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Privacy Policy

Here we explain how we process personal data when you use the FODMAPP app.

Last updated: 20 August 2026 · Version 2.0

1. About this privacy policy

This privacy policy explains how Telemark Software Solutions AS processes personal data when you use the FODMAPP app and our website. It applies to everyone who uses FODMAPP.

Telemark Software Solutions AS is the data controller for the processing described here. You can contact us at [email protected].

FODMAPP is built on Google Firebase for authentication, storage and operations, and uses Google’s Gemini AI models for the AI features. Because the app deals with food, digestion and symptoms, we process health data, and we therefore explain in particular detail below what happens to that information.

2. In brief

  • We process information about your diet, digestion and symptoms. This is health data, and we process it only on the basis of your explicit consent.
  • Your AI chat conversations are deleted automatically after 24 hours. The food and symptom entries you record are stored on your account so that you have a history, and you can delete them in the app at any time.
  • Text and images you send to the AI features are transferred to Google’s Gemini models for processing. We do not use your data to train our own AI models.
  • Photographs are not stored on our servers. They are sent straight to the AI provider for the analysis and discarded afterwards.
  • We send you the service messages needed to run your account. Our newsletter is sent only if you switch it on in the app’s settings, and you can switch it off again at any time.
  • We never sell your personal data, and we do not use it for advertising or third-party profiling.
  • You can request access, correction and deletion at any time, and withdraw your consent in the app.

3. What personal data we collect

a) Account data

  • Email address, and first and last name if you provide them
  • Password, stored in encrypted (hashed) form – or your login method if you use Google Sign-In or Apple Sign-In, in which case we receive your name and email address from them, and your telephone number and profile picture where the provider supplies them
  • Language setting, app version and country/region
  • Record of the consents you have given: which version of the terms and privacy policy you accepted and when, whether you have consented to the processing of health data and when, whether you have consented to marketing, and your acceptance of the age requirement (at least 16 years), recorded when you accept the terms

b) Subscription data

  • Subscription status and type, trial period status, start and renewal dates
  • A pseudonymous subscriber ID with RevenueCat, and the purchase history reported by the app store
  • We never receive or store your card details. Payment is handled entirely by Apple or Google

c) Health-related data

  • The messages you write in the AI chat, including anything you tell us about digestion, symptoms, reactions to food, diagnoses or medication. Chat messages are deleted automatically after 24 hours; see section 10
  • The entries you record in the app: meals, symptom and pain logs, bowel movements (Bristol scale), sleep, stress, menstruation and medication
  • Your trigger profile, your safe foods and your reintroduction tests
  • The AI’s analyses, FODMAP scores and recommendations linked to your account
  • The history of the above, which is stored on your account until you delete it, withdraw your consent or delete your account

d) Images

  • Photographs you take or upload for analysis – food, dishes, menus, ingredient lists, barcodes or the contents of your fridge
  • Images are not stored on our servers. They are passed straight to the AI provider for the analysis and discarded once it is complete. Images uploaded by older versions of the app are deleted automatically within 48 hours

e) Technical and usage data

  • Device model, operating system, app version and language
  • Crash and error reports via Firebase Crashlytics, and performance data such as app start-up and network timings via Firebase Performance Monitoring
  • Usage statistics via Google Analytics for Firebase, such as which screens and features are used – including which onboarding steps you complete
  • Simple counters kept on your account, such as how many times you have opened the app and how many chat messages and camera analyses you have used
  • Usage events are linked to an app-instance identifier and to your user ID, and on Android the analytics service may also collect the device’s advertising ID. This data is therefore personal data. We use it only to understand and improve the app – never for advertising, and we do not share it with advertising networks; see section 14

f) Correspondence and feedback

  • Emails and support enquiries you send us, and our replies
  • Bug reports and app ratings you submit in the app, which include your user ID and any text you write

g) Location

  • If you use the toilet finder, your approximate location is sent to the OpenStreetMap Overpass service to look up nearby toilets. We do not store your location, and it is not linked to your account

4. Health data and your explicit consent

Information about digestion, symptoms and reactions to food is classified as data concerning health, which is a special category of personal data under Article 9 of the GDPR. Such data may only be processed where a specific condition is met.

We process your health data solely on the basis of your explicit consent under Article 9(2)(a), together with Article 6(1)(a). You give this consent in a separate dialogue in the app before the AI features are made available to you, and it covers the storage of your conversations and entries and the transfer of the content to our AI provider for processing.

The consent is voluntary. You may withdraw it at any time in the app’s settings or by contacting us, and withdrawal is as simple as giving consent. If you withdraw your consent, we stop the processing and delete the stored health data, and the AI features can no longer be made available to you. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

5. Why we process your data, and our legal basis

  • Creating and operating your account, and delivering the subscription you have purchased – necessary for the performance of our contract with you, Article 6(1)(b).
  • Sending service messages, including welcome information, receipts, security notices and notices of changes to the terms – performance of the contract, Article 6(1)(b).
  • Storing and processing your health-related data and images so the AI features work – your explicit consent, Article 9(2)(a) together with Article 6(1)(a).
  • Sending our newsletter and other marketing – your consent, Article 6(1)(a), and section 15 of the Norwegian Marketing Control Act.
  • Security, troubleshooting, and preventing misuse, fraud and abuse of trial periods – our legitimate interest in a secure and functioning service, Article 6(1)(f).
  • Statistics and improvement of the app, based on aggregated and anonymised data – our legitimate interest, Article 6(1)(f). Fully anonymised data falls outside the scope of the GDPR.
  • Accounting and complying with statutory obligations – legal obligation, Article 6(1)(c).

6. How your data is processed by AI

The AI features – AI chat, camera analysis and barcode scanning – are powered by Google’s Gemini models, accessed through Firebase AI Logic and Vertex AI. The requests go from the app to Google’s infrastructure. Our app development platform (FlutterFlow) is not part of this chain and does not receive your content.

What is sent

  • The text you write in the chat
  • A limited amount of health context from your account, so that the answer fits your situation: your trigger profile and safe foods, your tolerance profile and FODMAP protocol status, the findings of your most recent AI analysis, your stress level, your five most recent symptom logs and your seven most recent scans
  • For the AI analysis: up to 30 days of the entries you have recorded, including meals, symptoms, bowel movements, sleep, stress, menstruation and medication
  • Photographs you submit for analysis, and ingredient lists retrieved for a scanned barcode
  • We do not send your name, email address, user ID or payment information
  • Your stored chat history is not sent to the AI provider – each session starts a new conversation

Why, and on what basis

  • The sole purpose is to generate the answer or analysis you have asked for
  • Because the content contains health data, the basis is your explicit consent, Article 9(2)(a) together with Article 6(1)(a). You give it before the AI features are made available to you
  • Google acts as our data processor and processes the content on our instructions
  • We do not use your content to train our own AI models, and we do not sell it

Storage and deletion

  • Images are not stored on our servers; they are discarded once the analysis is complete
  • Chat messages are deleted automatically after 24 hours – both by the app and by an hourly server routine. You can also delete the conversation history yourself at any time in the app
  • Your food and symptom entries remain on your account until you delete them, withdraw your consent or delete your account. All three can be done in the app
  • The AI provider may retain content for a short period for operational and abuse-monitoring purposes under its own terms, after which it is deleted
  • A limited number of authorised personnel may access content where strictly necessary for troubleshooting, security or handling misuse

Important limitations

  • AI-generated answers may be incomplete or incorrect, and are general information, not medical advice
  • The AI makes no decision that has legal effect for you; see section 14
  • You decide what you write. We encourage you not to include more health information than is necessary to get a useful answer

7. Emails and marketing

Service messages

For as long as you hold an account, we send you the emails and notifications needed to deliver the service. These include a welcome email with getting-started information when you become a paying subscriber, password and security notifications, operational notices, and notices of changes to the terms or this privacy policy. Receipts for purchases are issued by Apple or Google. The basis for these is the performance of our contract with you, Article 6(1)(b), and you cannot unsubscribe from them while you hold an account.

We do not send our own reminder before a free trial ends. Apple and Google notify you themselves before a trial converts into a paid subscription, and you can cancel at any time in your App Store or Google Play account.

Newsletter and marketing

We send our newsletter with low-FODMAP tips, recipes, news and offers only if you switch it on under «Newsletter by email» in the app’s settings. It is off by default, it is separate from your acceptance of the terms, it is voluntary, and it is not a condition for using FODMAPP.

You can switch it off again at any time in the same place, or use the unsubscribe link in any marketing email. We record when consent is given and withdrawn so that we can demonstrate compliance with the rules on electronic marketing.

We do not sell or disclose your email address to others for marketing purposes, and we do not use your health data to target marketing.

8. Who we share your data with

We do not sell personal data. We use the following data processors and providers, all of whom are bound by a data processing agreement or equivalent terms:
  • Google Firebase – authentication, database, storage, crash reporting, performance monitoring and analytics
  • Google (Firebase AI Logic / Vertex AI) – processing of text and images in the AI features
  • RevenueCat – subscription management, using a pseudonymous subscriber ID
  • Apple and Google – as sellers of subscriptions and providers of the app stores
  • Resend – delivery of service emails and newsletters
  • Open Food Facts – product lookups by barcode. Only the barcode is sent; no personal data is transferred
  • OpenStreetMap / Overpass – the toilet finder. Your approximate location is sent in order to look up nearby toilets; it is not stored and is not linked to your account
  • Content delivery networks – the app loads animations (LottieFiles), typefaces (Google Fonts) and certain images from external content networks. Your IP address is transmitted when that content loads; no account data is shared
We may also disclose data where we are required to do so by law, or in order to establish, exercise or defend legal claims.

9. Transfers outside the EEA

Our database is located in the EU (Firestore, European multi-region), and your account data and your entries are stored there.

Some processing nevertheless takes place outside the EEA. The AI processing is not restricted to a European region, and some of our server functions run on infrastructure in the United States. Where personal data is transferred out of the EEA, we rely on the safeguards required by Chapter V of the GDPR: the European Commission’s Standard Contractual Clauses, and/or the provider’s certification under the EU–US Data Privacy Framework.

You may contact us at [email protected] for information about the safeguards that apply to a specific transfer.

10. How long we keep your data

  • Account data – for as long as you have an account. On deletion, data is removed within 30 days, and from backups within 90 days.
  • AI chat conversation history – deleted automatically after 24 hours. You can also delete it yourself at any time in the app.
  • Food and symptom entries – until you delete them, withdraw your consent, or delete your account.
  • Images – not stored. Images uploaded by older versions of the app are deleted within 48 hours.
  • Crash reports – up to 90 days.
  • Usage statistics in Google Analytics – up to 2 months at user level. Aggregated reports, which cannot identify you, are kept longer.
  • Usage counters on your account – for as long as you have an account.
  • Purchase and accounting records – 5 years after the end of the financial year, as required by the Norwegian Bookkeeping Act.
  • Record of consent to marketing – for as long as the consent is in force; it is stored with your account data and deleted with the account.
  • Support correspondence, bug reports and app ratings – up to 2 years.

11. Security

We use encrypted connections (HTTPS/TLS) for all communication between the app, our servers and our providers. Passwords are stored hashed and are never available to us in plain text. Access to production data is restricted to the small number of people who need it, and is protected by two-factor authentication.

If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the Norwegian Data Protection Authority within 72 hours, and we will notify you where the law requires it.

12. Your rights

You have the right to:
  • Access – be told what data we hold about you and receive a copy
  • Rectification – have incorrect data corrected
  • Erasure – have your data deleted, including the right to be forgotten
  • Restriction – ask us to limit our processing
  • Object – object to processing based on our legitimate interest
  • Data portability – receive your data in a structured, commonly used, machine-readable format
  • Withdraw consent – at any time, without giving a reason
  • Lodge a complaint – with a supervisory authority
To exercise your rights, contact [email protected]. We reply without undue delay and no later than one month. See also our Delete account page.

If you believe we are processing your personal data unlawfully, you may complain to the Norwegian Data Protection Authority (Datatilsynet), postboks 458 Sentrum, 0105 Oslo, www.datatilsynet.no. If you live in another EEA country, you may also complain to the supervisory authority in your own country.

13. Children

FODMAPP is not intended for children. You must be at least 16 years old to create an account and use the app. We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe that a child has nevertheless provided us with personal data, please contact us at [email protected] and we will delete the information.

14. Automated decision-making and profiling

The AI features generate information, assessments and recommendations, but they do not make any decision that has legal effect for you or otherwise significantly affects you within the meaning of Article 22 of the GDPR. You always decide for yourself what you eat.

We do not carry out profiling for advertising purposes, we do not use your health data to build marketing profiles, and we do not disclose data to advertising networks.

15. Cookies and the website

Our website uses only what is necessary to make the site work. We store your choice of language and your response to the cookie banner locally in your browser. We do not use advertising cookies, and we do not track you across other websites.

The website loads typefaces from Google Fonts and certain images and store badges from external sources (including Apple and Wikimedia), which means your IP address is transmitted to those providers when a page loads. The app itself uses Firebase Analytics as described in section 3(e).

16. Changes to this privacy policy

We may update this privacy policy, for example when we introduce new features or when the rules change. The date and version number are shown at the top of the page.

In the case of material changes, we will notify you in the app or by email in good time, and where the law requires it we will ask for your consent afresh. Older versions are available on request.

17. Contact

Data controller: Telemark Software Solutions AS

Org. no.: 936 367 194

Registered address: Østli 15, 3718 Skien, Norway

Email: [email protected]

Website: www.fodmapp.com

For privacy enquiries, please write «Privacy» in the subject line so that we can handle your request promptly.

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