1. Controller & Contact
Controller: László Orosz, trading as “Ladybug App”
Service / Postal Address: 4481 Nyíregyháza, Templom u. 3., Hungary
Contact Email: ladybug@theladybugapp.com
EU Lead Supervisory Authority: National Authority for Data Protection and Freedom of Information (NAIH), Hungary
EU Representative (GDPR Art. 27): Not required because the controller is established in the EU (Hungary).
United Kingdom representative: We have appointed Prighter Group, with its local partners, as our privacy representative and point of contact in the United Kingdom. You can use the Prighter portal at Prighter privacy portal to contact the representative or exercise privacy rights.
2. Data We Collect
Account & profile data: email address, name or display name where provided, account identifiers, registration and last-seen information, units, reset-time settings, dietary pattern, preferences and other account settings you choose to save.
Nutrition and wellness inputs: information you choose to enter or create, such as weight, meals, portions, custom meals, nutrient intake and progress, supplements and related food or nutrition information. Depending on the context, some of this information may constitute health data or other special-category personal data.
Personalisation and recommendation data: dietary preferences, saved preferences, recommendation feedback and the meal or nutrient context used to generate food suggestions or determine what may be useful next.
Content and interaction data: favourites, saved content, Journal likes or similar interactions, and notification/unread status used to provide account features.
Setup and local-state information: we may store whether onboarding, legal notices or setup steps have been completed. Profile information or preferences that you choose to save may be stored or synchronised for account functionality. Information expressly described in the app as local-only remains on the device unless the app tells you otherwise.
Device, app and technical data: device identifier, platform, operating-system version, device model, app version, push-notification token, timestamps and last-seen information. When you use Ladybug's website or cloud services, our hosting, security and infrastructure providers may also process IP address and standard technical request/log information.
Billing and access data: Stripe customer identifiers and direct-subscription status where applicable; Apple App Store product, transaction/entitlement, status, expiry and environment information for iOS purchases; and internal access information such as Free/Premium status, plan cadence, access source, gift or promotional entitlement status and subscription lifecycle state.
Marketing and communication-preference data: newsletter/marketing opt-in or opt-out status, consent source, version and timestamp, unsubscribe or suppression status, email-provider synchronisation status, campaign-delivery history and information used to avoid irrelevant or repetitive promotional messages. For optional marketing emails, delivery/open/click information may be processed where lawful and supported by the provider.
Support and contact data: messages you send us through email, the website contact form or other support channels, plus information reasonably needed to respond.
Website and cookie/analytics data: where the Ladybug website uses cookies, analytics or similar technologies, we may process browser/device information, IP address and interaction data as described in the relevant notice or consent control. Non-essential technologies are used only where legally permitted.
3. Purposes & Lawful Bases
Provide the app, website and account features — performance of our contract with you (GDPR/UK GDPR Art. 6(1)(b)).
Nutrition tracking, progress calculations, food suggestions and personalisation — performance of the service you request. Where the information involved constitutes health data or other special-category data, we rely on your explicit consent where required (Art. 9(2)(a)).
Where required, Ladybug asks for that explicit consent through the in-app legal acceptance screen before you use features that process wellness or nutrition information. You may withdraw consent at any time by contacting us. Withdrawal does not affect processing already carried out lawfully, but it may prevent or limit features that require that information.
Subscriptions, access control and billing — contract; legal obligation for accounting/tax records; and legitimate interests for payment security, fraud prevention and entitlement administration.
Account/service administration, including maintaining Free/Premium status, registration/last-seen information and compatibility state — contract and legitimate interests in keeping the service accurate, secure and reliable.
Operational communications such as account, security, billing, service-change and support messages — contract and/or legitimate interests. These are not marketing communications.
Optional marketing email — consent (Art. 6(1)(a)), or another lawful basis where specifically permitted by applicable law. For users who have opted in, we may use account status, account age and communication history to select relevant messages and avoid excessive or repeated promotions. You can unsubscribe at any time.
Push notifications — your permission/consent. You can disable them through device settings and any available in-app controls.
Content interactions, favourites, saved items and unread indicators — contract and/or legitimate interests in providing and improving the requested user experience.
Diagnostics, performance and service improvement — legitimate interests in maintaining a stable and useful service; where ePrivacy or similar rules require consent for a technology such as a non-essential web cookie, we seek that consent first.
Security, abuse prevention and legal compliance — legitimate interests and/or legal obligation.
4. Retention
Account, profile and account-linked nutrition data: generally kept while your account is active. When account deletion is completed, active Ladybug account data is removed from our production systems, subject to information we must or are permitted to retain for legal, security, fraud-prevention or compliance purposes.
If consent for special-category processing is withdrawn, we stop the relevant consent-based processing and handle deletion or restriction as appropriate, subject to legal and technical retention requirements.
Billing and transaction records: retained for the period required by applicable accounting, tax and consumer-protection law.
Support communications and security records: retained only for as long as reasonably necessary to provide support, investigate incidents, comply with law or establish, exercise or defend legal claims.
Marketing consent, preference and suppression records: may be retained after opt-out where necessary to demonstrate consent history and ensure that we continue to honour your unsubscribe or suppression choice.
Campaign-delivery and communication-history records: kept only as long as reasonably needed to manage marketing eligibility, cooldowns, suppression and compliance.
Backups and provider copies: deleted data may remain temporarily in provider backups or technical recovery systems until those copies are overwritten or expire according to the relevant provider's normal backup cycle. Such copies are not used for ordinary account operation.
We may retain genuinely de-identified or aggregated information that no longer identifies you.
5. International Transfers
Ladybug and its service providers may process personal data in the EEA, the United Kingdom, the United States and other countries in which the relevant provider operates.
Where personal data is transferred outside a jurisdiction recognised as providing adequate protection, we use or rely on appropriate lawful safeguards made available by the relevant provider, such as Standard Contractual Clauses, the UK Addendum/IDTA or another valid transfer mechanism where applicable.
6. Your Rights & How to Complain
Depending on applicable law, you may have rights of access, rectification, erasure, restriction, portability, objection and withdrawal of consent. You may object to direct marketing at any time.
You can make a request by emailing ladybug@theladybugapp.com, using available in-app controls, or contacting our UK representative through the Prighter portal where applicable. We normally respond within one month, subject to lawful extensions for complex requests.
We may need to verify your identity before completing a request. Normal requests are free of charge; a reasonable fee or refusal may apply only where permitted by law for manifestly unfounded or excessive requests.
You may complain to the competent supervisory authority, including NAIH in Hungary or the relevant authority in your country. UK users may complain to the ICO.
Ladybug uses automated rules to calculate nutrient progress, generate food suggestions and, for opted-in users, determine eligibility for certain communications. These processes do not make solely automated decisions that produce legal or similarly significant effects.
7. Communications & Email Preferences
Service/operational messages: account, security, billing/receipt, important service-change and support communications. These are not marketing and may be necessary to provide or secure the service.
Marketing email: occasional product information, Premium information, recipes, Journal/content highlights or similar updates may be sent only where we have an appropriate lawful basis. Our current consent system records the choice and its source/version so that we can respect it consistently.
Marketing relevance and frequency: for opted-in recipients, we may use information such as Free/Premium status, account age, previous campaign delivery and cooldown status to decide whether a particular optional message is relevant and to avoid sending it too often.
Email provider and suppression: we use an email-service provider for optional marketing. Unsubscribe, spam and hard-bounce events may be returned to Ladybug so that we can mark the address as unsubscribed or suppressed and stop future marketing sends.
Push notifications: optional notifications may announce recipes, Journal posts, feature updates or similar in-app content. You can change or disable notification permissions through your device settings.
Measurement: we do not intentionally add marketing tracking to essential service messages. For optional marketing emails, limited delivery/open/click measurement may be used where lawful. We keep a minimal suppression record after opt-out so that we can continue to honour your choice.
8. Service Providers & Security
We use service providers only where needed to operate Ladybug and require appropriate contractual and security protections where applicable.
Key providers include Google Firebase / Google Cloud Platform for authentication, database and cloud functions; Stripe for direct payments and subscriptions; Apple for App Store purchases and subscription administration; Brevo for optional marketing-email delivery and preference/suppression synchronisation; and our operational email, website-hosting and infrastructure providers.
Some providers, including payment platforms, may act as independent controllers for parts of their own processing such as fraud prevention, legal compliance or transaction administration. Their own privacy notices apply to that processing.
Security measures include encryption in transit and at rest where supported, access controls, MFA for administrative systems, logging, secrets management, secure-development practices, backups and service-resilience measures.
If a personal-data breach requires notification under applicable law, we will notify the competent authority and affected users within the legally required timeframes.
9. Children & Age Limits
Ladybug is intended for adults. As stated in our Terms, you must be 18 years or older to use the service.
We do not knowingly offer Ladybug accounts to children. If we learn that personal data has been collected from a child contrary to our age restriction or applicable law, we will take appropriate steps to delete the account/data or otherwise comply with the law.
10. Changes
We may update this Privacy Policy to reflect changes in Ladybug, our processing practices or applicable law. We will identify the current version and effective date and may notify you of material changes in-app, by email or through another appropriate method.
Where a material legal update requires renewed acknowledgement or consent, Ladybug may require you to review and accept the updated legal version before continuing to use some or all features.
11. How to Contact Us
Questions or requests about this Privacy Policy or your personal data can be sent to ladybug@theladybugapp.com.
