Privacy policy
Last updated 23 September 2026. Applies to the Emollient iOS app and to emollient.co.uk.
Emollient collects no personal data. There is no account, no sign in, no email field, no analytics and no third party SDK of any kind. The app links Apple frameworks and StoreKit and nothing else.
Who is responsible
Povilas Konopackas, the developer of Emollient, is the data controller for the purposes of the UK GDPR and the EU General Data Protection Regulation. Questions about this policy go to pkincorporate@gmail.com.
Photographs and the camera
When you scan a label, the image is processed on your device by Apple's Vision framework. It is not uploaded, not transmitted and not seen by anyone. The ingredient data the app compares against ships inside the app rather than being fetched from a server, so a scan works with the network switched off.
If you choose to keep a scan, a cropped image of the label and the text read from it are written to the app's own container on your device. Deleting that scan in the app deletes both. Nothing is written anywhere else, and nothing is backed up to any service the developer controls.
What the app stores on your device
- Scans you chose to keep: the cropped label image, the recognised names, and the time of the scan.
- Your own avoid list, if you added ingredients to it.
- Whether you have completed the first run screens.
- Your purchase entitlement, as reported by StoreKit.
All of it is local. Deleting the app deletes all of it.
Payments
Subscriptions and the one time purchase are handled entirely by Apple through the App Store. The developer never receives your name, your email address, your payment details or any identifier that could point back to you. What the app receives from StoreKit is whether a purchase is active. Apple's own handling of a transaction is governed by Apple's privacy policy.
Tracking
The app does not track you across apps or websites, contains no advertising identifier, and does not present the App Tracking Transparency prompt, because there is nothing to ask for.
Links out of the app
Some pages link to a source document, for example an IARC monograph, a EUR-Lex text or Open Beauty Facts. Following one opens your browser and you are then on that organisation's site under its own policy. No identifier is attached to those links.
This website
emollient.co.uk is a set of static pages hosted on Cloudflare Pages. There are no cookies, no analytics script and no tracking pixel.
Cloudflare processes request data, including your IP address, on the developer's behalf and under his instructions, in order to serve the page and to protect the site from attack. An IP address is personal data, so that processing has a lawful basis: legitimate interests under Article 6(1)(f), namely running a website that stays up. The logs are held by Cloudflare for a short period and deleted on Cloudflare's own schedule. They are never exported, never combined with anything else, and never used to build a profile. Cloudflare Inc. is in the United States, and the transfer relies on the Standard Contractual Clauses with the UK Addendum. See Cloudflare's privacy policy.
Your rights
The GDPR gives you rights of access, correction, erasure, restriction, portability and objection over personal data held about you. The app holds none, so on the app there is nothing to disclose, correct or erase. The only personal data connected with this service at all is the request data the web host processes to serve these pages, described above. Write to the address above to exercise any right over it and the developer will answer within one month. You may also complain to your national supervisory authority, or to the Information Commissioner's Office in the United Kingdom.
Children
The app is rated 4 and up and collects nothing from anyone, of any age.
Changes
If this policy changes, the date at the top changes with it and the previous version is replaced. A change that introduced any data collection would be announced in the app before it took effect.