Privacy policy

1. Who we are

Surplus is an iPhone app and two websites, eatsurplus.com and help.eatsurplus.com, run by Forge Wealth Group Ltd, a company registered in England and Wales (company number 16240779), whose registered office is at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. Surplus is our trading name. In this policy, “we”, “us” and “our” mean Forge Wealth Group Ltd.

We are the controller of the personal information this policy describes: we decide why and how it’s used.

This policy covers the Surplus app, our websites, and any email you send us. To ask about it, or about your information, email [email protected] with “Privacy” in the subject, or write to us at the address above.

2. What we collect

Information you give us

• Your profile: your height, sex, date of birth, starting, current and goal weight, how quickly you want to gain, your activity level, your units and other settings, and the country whose foods you see first.
• What you log and plan: foods and drinks, with their names, calories, protein, carbohydrates, fat and any other nutrients they come with (sugar, fibre, saturated fat, sodium, potassium), their brand, barcode, serving, the time you ate them and the meal they’re in; your recipes and their ingredients; your meal plans, meal times and shopping list; your water; and your weigh-ins.
• Photos you choose to add: progress photos on your weigh-ins, and photos for your recipes.
• Your consents: the date and time you agreed to the health data and data transfer consents (section 3).
• Messages you send us: your email address and what you write. If you use Contact Support in the app, the email it drafts includes the app’s version and your iOS version, so we can help.

Information that comes with an account

When you sign in to a Surplus account:

• Your email address, if you sign in with email, or if Apple or Google shares it. With Sign in with Apple you can choose to hide your email, and we then get a private relay address from Apple instead.
• An identifier for your Apple or Google account, so we know it’s you next time. If you sign in with Google, Google may also share your name and a link to your profile picture. We don’t use either.
• A username Surplus makes up for you, like SteadyOtter4821.
• Sign-in records kept by our sign-in service: when you signed in, and the IP address and type of device each session came from. These keep your account secure.
• Your password, if you use email. Our sign-in service stores only a scrambled (hashed) version, and nobody can read it, us included.

Information from your phone

• Camera: used only while you scan a barcode or take a photo in Surplus.
• Photos: Surplus doesn’t have access to your photo library. When you pick a photo, iOS hands Surplus only that photo. Surplus shrinks every photo and saves it without its location or other hidden information, and never saves anything to your camera roll.
• Apple Health: if you allow it, Surplus reads your step count to show it to you. See section 4.
• Notifications: if you turn reminders on, they’re scheduled on your phone. We don’t send push notifications from a server, so your device’s notification address never reaches us.
• Your phone’s region: Surplus uses it to choose your food country until you pick one. The location and time zone on your Profile are read from your phone’s settings each time you look and are never stored. Surplus doesn’t use location services or GPS.

What we don’t collect

We don’t collect advertising identifiers, contacts, your microphone, your precise or approximate location, or anything about your use of other apps and websites. Surplus contains no advertising, analytics or crash-reporting tools.

If you’ve chosen to share analytics with app developers in your iPhone settings, Apple may send us anonymous crash and usage reports. You can turn this off in Settings › Privacy & Security › Analytics & Improvements.

3. Your health data

Your weight, the food you log and your progress photos are health data. Under UK and EU data protection law they are a “special category” of personal data, and under some US state laws they are “consumer health data”. We treat them with extra care.

We only use your health data because you’ve given your explicit consent. Before you set up Surplus, the app asks you to tick this:

Health data processing. Surplus may process my health data — my weight, the food I log and my progress photos — to provide its nutrition and weight-gain features.

We use your health data only to run Surplus for you: to work out your targets, show your progress, estimate your stomach level, plan your meals and remind you to eat. We never use it for advertising, never sell it, and only share it with the service providers in section 6 who help us run Surplus.

You can withdraw your consent at any time. Surplus can’t work without this information, so withdrawing it means deleting your account: in the app, go to Profile › Privacy › Data Consents, or Profile › Help › Delete account, or email us (section 9). Withdrawing doesn’t make anything we did before it unlawful.

If you live in the United States, our consumer health data privacy policy explains your rights over this data in more detail.

4. Apple Health

• Surplus asks Apple Health for permission to read your step count, and nothing else. It never writes anything to Apple Health.
• Your steps are read on your phone when you open Surplus, to show them on Today and on the Steps page. They’re not stored by Surplus, not synced to your account and never sent to us or to anyone else.
• We never use Apple Health data for advertising or marketing, never sell it, and never share it with anyone.
• You can turn this off at any time in your iPhone’s Settings › Privacy & Security › Health › Surplus.

5. How we use your information

Under UK and EU data protection law, we need a legal reason (a “lawful basis”) for each use.

Running Surplus for you

Your targets, logs, plans, shopping list, reminders, progress and stomach level.

• Information: your profile, what you log, your photos.
• Lawful basis: performing our contract with you. For health data, your explicit consent.

Keeping your information in your account

So it’s there when you sign in on a new phone.

• Information: everything in section 2 except your photos.
• Lawful basis: performing our contract with you. For health data, your explicit consent.

Your account and its security

Creating your account, keeping it secure, and checking it’s you before it’s deleted.

• Information: account information and sign-in records.
• Lawful basis: performing our contract with you, and our legitimate interest in keeping accounts safe.

Finding foods

When you search for a food or scan a barcode.

• Information: the words you search for, the barcode, and your food country.
• Lawful basis: performing our contract with you.

Checking whether you have Premium

• Information: the purchase record Apple keeps on your phone.
• Lawful basis: performing our contract with you.

Answering your emails

• Information: your email address, your message, and your app and iOS versions.
• Lawful basis: our legitimate interest in helping you.

Keeping records and dealing with legal claims

• Information: consent records and emails.
• Lawful basis: legal obligations, and our legitimate interest in defending legal claims.

Surplus doesn’t make decisions about you by automated means that have legal or similarly significant effects. Your targets and stomach level are calculated from what you enter, and you can change them by changing your details.

6. Who we share it with

We don’t sell your personal information and don’t share it for advertising (what some US laws call “cross-context behavioural advertising”). We share it only with:

• Supabase, Inc., which hosts our database and sign-in service and sends account emails, like confirming your address or resetting your password. Your account’s information is stored on its servers in Ireland. Supabase works for us under a data processing agreement and may only use your information to provide its service to us.
• Apple, which handles App Store purchases and subscriptions, Sign in with Apple, and the iOS features Surplus uses. We never see your card details. Apple’s privacy policy covers what Apple does with your information.
• Google, if you choose Sign in with Google, to confirm who you are. Google’s privacy policy applies.
• Cloudflare, Inc., which hosts our websites and forwards email sent to [email protected].
• Open Food Facts, a free, open food database run by a French non-profit. When you search for a food or scan a barcode, Surplus sends Open Food Facts the words you typed or the barcode, and your food country. It doesn’t send your name, your account or any identifier, but like any website Open Food Facts sees your IP address. Open Food Facts’ privacy policy covers this. Searching the food library built into Surplus happens on your phone and sends nothing.

We may also share information:

• with professional advisers, like lawyers and accountants, who must keep it confidential;
• when the law requires it, or to protect someone’s safety, our rights or the rights of others;
• with a buyer or successor if our business is sold, merged or reorganised. They would have to keep to this policy, and we’d tell you before it changed.

7. Where your information is kept

On your phone. Everything you enter is saved on your iPhone first, so Surplus works without an internet connection. If you back up your iPhone to iCloud or a computer, Surplus’s information can be part of that backup, which Apple’s terms cover.

On our servers, when you’re signed in to an account: with Supabase, in Ireland, in the European Union.

Transfers between countries. If you live outside the European Union, for example in the UK, the US, Canada, Australia or New Zealand, your information is sent to Ireland. Before you start, Surplus asks you to agree to this:

Transfer outside your country or region. Surplus may store my personal data on servers in Ireland, in the EU, to provide its service. I’m aware this may be outside my country or region, and its data-protection laws may differ from mine.

Information sent from the UK to the EU is covered by the UK’s adequacy regulations. Some of our providers are based in the US and may reach information from there. Where they do, we rely on the EU–US Data Privacy Framework and its UK extension where the provider is certified, or on standard contractual clauses approved by the European Commission and the UK.

8. How long we keep it

• Your account and everything in it: for as long as you have an account.
• Something you delete in the app: it’s removed from your phone straight away and hidden on our servers, and it’s erased from our servers completely when you delete your account.
• When you delete your account: your account and everything in it, including your sign-in records, are deleted from our servers straight away. Any copies in our hosting provider’s backups are overwritten within 30 days.
• On your phone: until you delete it, delete your account, or delete the app.
• Emails you send us: for up to two years after our last message, unless we need them longer for a legal claim.

9. Deleting your account

In the app, go to Profile › Help › Delete account and confirm it’s you. This deletes your account and everything in it — every meal, recipe, plan and weigh-in — from our servers and from your phone. It can’t be undone.

Deleting your account doesn’t cancel a Premium subscription, because Apple manages subscriptions. Cancel it in your iPhone’s Settings › your name › Subscriptions first.

If you haven’t created an account, everything you’ve entered is only on your phone, and deleting the app deletes it.

If you can’t reach Delete account — for example because your trial or subscription has ended and Surplus is showing the subscribe screen — email [email protected] from the address on your account, and we’ll delete it for you within 30 days.

10. Your rights

Everyone

You can see, change and delete most of your information in the app. For anything else, email [email protected]. We’ll reply within one month, and it’s free. We may need to check it’s you before we act.

In the UK and the European Union

You have the right to:

• access your information and get a copy of it;
• correct information that’s wrong;
• delete your information;
• restrict how we use it, or object to how we use it, where we rely on legitimate interests;
• take your information with you (data portability): we’ll send it to you in a common, machine-readable format;
• withdraw your consent at any time (section 3).

You can also complain to a data protection authority: in the UK, the Information Commissioner’s Office; in Ireland, the Data Protection Commission; or the authority where you live. We’d appreciate the chance to put things right first.

In the United States

Depending on the state you live in, you may have the right to know what personal information we hold about you and get a copy of it, to correct it, to delete it, and to opt out of its sale, targeted advertising and certain kinds of profiling. We don’t sell your information, use it for targeted advertising or profile you, so there’s nothing to opt out of. We only use sensitive information, like your health data, to provide Surplus to you.

You can ask through someone you’ve authorised to act for you. We won’t treat you differently for using your rights. If we turn down your request, you can appeal by replying to our answer; if you’re still unhappy, you can contact your state’s attorney general. People in Washington, Nevada and other states with consumer health data laws have further rights, set out in our consumer health data privacy policy.

In Canada, Australia and New Zealand

You can ask to see and correct the information we hold about you, and withdraw your consent. If you’re unhappy with how we’ve handled your information, tell us first. You can then complain to the Office of the Privacy Commissioner of Canada, the Office of the Australian Information Commissioner, or New Zealand’s Office of the Privacy Commissioner.

11. Children

Surplus is for people aged 16 and over. We don’t knowingly collect information from anyone under 16. If you think someone under 16 has given us their information, email us and we’ll delete it.

12. Keeping your information safe

• Everything sent between the app and our servers is encrypted.
• Our database is set up so that each account can only ever reach its own information.
• Your sign-in is stored in your iPhone’s Keychain, and passwords are only ever stored scrambled.
• Deleting an account needs a fresh sign-in, so someone holding an old session can’t do it.
• Only the people who need to can reach our systems.

No system is perfectly secure. If a breach puts your information at risk, we’ll tell you and the authorities as the law requires.

13. Our websites

eatsurplus.com and help.eatsurplus.com don’t use cookies, analytics or tracking. When the help centre is opened from inside the app, your browser remembers that for the visit only, so it can hide the website’s own header. Nothing leaves your device.

Cloudflare, which hosts the websites, handles your IP address and the details of each request to show you the pages and to protect the sites from attack. It may set a strictly necessary security cookie if it needs to block an attack.

14. Changes to this policy

If we change this policy in a way that matters, we’ll tell you in the app or by email before the change takes effect. The date at the top shows when it last changed. Ask us if you’d like an earlier version.

15. Contact us

Email: [email protected]

Post: Forge Wealth Group Ltd, 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom