Privacy Policy

This Privacy Policy (“Policy”) describes how VLT Holdings, Inc. (“SnapWell,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes your personal information when you use the SnapWell mobile application and related services (the “Services”). It also describes your choices and rights regarding your personal information. This Policy forms a part of our Terms of Service, and terms used but not defined here have the meaning given in the Terms of Service.

By using the Services, you agree to the practices described in this Policy. If you do not agree, please do not use the Services.

1. Who we are

SnapWell is a nutrition-tracking app that lets you log meals by photographing them or describing them with your voice. We use artificial intelligence to identify foods, estimate portions, and track your intake against personalized health goals you set.

For any privacy questions, contact us at privacy@snapwell.app.

2. Age requirement

You must be at least 18 years old to use the Services. The Services are intended for adults and are not designed for or directed to anyone under 18. We do not knowingly collect personal information from anyone under 18. If we become aware that someone under 18 may have provided us with personal information, we will investigate and, if applicable, take steps to remove the data and delete that individual’s account.

3. Information we collect

We collect only the information needed to make the Services work. This falls into a few categories.

Information you provide

• Account information. When you sign in with Sign in with Apple, we receive a unique identifier and, if you choose to share it, your name and email address (which may be an Apple private-relay address).
• Meal photos. Images you capture or upload to log a meal.
• Voice recordings. Audio you record to describe a meal. This audio is used only to generate a text transcription and is not retained afterward (see Section 6).
• Food and nutrition logs. The foods you log, portions, and the nutrition data associated with each entry.
• Health and profile data. Information you enter to personalize your goals, such as height, weight, age, sex, activity level, and dietary targets (for example, daily calorie or macronutrient goals).
• Apple Health (HealthKit) data. With your permission, health and fitness data you choose to share from Apple Health. See Section 9 for how we handle this data.
• Communications. Information you provide when you contact us for support or otherwise communicate with us, including your email address and the contents of your message.

Some of the information above — particularly your food logs, body measurements, and dietary goals — may be considered sensitive personal information under applicable law, because it can indicate or allow someone to infer a health condition. We treat this information accordingly (see Section 8).

Information collected automatically

• Device and technical information. Device model, operating system version, app version, and basic diagnostic data used to keep the Services stable.
• Usage information. How you interact with features, used to operate and improve the Services.

We do not ask for or store payment card numbers, government IDs, or banking details. Subscription billing is handled entirely by Apple through the App Store; we never see your payment information.

4. How we use your information

We use your personal information to:

• Provide the Services. Identify foods and estimate portions from your photos and voice recordings, look up nutrition data, calculate your intake, and track your progress against the goals you set.
• Maintain your account. Manage your account, sync your data, and provide troubleshooting and support.
• Communicate with you. Respond to your questions and requests, and send administrative information such as changes to our terms and policies.
• Improve and personalize the Services. Diagnose problems, develop and test features, and tailor suggestions and reporting to your goals.
• Maintain security and protect rights. Monitor and protect the security of the Services, and prevent and detect fraud, unauthorized access, and other misuse.
• Satisfy legal obligations. Comply with applicable law and respond to legally valid requests from authorities, and defend our rights in legal matters.

We do not sell your personal information, and we do not use your meal photos, voice recordings, or health data to serve you third-party advertising.

5. How we disclose your information

To deliver core features, some of your data is processed by trusted third-party service providers. These providers process data on our behalf to provide their service and are not permitted to use it for their own purposes.

When you log a meal, the relevant photo or audio is transmitted to the applicable AI provider for processing and a result is returned to the App. We encourage you to review each provider’s own privacy terms. We do not knowingly send these providers more data than is needed to return a result.

Beyond these service providers, we may disclose your personal information:

• For legal and safety reasons. To comply with applicable law, respond to legally valid requests from law enforcement or regulators, enforce our Terms, or protect the rights, property, or safety of SnapWell, our users, or others.
• In a business transaction. In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, in which personal information may be among the assets transferred. We will require the recipient to honor this Policy or notify you of any material change.

6. How we retain your information

We retain your personal information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it; whether we can achieve those purposes by other means; and applicable legal requirements.

In practice:

• Your account data, food and nutrition logs, and profile data are stored on cloud infrastructure provided by Supabase and retained for as long as your account is active.
• Meal photos are stored in a private storage bucket on Supabase, associated with the meal you logged. They are deleted when you delete your account.
• Voice recordings are transmitted to our transcription provider to convert your spoken description into text. We do not retain voice recordings after transcription; only the resulting text and the food/nutrition entry derived from it are kept.
• All data is stored on infrastructure located in the United States.

When you delete your account, we delete or de-identify your personal information within 2 days, except where we must retain it to meet a legal obligation. If we de-identify information, we will keep and use it only in de-identified form and will not attempt to re-identify it except as permitted by law.

7. How we protect your information

We maintain reasonable technical, organizational, and administrative safeguards — including encryption in transit — designed to protect the personal information under our control from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no information security measures can guarantee absolute security.

8. Your privacy rights

Depending on where you live, you may have certain rights over how your personal information is collected, used, and shared, including:

• Right to access and data portability. The right to confirm whether we are processing your personal information and to obtain a copy in a portable and, where technically feasible, readily usable format.
• Right to deletion. The right to request that we delete your personal information, subject to certain exceptions under applicable law.
• Right to correction. The right to request that we correct inaccuracies in your personal information.
• Right to opt out of certain processing. This includes the “sale” or “sharing” of personal information and the use of personal information for “targeted advertising,” as those terms are defined under applicable law. SnapWell does not sell or share your personal information, and does not use it for targeted advertising.
• Right to limit the use of sensitive information. Some states give residents the right to limit the use of sensitive personal information. We use your sensitive personal information (such as your health and dietary data) only to provide the Services and not for any incompatible purpose.
• Right against discrimination. We will not discriminate against you for exercising any of these rights.
• Right to appeal. Where applicable, you may appeal a decision on a privacy-rights request by emailing privacy@snapwell.app with “APPEAL” in the subject line.

California residents (CCPA/CPRA). Diet and health information is treated as “sensitive personal information.” We use it only to provide the Services’ core functionality and do not sell or share it for cross-context behavioral advertising.

How to exercise your rights. The easiest way is to submit a request through our Your Privacy Choices form. You can also email us at privacy@snapwell.app. We will respond within the timeframe required by applicable law. Where legally permitted, you may submit a request through an authorized agent; we will need to verify the agent’s identity and your authorization before acting on the request.

9. Apple Health (HealthKit)

SnapWell integrates with Apple Health. With your permission, we may read certain data from HealthKit and write data we generate (such as your logged nutrition and calorie intake) back to HealthKit. You control this access through iOS permissions and can grant or revoke it at any time in the Settings app or the Health app.

We use HealthKit data solely to provide and personalize features within the App. Consistent with Apple’s requirements:

• We do not use HealthKit data for advertising or any use-based data mining beyond providing your own health and fitness service.
• We do not sell HealthKit data or share it with third parties for marketing or advertising.
• We do not disclose HealthKit data to any third party except to provide a service you have requested, and never without your authorization.

Data you choose to share through HealthKit is also governed by Apple’s own terms and privacy policy.

10. Changes to this policy

We may update this Policy from time to time. When we make material changes, we will update the “Last updated” date and, where appropriate, notify you in the App. Your continued use of the Services after a change takes effect means you accept the updated Policy.

11. Contact us

If you have any questions or concerns regarding this Policy or our privacy practices, contact us at privacy@snapwell.app, or write to us at:

VLT Holdings, Inc.
ATTN: SnapWell Privacy/Legal
6-05 Saddle River Road, STE 169
Fair Lawn, NJ 07410