Statutory Notice Under Section 5, DPDP Act 2023 (India)

Official Privacy Policy

Published by Creative Apps Lab • Grievance Officer: Mitesh Viras • Last Updated: November 2026

Digital Personal Data Protection Act, 2023 (DPDP Act) Notice

Statutory Notice pursuant to Section 5, Section 6, and Section 8(10) of the DPDP Act 2023

In compliance with the Digital Personal Data Protection Act, 2023 (India), this document provides an itemized statutory disclosure of: (1) every item of personal data collected, (2) the exact purpose for which each item is processed, (3) how you can withdraw consent or exercise Data Principal rights under Sections 11, 12, and 14, and (4) the contact details of our designated Grievance Officer.

AI-Generated Results — No Guarantee

IngrediScan AI only scans the ingredients on a food label and uses AI to point out which look good and which look harmful. All results are generated by AI, may be inaccurate or incomplete, and are provided without any guarantee. Always check the physical label and consult a professional for allergies or health conditions. See our Terms & Conditions.

This Privacy Policy is issued by Creative Apps Lab ("we," "us," or "our"), operating the IngrediScan AI Android application (package: com.createappslab.ingrediscanai) and web services at creativeappslab.com.

Under the Digital Personal Data Protection Act, 2023 (India), Creative Apps Lab is a Data Fiduciary, and you are a Data Principal. This notice is issued under Section 5 of the Act to inform you of the exact personal data collected, the precise purpose for processing each data point, how your rights are protected, and the grievance redressal mechanism available to you.

1. Comprehensive Data Inventory: What Data We Collect and Why

Pursuant to Section 5(1) and Section 6 of India's DPDP Act 2023, the following schedule sets forth every single item of personal data collected, the statutory processing purpose, the storage location, and the retention duration:

Personal Data ItemWhat We TakeWhy We Take It (Statutory Purpose)Storage & Retention
User Display NameName from Google AccountPersonalize dashboard greeting (e.g. "Hello, Priya") and identify user profile in account settings.Laravel Cloud API. Retained until account deletion.
Google Email AddressVerified email addressPrimary authentication key, issuing session tokens (Sanctum), cross-device cloud sync, processing data erasure requests, and statutory security notices.Laravel Cloud API. Retained until account deletion.
Google User ID (UID)Unique cryptographic Google IDImmutable identifier to authenticate requests and securely associate scan logs with the proper user record.Laravel Cloud API. Retained until account deletion.
Profile Picture URLGoogle avatar URLDisplay user avatar icon in top navigation bar and profile screen.Laravel Cloud API. Retained until account deletion.
Food Label PhotosCamera frames of package labelsAI vision analysis to read ingredient lists and cross-reference additives against safety knowledge. Sent to our AI providers (see Section 7).Held temporarily in our server storage only while the scan runs; deleted when the scan completes or fails. Not kept in your history.
Dietary PreferencesVegan, Vegetarian, Gluten-FreeTailor ingredient evaluation to highlight non-compliant ingredients (e.g. flagging gelatin or dairy for vegans).Laravel Cloud API & local DB. Retained until user updates or deletes profile.
Health-Adjacent SettingsDiabetes alerts, Kids, PregnancyCalculate specialized family risk warnings (e.g. flagging hidden sugars for diabetics, synthetic dyes for kids, teratogens for pregnancy).Laravel Cloud API & local DB. Retained until user updates or deletes profile. Sent to our AI providers with each scan to personalise the result.
Age, Gender, Country & App SettingsOptional profile fields; analysis sensitivity, language, dark mode, notification choicePersonalise scan analysis (age, gender and country are sent to our AI providers with each scan) and remember your app settings.Laravel Cloud API. Retained until you change them or delete your account.
Credits & Purchase StatusScan credit balance, unlimited-scans expiry, purchase event IDsApply your free credit, purchased credit packs or unlimited-scans subscription, and refund a credit when a scan fails. We do not receive your card or payment details.Laravel Cloud API. Balance deleted with your account. Your email is kept separately after deletion (see Section 5).
Push Notification TokenFirebase Cloud Messaging device tokenTell your device when a scan you started has finished or failed.Laravel Cloud API. Removed on sign-out, when Google reports it invalid, or on account deletion.
Usage AnalyticsScreens viewed, scan started/completed/failed events, paywall views, app version, country, credit balance, your internal user IDUnderstand which features work, fix failures and improve the app. Never includes your name, email or scan content.Mixpanel. Retained until you ask us to delete it (see Section 7).
Food Scan HistoryProduct name, brand, score, risk rating, ingredient list with risk levels, suitability notes, timestampsProvide personal pantry logs, allow filtering past scans by risk level, and sync logs across devices.Laravel Cloud API & local DB. Retained until user deletes records or account.
Device Model & OSDevice name (e.g. "Pixel 8"), Android OSManage individual session tokens so users can revoke specific device logins, and diagnose device-specific camera bugs.Laravel Cloud API (Sanctum tokens table). Auto-purged on token revocation.
IP Address & Coarse RegionNetwork IP, Country/State (Never GPS)Security rate-limiting (preventing API brute-forcing), DDoS protection, and routing to nearest cloud region.Server and network-proxy (Cloudflare) access logs, kept only as long as needed for security.
Advertising IDNot collectedThe app contains no advertising SDK and does not read your Google Advertising ID.Not applicable.

2. Camera Processing & Temporary Photo Handling

When you initiate a food scan, the App requests camera access (android.permission.CAMERA).

• Strict Purpose Limitation: The camera is used solely to capture images of physical food packaging, ingredient lists, and nutrition tables.

• Zero Facial / Biometric Processing: We do not scan faces, eye retinas, or biometric markers. Any face accidentally in the viewfinder is ignored during OCR text extraction.

• How a photo travels: When you submit a scan, your photos are uploaded over HTTPS to our server, held in temporary storage, and passed to an AI vision provider (Section 7) so it can read the label. A temporary, expiring link may be used so the provider can fetch the image.

• Deleted when the scan ends: We delete the uploaded photos as soon as the scan completes or fails. They are not part of your scan history, and are never sold.

• No training by us: We do not use your photos to train our own models. Our AI providers process them under their own terms; see Section 7.

3. Google Sign-In & Authentication

IngrediScan AI requires signing in with your Google Account via Firebase Authentication and Google Credential Manager.

  • Data Received: Google display name, verified email address, avatar photo URL, and unique Google user identifier (UID).
  • Why It Is Collected: To establish and secure your account, authenticate requests via encrypted Laravel Sanctum bearer tokens, and prevent unauthorized access to your scan history.
  • No Password Storage: We never see, process, or store your Google password. Authentication is completed securely via Google OAuth 2.0.

4. Dietary Preferences & Health Conditions

Users may optionally select dietary profiles (Vegan, Vegetarian, Gluten-Free) and health sensitivity alerts (Diabetes, Pregnancy, Children's hyperactivity).

  • Why It Is Collected: To customize the algorithmic risk evaluation. For example, if Diabetes alert is enabled, the app flags hidden high-glycemic sweeteners (such as maltodextrin and high-fructose corn syrup).
  • Shared with AI providers, to do the analysis: Your dietary preference, health conditions, age, gender and country are sent with each scan to the AI providers listed in Section 7, so the result fits you. Your name and email are not sent.
  • Never sold or shared with advertisers or insurers: We run no advertising and do not share this data with insurance entities.

5. Scan History & Cloud Pantry Synchronization

When a food package is analyzed, a textual record (product name, brand, safety score, flagged additives, and timestamp) is stored in our secure Laravel API database:

  • Why It Is Collected: Allows you to review past food safety evaluations, filter products by risk tier, and view your scanned pantry on any Android device you log into.
  • Encryption in Transit: All communications between the mobile app and Laravel API are secured using Transport Layer Security (TLS 1.3 / HTTPS).
  • User-Controlled Deletion: You can delete individual scans directly by swiping in the app, or delete your entire history at once via Settings.
  • What survives account deletion: To stop the one-time free scan credit being claimed again, we keep your email address (lower-cased) and the date the free credit was granted in a separate record after you delete your account. It is used only for this purpose. A log of purchase event IDs is also kept so payment notifications are not processed twice. Everything else tied to you is deleted.

6. Device, Network & Telemetry Data

The App collects basic technical telemetry to ensure security, rate-limiting, and crash stability:

  • Network State (ACCESS_NETWORK_STATE): Checks whether the device is connected to Wi-Fi or cellular data to prevent failed AI scan calls when offline.
  • Device Name & Hardware Info: Stored alongside session tokens so users can identify and terminate active logins on specific phones.
  • IP Address: Used for security and rate-limiting (for example, sign-in attempts per IP, and scan submissions per account) to defend against DDoS attacks and brute-force abuse.

7. Third-Party Services & Data Processors

We use the following outside services to run IngrediScan AI. The app contains no advertising SDK, and we do not sell your data. Each provider handles data under its own privacy policy.

ServiceWhat it does for usData it receives
Google Sign-In & Firebase Authentication (Google LLC)Sign-in with your Google account. We also verify your Google ID token with Google.Your Google ID token, name, email, profile photo URL and Google user ID.
OpenRouterRoutes each scan to an AI vision model (the primary AI path).Label photos (by temporary link or upload), your dietary preference, health conditions, age, gender and country, and your analysis-sensitivity setting. No name or email.
AI model providers reached through OpenRouter: Alibaba Cloud (Qwen), Google (Gemini), Z.ai (GLM) and DeepSeekRead the label and produce the safety analysis. DeepSeek and the others are also used to explain a single ingredient.Same as above for scans. Ingredient explanations send only the ingredient name, E-number, category and risk level.
Alibaba Cloud (Qwen) and Google (Gemini), directBackup AI providers used if the primary path fails.Same as the scan data above.
Firebase Cloud Messaging & Firebase App Check (Google LLC)Notify your device when a scan finishes, and help confirm requests come from the genuine app.A device push token, plus app-integrity signals.
RevenueCat and Google Play BillingHandle credit-pack and unlimited-scans purchases and entitlements.Your internal user ID and purchase details. Card details go only to Google Play; we never see them.
MixpanelProduct analytics.Anonymous-then-identified usage events, app version, country, credit balance and your internal user ID. Never name, email or scan content.
Google Play (in-app updates)Offers you a newer version of the app.Standard Google Play update checks.
Cloud hosting, object storage and CloudflareRun our servers and database, hold photos temporarily, and protect against attacks.All data we process, encrypted in transit. Cloudflare sees request metadata such as IP address.
  • Absolute isolation from advertising: no ad network receives any data from the app, because there are none.
  • Analytics deletion: deleting your account does not automatically erase your Mixpanel events. Email the Grievance Officer (Section 13) with the subject [DPDP Erasure] and we will request their deletion.
  • Provider changes: we may change AI providers or models to keep scans accurate and available. We will update this table when we do.

8. India: DPDP Act 2023 Statutory Data Principal Rights

If you are located in India, your personal data is protected under the Digital Personal Data Protection Act, 2023. Creative Apps Lab acts as a Data Fiduciary, and you hold enforceable statutory rights as a Data Principal:

A. Right to Access Information (Section 11)

You have the right to request a plain-language summary of all personal data processed about you, the identities of all data processors (such as cloud hosting providers), and any other relevant processing details.

B. Right to Correction and Erasure (Section 12)

You have the right to correct inaccurate or misleading personal data, complete incomplete records, or demand the complete erasure of your personal data when it is no longer necessary for the specified purpose. You can exercise this instantly via the in-app "Delete Account" button or via our Delete Account Portal.

C. Right of Grievance Redressal (Section 13)

You have the legal right to readily available grievance redressal through our designated Grievance Officer. All grievances will be formally acknowledged within 48 hours and resolved within 30 calendar days.

D. Right to Nominate (Section 14 — India Specific)

Under Section 14 of the DPDP Act 2023, every Data Principal has the right to nominate any other individual who shall, in the event of death or incapacity of the Data Principal, exercise all statutory data rights on their behalf. You or your authorized nominee may register a nomination by emailing our Grievance Officer with the subject line [DPDP Right to Nominate].

E. Cross-Border Data Transfers (Section 16)

Transfers of data to global AI and analytics providers (those listed in Section 7, which may be outside India) comply with Section 16 of the DPDP Act 2023 and occur exclusively to non-blacklisted jurisdictions under active Data Processing Agreements (DPAs).

9. Children's Data Protection (Section 9 DPDP Act)

Under Section 9 of India's DPDP Act 2023, any individual under 18 years of age is classified as a child. IngrediScan AI enforces strict statutory compliance:

  • Intended Audience: IngrediScan AI is intended for adult consumers, parents, and legal guardians (18+).
  • Parental Authority: When parents use the app to check food safety for their children, they do so under lawful parental authority. No personal profiles or identifying data of children are created.
  • Prohibition of Child Profiling: We enforce ZERO tracking, ZERO behavioral monitoring, and ZERO targeted advertising directed at children.

10. European Union & UK: GDPR Compliance

For users residing in the European Economic Area (EEA) and United Kingdom under Regulation (EU) 2016/679 (GDPR):

  • Lawful Basis: Processing of food scans and user accounts is conducted on the basis of your explicit consent (Art. 6(1)(a) GDPR).
  • Data Subject Rights: Right to Access (Art. 15), Rectification (Art. 16), Erasure / "Right to be Forgotten" (Art. 17), Restriction of Processing (Art. 18), Data Portability (Art. 20), and Right to Object (Art. 21).
  • International Transfers: Managed via European Commission Standard Contractual Clauses (SCCs).

11. United States: COPPA & California CCPA/CPRA

Children's Online Privacy Protection Act (COPPA): We do not knowingly collect personal identifiable information from children under 13.

California Consumer Privacy Act (CCPA/CPRA): We do not sell or share personal data for commercial consideration. California residents hold statutory rights to know, delete, and opt out of advertising sharing.

12. Data Breach Notification Protocol (72-Hour SLA)

In compliance with Section 8(6) of the DPDP Act 2023 and Article 33 of the GDPR, in the event of a confirmed personal data breach affecting our cloud systems:

  • We will report the incident to the Data Protection Board of India (DPBI) and relevant European Supervisory Authorities within 72 hours.
  • Affected Data Principals will be notified directly without delay, outlining the nature of the breach, affected categories, and mitigating steps taken.

13. Designated Grievance Officer & Statutory Contact (Section 8(10))

In compliance with Section 8(10) of the DPDP Act 2023 and Rule 3(2) of the Information Technology Rules, Creative Apps Lab has appointed a designated Grievance Officer to handle user inquiries, DPDP Data Principal rights requests, nomination claims, and privacy grievances:

Designated Grievance Officer: Mitesh Viras (Privacy & Regulatory Compliance)

Data Fiduciary Entity: Creative Apps Lab

Statutory Grievance Email: grievance@creativeappslab.com

General Support Email: creativeappslab29@gmail.com

Subject Line for Priority Handling: [DPDP Grievance] / [DPDP Erasure] / [DPDP Nominate]

Statutory Resolution SLA: Formal acknowledgment within 48 hours; full resolution within 30 calendar days.