Privacy Policy

Last updated 29 August 2026. Applies to the Seroa mobile app.

Seroa is a nutrition planning app. This policy describes what it actually collects, where that data goes, how long it is kept and how to get rid of it. It describes the app as it is built, not as it might be one day.

Who operates Seroa

Seroa is operated by Twilight Zero Systems Ltd, a private limited company registered in the United Kingdom under company number 17426643. Twilight Zero is the parent brand; Seroa is the product. Twilight Zero Systems Ltd is the controller of the personal data described in this policy — it decides what is collected and why.

Registered office: 124 City Road, London, EC1V 2NX, United Kingdom.

For any privacy question, request or complaint, email support@twilightzero.com.

What Seroa collects

Account

Your email address and password when you create an account. Passwords are handled by our authentication provider and are stored hashed — Seroa never sees your password. Each account has an internal identifier used to keep your records separate from everyone else's. If sign-in with Apple or Google is offered and you use it, we receive the identity that provider returns.

Your profile

What you enter so Seroa can calculate a plan: your name if you give one, date of birth, sex, height, weight and target weight, activity level, goal, country, locale, timezone, unit and appearance preferences, dietary preferences, allergies, disliked foods, cuisine preferences, cooking time and budget.

Date of birth is used to confirm you are 18 or over, and — with sex, height, weight and activity — to calculate your energy and macronutrient targets.

Nutrition and health-related records

Meals and food items you log, your plan and any locked meals, saved and repeated meals, weight history and any note attached to it, water logs, fasting sessions, challenges, generated grocery lists, and the personal food model — the evidence, behavioural aggregates and conclusions Seroa builds from your own logging in order to adapt your plan.

Some of this is health-related information. It is used to run the app for you. It is not sold, and it is not used for advertising.

What you capture

The structured result of an analysis — the foods identified, portions, confidence and any warnings — is stored with the meal so you can review and correct it.

Uploads that never finish. A photo is sent to us before it is analysed, so if a scan is interrupted — you close the app, the network drops, or the analysis fails — the uploaded file can be left behind without ever becoming a meal. Those unfinished uploads are removed automatically, normally within about two hours. This applies even if you have chosen "Delete after use": that setting removes the photo as soon as an analysis completes, and a scan that never completes is cleaned up by this sweep instead.

Subscriptions

If you subscribe, our subscription provider tells us whether your subscription is active, which product it is and when it expires. Seroa never receives your card details. Payment is handled entirely by Apple or Google.

We keep a deliberately small record of each subscription event: the provider's reference for it, the kind of event, which product and entitlement it concerned, whether it was a test or a live purchase, and when it happened. The provider's original message is not stored at all — so the purchase and transaction details it contains, and any other identifiers it may carry, are used to process the event and then discarded rather than written down. The event reference is kept so that a message the provider re-sends is not processed twice.

What Seroa does not collect

This is worth stating plainly, because many apps do the opposite:

• There is no analytics, crash-reporting, advertising or attribution service in the app.
• There is no advertising identifier and no cross-app or cross-site tracking.
• Seroa does not collect your device location, contacts, calendar or browsing history.
• Seroa does not sell your data or share it with data brokers.

AI processing

When you scan a meal or a label, record a voice note, or type what you ate, that content is sent to Google's Gemini API to identify the foods and estimate portions. Along with it we send your country and cuisine preferences, so the result makes sense.

Your dietary restrictions and allergies are sent only when Seroa builds you a plan, where they are hard constraints on what it may suggest — a plan generated without them could put something in front of you that you cannot safely eat. They are not sent when you scan, photograph or describe a meal: they made no difference to identifying what is in a picture, so they are no longer included there.

We do not send your email address, your name, your account identifier, your date of birth or your weight to the AI provider.

Seroa uses the paid tier of the Gemini API, and the developer-controlled request logging and storage settings on Seroa's Google project are switched off. Beyond those settings, Google's handling of content sent to its API is governed by Google's own terms for that service. Seroa does not control it and makes no promise on Google's behalf about how long they keep it.

Why we are allowed to use your data

UK data protection law requires a lawful basis for each purpose, and a second, stricter condition for information about health. Ours are set out below, purpose by purpose, rather than as one sentence covering everything.

We do not claim a legal obligation to process any of this, because we have not identified one that applies. There is no advertising, no profiling for advertising, and nothing is sold or shared with data brokers.

Health information and your explicit consent

Your body measurements, weight goal, weight history, dietary restrictions and allergies — especially taken together, and combined with what you log — can say something about your health. We treat that as health data, which UK law protects more strictly. The condition we rely on is your explicit consent.

That is why Seroa asks you directly, in a step of its own, before it records any of it. That step is separate from the Terms of Use: agreeing to the terms is not consent to this, and continuing past a screen is not either. The box is not pre-ticked, and Seroa records which version of this policy you were shown and when.

You can withdraw that consent at any time, in Profile → Health data consent. Because that consent is the only thing permitting us to hold this information, withdrawing it does not merely stop us using it — we erase it. If you withdraw:

• meal analysis, voice and text logging, plan generation and personalisation stop working immediately;
• the health information held under that consent is erased: your body measurements, goal and activity level, your calculated targets, your dietary restrictions and allergies, your weight history, your meal diary and the photos in it, your plans, and everything Seroa learned from them. Your records go immediately. The stored files — meal and label photos, any voice file, any export you generated — are normally removed in the same moment; if one cannot be removed straight away our servers keep trying automatically until it is gone. There is nothing you need to do, and you do not have to come back to the app for it to finish;
• your account stays. Your sign-in, email, subscription and app preferences are untouched. This is not the same as deleting your account;
• your date of birth is kept, because it is what confirms you are 18 or over — that is a separate reason from the one you withdrew;
• the record that you gave and then withdrew consent is kept, because the law requires us to be able to show it. It contains no health information;
• you can consent again later and start fresh, but what was erased is gone.

Export your data first if you want a copy — Profile → Export my data. Erasure cannot be undone.

Withdrawing does not undo processing that already happened, which is normal and is what the law says. Because Seroa's features all depend on this information, withdrawing leaves very little the app can usefully do — if what you want is the account gone as well, deleting it is one tap away and remains available whether or not you have withdrawn.

Service providers

The nutrition and barcode lookups are made by our server, not by your device, so those two services do not receive your device's network address.

Security

Connections between the app, our servers and the services above use HTTPS. Your database records are protected by row-level security so that an account can reach only its own rows. Your meal images, voice files and exports are kept in private storage scoped to your account and are not publicly readable. Actions that matter — committing a scan, exporting, deleting your account — are authenticated and carried out on the server.

Your sign-in session is held in the app's private storage on your device. No method of storage or transmission is perfectly secure, and Seroa does not claim any certification or independent security accreditation.

How long data is kept

• Your account and records — until you delete them, delete your account, or withdraw your health data consent, which erases the health-related records as described above.
• Meal and label photos — the retention you choose in the app. The default is 30 days; you can set immediate deletion after use, or up to a year. You can change it at any time in Profile.
• Uploads from scans that never completed — removed automatically, normally within about two hours.
• Voice notes — deleted as soon as the analysis finishes.
• Export files — held in your private storage area until you delete your account. The download link expires after ten minutes.
• Your consent record — the fact that you gave or withdrew consent, which version of this policy you were shown and when. Kept for as long as your account exists, because the law requires us to be able to demonstrate it; it survives withdrawal, since it is the proof the withdrawal happened, and is removed when you delete your account.
• AI usage counts and daily allowance counters — kept while your account exists so your allowance can be measured, and removed with it. They record how many requests of each kind were made and roughly what they cost, not what was in them.
• Request references used to stop a retry being processed twice — kept while your account exists and removed with it.
• Minimal subscription event records — kept for as long as they are needed to keep subscription entitlement correct, stop a re-sent message from being processed twice, and resolve billing questions. When you delete your account the link to you is removed, and what remains is described below.

Where a period is not fixed above, the criteria are the same in each case: we keep something while your account exists and it is doing a job that cannot be done without it, and we remove it when the account goes or the job ends. We do not keep anything for a fixed statutory period, because we have not identified one that applies to this data.

Deleting your account

You can delete your account from inside the app: Profile → Delete account & data. It is immediate and cannot be undone. If you cannot use the app, the account deletion page explains how to request it.

Deleting your account removes your sign-in identity and every record tied to it — profile, meals and meal items, plans and planned meals, plan generations, saved meals, weight and water entries, fasting sessions, challenges, grocery items, everything the personal food model learned about you, and your AI usage records — together with your meal images, any voice files and your exports.

Getting a copy of your data

In the app, Profile → Export my data produces a JSON file containing your account identifier and email, your profile, your meal scans, meals and meal items, planned meals and plan generations, saved meals, the personal food model's signals, behavioural statistics and learned insights in readable form, grocery items, fasting sessions, challenges, weight and water entries, and any consent records. Your meal images and AI usage records are not included in the export file.

Your choices

• Choose how long meal photos are kept, including deleting them immediately after use.
• Review and reset what Seroa has learned about you, from Profile.
• Export your data, or delete your account, at any time.
• Use the app without photos or voice — typing what you ate, or searching foods manually, works without granting camera or microphone access.
• Camera and microphone access are only requested when you first use those features, and can be withdrawn in your device settings.

International processing

Seroa relies on the service providers listed above, which operate internationally. Your data may therefore be processed outside the country you live in, including in the United States and Singapore. Seroa does not promise that data stays in any particular country or region.

Which protection applies depends on where the provider is. Where a provider is in the European Economic Area, the transfer is covered by the UK's adequacy regulations. Everywhere else we rely on the transfer protections written into that provider's own data processing terms — in each case the UK Information Commissioner's International Data Transfer Addendum to the European Commission's Standard Contractual Clauses. These apply automatically under our agreements with them; there is nothing for you to do.

You can ask us which protection applies to a particular provider, and for a copy of the relevant terms, by emailing support@twilightzero.com.

Your rights

Under UK data protection law you can ask us to give you a copy of your data, correct it, delete it, restrict or object to how we use it, or send it to another service in a portable form. Where we rely on your consent, you can withdraw it. Most of these you can do yourself, immediately, without asking us:

• A copy of your data — Profile → Export my data.
• Correction — edit your profile, goals and preferences in the app.
• Deletion — Profile → Delete account & data, or the account deletion page.
• Withdrawing consent — Profile → Health data consent. This also erases the health information held under it.
• Anything else — email support@twilightzero.com and we will respond within one month.

If you are not satisfied with how we have handled your data, you can complain to the UK regulator, the Information Commissioner's Office, at ico.org.uk. You are welcome to raise it with us first, but you do not have to.

Adults only

Seroa is for adults aged 18 and over. It asks for your date of birth when you set up your account and does not accept accounts below that age. It is not directed at children, and we do not knowingly collect data from them. If you believe a child has created an account, contact us and it will be removed.

Changes to this policy

If this policy changes, the updated version will be posted here with a new date at the top. Material changes will be signalled in the app.

Contact

Privacy questions, access requests and complaints: support@twilightzero.com. The support page lists what you can do yourself without contacting us.

Seroa is operated by Twilight Zero Systems Ltd, a private limited company registered in the United Kingdom under company number 17426643.