find and fix problems, not to infer anything about you. With the switch off, only the technical details above go.
Feedback arrives under your support ID (section 3.8), so we can see it beside the other records our team keeps for that ID (section 3.13) and reply to you in Trace (section 3.11). If Trace can't confirm with our servers that it's the genuine app at that moment (section 3.3), your feedback arrives without an ID, and we can't reply to it. To keep that kind of feedback from being abused, our servers limit it for each internet (IP) address, counting in memory under a scrambled form of the address.
What you write or show can include health information, such as a food, a supplement or a medication. Send only what you're comfortable sharing. We use feedback to answer you, to fix problems you tell us about and to improve Trace. Your stars don't decide who is asked to rate Trace in the App Store or Google Play.
A screenshot is sent if you add one: you pick it, and the app reminds you that it may show what you eat or take. We keep it for up to 30 days, and access to it is limited to the team members who need it.
If you say it's OK to quote you, we may show your words, unedited, with your stars and your first name if you gave one, among the reviews on the Trace Plus offer in the app, where anyone using Trace can read them. We record the date and that you said OK in the app. We choose which feedback to show. To take back your OK, write to us (section 13), and we'll remove your quote from the offer; phones stop showing it the next time they check for Trace's updates.
We keep feedback, and what the app sends with it, for up to 2 years, as we keep messages you send us (section 3.9).

3.11 Our replies, in Trace

When we reply to your feedback, the reply waits on our servers under your support ID. Trace picks it up the next time it checks our servers for what's new, as it does for notices and the Trace Plus offer, shows it to you, and tells our servers that it was shown. A reply waits for a limited time, currently up to 30 days. We reply in Trace, so you don't need to give us an email address. We keep our replies for up to 2 years, as we keep feedback.

3.12 How you found Trace

Trace may ask you: "How did you find Trace?" Answering is optional, and you can skip it. You can pick an answer, such as App Store search, a friend or family member, social media, or a pharmacist or doctor, and add a few words. Your answer arrives under your support ID.
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On Android, Google Play tells the app which link it was installed from (its install referrer), such as the name of one of our campaigns or the code in someone's Trace invite link. The app may send it to us, for example with your answer. If it holds an invite code, we know whose invite link you used.
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Invite links. If we give you a personal invite link to share, its code is random, not your support ID. On Android, when someone installs Trace from your link and answers the question, we can see that they came through your link. On iPhone, the App Store doesn't pass the code on, so we see only a count of the people who came through invite links.
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On iPhone, if we advertise Trace in the App Store's search results (Apple Search Ads), the app can get an attribution token from Apple and give it to our subscription management provider. The provider asks Apple whether you installed Trace after one of our ads there and, if so, which campaign, ad group and search keyword. Apple gives this without your advertising identifier, and Trace doesn't ask for the tracking permission. We use this while we run those ads.
This isn't advertising tracking. Advertising tracking follows you across other companies' apps and websites, usually with an advertising identifier, to choose or measure the ads you see. Trace doesn't currently do that, include advertising SDKs or read your advertising identifier. What we learn here is how you arrived, which we use to understand which ways of finding Trace work and to thank people who share it. The App Store and Google Play also give us counts, such as how many people came from a search, that identify no one.

3.13 What our team sees about you

Our team uses a private website to look after the people who use Trace. For each support ID, it can show:
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your Trace Plus record (section 3.8);
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from our subscription management provider: when it first and last saw your support ID, the app version, the platform and the country, which the provider works out from your internet address without keeping the address;
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from our own servers: when Trace on your phone first and last checked in with them, iPhone or Android, and the app version;
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your feedback and our replies (sections 3.10 and 3.11), and how you found Trace (section 3.12);
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tags and notes our team keeps about you and Trace, such as "asked for a dark mode". We don't keep them about your health, apart from our notes on what you share for help (section 3.17).
It doesn't show what you log in Trace, unless you show it to us, for example in a screenshot, turn on sharing with our team (section 3.15), or give us a code for help (section 3.17). While we keep it, it can also show what your phone sent to Trace's AI features (section 3.3), which currently only the person who runs Trace can open. Access to a person's records, and more narrowly to screenshots, is limited to team members whose role needs it. We use these records to answer you, to thank you, to fix what you tell us about and to understand how Trace is doing. Your country also tells us which privacy law applies when you write to us.
When the website counts people, for example how many kept using Trace after a month or how people found it, it shows any group smaller than 5 as "fewer than 5", so a number can't point to anyone. Some numbers are kept with no ID at all, such as how many phones checked for Trace's updates each day, and in which language.
If your Plus moves from one support ID to another, for example when you sign in after using Trace without an account, these records move with it.
To have these records forgotten, write to us with your support ID (section 3.8). We'll delete the records our team and servers keep under it, such as your feedback and its screenshot, our replies, how you found Trace, our tags and notes, what you shared with our team (section 3.15), what your phone shared for help (section 3.17), the safety signals kept under a code made from your ID (section 3.16) and what the website keeps from the subscription management provider. We keep a scrambled form of the ID, which lets us recognize it so the records aren't rebuilt. Deleting your account does the same for your account's ID. The Trace Plus records in section 3.8 are kept as section 8 describes.

3.14 What we don't collect

We don't receive your payment card or bank details: the App Store or Google Play handles payment. We don't collect your precise location: apart from the internet address any connection carries (section 3.7) and your phone's time-zone offset (section 3.3), the location we see is no more precise than a country (sections 3.8 and 3.13). We don't collect your contacts or advertising identifier. We don't read data from Apple Health or Health Connect. We don't use advertising SDKs or track you across other companies' apps or websites for advertising; how you found Trace (section 3.12) is something different. The Google service diagnostics used by Android's cup tools are described in section 3.7. This section describes our current practice; section 12 explains how it can change.

3.15 Sharing with our team (off unless you turn it on)

In Settings › Your data › Share with Trace's team, you can let our team see what Trace's AI sees, so we can find where Trace gets things wrong and fix it. It's off unless you turn it on, and the switch is all it takes.
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How it differs from what our servers keep anyway: without this switch, what your phone sends to Trace's AI may be kept for a period we set, which may be none, to keep Trace secure, prevent abuse, fix problems and meet legal obligations, and only the person who runs Trace can open it (section 3.3). With it on, it's kept longer and people on our team look at it to find where Trace gets things wrong.
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What's kept while it's on: from when you turn it on, what your phone sends to Trace's AI features (meal photos, the words you type or say, and your fixes), the answers Trace gives, which of our AI services answered and how long it took. It's kept under your support ID (section 3.8). It can include health information, such as what you eat.
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Who sees it: members of our team look at it, on our team's private website (section 3.13). No one outside our team looks at it; our service providers store it for us (section 6).
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How long: up to a year, then it's deleted. We don't use it to train AI models.
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Stopping: turn the switch off. That stops it and deletes what was kept for our team, apart from backup copies, which are deleted on their own schedule (section 8). Deleting your account, or asking us to forget your support ID (section 3.13), deletes it too.
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Your consent: the switch is your consent. We record when you turned it on or off, and the version of its words (Share with Trace's team).
Turn it on only if you're comfortable with our team seeing what you share. Everything else in Trace works the same either way.

3.16 Safety signals: how Trace is used, not what you log

To protect Trace and the people who use it, for example against scripts, automated use and copies of the app, to keep fair use fair, and to compare versions of a screen, Trace records how it's used:
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From the app: for example, the screens you reach and the controls you tap or change, how far each tap lands from the middle of its control, and the time between them, with the app's version, the platform and the version of a screen you were shown in a test. Screens and controls are recorded in a way that doesn't show which of Trace's health features you use: those that could are recorded only under a general label.
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On our servers: for example, for each meal request, such as a photo, Say it or Fix issue, when it arrives, how it ended and how long it took; your other AI requests only as a count for each hour; and whether you started Trace Plus or its free week. None of these signals includes the feature's name, its cost or its content; our technical records keep the feature and cost, without content (section 3.7).
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Not recorded: what you type, the words on the screen, your journal, photos, doses or location.
A scrambled code, not your ID. These signals are kept under a code our servers make from your account's or phone's ID with a secret key. Only the part of our servers that answers the app uses the key: to file each signal under its code, to apply a slow-down or block, and to delete the signals when you ask. Our team's website, our statistics and the service provider that checks the numbers work without the key or your IDs, so they can't connect these signals to your other records. We don't use the signals to recognize your phone after Trace is installed again.
What happens with them:
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Our servers check them regularly for signs of automated use, such as taps that always land in the exact middle, perfectly regular timing, or meal requests while the app isn't being used. A service provider that checks usage numbers may help judge a flagged pattern, from the numbers alone and without any ID or code.
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If the checks find signs of automated use, AI features for that phone or account may slow down automatically for a while, currently 24 hours. Nothing else in Trace changes, and the slow-down ends by itself.
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Our team may also limit or block a phone or account. Currently, a person decides every block. A blocked phone shows how to reach us, and you can ask a person to look again. We can lift a slow-down or a block at any time.
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For an A/B test, your phone may be shown one version of a screen at random, and we count the results for each version. Tests run on screens that don't show your health.
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We keep totals with no code at all, for example how many people reach a screen, how often a control is tapped, the results of a test, and how often Fix issue renamed one food to another, which we show only when 5 or more fixes match. We keep these totals de-identified and don't try to tell who is in them.
How long: the signals and what the checks found, up to 30 days; the record of a slow-down or block, until 30 days after it's lifted; totals with no code, as long as they're useful. Deleting your account, or asking us to forget your support ID (section 3.13), deletes the signals under its code too.
These signals protect Trace and everyone who uses it, so there's no switch for them in the app. We don't use them for ads, sell them or share them with other companies, other than the service providers that work for us (section 6).

3.17 Help from our team (only with the code your phone shows)

If you ask us for help and our team needs to see what happened in your Trace, we can ask your phone to share. Nothing is shared until you give us the code your phone shows.
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How it starts: when our team asks, your phone shows a six-digit code at the top of Today, with what sharing means. Your phone makes the code itself, and our servers receive only a scrambled form of it. If you want our help, read the code to our team by phone, email or message, and our team enters it. Giving us the code is your consent. If you'd rather not, tap Not now or let the code run out, and nothing is shared.
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What your phone shares: from then on, it sends our servers what Trace keeps on it, including your whole journal from its first day: meals with their photos, words, answers and fixes; the supplements and medicines you take, your doses and skips, and why you take them; water, exercise, weight and check-ins, such as mood, sleep and symptoms; notes and saved foods; your profile, such as your age, sex, height, weight and whether you're pregnant or breastfeeding; your targets and reminders; cup and label photos; what Trace works out and shows you, such as totals and the safety check; and your phone's details. While you share, what your phone sends to Trace's AI and the answers it gets back are kept too. It's kept under your support ID (section 3.8), and it includes health information, which our Consumer Health Data Privacy Policy also covers.
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Why: so our team can find what went wrong, help you and fix Trace.
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Who sees it: the members of our team who are helping you, on our team's private website (section 3.13). Our service providers store it for us (section 6), and an AI service may help our team understand it, for example by sorting your fixes by kind of problem (section 5). We don't use it to train AI models.
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How long: up to 30 days from when you give the code. Sharing ends when the 30 days are up, when you stop it, or when our team ends it. Then your phone stops sending, and what it shared is deleted from our servers within minutes, apart from backup copies, which are deleted on their own schedule (section 8).
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Stopping: tap Stop sharing on Today or in Settings › Your data, at any time. Only you can start it again, with a new code.
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What stays: our team's own notes about what it found, which may mention what it saw, such as a meal Trace misread; they're kept with our other notes about you (section 3.13). An idea for improving Trace that came from what you shared may stay, without the link to you. We also keep a record of the share: when it was asked for, started and ended, and the version of the words your phone showed (Help from Trace's team), as proof of your choice, for 2 years after what you shared is deleted.
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Deleting your account, or asking us to forget your support ID (section 3.13), deletes all of it, including our notes and the record of the share.
Give the code only if you asked us for help and you're comfortable with our team seeing what Trace keeps on your phone. Everything else in Trace works the same either way.

4. Why we use it

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To provide the features you ask for.
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To process health information for those features, with your agreement, given when you continue past setup (section 3.3), which you can withdraw at any time (section 9).
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To send content to AI services to analyze it, with the same agreement, given before anything is sent.
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To provide Trace Plus, and to keep the records of purchases the law requires (section 3.8).
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To read and answer the feedback you send, including any health information you choose to put in it, to reply in Trace, and to fix and improve Trace from what you tell us (sections 3.10 and 3.11).
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With your OK, to show your feedback as a review on the Trace Plus offer (section 3.10).
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If you give us the code your phone shows, to look at what Trace keeps on your phone, find what went wrong, help you and fix Trace (section 3.17).
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To understand how people find Trace and how it's doing, from what you tell us and the records in sections 3.12 and 3.13.
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To improve Trace and develop new features, for example from your feedback and from statistics that don't identify you.
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To keep the service secure, prevent abuse and fix problems.
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To protect Trace against automated use and copying, and to compare two versions of a general screen (section 3.16).
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To comply with the law and respond to lawful requests.
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To create de-identified, aggregated statistics, for example how often a feature fails. Data that is truly de-identified is no longer personal data. We keep it de-identified, don't try to re-identify it, and require anyone we share it with not to try either.
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Optional: for our team to look at what Trace's AI sees and improve Trace, only if you turn on sharing with our team (section 3.15); or for health research, only with your separate consent. Both are off unless you turn them on.
Your journal and Trace's on-device features send nothing, unless you give our team a code so we can help you (section 3.17). What the lookups and AI features send is described in sections 3.2 and 3.3, and each AI feature also says what it sends in its first-use guide.
You don't have to give us personal data. Your journal works on your phone, and the features that need data send it when you use them. Like any app that connects to the internet, Trace also sends technical information when it checks our servers for what's new (section 3.7), and safety signals while you use it (section 3.16).

5. Artificial intelligence

Some features use AI models run by our service providers. They return suggestions, which you review and can correct before saving. We don't make decisions with legal or similarly significant effects about you by automated means. Currently, the one automatic step is the short slow-down in section 3.16, and a person decides any block. To have a person look at a slow-down or a block, write to support@tracewhatyoutake.com.
Our AI providers' current terms don't allow them to use your content to train their models. They may keep it for a short time, as our Service providers page describes. What you share with our team (sections 3.15 and 3.17) isn't used to train AI models either. When you share for help, an AI service may also help our team understand what you shared, for example by sorting your fixes by kind of problem.

6. Who we share it with

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Service providers that process data to run Trace for us. Most work under contracts with us; our photo, meal and ranking provider currently works under its own published privacy policy, which says it doesn't train on what it receives. They host our servers, accounts and our team's website, provide AI analysis, check photos and usage numbers, and manage subscriptions. The kinds of providers we use, with what each receives and where, are on the Service providers page, which we keep up to date.
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Public databases and product catalogs, which receive lookup words, barcodes or product identifiers (section 3.2).
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Google's Android cup-tool services, under Google's own terms and privacy policy (section 3.7).
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Apple's push notification service, which delivers a meal's name and calories to its Lock Screen card on iPhone when an analysis finishes after you leave Trace, under Apple's own terms (section 3.3).
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The App Store or Google Play, which handle your Trace Plus purchase under their own terms (section 3.8).
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People using Trace, who can read your words, stars and first name on the Trace Plus offer, only if you said it's OK to quote you (section 3.10).
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The law. We may disclose data when the law requires it, or when we believe in good faith that it's needed to protect the rights, safety or property of our users, the public or MySupplements, as the law allows.
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Business transfers. If MySupplements is involved in a merger, acquisition, financing or sale of assets, personal data may transfer to the successor. It stays subject to this policy, and any later change follows section 12.
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With your consent, for any other purpose you agree to.
We don't sell personal data, and we don't currently share it for targeted or cross-context advertising or use it to profile you for advertising.

7. Where your data is processed

We are based in the United States, and our servers are in the United States (Oregon). Our service providers may process data in other countries, as described on the Service providers page.
If you live outside the United States, what Trace sends from your phone goes to the United States, where it's processed and kept as this policy describes. The United States has no single national privacy law. Protection comes from federal laws, such as the Federal Trade Commission Act, which forbids unfair and deceptive practices, and from state laws, such as California's. Courts and government authorities in the United States, and in the other countries where our providers work, can require access to data held there under their own laws. We protect your data as this policy describes wherever you live, and our service providers handle it as section 6 describes.

8. How long we keep it

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Your journal on your device: until you delete it in Settings or delete the app.
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What phones send to Trace's AI features: as long as needed to give the result, and then, if we keep it, for a period we set and can change, which may be none, to keep Trace secure, prevent abuse, fix problems and meet legal obligations; it's deleted automatically when that period ends (section 3.3).
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Without an account: your phone's daily allowance count is kept in our servers' memory (section 3.3), its monthly usage record for a limited time (currently the current and previous month), and the record our database keeps for your phone until you ask us to delete it.
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The phone check: what our servers need to check a request is held in memory for a short time, currently about ten minutes (section 3.3).
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A Lock Screen card's push token and look: in our servers' memory until the card is sent or you come back to Trace, and currently at most three minutes (section 3.3).
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Your account: until you delete it. Deleting it removes your account and the data our servers keep with it, including the records in sections 3.10 to 3.13, except what our Delete your account page lists as kept. Photos that were still uploading are removed by a later cleanup.
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Feedback and our replies: up to 2 years. A screenshot you add: up to 30 days. A quote you allowed: until you take back your OK or we stop showing it, with the record of your OK.
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What you share with our team: up to a year, and deleted when you turn sharing off (section 3.15). The record of turning it on or off is kept as proof of your choice.
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What your phone shares for help: up to 30 days, and deleted within minutes after sharing ends; our team's own notes stay as in section 3.13; the record of the share, for 2 years after what you shared is deleted (section 3.17).
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Days a usage limit was reached: for a limited time, as long as needed to spot automated use (section 3.3).
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Safety signals: up to 30 days; the record of a slow-down or block, until 30 days after it's lifted; totals with no code, as long as they're useful (section 3.16).
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Our team's tags and notes, how you found Trace, and what the subscription management provider last told us: until you ask us to forget them (section 3.13) or delete your account, or until we no longer need them to help you.
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When your phone first and last checked in: until you ask us to forget it or delete your account, or a limited time after your phone stops checking in.
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Backups: deleted data can remain in backup copies of our database until those copies are deleted. Backup copies are kept for a limited time, as long as needed to restore the service after a failure, and then deleted. We use backups to restore the service and as the law requires, and protect them like our other systems.
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Technical logs: see section 3.7.
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Trace Plus records: while you have Plus, and afterwards as long as we need them for support, refunds, and the financial and tax records the law requires.
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Exceptions: we may keep data longer where the law requires it, or where we need it to establish, exercise or defend legal claims, to prevent fraud or abuse, or to keep the service secure, for as long as that need lasts.

9. Your rights and choices

In the app, at any time:
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export your data (Settings › Your data › Export backup);
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delete everything on your device (Settings › Your data › Delete all data);
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delete your account (Settings › Your account › Delete account; see Delete your account);
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stop sending content to AI by not using the features in section 3.3;
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turn sharing with our team on or off (Settings › Your data › Share with Trace's team, section 3.15);
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stop sharing for help at any time (Today, or Settings › Your data, section 3.17);
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manage or cancel Trace Plus in your App Store or Google Play subscriptions;
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turn off device permissions.
By email to support@mysupplementsapp.com, wherever you live, you can ask:
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to access your personal data, get a copy of it, and know how we use it and who we've shared it with;
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to correct it or delete it;
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to object to how we use it, or to withdraw a consent you've given;
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to forget what our team keeps under your support ID (section 3.13), to delete the record our database keeps for your phone (section 3.3), or to take back your OK to quote you (section 3.10).
Requests are free, unless the law allows a fee, for example for requests that are clearly unfounded or excessive. We'll verify your request, usually by asking you to confirm from your account's email or, without an account, by the support ID shown in Settings › Trace Plus. We'll answer as soon as we can, within the time your law sets: for example, 20 working days in New Zealand, 30 days in Canada and Australia, and 45 days under U.S. state laws. We won't treat you differently for using your rights. If you aren't satisfied with our answer, you can complain to the privacy authority where you live (sections 9.1 and 9.2).

9.1 Your rights under U.S. state laws

Depending on your state, including California, Colorado, Connecticut, Virginia, Texas and others, you have the right to know, access, correct and delete your personal data, to get a copy, and to appeal a decision about your request by emailing us with "Appeal" in the subject line. If we deny an appeal, you can contact your state attorney general. You can use an authorized agent.
We don't sell or share personal data, and we use sensitive personal information (health information and account credentials) only to provide the features you request and for the other purposes the law permits.
Washington and Nevada residents: see our Consumer Health Data Privacy Policy.

9.2 Canada, Australia, New Zealand, Japan, Singapore and Hong Kong

Canada. You can withdraw your consent at any time; some features then stop working. You can complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca). In Quebec, our person in charge of the protection of personal information is Moon Kim (section 1). You can also ask us for your personal data in a structured, commonly used technological format, and complain to the Commission d'accès à l'information du Québec (cai.gouv.qc.ca).
Australia. Our service providers receive personal information in the United States and in the other countries on our Service providers page, and we stay accountable for how they handle it. Please complain to us first. If you aren't satisfied with our answer within 30 days, you can complain to the Office of the Australian Information Commissioner (oaic.gov.au).
New Zealand. If we don't correct your personal information as you ask, you can ask us to attach your statement of the correction to it. You can complain to the Privacy Commissioner (privacy.org.nz).
Japan. This is the information Japan's Act on the Protection of Personal Information asks us to make available:
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Business: MySupplements LLC, 108-14 72nd Ave, Forest Hills, NY 11375, USA, represented by Moon Kim.
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Purposes: we use personal information only for the purposes in section 4.
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Special care-required personal information, such as a medication a doctor prescribed for you: we collect it only with your consent, which you give when you continue past setup (section 3.3).
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Providing it to recipients in a foreign country: we provide personal information to our service providers in the United States, and in the other countries on our Service providers page, to run Trace. Section 7 describes the United States' privacy system, and the Service providers page says what each provider receives and how long it keeps it. You agree to this when you continue past setup.
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Security measures: for example, a privacy officer responsible for personal information; access limited to the people and systems that need it, each with their own sign-in; encryption in transit and at rest; managed storage of secrets; deletion on set schedules; and checks of our service providers' terms for how they use and keep data. Our servers are in the United States, whose system is described in section 7.
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Requests: you can ask us to disclose the personal information we hold about you and our records of providing it to others; to correct, add to or delete it; or to stop using it or providing it to others, by writing to support@mysupplementsapp.com. We don't currently charge for requests.
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Questions and complaints: our privacy officer (section 1). You can also contact the Personal Information Protection Commission (ppc.go.jp).
Singapore. Our data protection officer is Moon Kim (section 1). You can complain to the Personal Data Protection Commission (pdpc.gov.sg).
Hong Kong. You can ask to access and correct your personal data under the Personal Data (Privacy) Ordinance by writing to our privacy officer (section 1), and complain to the Privacy Commissioner for Personal Data (pcpd.org.hk).

10. Children

Trace is not for people under 18, and we don't knowingly collect personal data from them. If you believe a child has given us personal data, contact us and we'll delete it.

11. Security

We use safeguards suited to the data, for example:
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encryption in transit and at rest on our servers, including our database, its backups and photo storage;
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access limited to the people and systems that need it, secrets kept in a managed vault, and a separate sign-in for our team's website, where each team member's role decides what they can see.
Your journal on the phone is protected by your device's security.
No system is perfectly secure. If a breach affects your personal data, we'll notify you and the authorities as the law requires.

12. Changes to this policy

What Trace collects, and how we use it, may change as Trace changes, including what "In short" describes. Before a change takes effect, we'll update this policy, post the new version with its effective date and tell you, for example in the app, normally at least 30 days ahead for a material change. Where the law requires it, we'll ask for your consent first, including before we use data we already have in a new way. When a new feature sends personal data in a new way, we'll tell you what it sends, for example in the app before you first use it.

13. Contact

support@mysupplementsapp.com · MySupplements LLC, 108-14 72nd Ave, Forest Hills, NY 11375, USA
Earlier versions
All legal documents
Trace is made by MySupplements LLC.