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Privacy Policy

Last updated

Washington residents: see our Washington Consumer Health Data Privacy Policy.

CholesTrack is operated by Peakline Innovations LLC ("Peakline," "CholesTrack," "we," "us," or "our"). This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you use the CholesTrack mobile application, our website at cholestrack.com, and related services (collectively, the "Service").

Your privacy is especially important to us because CholesTrack handles information relating to nutrition, health goals, and certain health conditions.

This Privacy Policy is intended to provide notice of our privacy practices. It is not intended to obtain consent where applicable law requires a separate, affirmative consent. Where such consent is legally required, we will request it separately.

Please also review our Terms of Service and, where applicable, our Consumer Health Data Privacy Policy.

1. CholesTrack Is a Wellness and Informational Service

CholesTrack is a consumer nutrition and wellness application. It is not intended to provide medical advice, diagnose a condition, provide medical treatment, or replace a physician or other qualified healthcare professional.

Information about nutrition, cholesterol, health scores, nutrient targets, trends, and other information presented through CholesTrack is provided for informational and general wellness purposes.

Please review the medical and wellness disclaimer contained in our Terms of Service.

2. Information We Collect

The information we process depends on the features you choose to use.

Account and Identity Information

When you create or use an account, we may receive:

  • your email address;
  • your name, if provided;
  • an internal account identifier;
  • authentication information supplied through Sign in with Apple, Sign in with Google, or another supported authentication method; and
  • an Apple private-relay email address if you choose Apple's Hide My Email feature.

We do not receive your Apple ID or Google password.

Depending on what you choose to provide, CholesTrack may process:

  • age;
  • sex;
  • height;
  • weight entered directly into CholesTrack;
  • activity level;
  • nutrition preferences and customized nutrient targets;
  • health-related selections, such as general prevention, high cholesterol, high LDL, high blood pressure, familial hypercholesterolemia, post-cardiac-event status, statin use, or plant-based diet selection;
  • foods and meals you log;
  • serving sizes and quantities;
  • meal dates and times;
  • nutrient intake information;
  • custom foods and recipes;
  • personalized nutrient targets; and
  • Health Scores and trends generated from information you provide.

Some of this information may constitute sensitive personal information, medical information, or consumer health data under applicable law.

We use this information to provide the functionality you request, such as calculating targets, displaying nutrition intake, generating Health Scores, and showing trends.

Cholesterol Lab Values and Lipid Journey Information

If you enter cholesterol laboratory values or milestones into the Lipid Journey feature, those values are stored locally on your device.

Peakline does not receive, upload, or store your Lipid Journey laboratory values on its servers.

The App may process this information locally to display charts and trends to you. You can delete this information from the App or export it locally where that feature is available.

Apple Health Information

If you grant permission, CholesTrack may read certain information from Apple Health, currently including step count and body weight.

Apple Health information is processed and displayed on your device. Peakline does not upload or store this Apple Health information on its servers.

We do not use Apple Health information for advertising, marketing, profiling, data brokerage, or unrelated purposes.

You can revoke CholesTrack's Apple Health permissions through Apple's Health or device settings.

Food Searches, Barcode Scans, and Custom Foods

When you search for or log food, we may process:

  • search text;
  • barcode or UPC information;
  • selected foods;
  • serving sizes;
  • nutrition facts; and
  • information necessary to associate your own unverified or custom catalog submissions with your account.

Search terms that produce no catalog results may be retained separately from your account identity for a limited period so that we can understand missing foods and improve FoodDB.

Nutrition-Label Photographs

If you choose to photograph a packaged food or nutrition label, the photographs may be uploaded to Amazon Web Services for processing.

We may use Amazon Web Services services, including Amazon S3, AWS Lambda, and Amazon Bedrock, to store and process these images and extract product and nutrition information.

Automated extraction may make mistakes. CholesTrack may therefore ask you to review or confirm extracted information.

Authorized CholesTrack personnel may review submitted product images when necessary to verify or administer catalog submissions.

Photographs may incidentally include information that you did not intend to submit. When using this feature, please photograph only the product and information necessary for the feature.

Voice search is optional.

When you use voice search, CholesTrack uses Apple's speech-recognition capabilities to turn speech into text. On-device speech recognition is preferred when available. Depending on your device, operating-system capabilities, language, or other factors, Apple may process audio through its speech-recognition service.

Peakline does not receive or store your voice recording.

We receive or process the resulting text only as necessary to perform your food search. As with typed searches, a search that produces no results may be retained in de-identified or non-account-linked form to improve the catalog.

You may disable microphone and speech-recognition permissions in your device settings.

Subscription Information

Premium subscriptions are processed by Apple through the App Store.

We may receive information necessary to determine whether your Apple purchase currently entitles your device or App environment to Premium features.

Peakline does not receive your credit-card number or other payment-card credentials from Apple.

Technical and Security Information

When the Service communicates with our systems and service providers, technical information may be generated, including:

  • IP address;
  • timestamps;
  • App and operating-system version;
  • request and response information;
  • technical error information;
  • security and abuse-prevention information; and
  • certain account or submission identifiers needed to provide requested functionality.

For example, some FoodDB requests may contain an internal CholesTrack user identifier so the Service can identify catalog entries associated with your own submissions. Such identifiers may therefore appear in server or infrastructure logs.

We use technical information for security, troubleshooting, fraud and abuse prevention, service operation, and reliability.

Apple Developer Analytics

If you have chosen to share analytics with developers through Apple's settings, Apple may provide Peakline with crash, performance, or usage information.

CholesTrack does not currently include third-party advertising SDKs.

Communications

If you contact us, we may retain your message, email address, and related correspondence so we can respond, maintain records of the request, investigate issues, or comply with legal obligations.

3. How We Obtain Information

We obtain information:

  • directly from you;
  • from your use of the Service;
  • from Apple Health when you expressly authorize access;
  • from Apple or Google when you choose their authentication services;
  • from Apple in connection with App Store subscriptions;
  • from your device when you authorize camera, microphone, or speech-recognition functions; and
  • from our systems and service providers when they generate operational, security, or diagnostic information.

We may also generate information from other information you provide, including nutrition totals, nutrient targets, Health Scores, and trends.

4. How We Use Information

We use personal information as reasonably necessary to:

  • create and maintain your account;
  • authenticate you;
  • provide food logging and meal tracking;
  • sync account information and meal data across supported devices;
  • calculate personalized nutrient targets;
  • calculate and display Health Scores and trends;
  • provide requested barcode, photograph, voice-search, and food-search functionality;
  • process and verify food-catalog submissions;
  • administer Premium functionality;
  • provide customer support;
  • protect accounts and the Service against fraud, abuse, attacks, or unauthorized access;
  • diagnose technical problems;
  • maintain and improve the Service and FoodDB;
  • comply with applicable law;
  • respond to valid legal process;
  • enforce our Terms of Service; and
  • protect the rights, safety, and security of users, Peakline, or others.

We do not use your health profile, meal logs, Apple Health information, or cholesterol information for targeted advertising.

5. Automated and Artificial Intelligence Processing

Certain CholesTrack features use automated processing.

For nutrition-label capture, information you choose to submit may be processed using Amazon Web Services, including Amazon Bedrock, to extract nutrition information from the image.

Automated and AI-generated results may be incomplete or inaccurate and should be reviewed before you rely on them.

If we introduce new AI features that materially change the categories of personal or consumer health information we collect, the purposes for which it is processed, or the parties that receive it, we will update our disclosures and obtain additional consent where required before the new processing occurs.

6. When We Disclose Information

We disclose information only as described below or as otherwise disclosed to you at the time of collection.

Service Providers and Processors

We use companies that process information on our behalf to operate the Service. Depending on the feature involved, these include:

Supabase — authentication, account information, profiles, meal and nutrition data, custom foods, database services, and related infrastructure.

Amazon Web Services — FoodDB infrastructure, API services, databases, security logging, product-image storage and processing, and Amazon Bedrock automated extraction.

Apple — Sign in with Apple, App Store subscription functionality, optional speech recognition, Apple developer analytics where enabled by the user, and Apple Health functionality initiated and controlled by the user.

Google — Google authentication where you choose Sign in with Google.

Vercel — hosting and infrastructure for cholestrack.com.

These providers may process information only for the purposes of supplying services to us or as otherwise permitted by applicable law and their applicable agreements with us.

Shared Food Catalog and De-Identified Catalog Information

If you choose to contribute product or food information to FoodDB, factual product and nutrition information from the contribution may be separated from your identity and incorporated into the shared CholesTrack food catalog.

This may include product names, UPCs, serving information, ingredients or nutrition facts, and related factual catalog metadata.

Once catalog information has been de-identified so that it is not reasonably linkable to you, Peakline may retain, use, improve, distribute, or commercially license that factual catalog information as part of FoodDB.

We do not sell or license your identifiable health profile, meal history, account information, cholesterol information, or Apple Health information as part of FoodDB.

Original user photographs are not themselves made part of a commercially licensed catalog unless we separately disclose that use and have an appropriate legal basis or authorization.

We may disclose information when we reasonably believe disclosure is necessary to:

  • comply with applicable law, regulation, court order, subpoena, or other valid legal process;
  • investigate or prevent fraud, abuse, security incidents, or unlawful conduct;
  • enforce our legal agreements; or
  • protect the rights, property, safety, or security of Peakline, our users, or others.

Nothing in this paragraph is intended to authorize disclosure prohibited by applicable health-privacy or medical-information law.

Business Transactions

Information may be transferred as part of a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar business transaction.

Any recipient remains subject to applicable privacy law with respect to personal and consumer health data it receives.

We may disclose information when you direct us to do so or provide consent.

7. No Sale of Personal or Consumer Health Information

Peakline does not sell identifiable personal information or consumer health data.

We do not share personal information for cross-context behavioral advertising.

We do not disclose your health profile, meal history, cholesterol information, or Apple Health data to data brokers, advertisers, employers, health insurers, or healthcare providers unless you expressly direct us to do so or disclosure is otherwise legally required and permitted.

The use or commercial licensing of factual FoodDB information that has been appropriately de-identified and is no longer reasonably linkable to an individual is different from selling a user's personal or consumer health information.

8. Advertising and Cross-Service Tracking

The CholesTrack iOS application does not currently contain advertising SDKs or third-party behavioral advertising technology.

We do not permit third parties to collect your health information through CholesTrack over time and across unrelated websites or online services for targeted advertising.

To the extent a browser-based Do Not Track signal does not correspond to activity occurring on our Service, it may not alter our practices. Where applicable law requires us to recognize a legally valid privacy-preference signal, we will do so as required.

9. Data Retention

We retain information only for as long as reasonably necessary for the purposes described in this Policy, including providing the Service, complying with legal obligations, protecting the Service, resolving disputes, and enforcing agreements.

Account, profile, nutrition, and meal information is generally retained while your account remains active.

You may delete your account through the App. Account deletion initiates deletion of personal information associated with your account, subject to information we must retain under applicable law and temporary copies contained in backups.

Consumer health data subject to a legally valid deletion request will be deleted within the time required by applicable law. Where Washington's My Health My Data Act applies, deletion from archived or backup systems will occur within the period permitted by that law.

Original nutrition-label photographs are retained for .

Server and infrastructure logs are generally retained for .

Zero-result catalog searches are generally retained for when retained for catalog-improvement purposes.

Information that has been properly de-identified so it is no longer reasonably linkable to you, including factual FoodDB catalog contributions, may be retained indefinitely.

10. Account Deletion

You can delete your CholesTrack account from within the App.

You may also contact us at support@cholestrack.com concerning a privacy or deletion request.

Deleting CholesTrack from your device does not, by itself, delete your account or cancel an App Store subscription.

Deleting your CholesTrack account also does not automatically cancel an App Store subscription. Subscriptions must be managed through Apple.

Locally stored information may need to be separately removed from the device or App as appropriate.

11. Security

We use administrative and technical safeguards intended to protect information appropriate to its sensitivity.

These safeguards include encrypted network connections using TLS, authentication controls, database access controls, Supabase row-level security for ordinary user access, access restrictions, and security controls provided through our infrastructure providers.

Authorized administrative personnel may access information when reasonably necessary to administer, secure, troubleshoot, maintain, or comply with legal obligations relating to the Service.

No information system can be guaranteed to be completely secure. Accordingly, we cannot guarantee that unauthorized access, loss, misuse, or disclosure will never occur.

If we discover a security incident involving personal or consumer health information, we will investigate and provide legally required notifications to affected individuals, regulators, or others as required by applicable law.

12. Your Privacy Choices and Rights

Regardless of where you live, CholesTrack provides mechanisms for you to view or edit many account details directly through the App and to delete your account.

Depending on applicable law, you may also have rights to:

  • obtain information about whether we process information about you;
  • access personal information;
  • obtain a copy of certain information;
  • correct inaccurate information;
  • delete information;
  • withdraw consent to certain future processing;
  • obtain information about disclosures of consumer health data;
  • restrict or limit certain processing;
  • appeal our response to a privacy request; and
  • exercise privacy rights without unlawful discrimination.

To exercise a right that is not available directly in the App, contact:

support@cholestrack.com

We may take reasonable steps to verify that you are the person to whom the requested information relates.

We will respond within the period required by applicable law.

13. California Residents

California law provides various privacy protections depending on the nature of the information, the business, and the circumstances.

To the extent the California Consumer Privacy Act, as amended ("CCPA"), applies to Peakline, California residents may have rights including access, deletion, correction, information about collection and disclosure, limitation of certain uses of sensitive personal information, opt-out rights where personal information is sold or shared, and protection against unlawful discrimination for exercising those rights.

Peakline does not currently sell personal information or share personal information for cross-context behavioral advertising.

Health-related information may also receive protection under other California laws, including, where applicable, laws governing medical information. Nothing in this Policy is intended to waive or limit any right that cannot lawfully be waived.

California residents may submit a privacy request using support@cholestrack.com.

14. Washington Consumer Health Data

Washington consumers should review our separate Consumer Health Data Privacy Policy, available at:

That policy explains the categories and sources of consumer health data we process, our purposes, applicable disclosures, and rights provided under Washington's My Health My Data Act.

15. Nevada Consumer Health Data

For purposes of Nevada law, consumer health data that CholesTrack may process can include health-condition selections, body measurements, diet and nutrition information, foods and meals, health-related preferences and targets, and health-related information derived from those inputs.

The sources of this information are primarily you, information generated by CholesTrack from information you provide, and Apple Health information you expressly authorize the App to process locally.

We process this information to provide the nutrition-tracking, personalization, scoring, trend, and other functionality you request.

We do not sell consumer health data.

Where service providers process consumer health data for us, they do so for purposes of providing requested functionality or operating the Service.

You may request access, correction, or deletion of applicable consumer health data or withdraw consent to future collection or sharing where provided by law by contacting support@cholestrack.com.

If we refuse a qualifying request, you may appeal by emailing support@cholestrack.com with "Privacy Appeal" in the subject line.

We do not permit third parties to collect consumer health data through the Service over time and across unrelated websites or online services for advertising.

If we materially change the categories, purposes, or recipients of consumer health data in a manner requiring additional consent, we will provide notice and obtain consent before carrying out that activity.

16. Canadian Users

If you use CholesTrack from Canada, your information may be transferred to and processed in the United States, including by service providers located or operating there.

As a result, information may be subject to lawful access by courts, law-enforcement authorities, or governmental authorities in jurisdictions where it is processed.

Where Canadian privacy law applies, Peakline processes personal information for identified and appropriate purposes and seeks meaningful consent where required, taking into account the sensitivity of the information.

You may contact us to request access to or correction of personal information or to withdraw consent where applicable, subject to legal and contractual restrictions.

Peakline's Privacy Officer can be reached at:

Privacy Officer
Peakline Innovations LLC
support@cholestrack.com

If CholesTrack is offered to residents of Quebec, Peakline will process personal information in accordance with applicable Quebec privacy requirements.

17. Children

CholesTrack is intended for adults.

You must be at least 18 years old to create or use a CholesTrack account.

We do not knowingly permit children under 18 to create accounts. If we learn that an account has been created by a person who does not meet our age requirement, we may delete the account and associated information.

If you believe a minor has provided information to us, contact support@cholestrack.com.

18. Third-Party Services

Certain features interact with services operated by companies such as Apple and Google.

Those companies may independently process information under their own terms and privacy policies when you interact directly with their services.

This Privacy Policy governs Peakline's handling of information and does not replace the privacy policies of independent third parties.

19. Changes to This Privacy Policy

We may update this Privacy Policy as our Service, technology, or legal obligations change.

When we update it, we will change the "Last Updated" date.

If a change materially affects how we collect, use, or disclose sensitive or consumer health information, we will provide additional notice and obtain consent where required before applying a new practice to your information.

20. Contact Us

For privacy questions, requests, or complaints:

Peakline Innovations LLC
Attn: Privacy Officer
support@cholestrack.com

For general support, contact support@cholestrack.com.