Privacy Policy
Effective date: 15 October 2026
Servicios-Fuente Moderna S.L., Pl. de Carlos Trías Bertrán, 4, 28020 Madrid, España, operates the Secure Clean app and the website theinstictdietbook.com. For everything described below the company is the data controller. Questions about this notice go to contact@theinstictdietbook.com.
1. What this notice covers
This notice explains which personal data we collect when you visit theinstictdietbook.com, buy a subscription or use the Secure Clean app, why we collect it, how long we keep it and which rights you have. It does not cover websites or services of other companies that we link to, such as the Apple App Store or our payment provider; each of them has its own notice.
We apply Regulation (EU) 2016/679 (GDPR), the Spanish Organic Law 3/2018 on Personal Data Protection and, for visitors from the United Kingdom, the UK GDPR. Where local consumer or privacy law gives you more protection than this notice, the law wins.
The app itself does not use cookies, advertising identifiers or any form of cross-app tracking. Cookies exist only on the website and are described in the Cookie Policy.
2. Data we collect
We collect data in these situations.
- When you buy a subscription on the website. Name, email address, country, the plan you chose, the amount paid, the date of payment and the transaction reference returned by the payment provider. We never see or store your full card number.
- When you use the app. The email you sign in with. Any technical data the app itself sends is listed in its privacy label on the App Store page.
- When you use a form on this website. The contents of the contact, sign-in or plan request form: name, email, chosen plan and your message. Form submissions are delivered to our team mailbox by an email service provider.
- In your browser. Two local-storage entries: your answer to the cookie banner and the email you entered in the sign-in form. They stay on your device and are not sent to us.
- When you write to us. Whatever you put in the message, plus your email address so that we can answer.
Photos, screenshots, contacts and metadata are read by the app only on your device, with the permissions you grant in iOS. The app compares them, groups them and shows the result to you. None of this content, and no thumbnails or hashes of it, is sent to our servers. If you revoke a permission in Settings, the related feature stops working and nothing else changes.
3. Payment information
Payments are made on a page of a licensed payment service provider, reached through the payment link we email you. Card details are typed into a form that belongs to that provider and travel straight to it. We receive only a confirmation that the payment succeeded, the last four digits of the card, the card brand and a token that lets the provider charge renewals. The provider is an independent controller for the card data and publishes its own privacy notice at checkout.
4. Why we use the data and on which legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Create your account, deliver Premium features, send the welcome email with your password | Name, email, plan, payment confirmation | Performance of a contract (Art. 6(1)(b) GDPR) |
| Charge renewals, issue invoices, handle refunds and chargebacks | Email, plan, amount, transaction reference, card token held by the provider | Contract and legal obligations (Art. 6(1)(b) and (c)) |
| Answer support requests | Email, message content | Contract; legitimate interest in resolving problems (Art. 6(1)(f)) |
| Keep accounting records for the tax authority | Invoice data | Legal obligation (Art. 6(1)(c)) |
| Answer plan requests and send payment links | Email, chosen plan | Steps at your request before a contract (Art. 6(1)(b)) |
We do not make decisions about you by automated means that have legal or similarly significant effects, and we do not build interest profiles for advertising.
5. Who receives the data
We share personal data only with companies that help us run the service, and only the part they need:
- the payment service provider, for charging and refunds;
- our website hosting provider;
- the email service provider that delivers website form submissions to our team mailbox and carries our replies;
- advisers such as accountants or lawyers, when a specific case requires it;
- public authorities, when a law or a court order obliges us.
Each provider is bound by a data processing agreement under Art. 28 GDPR. We never sell personal data and never hand it to data brokers.
6. Marketing
We do not send marketing emails unless you ask for them. The website does not use advertising cookies or tracking pixels.
7. Your rights
Under the GDPR you may ask us, free of charge, to:
- confirm whether we process your data and give you a copy (access);
- correct inaccurate or incomplete data (rectification);
- delete data we no longer need, or that we processed on the basis of consent you have withdrawn (erasure);
- limit processing while a dispute about accuracy or lawfulness is resolved (restriction);
- receive the data you gave us in a machine-readable format (portability);
- object to processing based on legitimate interest, including any direct marketing (objection);
- withdraw consent at any time, without affecting what was done before.
Write to contact@theinstictdietbook.com from the email address linked to your account, or send a letter to Pl. de Carlos Trías Bertrán, 4, 28020 Madrid, España. We answer within one month; for complex requests the period may be extended by two further months, and we will tell you if that happens. If you are not satisfied, you can complain to the Agencia Española de Protección de Datos (aepd.es) or to the supervisory authority of the country where you live.
8. Cookies and browser storage
The website uses no analytics or advertising cookies. It keeps two local-storage entries that are needed for the banner and the sign-in form. They are listed in the Cookie Policy.
9. Transfers outside the EEA
Some of our service providers, including the email service provider that handles form submissions, may process data outside the European Economic Area. Where that happens we rely on an adequacy decision of the European Commission or on Standard Contractual Clauses with additional safeguards. A copy of the relevant safeguards can be requested at the contact address.
10. How long we keep data
- Account data: for as long as the account exists and for 12 months after the last subscription ends, so that you can restore access or request a refund.
- Invoices and payment records: 6 years, as required by Spanish commercial and tax law.
- Support correspondence and form submissions: 24 months after the last message.
- Browser storage entries: until you clear them or press Sign out.
When a period ends the data is deleted or anonymised.
11. Security
Connections to theinstictdietbook.com are encrypted with HTTPS. Access to customer records is limited to staff who need it for their work. Photos you move to Secret Folders stay on your device behind the PIN you choose.
If a breach is likely to put your rights at risk we will inform you and the supervisory authority within the deadlines of Art. 33 and 34 GDPR.
12. Children
The website and the app are intended for people aged 16 and older. We do not knowingly collect data from younger children. If you believe a child has created an account, contact us and we will delete it.
13. Changes to this notice
We may update this notice when the service or the law changes. The date at the top shows the current version. For material changes we send an email to account holders at least 14 days before the new version applies.
14. Contact
Servicios-Fuente Moderna S.L.
Pl. de Carlos Trías Bertrán, 4, 28020 Madrid, España
Email: contact@theinstictdietbook.com