Last updated: 16 August 2026 · Effective: 16 August 2026
Nurtu holds health information about a child. We treat that as the most sensitive category of personal information there is, and this policy is written to be read — not to be survived.
Nurtu is operated by INNOVURA PTY LTD (ABN 24 650 707 789, ACN 650 707 789), an Australian private company registered in Victoria, Australia ("we", "us", "our").
We are the data controller for the information described in this policy.
| Privacy enquiries | hello@nurtu.app |
|---|---|
| Registered office | Victoria, Australia. Our full registered office address is on the public ASIC register against ACN 650 707 789, and we will provide it in writing on request. |
Nurtu is designed and sold for use by a parent or carer. It is not directed to children, and a child does not have an account, a login, or any way to enter information into it.
Information about your child reaches us because you choose to record it. We do not knowingly collect personal information directly from a child. If you believe a child has provided us with information, contact us and we will delete it.
This is health information and we treat it as sensitive. You give it to us — we do not collect it from your child. Not every parent provides every category below; you only tell us what you choose to:
If we later introduce account-linked subscription syncing, we will update this policy and our App Store privacy disclosures accordingly.
If you use the voice log, your speech is converted to text. Where your device supports on-device speech recognition, this happens on your phone and the audio never leaves it. The recording is written to temporary storage only so a failed transcription can be retried, and is deleted as soon as the note has been processed. We do not retain audio recordings.
It helps to keep three things apart: the raw audio, which is temporary and is not intentionally retained after processing; the transcript text produced from it; and the entries you choose to save. If you choose to save the resulting entries, transcript-derived text, typed notes and other free-text entries may be stored with your Nurtu account and child profile and may therefore be associated with that account.
If AI processing is enabled, relevant voice-note text may be sent through Nurtu's server to OpenAI to help organise the note into structured entries (see §6). If AI processing is not enabled, Nurtu uses its available local/on-device alternative and does not send the transcript to OpenAI.
When you use Scan Label or Snap Meal, a photograph you choose or take may be sent through Nurtu's API to OpenAI so that food, meal or nutrition information can be analysed and a result returned to you.
Nurtu does not intentionally persist the original photograph in its own database after the request has been processed. These photographs are not used by Nurtu for advertising.
AI image processing occurs only where the required AI consent has been given. If AI processing is turned off, Nurtu does not send the photograph to OpenAI and will tell you that the AI feature is unavailable rather than silently transmitting it.
OpenAI may retain API customer content in abuse-monitoring logs for up to 30 days by default, subject to its applicable data-retention controls and policies.
Some Nurtu features use OpenAI to help organise information or create personalised results. These include features such as voice-note organisation, food analysis, Scan Label, Snap Meal, recipes or recaps where AI is used, and the First Light starting experience.
AI processing is optional. Nurtu asks for your consent separately, and AI processing is off unless you choose to enable it.
If you decline AI processing, Nurtu remains usable. Where a local or on-device alternative is available, Nurtu uses that alternative. Features that require third-party AI processing will tell you that AI is turned off rather than sending information without your permission.
You can change your AI-processing choice later from More → Your data.
First Light creates a starting reflection from the information you chose to provide during setup.
If AI processing is enabled, Nurtu may send a limited set of setup categories to OpenAI to help create the personalised First Light reflection and rank starting food ideas from a fixed list maintained by Nurtu. Those categories are: food sensitivities; focus and preferences; constraints; sensory preferences; calming strategies; day-pattern selections and things being watched; and goals. The server uses a strict allow-list so only approved categories can be included.
We do not send direct identifiers such as your child's name, age, diagnosis, contact details or Nurtu account ID as part of the First Light request.
Nurtu may also use the limited First Light profile categories to offer a small number of starting food ideas.
These food ideas come from a fixed list maintained by Nurtu. AI may help rank or explain appropriate options from that list, but it is not permitted to invent foods or research citations for this feature.
The suggestions are starting ideas based on the profile you provided. They are not prescriptions, medical advice or statements that a particular food treats ADHD, autism, ARFID or any other condition. Where Nurtu shows supporting evidence alongside a starting food idea, that evidence relates to a general principle such as sensory characteristics or balanced nutrition; it does not establish that the individual food will work for your child.
We record which screens and features are used, so we can tell whether the app works. These events are tied to a random identifier generated on your device, which is not linked to your account, your name or your child.
Analytics never include your child's name, age, diagnosis, medications, log contents, notes, or any free text. This is enforced by an allow-list in our code, not merely by policy. You can turn analytics off entirely in More → Your data.
For First Light this means feature-level events only — for example whether a First Light reflection was generated, or whether a starting food idea was opened. Profile traits, sensitivities and generated insight text are not sent to analytics.
Our servers record IP address, request time and device platform for security and abuse prevention, retained for a short period.
| Purpose | Lawful basis (UK/EU GDPR) |
|---|---|
| Store your child's logs and show them back to you | Explicit consent — Article 9(2)(a) |
| Find patterns and generate reports you request | Explicit consent — Article 9(2)(a) |
| Convert your voice notes into entries | Explicit consent — Article 9(2)(a) |
| Score foods against your child's profile | Explicit consent — Article 9(2)(a) |
| Optional AI processing you switch on: organising voice notes, requested AI food analysis, Scan Label and Snap Meal, requested AI recaps or recipes where applicable | Explicit consent — Article 9(2)(a), given as a separate AI-processing consent |
| Optional AI processing for personalised First Light insights and starting food ideas | Explicit consent — Article 9(2)(a), given as a separate AI-processing consent |
| Manage your account and subscription | Performance of a contract — Article 6(1)(b) |
| Anonymous product analytics | Consent — Article 6(1)(a). In the UK and EEA nothing is collected until you switch it on; elsewhere it is on by default and you can switch it off. |
| Security, fraud and abuse prevention | Legitimate interests — Article 6(1)(f) |
Because the information about your child is health information, we rely on your explicit consent, which you give when you set up a profile. You can withdraw it at any time by deleting the profile or your account. Withdrawal does not affect processing carried out before you withdrew.
AI processing is optional and rests on a separate explicit AI consent, which is off unless you switch it on. You can withdraw that consent on its own, from More → Your data, without deleting the profile.
Under the Australian Privacy Act 1988 (Cth), health information is "sensitive information" and we collect it only with your consent, in accordance with Australian Privacy Principle 3.
We use a small number of service providers to operate Nurtu. Their handling of information is governed by their applicable agreements, terms and privacy obligations, as described below.
| Provider | What it does | What it receives | Location |
|---|---|---|---|
| Supabase | Database and account sign-in | Your account email; your child's profile and logs | Sydney, Australia |
| Railway | Hosts Nurtu's API infrastructure. | API requests and limited technical/request metadata. Nurtu's application does not intentionally persist uploaded photographs or full request bodies in Railway storage. Railway may retain platform or infrastructure logs according to the applicable service configuration and its policies. | According to the applicable Railway project configuration |
| OpenAI | Helps organise voice-note text; analyse food information and requested photographs; support selected AI-powered food, recipe and recap features; and create the optional AI-enhanced First Light starting reflection and starting food ideas. | The text of a voice note where AI processing is enabled; food or medicine names needed for a request; photographs submitted through Scan Label or Snap Meal; and, for First Light, a limited set of setup categories selected by the parent — food sensitivities, focus and preferences, constraints, sensory preferences, calming strategies, day-pattern selections and goals. We do not send direct identifiers such as your child's name, age, diagnosis, contact details or Nurtu account ID as part of the First Light request. Nurtu's server applies an allow-list before those profile details can be sent. For First Light food ideas, OpenAI can only work from a fixed candidate list supplied by Nurtu. Nurtu separately controls the food candidates and evidence references. By default, OpenAI does not use API inputs or outputs to train its models unless we explicitly opt in to data sharing. OpenAI may retain API customer content in abuse-monitoring logs for up to 30 days by default, subject to its applicable data-retention controls and policies. | According to OpenAI's applicable infrastructure and data-residency configuration |
| PostHog | Anonymous product analytics | Event names and counts only (see §3.8) | According to the applicable PostHog project configuration |
| Apple | App distribution and payments | Purchase and subscription data | Per Apple's policy |
| RevenueCat | Manages subscription entitlement information. | An anonymous purchase identifier and subscription/product entitlement information. Nurtu does not send RevenueCat payment-card details. RevenueCat is not currently linked to the parent's Nurtu/Supabase account. | Per RevenueCat's applicable policy/infrastructure |
Nurtu's primary database is hosted in Australia. When you enable AI features, selected information described in this policy may also be processed by OpenAI outside Australia, depending on the applicable service infrastructure and data-residency configuration.
Information that may be processed through OpenAI includes voice-note text, food or medicine names needed for a request, photographs submitted through Scan Label or Snap Meal, and the limited setup categories used for First Light — food sensitivities, focus and preferences, constraints, sensory preferences, calming strategies, day-pattern selections and goals.
We do not send direct identifiers such as your child's name, age, diagnosis, contact details or Nurtu account ID as part of the First Light request.
API requests and limited technical/request metadata may also pass through Nurtu's hosting infrastructure.
Where personal information is disclosed overseas, we take reasonable steps as required by applicable Australian privacy law, including Australian Privacy Principle 8, to protect it.
| What | How long |
|---|---|
| Your child's profile and logs | Until you delete them, or 24 months after your account becomes inactive, whichever comes first |
| Raw voice recordings | Not intentionally retained after processing — deleted once the note is processed |
| Saved voice-note transcripts and free-text entries | Text you choose to save may be retained with the Nurtu profile until it or the account is deleted, subject to Nurtu's deletion and backup practices |
| Copies sent to OpenAI for processing | OpenAI may retain API customer content in abuse-monitoring logs for up to 30 days by default, subject to its applicable retention controls and policies |
| Scan Label / Snap Meal photographs | Nurtu does not intentionally persist the original photograph in its own database after processing. A copy submitted to OpenAI may be subject to OpenAI's applicable API retention controls, including abuse-monitoring retention of up to 30 days by default. |
| First Light report and starting food ideas | The generated Starting Point is cached on the device for fast access and may be regenerated when relevant profile information changes. It is not currently synced as a dedicated report record to the Nurtu cloud database. |
| Analytics events | 14 months |
| Technical and security logs | Retained only as needed for security and operations, and according to applicable infrastructure-provider settings and policies |
| Accounting and transaction records | Retained for the period required by applicable tax, accounting and legal obligations. Apple, RevenueCat and other payment-related service providers may retain transaction information under their own policies. |
When you delete your account we delete your data from our live systems within 30 days, and from backups within a further 90 days.
We may disclose information where we are required to by law — for example under a court order, a subpoena, or a lawful request from a regulator — or where we reasonably believe it is necessary to prevent serious harm to someone's life, health or safety. We will tell you when this happens unless we are legally prevented from doing so.
No system is perfectly secure. If a data breach occurs we will notify you and the relevant regulator:
| Where you are | Who we notify, and how fast |
|---|---|
| Australia | You and the Office of the Australian Information Commissioner, where the breach is likely to result in serious harm (Notifiable Data Breaches scheme) |
| UK / EEA | The relevant supervisory authority within 72 hours, and you without undue delay where there is a high risk to you |
| United States | We will notify affected individuals and relevant regulators as required by applicable federal and state breach-notification laws, including the FTC Health Breach Notification Rule where it applies. |
Wherever you live, you can:
You can turn optional AI processing on or off from More → Your data. Turning AI processing off prevents new information from being sent to OpenAI through Nurtu's AI features. Local logging and non-AI features remain available. Withdrawing AI consent does not require you to delete your child's profile, and analytics remains a separate control.
If you are in the UK or EEA you also have the right to restrict or object to processing, to data portability, and to lodge a complaint with your supervisory authority. In the UK that is the Information Commissioner's Office.
To exercise any right, email hello@nurtu.app. We respond within 30 days. We will not treat you differently for exercising a right — no reduced service, no different price.
The information is about your child, and the rights above are ultimately theirs. As they grow older they may be able to exercise those rights themselves. If your child asks us to delete information about them, we will consider that request on its merits, taking their age and understanding into account.
State privacy laws differ, but our answer to nearly all of them is the same: we do not sell your personal information, we do not "share" it for cross-context behavioural advertising, and we do not use it for targeted advertising. There is no advertising in Nurtu and no advertising SDK in the app.
Because we do not sell or share, there is nothing for a universal opt-out signal such as Global Privacy Control to opt out of. We honour one regardless.
| Where you are | What you can do |
|---|---|
| Every US state | Access, correct, delete and take a copy of your information — all of it available in the app, without asking us |
| California | Know, delete, correct, and opt out of sale or sharing (CCPA/CPRA). You may use an authorised agent. |
| Colorado, Connecticut, Virginia, Texas, Oregon, Montana and other states with comprehensive laws | The same rights, plus the right to appeal if we refuse a request. To appeal, reply to our decision and we will reconsider and respond in writing. |
| Washington and Nevada | Additional rights over consumer health data, including withdrawal of consent. See our separate Consumer Health Data Privacy Policy. |
Your child's information may qualify as sensitive data, consumer health data or other specially protected information under applicable US state privacy laws. We treat child-related health and wellness information as sensitive information and collect it with the consent described in this policy and in the app.
Please contact us first at hello@nurtu.app — we will acknowledge within 5 business days and respond within 30 days.
If you are not satisfied, you can complain to the Office of the Australian Information Commissioner (OAIC), or to your local supervisory authority if you are in the UK or EEA.
Nurtu is not currently offered in the United Kingdom, the European Economic Area or Switzerland. The app is not sold in those App Store territories, and we do not market it there.
Article 27 of the UK and EU GDPR requires a business outside those regions to appoint a local representative before offering goods or services to people inside them. We will appoint one, and name them here, before Nurtu becomes available in those markets. Until then there is nothing to list, and we would rather say so plainly than name a placeholder.
If you are in the UK or the EEA and have somehow ended up using Nurtu, the rights in §10 apply to you anyway — email hello@nurtu.app and we will honour them.
If we change this policy in a way that materially affects how we handle your information, we will tell you in the app and by email before the change takes effect. The date at the top always shows the current version.
Nurtu records what you observe. It does not diagnose, treat, cure or prevent any condition, it is not a medical device, and it is not a substitute for advice from a qualified health professional. Nothing in Nurtu should be used to make a clinical decision on its own.
First Light insights and starting food ideas are informational starting points based on information provided by the parent; they are not medical or dietary prescriptions.