DRAFT — pending legal review. Not yet in force. Yellow marks = data for you to confirm or replace.

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Spoon & Sketch — Privacy Policy

Version: 2026-06-11 · Effective date: TODO: set publish date

This Privacy Policy explains what personal data the Spoon & Sketch mobile application (the “App”) collects, why, and what rights you have. We keep it in plain language on purpose — if anything is unclear, write to us.

1. Who we are (data controller)

The App is operated by Anhelina Ermakova, an individual developer based in Montreal, Quebec, Canada (the “Operator”, “we”). TODO: replace name/location if you register a company
Contact for all privacy matters: privacy@spoonsketch.com TODO: confirm mailbox + domain (.com vs .app)

Under the EU General Data Protection Regulation (“GDPR”), the Operator is the data controller for the personal data described in this Policy. Under Quebec’s Act respecting the protection of personal information in the private sector (as amended by Law 25) and Canada’s PIPEDA, the Operator is the person in charge of the protection of personal information (privacy officer); contact them at the email above.

2. Scope

This Policy covers the App (iOS and web), the @spoonsketch_bot Telegram bot, and any related services. It does not cover third-party services you use alongside the App (e.g., Telegram itself, your email provider) — their own policies apply there.

3. What we collect

We collect only what the App needs to work. You can use most features without granting optional permissions.

3.1 Account data. Your email address; if you sign in with Apple or Google, the identifier and (if you share it) name/email those services provide. Sign-in uses one-time magic links — we never store a password.

3.2 Content you create. Recipes (text, ingredients, steps, tags), photos and screenshots of recipes you upload or send to the bot, drawings and decorations you make in the editor, cookbooks, dedications, and similar content.

3.3 Telegram data (only if you connect Telegram). Your Telegram ID and @handle, and the messages (links, photos, captions) you send to our bot for recipe import. Connecting Telegram is optional.

3.4 AI processing records. When you use AI features (recipe extraction, “Make me Sketch” sticker matching), we log the request type, status, and token usage for quota and abuse-prevention purposes (see §5).

3.5 Technical and usage data. IP address, device model, OS version, app version, language; crash and error reports (via Sentry); and — only with your consent — product analytics events (via PostHog), such as which screens you use. Analytics events do not include your recipe content.

3.6 Payment data (when paid features are offered). Purchases are processed by Apple’s App Store and managed via RevenueCat. We receive subscription status and transaction identifiers — never your card number.

3.7 Print order data (when book printing is offered). If you order a printed cookbook, we collect the recipient name and shipping address and share them with our print partner (Lulu xPress) solely to produce and deliver your order.

3.8 Consent records. We keep a log of when you accepted these terms and which version, and your on/off choices for AI features and analytics — the GDPR requires us to be able to demonstrate consent.

4. Why we process it (purposes and legal bases)

PurposeDataLegal basis (GDPR Art. 6)
Provide the App: accounts, sync, storage3.1, 3.2, 3.3Contract (6(1)(b))
AI features: recipe extraction, sticker matching3.2, 3.3, 3.4Consent (6(1)(a)) — off until you enable it; withdraw any time in Settings → Privacy
Product analytics3.5 (PostHog)Consent (6(1)(a))
Crash diagnostics, security, abuse and quota enforcement, content moderation3.4, 3.5Legitimate interests (6(1)(f)) — keeping the service working and safe
Payments and subscription management3.6Contract (6(1)(b))
Printing and shipping your book3.7Contract (6(1)(b))
Legal compliance (consent records, unlawful-content reports)3.8, moderation logsLegal obligation (6(1)(c))

We do not sell personal data, do not show ads, and do not use your data for third-party marketing.

5. AI features — what actually happens

When you enable AI features and use them:

Recipe links you share are fetched and their text is sent to Anthropic (Claude model) to extract a structured recipe. Photos and screenshots you submit are sent the same way. “Make me Sketch” sends your recipe’s title, ingredients, and tags to Anthropic to choose matching stickers; sticker placement is computed on our servers. Photos uploaded via Telegram are automatically scanned by an AI safety classifier before being processed (an App Store content-safety requirement); images that fail the scan are deleted.

Our Anthropic configuration uses zero data retention — your content is not used to train AI models. TODO: lawyer to verify Anthropic DPA/ZDR status If and when stylized photo effects are offered, photos you select for stylizing will be processed by OpenAI under the same consent toggle, with API inputs excluded from model training. TODO: verify OpenAI API data-retention terms + DPA before that feature ships

AI output can be wrong. Review extracted recipes (especially quantities and cooking times) before relying on them.

6. Who we share data with (processors)

ServiceWhatWhere
SupabaseDatabase, authentication, file storage, server functionsEU/US TODO: confirm region
AnthropicAI processing (§5)US
OpenAIStylized photo effects (when offered; only photos you choose to stylize; not used to train models)US
SentryCrash and error reportsUS/EU
PostHogAnalytics (consent-based)EU
AppleApp distribution, in-app purchases, Sign in with AppleUS
GoogleSign in with Google (if you choose it)US
RevenueCatSubscription management (when offered)US
Lulu xPressPrinting and shipping your book (when offered; receives name + shipping address)US + its delivery partners
TelegramMessage delivery for the bot (only if you connect it)per Telegram’s policy
Railway / UpstashHosting for the Telegram bot and its job queueUS/EU

Each provider processes data under a data processing agreement and only on our instructions. Note for Quebec residents (Law 25): your personal information is stored and processed on servers located outside Quebec (EU/US, per the table above); we assess each such transfer to ensure adequate protection. Where data leaves the EEA, transfers rely on the EU–Canada adequacy decision, EU Standard Contractual Clauses, and/or the EU–US Data Privacy Framework, as applicable.

7. How long we keep data

Account and content — for as long as your account exists. Deleting your account (Me → Delete account) permanently deletes your recipes, photos, drawings, cookbooks, Telegram connection, and AI logs. This is immediate and irreversible.

Backups — deleted data may persist in encrypted backups for up to 30 days before rotation. TODO: align “30 days” with your Supabase plan

Moderation records — retained as required for legal compliance (e.g., reports of unlawful content), even after account deletion.

Consent records — retained as long as needed to demonstrate compliance.

Analytics/crash data — per the retention settings of PostHog/Sentry, capped at 24 months. TODO: set these caps in PostHog/Sentry dashboards

8. Your rights

Everyone, in-app, no email needed: export your data (Me → Settings → Export my data; JSON, once per 24h); delete your account and all data (Me → Settings → Delete account); turn AI features or analytics on/off (Settings → Privacy).

If you are in Canada (PIPEDA and, in Quebec, Law 25): you have the rights of access and rectification, the right to withdraw consent, and — under Law 25 — the rights to data portability and to be informed about and have reviewed any decision based exclusively on automated processing. You may complain to the Office of the Privacy Commissioner of Canada (OPC) or, in Quebec, to the Commission d’accès à l’information (CAI).

If you are in the EU/EEA/UK (GDPR): you also have the rights of access, rectification, erasure, restriction, portability, objection, and the right to withdraw consent at any time (without affecting prior processing). You may complain to your local supervisory authority.

If you are in Ukraine (Law No. 2297-VI): we extend you the rights set out in Article 8, including to know whether your data is processed, to access it, and to demand correction or deletion; you may also complain to the Ukrainian Parliament Commissioner for Human Rights (Ombudsman). When Ukraine’s new data protection law (draft No. 8153) enters into force, the rights it grants will apply automatically.

If you are a California resident (CCPA/CPRA): we do not sell or “share” personal information and have not done so in the preceding 12 months. You have the rights to know, delete, correct, and to non-discrimination for exercising them. The categories we collect are listed in §3 (identifiers; customer records; internet activity; coarse IP-derived region; user content). Exercise rights in-app (above) or by email. We honor requests regardless of whether the CCPA’s thresholds technically apply to us.

We respond to privacy requests within 30 days (GDPR/Ukraine) or 45 days (CCPA).

9. Children

The App is rated 4+ in the App Store, which describes its content (no objectionable material), not its audience. The App is not directed at children, and you must be at least 13 years old (or 16 where the GDPR sets that age for consent without parental approval) to create an account. We do not knowingly collect personal data from children below these ages (per COPPA and GDPR Art. 8). If you believe a child has created an account, contact us and we will delete it promptly.

10. Security

Data is encrypted in transit (TLS) and at rest. Session tokens are stored in the device’s secure keychain. Access to production data is restricted to the Operator. Database access is enforced with row-level security so each account can only ever read its own data. No system is perfectly secure — if a confidentiality incident presents a risk of serious injury, we will notify you and the relevant authority as required by law: the CAI and affected persons under Quebec’s Law 25, and the competent supervisory authority within 72 hours where the GDPR applies. We maintain the incident register Law 25 requires.

11. Changes to this Policy

When we change this Policy materially, the App will show you the new version and ask you to review it before continuing (each version is dated and tracked). Continued use after non-material changes constitutes acceptance.

12. Contact

Anhelina Ermakova, Montreal, Quebec, Canada TODO: replace if operator changes
Email: privacy@spoonsketch.com TODO: confirm mailbox; consider support@

We answer in English, Ukrainian, and French. TODO: Bill 96 — create privacy-policy.fr.html before Canadian launch


This Policy is available in Ukrainian and English. In case of discrepancy, the English version prevails. TODO: lawyer to confirm prevailing language (note Bill 96 French rules)