Privacy Policy

Supersedes Version 2.4 (22 October 2026), which superseded Version 2.3 (28 September 2026), which superseded Version 2.2 (19 September 2026), Version 2.1 (1 September 2026), Version 2.0 (5 August 2026) and Version 1.0 (3 June 2026)

What changed in Version 2.5: the Nureo app has a new Vitamins & minerals report in the You tab. It adds up the vitamins and minerals in the meals you log and the supplements you tick in your Stack, and compares the totals with published Australian reference values. To choose the right reference values, the app can ask for your sex, your date of birth and whether you are pregnant or breastfeeding, all optional. A new clause 3.6 explains what the report does and what it does not do (it does not diagnose, does not say you are deficient, and does not tell you what to take), what Nuri can read, and how we record your agreement when you first open it. Clauses 1.1, 3.1, 3.3, 5, 7.1, 8, 10.5, 11, 12, 13 and Appendix A are updated to match. We also fixed a numbering error: two clauses were both numbered 3.5. The plate calibration clause now sits before Symptoms as 3.4, Symptoms stays 3.5, and the clauses from Payment information onward are now 3.7 to 3.12.

What changed in Version 2.4: Google is retiring the AI model the Nureo app used, and the models that replace it are not offered in Australia. AI features in the Nureo app (Nuri, meal photo and label reading, receipt and supplement label reading) are now processed by Google in the United States. Your account and health records are still stored in Australia. Clauses 1.1, 7, 10.1 and 11 are updated: the sign-up page now names health information in the line you agree to, and offers a separate, optional tick for AI. If you did not tick it, the app asks before anything is sent. The practitioner and clinic workspace is unchanged and still processes AI in Sydney.

What changed in Version 2.3: the Nureo app now has a Map that can use your device's location, with your permission, to show the cafés, grocers and markets near you. Clause 3.10 is rewritten to say exactly when location is used, what leaves your device (a coarse map area, never your exact position), and that it is never stored, tracked in the background, or used for advertising.

What changed in Version 2.2: the Nureo app now tells Meta (Facebook and Instagram) when it is installed, when an account is created, when a free trial starts and when a subscription is bought, so we can measure our advertising. New clause 10.5 says exactly what Meta receives and what it never receives. Clauses 3.9, 5, 10.1, 11 and 17 are updated to match. RevenueCat, our in-app subscription processor since 14 September 2026, is now listed in clauses 10.1 and 11.

Nureo Pty Ltd | ABN 84 696 935 154 | 25 South Street, West Wodonga VIC 3690

1. Introduction

Nureo Pty Ltd ('Nureo', 'we', 'us', 'our') operates the Nureo health and nutrition platform. This Privacy Policy explains how we collect, hold, use and disclose your personal information — including your health information — when you use the Nureo mobile application, our website, and the practitioner and clinic workspace (together, the 'Platform').

This Policy is prepared in accordance with the Privacy Act 1988 (Cth) ('Privacy Act') and the Australian Privacy Principles ('APPs') in Schedule 1 of that Act. Because we provide a service that involves health information, we are bound by the Privacy Act regardless of our turnover, and the additional protections that apply to sensitive information apply to much of what we hold about you.

A note on how we have written this. Nureo's product is built on a principle: an assumption should never be presented as an observation, and where the app has guessed, it says so. We have tried to write this Policy the same way. Where we do something you would not expect, we have said it plainly rather than covering it with a general phrase.

This Policy should be read with our Terms of Service. If there is any inconsistency on a privacy matter, this Policy prevails.

1.1 Consent

When you create an account in the Nureo app, the line above the button says that by continuing you agree to our Terms of Service and this Policy, including Nureo keeping the health information you enter. That is how we ask for your consent to collect and hold your health information: Nureo cannot work without storing what you log, so it is a condition of having an account. We record when you agreed and the words you were shown.

On the same page, and separately, you can tick "let Nureo use Google's AI". It starts unticked and you can create an account without it. If you leave it unticked, the app asks the first time you use an AI feature, before anything is sent (clause 7.3).

We ask separately, at the time it becomes relevant, for your consent to:

• share information with a practitioner you engage;
• read data from Apple Health or Health Connect;
• log symptoms (clause 3.5); and
• show you your vitamins and minerals report, which uses your meals, your Stack and, if you choose to give them, your sex, your date of birth and whether you are pregnant or breastfeeding (clause 3.6).

You can withdraw any of these consents at any time in the Platform's privacy settings or by contacting us. Withdrawing your health-information consent means closing your account (clause 13). Withdrawing any other consent will limit the features that depend on it. It does not affect anything we lawfully did before you withdrew it.

2. Who We Are and How to Reach Us

Nureo Pty Ltd (ABN 84 696 935 154) is an Australian company based in Victoria.

We aim to respond to privacy enquiries within 5 business days.

3. What Personal Information We Collect

3.1 Account and identity information

• Name and preferred name
• Email address
• Date of birth and age. Your date of birth is optional. We use it to work out your age band, which decides which reference values the vitamins and minerals report uses (clause 3.6). The sign-up quiz may work out an estimated age, and an estimated age is never used for the report: the report uses general references instead.
• Your sex, if you choose to give it. This is optional. We use it only to choose the right reference values for the vitamins and minerals report (clause 3.6) and, when Nuri can read your report (clause 3.6), to help Nuri answer questions about it.
• Password (stored only as a one-way cryptographic hash — we never hold your plain-text password)
• Profile photograph, if you provide one
• Subscription tier and billing records
• Where you sign in with Apple or Google, the name and email address that service gives us

3.2 Health and wellbeing information you enter

• Daily check-ins: sleep duration and quality, hydration, movement, energy and mood
• Health focus area and your active and historical goals, milestones and progress
• Body measurements and weight, where you record them
• Progress photographs, where you upload them
• Reflections and notes you write

3.3 Food, scanning and nutrition information

This is the largest category of information we hold and the one most specific to Nureo. It includes:

• Meal logs — what you record eating, when, and the nutritional estimate attached to it.
• Photographs of food and of plates, taken through the scanner or selected from your library.
• Photographs of product labels (front-of-pack, ingredient panels and nutrition panels) where a product is not in our catalogue and you choose to photograph it.
• Photographs of shopping receipts, where you use Trolley Scan. A receipt may show the retailer, the date and time, the store location, the items purchased, the amounts paid, a loyalty or rewards number, and the last four digits of a payment card. To read the docket we send the photograph to our artificial intelligence provider (clause 7), which returns the item lines as text. We do not keep the receipt photograph. What we store against your account is the extracted result — the item lines, the store, the date, the total and the grade we calculated — and not the image it came from.
• Scan history — a record of every product you scan, including its identity, its score and the time of the scan. This includes products you scan in a shop and do not buy. We hold this because it lets the app offer to add products to your pantry once you have scanned them a few times, and because scan patterns are one of the signals Nuri uses when it looks for correlations. A scan history describes what you considered, not only what you ate, and we treat it as health information accordingly.
• Your pantry — the products you have confirmed you usually keep. Your pantry has no quantities and no expiry dates; it does not change when you eat something.
• Allergies, intolerances, dietary preferences and eating style — for example that you react to wheat, or that you eat gluten-free by preference. These are health information.
• Symptoms you log — what you felt, how bad it was on a five-point scale, when it started and stopped, and any note you attach. This is the most sensitive information we hold about you, and 3.5 sets out separately what we do and do not do with it.
• Health conditions you tell us about, and any practitioner protocol you are following, where you choose to record them. These are used to personalise your scores and warnings and, for a thyroid condition, haemochromatosis or chronic kidney disease, to decide which nutrients the vitamins and minerals report shows as an amount only (clause 3.6).
• Supplements and medicines you record in your supplement stack, so the app can check a scanned supplement against them for allergens and interactions, and so it can count the supplements you take towards your vitamins and minerals report and compare them with published upper levels. Which supplements you ticked as taken each day is kept on your profile for up to 35 days and used only to work out your daily and weekly totals. Older days are removed automatically when the app next loads the report.
• Weighed corrections — where you tell the app what a meal actually weighed. These build your personal accuracy record and, after enough of them, adjust future estimates.
• Your measured crockery — where you calibrate your plate or bowl (see 3.4).
• Depth measurements — on devices with a depth sensor, the app measures the volume of food standing above the plate at the moment you take a photo, and passes that measurement to the estimate.
• Your pregnancy or breastfeeding status, if you choose to tell us, and the date you last confirmed it. This is health information. Every 6 weeks the report shows a card asking you to confirm it, with the choices "Still right" or "Update", because it goes out of date.
• Nutrient totals that Nureo works out from your meals and your Stack: the amount of each of 17 vitamins and minerals, and of fibre, you took in each day and week, and how those compare with published reference values. This is health information that we create from what you log. The totals themselves are not stored. They are worked out each time you open the report. Each meal you log does store the vitamins and minerals worked out for it, as part of the meal log. Clause 3.6 explains the report.
• Your acknowledgement of the vitamins and minerals report notice, which is when you tapped, the version of the wording you were shown and the choice you made (clause 3.6).

3.4 The plate calibration photograph

If you choose to calibrate your crockery, the app asks you to photograph a plate or bowl with a bank card beside it, because payment cards are a fixed size worldwide and give the image a scale.

Be aware that the photograph you take does leave your device. It is sent to our artificial intelligence provider (clause 7), which measures the plate or bowl against the card and returns a single number — the diameter of your crockery, in centimetres. So the card is in an image that reaches that provider, and we are telling you so rather than describing this as an on-device measurement.

We do not read anything off the card except its outline. The provider is asked for one thing, and the reply it can give us has only four fields in it: whether a card was visible, the plate width, the bowl width, and a confidence score. There is no field in which a card number, name or expiry could reach us, and none is extracted or retained.

We keep the measurement. We do not keep the photograph. Calibrating is optional, and Nureo works without it — but if you do calibrate, it has to be a bank card: the measurement is taken against the ISO/IEC 7810 ID-1 size that every payment card shares, and no other object is accepted as a reference.

3.5 Symptoms you log

You can record how you feel — a symptom, how bad it was, when it started, and when it stopped. This is health information, and under the Privacy Act it is sensitive information, which is the most protected category the Act recognises. Your consent to us keeping it is part of the consent you give when you create your account (clause 1.1), which names the health information you enter. The first time you open the symptom log, the app shows you what happens to it; if your account was made before the sign-up page named health information, tapping "Got it, keep my log" on that card is where you give this consent, and we record when you did and the words you were shown. You can withdraw that consent and delete the whole record at any time.

What the app does with it is narrow, and worth stating plainly because symptom trackers often do more. Nureo records what you tell it and shows it back to you: on the day it happened, alongside what you had already logged that day, and as a pattern over the last thirty days. It counts. It does not assess.

Specifically, Nureo does not tell you what a symptom means, does not suggest a cause, does not name or rank possible conditions, and does not recommend a treatment or a change to your medication. Where the app shows you that two things you logged tend to occur near each other, that is arithmetic on your own entries and nothing more — it is not a finding about your health, and we say so wherever it appears. Nuri will not diagnose a symptom either, and will refer you to a practitioner if you ask it to. If Nuri personalisation is on, Nuri can read your last three weeks of symptoms alongside your meals, drinks and sleep, so it can answer a question such as what tends to come before a flare from your own entries. It points out what your log shows, says when there is too little to go on, and does not diagnose. That reading is processed by Google as clause 7 describes. Turn Nuri personalisation off and Nuri reads none of it.

Some entries cause the app to show you a message asking you to contact a doctor or, where relevant, an emergency or crisis line. That message is a referral and not an assessment: the app is not judging your symptom, it is declining to be the thing you rely on. It does not contact anyone on your behalf, and Nureo is not an emergency service.

Your symptom record is yours alone. It is not visible to practitioners, not shared into circles or with friends, not used for marketing, and not sold. No one else can read it unless you choose to share it, which is a deliberate act that sends a copy of the period you selected and can be revoked. Deleting your account deletes the record.

3.6 Your vitamins and minerals report

The You tab can show a report of the vitamins and minerals in what you have logged. This is health information, and under the Privacy Act it is sensitive information. Your consent to us keeping it is part of the consent you give when you create your account (clause 1.1), which names the health information you enter. The first time you open the report, the app shows you what it does and what happens to the information it uses. If your profile already has a date of birth that you entered, and you are 19 or over, the card has one button, "Got it, build my report". Otherwise the notice and the optional questions (your sex, your date of birth, and whether you are pregnant or breastfeeding) are in one sheet with two equal buttons, "Save and build my report" and "Skip, use general references". Each time you tap a button, we record when you tapped, the version of the wording you were shown and your choice. If you swipe the card away, nothing is recorded and it shows again next time. If your account was made before the sign-up page named health information, that tap is where you give this consent.

You can change your sex and date of birth in Account preferences, and remove pregnancy, breastfeeding or a health condition in Health conditions. To withdraw your consent to the report and have its records removed, email privacy@nureo.com.au (clause 2). Deleting your account removes everything (clause 13).

Each day and each week, Nureo adds up 17 vitamins and minerals, and fibre on its own. The 17 are calcium, iron, magnesium, phosphorus, zinc, iodine, selenium, vitamin A, thiamin (B1), riboflavin (B2), niacin (B3), vitamin B6, folate, vitamin B12, vitamin C, vitamin D and vitamin E. Potassium is shown as an amount only, for everyone. The report counts two things: the meals and drinks you log, and the supplements in your Stack that you have ticked as taken. For food, it uses Australian food composition data (AUSNUT 2023, from Food Standards Australia New Zealand, or FSANZ), multiplied by the weight of each portion. That weight is an estimate worked out from your photo or description, so the totals are estimates too, and the report shows how many of your meals it was able to count. For supplements, it takes the amounts printed on the label and converts them to the amount of the nutrient itself, for example the magnesium in a magnesium glycinate tablet. AUSNUT 2023 is published by FSANZ under a Creative Commons Attribution 4.0 licence (source: Food Standards Australia New Zealand). Nureo has adapted it by scaling the values to estimated portion sizes, and FSANZ does not endorse Nureo. As FSANZ notes, composition figures are averages, and the nutrient content of an individual food can vary considerably between batches and brands, with season, formulation, processing and where the ingredients come from.

The report then sets your totals beside published reference values. These are the Nutrient Reference Values for Australia and New Zealand, chosen by your sex, your age and whether you are pregnant or breastfeeding, if you have told us. These were developed by the National Health and Medical Research Council (NHMRC), the Australian Department of Health and Ageing and the New Zealand Ministry of Health (2006, with later updates), and are used under a Creative Commons Attribution 4.0 licence. Source: National Health and Medical Research Council. This does not imply endorsement. If you have not told us, or you are under 19, the report uses the general recommended dietary intakes that Australian food labels use for vitamins and minerals instead (Schedule 1 of the Australia New Zealand Food Standards Code). An estimated age, such as one the sign-up quiz may work out, is never used for the report. For supplements, the report also compares what you take with the upper level of intake published by the NHMRC. Some upper levels apply to supplements only, and the report counts only supplements for those. The one figure the report shows that is not an NHMRC upper level is for vitamin C, where the app uses a commonly cited figure of 1,000 mg and says so.

This is worth stating plainly, because nutrient trackers often do more. Nureo adds up what you logged and shows it beside a published figure. It counts. It does not assess.

Specifically, Nureo does not diagnose anything. It does not say that you are deficient, at risk or short of any nutrient, and it does not say that an amount is safe, healthy or ideal for you. Being under a reference value is arithmetic on your own entries, and it is not a finding about your health: a reference value is a general figure for a group of people, many foods are not counted, and your needs may differ. The report does not tell you what to take, what to buy, or whether to start, stop, raise or lower a supplement or a dose, and it names no product to fix a total. It does not link a symptom you logged to a nutrient. Where it shows an amount above an upper level for supplements, it is showing a published number, not telling you that you are in danger. We say this wherever the report appears, and the report ends with a note saying it gives estimates only, is general information and is not medical advice.

If you have ticked a thyroid condition, haemochromatosis or chronic kidney disease, the report shows the related nutrients as an amount only, with no bar, no percentage, no "under the reference" label and no list of foods to eat more of. For a thyroid condition that is iodine, for haemochromatosis it is iron, and for chronic kidney disease it is phosphorus and magnesium. If you have ticked more than one, all of their nutrients are shown as an amount only. Upper levels for supplements are still checked for these nutrients. The app points you to your doctor or specialist.

If you tell us you are pregnant or breastfeeding, the report uses the NHMRC reference values for pregnancy or breastfeeding. It is a lookup of published figures, nothing more, and it does not advise you on your pregnancy. Because this status goes out of date, the report asks you to confirm it every 6 weeks.

Report data reaches Nuri only when all three of these are true: Nuri personalisation is on (the same switch as for symptoms in clause 3.5), you have answered the report's first-open card, and AI features are on. Even then, it is sent only when you ask Nuri something about your vitamins, minerals, Stack or report. It is not sent with every message. What is sent is your totals, your sex, an age band (19 to 30, 31 to 50, 51 to 70, or over 70, never your date of birth) and your pregnancy or breastfeeding status. Nuri points to what the numbers show, says when there is too little to go on, and does not diagnose, give a dose, recommend a product, use the word deficiency, or link a symptom to a nutrient. That reading is processed by Google as clause 7 describes. Turn Nuri personalisation off and Nuri reads none of it.

Your report, and the sex, pregnancy status and totals behind it, are yours alone. Practitioners cannot read the report or the new profile fields, and none of it is in a practitioner export. It is not shown in circles or to friends, not used for marketing, not used for advertising, and not sold. Meta receives none of it (clause 10.5). No report, condition or pregnancy data is sent to analytics or to crash reports.

3.7 Payment information

• Your subscription plan and billing history
• Where you pay through the Apple App Store or Google Play, those stores process your payment and we receive only a confirmation that a subscription is active; we do not receive your card details
• Where you pay us directly or pay a practitioner through the Platform, our payment processor (Stripe) handles the card data. We store only a payment token and the last four digits, for identification

We never hold your full card number or bank account details on our systems.

3.8 Apple Health and Health Connect

Connecting Apple Health (on iOS) or Health Connect (on Android) is entirely optional and Nureo works fully without it.

If you connect it, we read only the data types you approve. Those types are:

• Steps
• Distance walked or run, and distance travelled
• Active energy burned, and basal (resting) energy burned
• Heart rate, and resting heart rate
• Sleep — both sleep sessions and time asleep
• Body weight
• Workouts, and workout routes

We read this data. We do not write to Apple Health or Health Connect. Every authorisation Nureo requests is read-only, and the app contains no path that writes a record back. Version 1.0 of this Policy said we write nutrition data back to Apple Health; that was never true of the app and has been removed.

We do not use Apple Health or Health Connect data for advertising, marketing, or any use-based data mining. We do not share it with data brokers or advertising platforms. We do not store it in iCloud. It is used only to show you your own information and to inform the features you have asked for.

3.9 Communications and community

• Messages you exchange with practitioners through the Platform
• Posts, comments, reactions and shared meals where you use the social and circles features, and your chosen visibility for each
• Reports you make about other users' content, and reports made about yours
• Support correspondence, feedback and survey responses
• Your participation in live seminars: which you join, questions you submit, and on-screen reactions. Most participants join as view-only and do not transmit camera or microphone. If you host or present, we process your live video and audio for the broadcast

3.10 Nuri conversations

The messages you send to Nuri and the responses it returns, together with the context passed with them (see clause 7).

3.11 Technical and device information

• Device type, operating system and app version
• IP address, and the approximate region derived from it
• App usage, session duration and feature interactions
• Crash reports and error logs
• Push notification token
• Session tokens and device identifiers
• The advertising-measurement events described in clause 10.5 (app installed and opened, account created, free trial started, store purchase)

3.12 Location

The Map tab, and the "Near you" card on Home, can use your device's location — only if you allow it. It is used to show the cafés, grocers, markets and other places around you on the map and to sort them by distance. Before your device's own permission prompt appears, the app shows a screen explaining what location is for, and you can say "Not now". If you decline, everything in Nureo still works: you move the map yourself. You can change your answer at any time in your device's settings. Your device may let you choose precise or approximate location; either works.

Location is used only while the app is open and on screen. Nureo does not request background location, does not track where you go, and does not build a history of where you have been.

What leaves your device is a coarse map area, not your position. On your device, your position is converted into a grid square roughly five kilometres across, and only that grid square (with the squares around it) is sent to our database to fetch the places inside it. Your exact coordinates are not sent to our servers, are not saved to your account or your health record, are not used for analytics or advertising, and are not shared with Meta, practitioners or other members. The most recent position is kept in the app's memory for a few minutes, so the map does not ask your device again every time you move it, and it is gone when the app closes.

The map itself is drawn by Apple Maps on iPhone and by Google Maps on Android. As with any map, those services receive the map area being displayed, under their own privacy terms. If you post a review of a place, the review is attached to the place you chose, not to your location.

Where we need an approximate region — for example to show practitioners near you — we derive it from your IP address, or you tell us.

One exception, and we are naming it rather than leaving it in the Apple Health clause. If you connect Apple Health or Health Connect and approve workouts, we read your workout routes — the GPS trace of a run or ride that your device already recorded. That is precise location data. It is read from Health, not from a location permission, and it is used only to draw the map on your own run summary. It is not uploaded to our servers, it is not stored by us, and it is not shared with practitioners or other members. The route for a single session is read from Health only while you have that run's summary open, drawn on your device, and discarded when you leave the screen. Nothing in the daily record we sync carries route data.

4. How We Collect Your Information

• Directly from you — when you register, complete your profile, check in, scan, log a meal, set a goal, upload a photo, message a practitioner, or contact support.
• Automatically — through your use of the Platform, including analytics, device information and technical logs.
• From your device, with permission — camera, photo library, depth sensor, Apple Health or Health Connect.
• From third parties — sign-in providers (Apple, Google), payment processors, and product data sources (clause 8).
• From practitioners — where you have engaged one and consented to them adding to your record.

Where practicable you may use parts of the Platform without identifying yourself or under a pseudonym. Features involving payment, practitioner engagement or the community require you to be identified.

5. Why We Use Your Information

We use personal information for the purpose we collected it for, for directly related purposes, where you have consented, or where the law permits or requires it.

To run the Platform — creating and managing your account; processing subscriptions; delivering scanning, scoring, logging, goals, pantry, audits and reminders; showing your vitamins and minerals report; facilitating practitioner discovery, booking and messaging; providing support.

To personalise what you see — adjusting a product's score for your allergies, preferences, conditions and goals; choosing the reference values in your vitamins and minerals report from your sex, age and pregnancy or breastfeeding status, and showing the nutrients tied to a condition you ticked as an amount only; grounding Nuri's answers in what you have actually logged; adjusting future estimates to your own measured bias; showing relevant practitioners.

To keep our estimates honest — building your accuracy record from your weighed corrections, and using aggregate, de-identified accuracy data to measure and improve the product.

To improve the Platform — analysing aggregated, de-identified usage; monitoring errors, performance and security incidents; research and development.

To build and correct the shared product catalogue — see clause 6.

To meet legal obligations — compliance, lawful requests, enforcing our terms, preventing fraud, and keeping tax and financial records.

To measure our advertising — learning which of our Facebook and Instagram ads lead people to install Nureo, create an account, start a trial and subscribe. See clause 10.5 for exactly what is sent.

To send you marketing, if you have agreed — see clause 9.

6. Community-Contributed Product Data

This is how the catalogue improves, and it is the reason a product you had to photograph today will simply scan for the next person.

What is shared: information about the product. What is not shared: anything identifying you. Your name, your account, your scan history and the fact that you were the contributor are not published, and are not visible to other members.

If you would prefer a submission not to be used this way, do not submit it for review — you can still use the label reading for yourself. If you have already submitted something and want it withdrawn, contact privacy@nureo.com.au, though we may not be able to remove information that has since been independently verified or corrected by others.

7. Artificial Intelligence

Several Nureo features use a generative AI model: Nuri, meal photo analysis, product label reading, receipt reading, supplement label reading, and crockery calibration.

7.1 What is sent, and where

When you use one of those features in the Nureo app, the relevant image or text is sent, together with context about you, to Google Vertex AI in the United States. Requests are routed through a Nureo server function in Sydney, authenticated with your own account credentials. No AI provider key is embedded in the app.

Only the request leaves Australia. Your account, your logs, your photos and your health record are still stored in Australia (clause 11). Google processes the request and returns the answer.

The context we send with a request may include your allergies, your dietary preferences, your health conditions, your goals, your recent logs, your measured crockery and, where available, the depth measurement from your device. When you ask Nuri something about your vitamins, minerals, Stack or report, and Nuri personalisation is on, you have answered the report's first-open card and AI features are on, the context also includes your nutrient totals, your sex (if you gave it), your age band (19 to 30, 31 to 50, 51 to 70, or over 70, never your date of birth) and your pregnancy or breastfeeding status (if you gave it). We send it because an estimate that does not know you react to wheat is less useful and less safe than one that does, and because Nuri cannot answer a question about your report without seeing it.

For meal photographs, we send only the part of the photo inside the framing square you lined the food up in, not the whole picture. The same image may be analysed more than once and the middle result used, because a single reading of one photograph is less reliable than several.

The practitioner and clinic workspace is different: its AI features run in Google Vertex AI's Sydney region and do not leave Australia. See the Practitioner Terms.

7.2 What Google may and may not do with it

Google acts as our data processor under the Google Cloud Data Processing Addendum, wherever the request is processed. Your prompts, images and the responses generated are not used to train or improve Google's models, are not reviewed by Google for product development, and are not used for advertising by Google or by us.

Until October 2026 we pinned AI processing to Sydney. Google is retiring the model we used there, and its replacements are not offered in Australia. We moved the app's AI processing to the United States on that basis, and we told members before it happened. We did not make this as a quiet configuration change.

7.3 Your consent

Because this sends health information to a third party, we ask for your explicit consent before the first time it happens, separately from your acceptance of this Policy or our Terms. You can withdraw it in privacy settings. If you do, the AI features stop working; barcode scanning, logging, and everything that does not require the model continue to work.

7.4 Retention

AI-generated responses are not stored as part of your health record. Conversation context within a Nuri session may be held briefly to keep the conversation coherent. Your Nuri message history is retained as described in clause 12.

8. Automated Decisions

Some things the Platform does are decided by software rather than by a person. We think you should know which, and we have set them out here.

None of these decisions is final and none is made about you by us in a way you cannot change. You can correct any estimate, weigh a meal to override it, change your allergy and preference settings at any time, decline a pantry proposal, and tell us when a score or a warning is wrong. Where you tell us a product's underlying data is wrong, a person at Nureo reviews it. The vitamins and minerals report does not decide anything about your health. It does not label you deficient, it does not decide what you should take, and nothing in it is passed to anyone else.

If you want to know why the Platform reached a particular result, contact privacy@nureo.com.au and we will explain it.

9. Direct Marketing

We may use your email address and push token to tell you about features, content and offers, but only where you have consented or where the Spam Act 2003 (Cth) permits it.

We do not use your health information to target marketing to you, and we do not use it to decide what marketing you receive.

You can opt out at any time by using the unsubscribe link in any marketing email, changing your notification settings, or emailing privacy@nureo.com.au. Opting out does not stop transactional messages such as billing confirmations, renewal notices and security alerts.

10. Who We Disclose Your Information To

We do not sell, rent or trade your personal information.

10.1 Service providers

We use third parties to run the Platform. They may use your information only to perform services for us, under contract, and must maintain appropriate security. They are:

10.2 Practitioners

If you engage a practitioner through the Platform, we share what is necessary for that engagement — your name, contact details, and the health information you choose to share. We ask for your specific consent before sharing health information with a practitioner, and you choose what to share.

Your pantry and your scan history are not shared with practitioners. They are not part of what a practitioner can see, at any subscription tier, and a practitioner cannot request them. What is in your cupboard is your business; if you want your practitioner to know, you can tell them.

Practitioners are independent professionals bound by their own confidentiality obligations and by the Privacy Act. Where a practitioner records information about you in their clinical record, they are the custodian of that record and their own privacy obligations apply to it.

10.3 Other members

Content you choose to post to the feed, to a circle, or to share with a friend is visible to those people. Every post has a visibility setting, the default is private, and you control it. Progress photographs are private to you unless you deliberately share one.

10.4 Legal, safety and business transfers

We may disclose personal information where the law requires it, including in response to a subpoena, court order or lawful request. We will tell you unless we are prohibited from doing so.

We may disclose it where we reasonably believe it is necessary to prevent a serious threat to someone's life, health or safety, or to investigate suspected fraud or a security incident.

If Nureo is involved in a merger, acquisition or sale of assets, your information may transfer to the successor. We will notify you by email and in-app before that happens.

10.5 Measuring our advertising (Meta)

We advertise Nureo on Facebook and Instagram. To learn which ads lead people to install and use the app, the Nureo app for iPhone and Android includes Meta's App Events software development kit. Meta Platforms, Inc. (United States) and Meta Platforms Ireland Limited receive the following from it:

• that the app was installed, and each time it is opened;
• that an account was created, and whether it was created with email, Apple or Google;
• that your free trial started;
• purchases and subscriptions made through the App Store or Google Play — the product, its price and the currency — which the SDK reads from the store itself;
• the technical information that accompanies any request from the app: device model, operating system and version, app version, language, time zone, and IP address.

What Meta never receives from Nureo: anything you enter, record or connect in the app. No health or wellbeing information, food or meal logs, scans, supplements, symptoms, nutrient totals, your vitamins and minerals report, sex, pregnancy or breastfeeding status, goals, quiz or questionnaire answers, Apple Health or Health Connect data, Nuri conversations, messages, photos, or your name, email address or phone number.

We do not collect your device's advertising identifier (the Apple IDFA or the Google advertising ID), and the app does not ask for permission to track you across other companies' apps. On iPhone, Meta attributes installs through Apple's SKAdNetwork and Meta's Aggregated Event Measurement, which report results in aggregate.

Because Nureo is a health and nutrition app, the fact that you installed and use it can suggest an interest in health. Meta receives that fact. Meta handles what it receives under its own privacy policy, and it may be able to connect these events with a Facebook or Instagram account used on the same device or network. You can see and disconnect activity that apps share with Meta under "Your activity off Meta technologies" in your Facebook or Instagram settings.

The app does not currently include a switch to turn this off. If you do not want Meta to receive these events, you can email privacy@nureo.com.au, or disconnect the activity in your Meta account as described above.

11. Information Sent Outside Australia

Your account data and your health information are stored in Australia. Nureo's database, file storage and authentication run in Google's Sydney (australia-southeast1) region. Our web application runs in Vercel's Sydney (syd1) region. Our live video, telehealth and email delivery run in Amazon Web Services' Sydney (ap-southeast-2) region. AI requests from the Nureo app are processed in the United States (first row below, and clause 7); AI in the practitioner and clinic workspace stays in Sydney.

Live seminars, telehealth consultations and their join tokens do not leave Australia. Both the media and the token-issuing function are hosted in Sydney.

A limited number of things do leave Australia. We have listed them individually rather than describing them generally:

Before disclosing personal information overseas we take reasonable steps to ensure the recipient does not breach the APPs, including data processing agreements binding them to APP-equivalent standards.

On consent and APP 8. Version 1.0 of this Policy relied on your consent to disengage APP 8.1, which would have meant you could not seek redress under the Privacy Act if an overseas recipient mishandled your information. We have removed that. We do not ask you to give up that protection. We rely on the reasonable-steps obligation in APP 8.1 and we accept accountability under s 16C for what our overseas processors do with your information.

A current list of the countries in which our service providers operate is available from privacy@nureo.com.au.

12. How Long We Keep Things

After the applicable period we securely delete or de-identify the information. You may ask us to delete earlier where we have no legal obligation to keep it.

13. Deleting Your Account

You can delete your account from within the app, in account settings. You do not need to email us, and you do not need to explain why.

Deleting your account removes your personal information, your health information (including your sex, date of birth, health conditions, pregnancy or breastfeeding status and your record of the vitamins and minerals report notice), your logs (including your meal logs and the vitamins and minerals worked out for them), your photographs, your pantry, your scan history, your Stack tick history and your community posts. Your Nuri conversations are not covered by this, because they are not ours to delete: they are written to storage on your device and reach our servers at no point. To remove them, uninstall the app or clear its data on each device you have used Nureo on. It does not remove:

• information we are legally required to retain (clause 12) — chiefly financial records and, where you have engaged a practitioner, the clinical record, which belongs to the practitioner and is subject to their retention obligations;
• product data you contributed to the shared catalogue, which is not linked to you (clause 6); and
• de-identified analytics, which cannot be linked back to you.

You can also request deletion from the web at nureo.com.au/delete-account, without opening the app.

Export your data before you delete it if you want a copy — see clause 14.

14. Your Privacy Rights

Access (APP 12). You may request access to the personal information we hold about you. Email privacy@nureo.com.au. We respond within 30 days. We may charge a reasonable fee for the cost of providing access, disclosed before we proceed. We may decline in the limited circumstances the Privacy Act permits, and will give you written reasons.

Correction (APP 13). If information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, ask us to correct it and we will take reasonable steps within 30 days. If we disagree, we will explain why and, if you ask, attach a statement to the record.

Deletion. See clause 13.

Export. You can request a machine-readable export of your data at privacy@nureo.com.au. We aim to provide it within 30 days.

Anonymity and pseudonymity (APP 2). Where practicable, you may deal with us anonymously or under a pseudonym.

Withdrawing consent. You may withdraw any consent at any time in privacy settings or by contacting us. See clause 1.1.

Explanation of an automated result. See clause 8.

15. Security

We hold health information, and we treat it accordingly. Our measures include:

• Encryption in transit (TLS) and at rest
• Passwords stored using one-way cryptographic hashing
• Per-user access rules enforced at the database layer, so one member's records cannot be read by another
• Access controls limiting staff and contractor access on a need-to-know basis
• Staff training on privacy and security
• Documented incident response procedures

No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. Use a strong, unique password and keep your device secure.

If you find a security vulnerability, tell us at privacy@nureo.com.au. We will not pursue you for reporting a genuine vulnerability in good faith.

16. Data Breaches

The Notifiable Data Breaches scheme under Part IIIC of the Privacy Act requires us to notify the Office of the Australian Information Commissioner (OAIC) and affected individuals of an eligible data breach — one likely to result in serious harm.

If one occurs we will contain it, assess it, notify the OAIC as soon as practicable, notify you if your information was involved, and tell you what happened, what was involved, and what we suggest you do.

Because we hold health information, we treat every suspected breach as high priority.

17. Cookies and Similar Technologies

The mobile app does not use browser cookies. It uses device identifiers, session tokens and analytics SDKs to keep you signed in, understand usage, and detect fraud. It also includes Meta's App Events SDK to measure our advertising, which is described in clause 10.5. The app does not collect your device's advertising identifier.

Our website, the member dashboard and the practitioner workspace are web applications and use cookies for one purpose: keeping you signed in. Those are strictly necessary cookies — without them you could not hold a session — and they are set when you sign in, not when you arrive.

We use Vercel Analytics for de-identified usage measurement. We do not run advertising, conversion or third-party tracking pixels on any page, and we do not use any non-essential cookie or tracking technology, which is why you are not asked to dismiss a consent banner. If we ever introduce one, we will ask for your consent before it is set, and we will not treat a generic banner as consent for anything that could reveal a health interest.

You can manage some tracking through your device settings; doing so may affect functionality.

18. Children

Nureo is for adults. You must be 18 or over to create an account, and we do not offer the Platform to anyone under that age. This is a single position: there is no under-18 tier and no parental-consent route.

We do not knowingly collect personal information from anyone under 18. If we learn that an account belongs to someone under 18, we will delete the personal information we hold for it and close the account.

If you are a parent or guardian and believe your child has given us personal information, contact privacy@nureo.com.au and we will remove it.

Information about children in your household. If you scan a lunchbox or a product for a child, we hold that as your data, not the child's, and Nureo's scoring is calibrated for adults. Do not use Nureo's scores to make clinical decisions about a child's diet.

19. Third-Party Links

The Platform may link to third-party sites and services. This Policy does not apply to them. Read their privacy policies.

20. Changes to This Policy

We may update this Policy. We will notify you of material changes by email and by prominent in-app notice at least 14 days before they take effect.

If a change would broaden how we use your health information, we will ask for your consent again rather than relying on your continued use.

Previous versions are available on request.

21. Complaints

Talk to us first. Email privacy@nureo.com.au with 'Privacy Complaint' in the subject line. We will acknowledge within 5 business days and aim to resolve within 30 days. If we need longer we will tell you why.

If you are not satisfied, you may complain to the Office of the Australian Information Commissioner:

• www.oaic.gov.au
• 1300 363 992
• enquiries@oaic.gov.au

The OAIC can investigate and make determinations, including ordering remedial action or compensation.

Appendix A — How We Meet Each Australian Privacy Principle

APP 1 — Open and transparent management. This Policy is published on our website and in the app. We have a Privacy Officer. From 10 December 2026, clause 8 discloses our automated decision-making.

APP 2 — Anonymity and pseudonymity. Available where practicable. Identification is required for payment, practitioner engagement and community features.

APP 3 — Collection of solicited personal information. We collect only what is reasonably necessary. Health information is collected with express, specific consent, sought at the point of collection rather than bundled.

APP 4 — Unsolicited personal information. Where we receive information we did not solicit and could not have collected under APP 3, we destroy or de-identify it.

APP 5 — Notification of collection. This Policy, plus in-app notices at the point of collection for camera, health data, AI processing, practitioner sharing, symptom logging and the vitamins and minerals report.

APP 6 — Use and disclosure. Used for the primary purpose, directly related secondary purposes, or with consent. Health information is not used for advertising. Supplement records are used for allergen and interaction checks and, since Version 2.5, for nutrient totals and the upper-level comparison.

APP 7 — Direct marketing. Consent-based, with opt-out on every message. Health information is not used to target marketing.

APP 8 — Cross-border disclosure. Clause 11 lists each overseas disclosure individually, including AI requests from the Nureo app, which are processed by Google in the United States. We rely on reasonable steps and contractual protections (the Google Cloud Data Processing Addendum), not on asking you to waive your redress rights, and we remain accountable under s 16C.

APP 9 — Government-related identifiers. We do not adopt, use or disclose government identifiers as our own.

APP 10 — Quality. We take reasonable steps to keep information accurate and current, and you can correct it yourself.

APP 11 — Security. Clause 15. We destroy or de-identify information we no longer need (clause 12).

APP 12 — Access. Within 30 days, refusable only on lawful grounds with written reasons.

APP 13 — Correction. Within 30 days, with a statement attached if we disagree.