Fluffy – Privacy Policy

Last updated: 2 November 2026 · Deutsch

Fluffy is an app that estimates the calories and nutrients of what you eat from what you write and photograph. This policy says which personal data Fluffy uses, why, who receives it, how long it is kept and how you delete it.

Who is responsible

exacode GmbH
Adalbertstraße 56
80799 München, Germany
Email: exacode.gmbh@gmail.com

exacode GmbH develops Fluffy and decides how its data is used ("we" in this policy). Write to the address above for any question about your data. We have not appointed a data protection officer.

What Fluffy uses

• Your account. You sign in with Apple. Apple gives us your email address, or a private relay address if you choose to hide yours, and your name if you share it. We keep them, with a user ID, in the sign-in service of Amazon Web Services.
• Your messages. What you write, the photos you take or choose, the barcodes you scan, the time you send each message with your time zone's offset from UTC (such as +02:00), the version of the app you send it from, and the language for Fluffy's answer, German or English: the one you pick for Fluffy in your iPhone's Settings, or, without such a choice, your iPhone's language.
• Fluffy's answers. The estimates for your meals, with their ranges, and the notes the AI makes on how it reached them.
• Fluffy's memory of your meals. A list of your past meals and the foods and products in them, built from all your chats, which Fluffy uses to understand your next messages.
• Your days. Which days you mark as complete, with the time of each change.
• Your notifications. If you allow notifications, the app leaves a small record on our servers so that we can send them: your iPhone's push address, which Apple gives the app, which of Apple's two push services the address belongs to, whether notifications are on, the version of the app, your time zone, such as Europe/Berlin, and when the record was last written. For each notification, our servers write into their logs the ID of the chat, whether Apple accepted it and the version of the app, never its text or the push address.
• Technical data. When the app uploads a message, our servers write your IP address, your user ID, the time and the barcodes you scan into their logs. When a message fails, the error they write may include part of it. At sign-in, Amazon's sign-in library in the app sends technical details of your iPhone, such as its model, system version and language, to the sign-in service; Amazon declares them as used for its analytics, not linked to you.

What you eat can say something about your health, for example a diet you follow. Fluffy does not ask for your location, your contacts or data from the Health app. It shows no advertising, and we use no tracking, no advertising service and no analytics service. We do not sell your data.

The app keeps your chats, photos, the memory of your meals and your days on your iPhone too. They are part of your iPhone's backup to iCloud or to a computer, if you have turned that on.

Why, and on what legal basis

• To run Fluffy for you: your account, your messages, the answers and your days, so that you can sign in, chat and see your estimates. Legal basis: the contract with you, Art. 6(1)(b) GDPR.
• To estimate your meals with AI, and to read chats ourselves: Fluffy sends your messages and photos to an outside AI service, and we read chats to fix errors and to improve the estimates. Legal basis: your consent, which you give when you tap Allow in the app, before your first message goes out. That is Art. 6(1)(a) GDPR and, as far as your meals say something about your health, Art. 9(2)(a) GDPR.
• To tell you when an answer is ready: the record of your iPhone above, and the text of each notification. Legal basis: your consent, which you give when you tap Allow in iOS's dialog, after Fluffy's question or from Fluffy's Settings, Art. 6(1)(a) GDPR and, as far as a notification says something about your health, Art. 9(2)(a) GDPR. This permission belongs to your iPhone: signing out does not withdraw it, and whoever signs in to Fluffy on that iPhone gets notifications too. You withdraw it by turning off Fluffy's notifications in your iPhone's Settings; Fluffy keeps estimating your meals without it.
• To keep the service working and secure: the server logs, to find errors and misuse. Legal basis: our legitimate interest, Art. 6(1)(f) GDPR.
• To test Fluffy before its release: what Apple shows us from TestFlight, to fix errors. Legal basis: our legitimate interest, Art. 6(1)(f) GDPR.

You can withdraw your consent at any time: delete your account in the app, or write to us. What happened before stays lawful. Without your consent, Fluffy cannot estimate your meals.

If you sign out, the app forgets your Allow on that iPhone and asks again at your next sign-in.

You do not have to give us any data, but Fluffy cannot work without the data above. Fluffy makes no decisions about you that have legal or similarly significant effects.

Who receives your data

• Amazon Web Services (AWS) stores all of the above and runs Fluffy's servers, in its data centres in Frankfurt, Germany. AWS works only on our instructions.
• OpenAI, in the USA, is the AI service that estimates your meals.
  • What it receives with each message: the chat so far, its photos, the product data of your barcodes, and a short list of your recent meals and known foods from Fluffy's memory. When you refer to an earlier meal, it also receives that earlier chat, even one you deleted in the app. It fetches each photo through a link that works for 24 hours.
  • How long OpenAI keeps it: up to 30 days, to find misuse, then OpenAI deletes it. We have told OpenAI not to store our requests and not to keep a record of each conversation.
  • OpenAI does not use this data to train its models.
  • Sending data to the USA: our contract with OpenAI uses terms the EU has approved for this, the EU standard contractual clauses.
• Anthropic: when we read chats to fix errors or to improve the estimates, we use Claude, Anthropic's AI assistant, so Anthropic receives the chats we read. Anthropic Ireland, Limited handles them as its own, under Anthropic's privacy policy and with model training turned off, and keeps them for up to 30 days. Anthropic sends data to the USA under the EU standard contractual clauses.
• Open Food Facts, a free food database, receives the number of a barcode you scan, from our server, never anything about you.
• Apple provides Sign in with Apple. If you test Fluffy through TestFlight, Apple shows us your name and the email address you were invited with, the crash reports and usage data that Apple collects on its own, and the feedback and screenshots you choose to send. Apple's own privacy policy covers both.
• Apple's push service delivers Fluffy's notifications to your iPhone. For each one, Apple receives the notification's text, which is the name of the meal with its calories and Fluffy's comment, Fluffy's reply, or the start of your message, together with your iPhone's push address, the ID of the chat and a short code made from your Identity ID. Apple keeps a notification until it can deliver it, at most one day. Apple's own privacy policy covers its push service.
• GitHub, in the USA, hosts this page and records the IP address of everyone who opens it. Sending data to the USA: GitHub is certified under the EU-US Data Privacy Framework.

How long we keep it

• Your account, chats, photos, memory and days stay as long as your account exists.
• The record of your iPhone for notifications stays as long as your account exists, with all its details. When you turn notifications off, the app marks it as off the next time Fluffy opens; when you sign out, the app marks it as off if your iPhone reaches our servers within a few seconds. Until then, a notification can still be sent. Another iPhone on which you allow notifications replaces the record, and deleting your account deletes it with the rest.
• Deleting a chat in the app removes it from your list. Its copy on our servers, and its meals in Fluffy's memory, stay until you delete your account.
• Earlier versions: our servers keep each earlier version of a file for 30 days after it changes or is deleted, then delete it.
• Chats we read are copied to our developer's computer for that work and deleted there within 90 days.
• Server logs are deleted automatically after 30 days. The record of an upload our servers failed to process, with the same technical data, is kept for 14 days.
• OpenAI and Anthropic keep data as described above.
• On your iPhone, your data stays until you delete your account in the app or delete the app. Signing out keeps your chats and photos on the iPhone.

How to delete your account

In the app, open Settings and tap Delete Account. This deletes your sign-in account, your chats, your photos, the memory of your meals and your days at once from the app and from our servers, and their earlier versions within 30 days. It also deletes them from your iPhone.

• The server logs stay until they are deleted after 30 days, and OpenAI and Anthropic keep their copies as described above.
• If you use Fluffy on a second device, delete the app there too. For up to an hour after the deletion that device can still send a message, which then stays on our servers until you write to us.
• If Fluffy is closed while it deletes your account, the copy on your iPhone stays until you delete the app.
• Your Apple ID keeps a note that you used Sign in with Apple with Fluffy until you remove it in your iPhone's Settings; the app shows you how after the deletion.

You can also ask us by email to delete your account. Send the Identity ID that Settings shows, so we can find your data. Without the app, you can install it again, sign in with the same Apple ID, which opens the same account, and delete it in Settings.

Your rights

You have the right to access your data, to have it corrected or deleted, to restrict its use, to receive it in a common format, and to object to its use based on our legitimate interest. You can withdraw your consent at any time. Write to us at the address above, with the Identity ID that Settings shows.

You also have the right to complain to a data protection authority. Ours is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany, www.lda.bayern.de.

Changes to this policy

When Fluffy changes what it does with your data, we change this page and its date before the change reaches you.