Privacy Policy

• There is no account and no server of ours. We cannot look you up, because there is nothing to look you up in.
• Your Health data, your food diary and everything you write stay in the app’s own database on your iPhone — and, if you back the phone up, in your own Apple backup of it.
• The mentor and the portfolio build run on your device only. That is not a setting — there is no consent and no fallback that would send their prompts anywhere.
• Meal and workout descriptions, and photos of labels and meals, are processed on the device or, with your explicit consent, in Apple Private Cloud Compute. You can keep recognition on-device only.
• Two third parties see anything at all: the App Store together with RevenueCat (that you bought a subscription) and our product analytics (that an app screen was opened). Neither can receive health data or anything you typed.

Sergei Andreev, 26a M. Khorenatsi str., Yerevan 0010, Armenia, operates the Health Portfolio app for iOS and this website. For any question about this policy, write to [email protected].

Apple Health data — sleep, steps, heart rate and variability, weight and body composition, nutrition and water — is read only for the categories you switch on in the Health permission sheet. iOS never tells us which categories you left off. This data is stored in the app’s database on your device, protected by iOS Data Protection, and is not transmitted to us.

Everything you enter yourself — meals, workouts, your answers in the investor questionnaire, notes about injuries or conditions, and questions to the mentor — is stored the same way, on the device.

Of what you enter, only descriptions of meals and workouts and photos of labels and meals can leave the phone — and only for recognition, with your consent. See the separate section below.

Subscriptions are handled by the App Store. RevenueCat verifies the receipt on its servers and receives an anonymous device identifier and purchase events. The app never calls its login API, so there is no account to attach to you.

Product analytics record that something happened — an onboarding step was viewed, the paywall was opened, a meal was logged. Events come from a closed list defined in code as a type, and the properties come from closed dictionaries; free text cannot physically be placed into them. The analytics provider is PostHog, hosted in the EU. Analytics are disabled entirely in development builds.

The same channel carries technical diagnostics that iOS itself hands to the app (MetricKit): how many times a day the app was closed and why — for example, because it ran out of memory — and the kind of a crash or freeze. These are counts and names from the same closed dictionaries: no crash logs, no memory contents, nothing from the screen.

If you arrived from an Apple Search Ads campaign, iOS can provide an attribution token that tells us which campaign the install came from. The IDFA is not used and we do not track you across apps or websites.

Notifications are scheduled on the device. There is no push server, and the text is composed days in advance — which is why it can never contain a number about your health.

The mentor’s prompts carry your Health data and whatever you wrote in your own words. They are processed by Apple’s on-device models, or by a model you downloaded to the phone, and they are not sent anywhere else — not to us, not to Apple, not to any cloud, under any consent and under any fallback.

The same holds for underwriting: the calculation that turns your data into targets and into the score.

This is enforced by the build itself. A build phase fails the entire build — release builds included — if the code that handles these prompts so much as references the private cloud.

Recognizing a meal from a photo or a description, a label from a photo or a workout from a description is more accurate than the on-device model can manage. With your explicit consent, and only for this recognition, the photo or the text may be processed in Apple Private Cloud Compute.

Processing there is ephemeral: the photo or text is stored nowhere and is unavailable to anyone, including Apple and the developer. We receive only the recognition result — the name of the dish or workout and its values.

You are asked before the first such use, and you can decline. The setting “On-device only” in Profile → Privacy keeps recognition on the phone permanently; it simply reads labels less accurately. Consent can be withdrawn there at any time.

• We do not sell your data and do not share it with data brokers.
• We do not use your data to train models.
• There is no advertising in the app and no cross-app or cross-site tracking.
• We do not write anything into Apple Health without an action of yours.
• We do not ask for your name, your email or your phone number.

Support is an email address, not a form inside the app: writing to us means we receive your address and whatever you put in the message — including, if you choose to describe it, something about your health. We ask for none of that, and the app sends us nothing on its own.

Correspondence is kept only as long as it takes to answer you and to remember what the conversation was about. Ask us to delete it and we will.

Because the data lives on your device, you control it directly. Deleting the app deletes its database with it — we keep no copy on a server for you to ask us about.

If iCloud Backup is switched on, the app’s database travels in your device backup, the way most apps do. That copy sits in your own Apple account and is encrypted; with Advanced Data Protection enabled it is encrypted end-to-end, with a key Apple itself does not hold. It never reaches us, and we cannot read it. iOS lets you choose which apps go into the backup, so you can leave this one out.

Profile → My data saves a copy as a single file. It is the second route — useful if you keep no device backup, or want your history somewhere outside Apple. That file is yours; we never receive it.

To cut off Apple Health, revoke access in Settings → Privacy & Security → Health. The app keeps working; it simply has fewer positions to open.

Cancelling a subscription is done in the App Store and does not delete anything.

Where the GDPR or a similar law applies, you have the right to access, correct, export and delete your personal data. In our case those rights are exercised on the device itself, because that is the only place the data exists: you can read it in the app, export it as a file, and delete it by deleting the app.

For the narrow slice held by third parties — the fact of a purchase at RevenueCat, an anonymous install identifier in analytics — write to us and we will delete what can be identified from your device identifier.

healthportfolio.app is static pages served through Cloudflare. It sets no cookies and asks you for nothing. Cloudflare processes technical request data, such as an IP address, in order to deliver the page and protect the site.

The app is not intended for anyone under 18, and we do not knowingly process their data.

Health Portfolio is a wellness product. It is not a medical device, it does not diagnose, treat or prevent disease, and what the mentor says is not medical advice. Talk to a doctor before changing your diet or training, especially if you have a condition or take medication.

If the policy changes, the date at the top changes with it, and the previous version stops applying from that date. A change that affects what leaves your device will also be announced in the app.

There are two versions of this notice, and they describe the same thing. This one is written from how the app actually behaves — what is computed on your iPhone, what leaves it and under which consent. The full notice covers the formal parts that privacy laws ask for in their own words: legal bases, transfers outside the EEA, retention periods, the rights of residents of individual US states, and how to complain to a supervisory authority.

Read this one to know what happens to your data. Read the full one if you need the legal detail. Where the two differ, this page is the one that describes the app correctly, and we will correct the other.

[email protected] · Sergei Andreev, 26a M. Khorenatsi str., Yerevan 0010, Armenia