Clem

Privacy Policy

Effective date: June 26, 2026 Last updated: June 26, 2026

This Privacy Policy explains how Clem (“Clem,” “we,” “us,” or “our”) collects, uses, shares, and protects information when you use the Clem mobile app (the “Service”). By using Clem, you agree to this Policy.

1. Who we are

Clem is operated by Tyler Piwowarski, an individual sole proprietor based in California, United States. In this Policy, “we” refers to this operator acting under the Clem brand. If you have any questions, you can reach us at privacy@clemapp.com.

Business succession. In the event Clem is sold, transferred, merged, or discontinued, user data may be transferred to a successor entity. We will provide reasonable advance notice to users by email, and any successor will be required to honor this Privacy Policy or obtain fresh consent before making material changes to how your data is handled.

2. Information we collect

We intentionally collect as little data as possible. The information we collect is:

Account information

Dietary preferences

Scan and cart data

Subscription status

Product analytics

Camera and photo library access (when you scan or set a profile picture)

Profile and social information (only if you use the social features)

Posts you share to your feed (only if you use the social features)

Push notification token (only if you enable notifications)

What we do not collect

We do not collect or store:

We do not use any advertising, attribution, or behavioral-tracking SDKs.

3. How we use your information

We use your information solely to:

We do not sell your personal information. We do not use your personal information for advertising or for profiling outside the scope of the Service.

Information shared with other users (social features)

Clem’s social features are optional. When you use them, some information becomes visible to other people:

You control this. Your profile can be public (visible to anyone using Clem) or private (visible only to followers you approve). You can switch your profile to private, hide individual scans, and delete your comments at any time in the app. This sharing happens between you and other Clem users at your direction — it is not a sale of your personal information and is not sharing for advertising.

4. How your photo is handled when you scan

When you capture or select a photo to scan:

  1. The photo is read into memory on your device and encoded as base64.
  2. It is sent over a TLS-encrypted connection to our Supabase Edge Function.
  3. The Edge Function forwards it to the Google Gemini API for analysis.
  4. The text analysis is returned to your device and saved to your scan history.

We store your scan photo as a product-catalog image. To build a shared catalog of grocery products that powers Search and Healthier Alternatives, the photo you scan is uploaded to Supabase Storage and saved against the product it depicts (for example, products/<product-id>.jpg) — not against your account or identity — and may be displayed as that product’s image elsewhere in the app. Because these are photos of grocery packaging stored by product rather than by user, we treat them as deidentified catalog content that is not linked back to you. The resulting text analysis (score, ingredients, highlights, etc.) is also retained in your scan history. We never access or retain any other photos from your library — only the single image you capture or select for a scan. If you also choose to post a scan to your social feed, a copy of that photo and the caption you write are stored and displayed as your user content to the people entitled to see that post — see Section 5.

Your profile picture (avatar) is handled differently from both of the above. If you set a profile picture, it is stored in a separate Supabase Storage bucket (profile-photos) that is public-read by design. Unlike the photos you scan (deidentified and keyed to the product) and unlike your feed-post photos (kept private and served through short-lived signed links), your avatar is intentionally public — it is served from a stable, public URL rather than a time-limited signed link, so it can load anywhere your profile or posts appear (your profile, the feed, comments, your followers/following lists, and people search). The image is saved under a path that links it to your account but uses an unguessable, random filename (for example, <your-user-id>/<random-id>.jpg), so that even a private-profile user’s avatar cannot be guessed or enumerated from their user identifier. When you change your avatar, remove it, or delete your account, the stored image is deleted or replaced. As with scanning, we only access the single photo you capture or select to set as your avatar — no other photos from your library.

Google Gemini’s retention and use of the image is governed by Google’s terms — see Section 6 below.

5. User content and social features

When you choose to post a scan to your Clem social feed, that post is user content you create and we store on your behalf. This section explains how it is collected, shown, controlled, and kept.

What we collect and store. The photo you took when scanning the product and the caption (text) you write to accompany it. These are saved against your account and the post you created.

Where it’s shown. Posts you share appear in the Clem social feed of the people who follow you. If your profile is public, your posts can also be seen by any Clem user who can view your profile. Posts you keep to yourself are not shown to anyone else.

Visibility controls. You stay in control of every post. You can:

Access control. Stored photos are private by default. Only people entitled to view a given scan — you, your approved followers, or (if your profile is public) any Clem user — can access the image, and they do so through time-limited signed links that expire. Images are not exposed at a public, permanent URL.

Retention. Photos and captions you post are kept until you delete the scan (or your account), at which point they are removed. We may also remove content that violates our community guidelines (see our Terms of Service).

This sharing happens at your direction, between you and other Clem users. It is not a sale of your personal information and is not sharing for advertising.

6. Third-party services we use

The Service relies on a small number of third parties. Each handles the data described below under its own privacy terms. We rely on our providers’ standard Data Processing Agreements (DPAs), as required under GDPR Article 28, to govern their processing of personal data on our behalf.

Supabase (database, authentication, and server-side functions; hosted on AWS) Supabase stores your account, dietary preferences, scan history, cart, and subscription status. Data is encrypted at rest and in transit. See the Supabase Privacy Policy.

Google Gemini API (AI analysis of scans and product information) When you scan or search for a product, the image and/or text is sent to Google’s Gemini API through our Edge Function so the AI can analyze it. Clem uses the paid (billed) tier of the Gemini API. Under Google’s paid-tier Gemini API terms, Google does not use the content you submit — prompts, images, or the responses Google generates — to train or improve their AI models. Google may retain the content for a limited period for abuse detection, safety, and legal-compliance purposes, but not for machine-learning training. See the Google Gemini API Additional Terms of Service and the Google Privacy Policy.

RevenueCat (subscription management) RevenueCat manages subscription purchases, receipt validation, and entitlement status on our behalf. It receives your anonymous user identifier and Apple purchase receipts. RevenueCat is SOC 2 Type II certified and is based in the United States. See the RevenueCat Privacy Policy.

PostHog (product analytics) PostHog logs product-analytics events (e.g., scans completed, paywall views, onboarding steps) and records masked session replays (see “Product analytics” in Section 2), linked to your anonymous user identifier. We do not enable heatmaps or autocapture. PostHog is SOC 2 Type II certified and is based in the United States. See the PostHog Privacy Policy.

Apple (Sign in with Apple, StoreKit for subscriptions) Apple handles authentication when you sign in with Apple and handles all payment processing for Clem Pro. Apple’s handling of that data is governed by Apple’s Privacy Policy.

Google (Sign in with Google, if you choose it) If you sign in with Google, Google handles that authentication. See the Google Privacy Policy.

Expo (push notification delivery) If you enable notifications, we use Expo’s push service (operated by 650 Industries, Inc., U.S.) to deliver notifications to your device through Apple’s Push Notification service (APNs). Expo receives your device push token and the notification content solely to route the message to your device. See the Expo Privacy Policy.

7. How long we keep your data

8. Your rights and choices

You can:

Appeals. If we decline to take action on a data request described above, you may appeal by emailing privacy@clemapp.com with the subject line “Privacy Request Appeal” and a brief description of the original request and why you believe the denial was incorrect. We will respond in writing with an explanation of our decision within 45 days. If your appeal is denied, you may submit a complaint to your applicable state attorney general or data protection authority.

9. European Economic Area, United Kingdom, and Switzerland (GDPR / UK GDPR)

If you are in the EEA, the United Kingdom, or Switzerland, the General Data Protection Regulation (or the UK GDPR) gives you specific rights.

Data controller. Tyler Piwowarski, operating Clem, is the data controller for the personal data described in this Policy. You can reach the controller at privacy@clemapp.com.

Legal bases we rely on.

Your rights. You have the right to access, rectify, erase, restrict, or object to our processing, the right to data portability, and the right to withdraw consent. Email privacy@clemapp.com to exercise any of these.

Right to lodge a complaint. You also have the right to complain to your local data protection supervisory authority.

International transfers. Your data is stored and processed in the United States (Supabase / AWS) and transmitted to Google’s Gemini API for analysis. Where required, we rely on Standard Contractual Clauses and our providers’ own transfer mechanisms.

10. California residents (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the CPRA, gives you specific rights.

Categories of personal information we collect. Identifiers (email, user ID, username, and — if you enable notifications — a device push token); customer-account information (name, profile details, subscription status); commercial information (products you’ve scanned, saved, or added to cart); internet/other electronic network activity (your interactions with the Service, including follows, likes, and comments, and masked session replays of your app usage); and user content (comments you post, captions and photos you post to your social feed, profile information you provide, and photos you submit for scanning, stored as deidentified product-catalog images keyed to the product rather than to you).

Categories of sources. Directly from you; from Apple or Google at sign-in; and generated by your use of the Service.

Purposes. Only to provide and secure the Service, as described in Section 3.

Third parties we share with. Service providers only, as listed in Section 6. Separately, when you use the social features, information you choose to share — your profile, the scans you share, and your likes and comments — is visible to other users of the Service at your direction. We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We have not done so in the past 12 months.

Your rights under the CCPA/CPRA. You have the right to know what we collect, to delete your personal information, to correct inaccurate information, to opt out of sale or sharing (not applicable — we do neither), to limit the use of sensitive personal information (we do not collect sensitive personal information), and not to be discriminated against for exercising these rights.

How to exercise your rights. Email privacy@clemapp.com, or use Settings → Delete Account in the app. We will respond within 45 days. We verify requests by matching the email address on your account.

11. Additional U.S. state privacy rights

Residents of Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia may have additional rights under their applicable state privacy laws, including the right to access, correct, delete, and obtain a portable copy of their personal information, and to opt out of targeted advertising, the sale of personal information, or profiling that produces legal or similarly significant effects. We do not engage in targeted advertising, the sale of personal information, or such profiling, so the opt-out rights do not currently apply to any processing Clem performs — but the access, correction, deletion, and portability rights are fully available to you.

To exercise these rights, email privacy@clemapp.com. We will respond within 45 days. We verify requests by matching the email address on your account. If we decline your request, you may appeal as described in Section 8.

12. Children’s privacy

Clem is not directed at children under 13, and we do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has created an account, email privacy@clemapp.com and we will delete the account and any associated data.

Clem is rated 4+ on the App Store because it contains no objectionable content, but the service itself is intended for general audiences 13 and older.

Teen users (13–17). Users between the ages of 13 and 17 may use Clem only with the consent of a parent or legal guardian. By using the Service, users under 18 represent that they have obtained such consent. In jurisdictions that require parental consent for users under 16 (such as certain EEA member states under GDPR Article 8), that higher age threshold applies instead. Parents or guardians may request deletion of a minor’s account by emailing privacy@clemapp.com.

13. Apple Sign In and “Hide My Email”

If you sign in with Apple and choose Hide My Email, Apple gives us an anonymized relay email address (ending in @privaterelay.appleid.com) instead of your real email. Messages we send to that address are forwarded by Apple to your real inbox. We cannot see your real email address and cannot unmask it. Deleting your Clem account works the same way whether you use a real or relay email.

If you revoke Clem’s access to Sign in with Apple (iOS Settings → Apple ID → Password & Security → Apps Using Apple ID → Clem → Stop Using Apple ID), you will be signed out of Clem and unable to sign back in with that Apple ID. To also delete your stored data, use Settings → Delete Account in the app before revoking.

14. Security

We protect your data with industry-standard measures:

No system is perfectly secure. If we discover a breach affecting your personal information, we will notify you as required by applicable law.

15. Changes to this Policy

We may update this Policy from time to time. If we make a material change, we will update the Effective Date at the top and notify you in the app or by email. Your continued use of the Service after an update constitutes acceptance of the updated Policy.

A diff history of every change is publicly visible in the Git history of the repository that hosts this page.

16. Contact

For questions or requests about this Policy or your data, email:

privacy@clemapp.com

Tyler Piwowarski, operating Clem California, United States