Holt Privacy Policy

Holt is a GLP-1 tracker made by Ace Studio Teknoloji Limited Şirketi (“we,” “us”). What you log in Holt is some of the most personal information you have — what you inject, when, what it did to you, what your body weighed that morning, and what your body looks like. This policy explains exactly what Holt records, where it goes, who can see it, and how you get rid of it. We’ve written it to be read, not skimmed past.

1. The Short Version

The rest of this page is the detail. This is the commitment behind it:

We never sell your data. Not your health entries, not your photos, not anything else — to anyone, ever.
We never share it for advertising. No targeted ads, no ad networks, no data brokers.
Nothing you log about your health reaches an analytics tool. Your shots, doses, side effects, weight, photos, and notes are not sent to any analytics, attribution, or marketing service. Those tools see that a screen was opened — never what was on it.
Only your meal photos go to an AI service, and only to estimate what you ate. Your progress photos never leave your account.
Apple Health stays under your control. Holt reads and writes only the categories you approve, and you can revoke either at any time in iOS Settings.
You can take it all with you, and you can delete it all. Export and deletion both live in the app, and deletion means deletion.

2. Who We Are, and What This Covers

Ace Studio Teknoloji Limited Şirketi is the data controller for the information described here. This policy covers the Holt iOS app and the Holt pages on acestudio.app.

This policy sits alongside our Terms of Use, which govern the app itself.

We are a software studio, not a healthcare provider, a pharmacy, or a clinic. We are not a covered entity or a business associate under HIPAA, and what you record in Holt is not protected health information in that sense. It is, however, health data under European and Turkish law — a special category that gets the strictest treatment — and we treat it that way regardless of where you live.

3. What Holt Records

Holt collects what it needs to be a useful record, and stops there.

What you enter

Injections. Medication, dose, date and time, and the injection site you rotate to.
How you felt. Side effects you log and any notes you write alongside them.
Body and activity. Weight and body measurements, water, calories, protein and fiber, steps, and workouts — whichever of these you choose to track or connect from Apple Health.
Photos. Meal photos and progress photos, covered in detail in the next section.

Your account

Holt signs you in with Apple or Google. With Apple, we receive an Apple user identifier and, if you choose to share them, your name and an email address — which can be a private relay address. With Google, we receive your Google account identifier, your email address and your name; we do not receive your profile photo or anything else from your Google account. We use these to create your account, show your name in the app, sync your data to your other devices, and get you back in if you reinstall. We never see your Apple or Google password.

Your subscription

Holt is free to download with an optional subscription. Apple handles the payment; we receive only the subscription status and purchase metadata needed to unlock features and help you when something goes wrong. Your card details never reach us.

Device and diagnostics

Device model, iOS version, app version, crash reports, and basic performance data — the things that tell us Holt broke before you have to. We also see an approximate region, derived from your App Store storefront and language settings. Holt does not collect precise location.

Reminders

If you turn on reminders, we store a push token for your device so the notification can be delivered. The notification itself is deliberately vague — it will not announce your medication on your lock screen.

When you write to us

Support emails, and whatever you include in them. If you send us health details to explain a problem, we treat them as health data.

4. Your Photos

Holt handles two kinds of photo, and it handles them differently. Please read this section even if you skip the rest.

Meal photos

When you photograph a meal, Holt sends that image to an AI service to estimate its nutrition, then saves the photo and the result to your account so your food log has something to show. How that works, and who receives the image, is set out in AI Processing and Providers below.

A meal photo often catches more than the plate — a room, a table, the people you’re eating with. Only the photo you take is sent, never anything else from your library, but it’s worth knowing what ’s in frame.

Progress photos

Progress photos are the most exposing thing in this app, and we treat them accordingly.

They are never sent to an AI provider. Not for analysis, not for estimation, not for anything. They are not processed by any third party.
They are never used to train any model — ours or anyone else’s.
They are visible to you alone. Holt has no sharing feature, no feed, and no community. Nobody else sees them unless you export one and share it yourself.
They are stored encrypted in your account, and access by our team is restricted and logged. We do not browse them.
You can delete any of them, at any time, individually or all at once.

Holt asks for access to your camera and photo library only when you use a feature that needs it, and it reads only the images you pick.

5. AI Processing and Providers

Holt’s meal analysis runs on AI infrastructure operated by Google (Gemini). To estimate what you ate, we send them the photo you took. That is the only AI processing in Holt, and the only data that leaves us for it.

What we send

The meal photo, and nothing else. No name, no email, no account identifier, no injection history, no weight, no progress photos, and nothing read from Apple Health. Google (Gemini) receives an image and returns an estimate; it has no idea whose meal it is.

What they may do with it

One thing: produce the estimate you asked for. Google (Gemini) is contractually barred from reusing your photo for its own purposes, and we never allow your data to be used to train third-party AI models. Any copy held for processing is temporary and deleted afterwards.

What the estimate is worth

It is an estimate produced by a model looking at a picture, not a measurement. It can be wrong, sometimes substantially. Please treat it as a rough guide — particularly if you are tracking protein on your clinician’s advice. Our Terms of Use say more about this.

6. Apple Health

Connecting Apple Health is optional, and Holt asks before it touches anything. Permission is granted per category, separately for reading and writing, and iOS shows you exactly what you’ve allowed.

Reading. So your weight, intake and activity appear next to your injection history without you typing them twice. Holt reads body mass, water, dietary energy, protein and fiber, steps, and workouts with their active energy and distance. What other apps record there — the last 30 days when you connect, then as it arrives, including while Holt is closed — is saved to your Holt account so it counts toward your day. If an entry is deleted in Apple Health, Holt deletes its copy too.
Writing. So what you log in Holt shows up in Apple Health too, and Health stays the one place your body data lives. Holt writes back the entries you make — weight, water, steps, workouts and their active energy, and the calories, protein and fiber from your food log — and only into the categories you’ve approved.
Revocable at any time. In Settings → Privacy & Security → Health → Holt, or in the Health app: your profile picture → Apps → Holt. Revoking takes effect immediately. Anything Holt already wrote stays in Apple Health under your control and can be deleted there; anything Holt imported can be deleted in Holt.
Never sent onward. Data read from Apple Health stays between your device and your Holt account. It is never sent to our AI providers, never used for advertising or marketing, never sold, and never disclosed to data brokers — as Apple’s rules require and as we would do anyway.

7. What We Never Do With Your Health Data

This section exists because in this category it is the question that actually matters.

We do not sell it. Under any definition, including the broad ones in US state privacy laws.
We do not share it for targeted advertising or cross-context behavioural advertising, and we do not give it to data brokers.
We do not send it to analytics or marketing tools. Your injection log, doses, side effects, weight, measurements, intake, photos, and notes are never passed to the services listed in Services We Rely On. Those services receive product events — a screen was viewed, a feature was used, the app crashed — with no health content attached.
We do not use it to train AI models, ours or anyone else’s. The only thing that reaches an AI provider is a meal photo, sent to answer one question and not retained.
We do not use it to make automated decisions about you that produce legal or similarly significant effects, and we do not profile you for anyone else’s benefit.
We do not hand it to your employer, insurer, or anyone else without your instruction, unless the law genuinely requires it — and where we’re permitted to tell you, we will.

8. Why We’re Allowed to Process It

If you’re in the UK, the EEA, or Türkiye, the law requires us to name a basis for each use.

Your health data: explicit consent. Health data is a special category under Article 9 GDPR and Article 6 of Türkiye’s KVKK. We process yours on the basis of the explicit consent you give when you start logging. You can withdraw it at any time by deleting your data or your account — see Your Choices and Control. Withdrawing doesn’t undo processing that already happened lawfully.
Your photos and the AI analysis: explicit consent. Holt asks for camera and library access before it takes a photo, and sending a meal photo for analysis is something you choose to do each time.
Your account and subscription: performance of a contract. We can’t give you an account, sync, or paid features without processing this.
Crash reports, diagnostics, and security: legitimate interests. Keeping Holt working and protecting it from abuse. We’ve weighed this against your privacy and kept the data minimal and health-free.
Tax, accounting, and lawful requests: legal obligation.

9. Where It Lives, and For How Long

Your entries and photos are stored in your account so they survive a lost phone and follow you to a new one. They’re encrypted in transit and at rest, and access is limited to the few people who need it to run the service.

We keep things only as long as they have a reason to exist:

Your health entries and photos — until you delete them, or until you delete your account.
Your account. When you delete it, we delete your data — every entry, every photo, everything attached to the account — within 30 days, backups included. It is not recoverable afterwards.
Crash and performance logs — up to 90 days, then deleted or reduced to aggregates that can’t be traced back to you.
Subscription and billing records — for as long as tax and accounting law requires us to keep them. This is the one category we cannot delete on request, and it contains no health data.
Support conversations — up to 24 months, so we have context if you write again.

10. Services We Rely On

A small, deliberate set of providers, each doing one job. Apart from Google (Gemini), named in section 5, which receives meal photos and nothing else, none of them receives your health data.

Apple — Sign in with Apple, App Store purchases, push notifications, and Apple Health on your device.
Google — Sign in with Google, if you choose it.
Google Firebase — account and data storage, plus Crashlytics for crash reporting and Analytics for non-health product events.
RevenueCat — subscription status and entitlements.
Amplitude — non-health product analytics: which features get used, where people get stuck.
OneSignal — delivering the reminders and notifications you’ve opted into.
Meta (Facebook SDK) — measuring which of our campaigns brought people to Holt. It receives app install and non-health product events only.
Google (Gemini) — estimating nutrition from meal photos, as described in section 5.

Each acts as our processor under a contract that limits them to what we’ve asked for. They cannot use your data for their own purposes.

We may also disclose data where the law requires it, or to protect people’s safety and our rights. If Holt is ever part of a merger or acquisition, your data may transfer with it — and this policy, or one at least as protective, will continue to apply.

11. International Transfers

We’re based in Türkiye and our providers operate in Europe and the United States, so your data may be processed outside your country. Where that happens we rely on the safeguards the law provides — Standard Contractual Clauses for transfers out of the UK and EEA, and the transfer mechanisms in Article 9 of the KVKK for transfers out of Türkiye.

12. Security

Data is encrypted in transit and at rest. Access to production systems is limited, authenticated, and logged. We keep the amount of health data flowing through our own systems as small as the product allows, because data you never hold is data you can never lose.

No system is perfectly secure, and we won’t pretend otherwise. If a breach ever affects your data, we will notify you and the relevant authority within the timeframes the law sets.

13. Your Choices and Control

Most of this is in the app, not in an email queue:

Export everything. Take a full copy of your data with you whenever you want.
Delete anything. Remove a single entry or photo, or all of them.
Delete your account. “Delete Account” in settings removes your account and everything attached to it within 30 days. It is not reversible, and it is not a hidden menu item.
Revoke Apple Health access — reading, writing, or both — at any time in iOS Settings.
Revoke camera and photo access in iOS Settings. The AI analysis only runs on photos you actively choose to send.
Turn reminders off in Holt or in iOS Settings.
Stop everything by deleting the app — though if you want your stored data gone, delete your account first.

If you’d rather we did it, write to support@acestudio.app and we will.

14. Your Rights

Depending on where you live, you have the right to access your data, correct it, delete it, take a portable copy, object to or restrict certain processing, and withdraw consent. In the UK and EEA these come from the GDPR; in Türkiye from Article 11 of the KVKK; in California and other US states from state privacy laws, which also give you the right not to be discriminated against for exercising them.

To exercise any of them, email support@acestudio.app. We may need to verify that the account is yours. We’ll respond within 30 days — or sooner where the law says so — and we don’t charge for it unless a request is repetitive or excessive.

If we turn a request down, we’ll tell you why, and you can appeal by replying to that answer. You can also complain to your data protection authority: in Türkiye the Kişisel Verileri Koruma Kurumu (KVKK), in the EEA or UK your national supervisory authority, and in the US your state Attorney General.

15. Children

Holt is for adults. It isn’t intended for anyone under 18, and we don’t knowingly collect their data. If we find out we have, we’ll delete it right away — and if you believe a minor has given us information, tell us at support@acestudio.app.

16. Changes to This Policy

We’ll update this page when our practices change, and the “Last updated” date at the top will always tell you when. If a change materially affects how we handle your health data, we’ll tell you in the app before it takes effect — and where the law requires consent for it, we’ll ask.

17. Contact

Questions about any of this? We’d rather you asked.

Ace Studio Teknoloji Limited Şirketi
Email: support@acestudio.app