LyoLog privacy policy
Version 1.3 · In force from 29 October 2026 Published at lyolog.app/privacy
This policy explains what personal data we process when you use the LyoLog app and the lyolog.app website, what we use it for, who we share it with, how long we keep it, and what you can require of us.
It is written to be understood. If anything is unclear, email support@lyolog.app and we’ll explain.
1. Who the controller is
| Data controller | Jan Panek |
| Tax identification number (NIF) | Y2362080V |
| Address | Rotonda de Versalles 23, 28512 Villar del Olmo, Madrid, Spain |
| Privacy contact | support@lyolog.app |
| Application | LyoLog |
LyoLog and Freeze-drying.tech are trading names of Jan Panek, a natural person. They are not separate companies. On Google Play the LyoLog app is published under the developer name Freeze-drying.tech.
We are not required to appoint a data protection officer under Article 37 GDPR or Article 34 of the Spanish LOPDGDD. Any privacy question can go to the address above.
2. What LyoLog is, and what it isn’t
LyoLog is an application for logging and optimising freeze-drying cycles: batches, tray weights, cycle stages, recipes, costs and photographs of the product.
It is not a medical or pharmaceutical product. It processes no health data. It does not operate in a GMP environment. It makes no automated decisions producing legal effects or similarly significantly affecting you. The estimates it produces are indicative; the full statement of what that means is in the Terms of Use and Subscription.
3. What we process, why, and on what legal basis
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Identity: email address, name | Create and run your account | Performance of the contract (Art. 6(1)(b) GDPR) | Life of the account; erased within 30 days of closure |
| Authentication: hashed password, your Google identifier if you sign in with Google, session tokens. If you sign in with Apple: your Apple user identifier, the email address Apple shares with us (an Apple relay address if you choose Hide My Email), and your name if you choose to share it; Apple sends the name only the first time you sign in. We also keep the refresh token Apple issues for your sign-in, for one purpose only: to revoke it at Apple when you delete your account. It is stored on our server and is not used for anything else. | Verify that it’s you | Performance of the contract | Life of the account |
| Preferences: country and city (free text), language, unit system, date format, currency | Adapt the interface and the calculations | Performance of the contract | Life of the account |
| Operational records: machines, batches, weights, stage durations, recipes, product categories, costs, quality scores | Deliver the core service | Performance of the contract | Life of the account; erased within 30 days |
| Recipes you share by link or PDF: the recipe content you choose to share; link code; creation and deactivation dates; total view and import counts, which do not identify visitors | Get the recipe to the people you choose | Performance of the contract, at your request. If you include another person’s data, legitimate interest (Art. 6(1)(f)) in providing the feature you asked for | Life of the account; erased within 30 days |
| Photographs of product, trays and machines | Attach a visual record to a batch or a machine | Performance of the contract; legitimate interest (Art. 6(1)(f)) as regards anyone incidentally in frame | Life of the account; erased within 30 days |
| Acceptance records: document version, content hash, archived text, language, platform, app version, timestamp | Evidence what you accepted and when | Accountability (Arts. 5(2) and 7(1) GDPR) | 5 years after closure, detached from your identity |
| Organisation membership: organisation, role, invitation status, visibility setting | Operate a shared workspace | Performance of the contract | Life of the account |
| Subscription: store subscriber identifier, plan, status, renewal date | Grant and manage paid access | Performance of the contract | Life of the account |
| Billing for direct business sales: company name, VAT number, address, amount | Issue invoices, meet accounting and tax obligations | Legal obligation (Art. 6(1)(c)) | 6 years from the end of the financial year |
| Transactional email: address and delivery status | Account verification, password reset, invitations, and communications about reports | Performance of the contract; for communications about reports, legal obligation (Art. 6(1)(c)) | 30 days of delivery logs at our email provider |
| Security: IP address, timestamp, user agent, request metadata | Protect the service against unauthorised access and abuse | Legitimate interest (Art. 6(1)(f)) | 7 days on our current hosting plan. We keep no separate long-term log |
| Bot protection on website forms: technical information about your browser and connection (IP address, TLS fingerprint, user agent) that Cloudflare Turnstile reads while a form page is open; and your IP address, to limit how often the form can be sent | Tell people apart from automated abuse of the form | Legitimate interest (Art. 6(1)(f)) in keeping the form usable and free of spam | Turnstile returns only a pass or a fail to us, and we keep nothing else. The sending limit uses your IP address to count the sends of one minute and does not store it. Cloudflare’s own use of these signals is explained in section 4 and in its Turnstile Privacy Addendum |
| Support and feedback: what you write to us by email, through the feedback form at lyolog.app/feedback or from inside the app; the type of message; your email address if you give one (in the app, your account email, only if you ask for a reply); the details sent with it (app version, device model and operating system, and the app screen you were on), which you can see, change or remove before sending; a screenshot, if you attach one in the app; a reference code | Answer you, fix problems, decide what to improve and, where needed, defend claims | Performance of the contract, if you have an account; legitimate interest (Art. 6(1)(f)) in hearing from people who use or are considering LyoLog, if you write without one | 3 years from closure of the matter. If you delete your account, feedback sent from it is deleted with it; the copy that reached our mailbox is kept as support correspondence (section 6) |
| Reports of shared recipes: from the reporter, name, email address, reported link, reason and good-faith statement; from the person who shared the recipe, the reported content, the decision and its reasons | Handle the report and communicate the decision | Legal obligation (Art. 6(1)(c)), under Arts. 16 and 17 of the Digital Services Act (Regulation (EU) 2022/2065). After the decision, legitimate interest (Art. 6(1)(f)) in defending possible claims | 3 years from the decision |
| Website analytics, only if you accept them: pseudonymous identifiers kept in cookies, pages visited, time on page, clicks and scrolling, device and browser type, approximate location (country or region), how you arrived at the site; with Microsoft Clarity, a replay of how you moved through a page, with anything typed into forms masked. Microsoft also uses what Clarity collects for its own purposes — see section 4 | Understand how the website is used and improve it | Consent (Art. 6(1)(a) GDPR and Art. 22.2 LSSI-CE). You can withdraw it at any time under Cookie settings | Google Analytics: 2 months. Microsoft Clarity: session recordings 30 days, heatmaps 13 months |
| Visit counts without cookies: pages viewed, referring site, country and browser type, in aggregate | Know how many people visit the website | Legitimate interest (Art. 6(1)(f)) | Aggregate figures only; no identifier is stored on your device or kept about you |
| iPhone waiting list: email address, language and date of sign-up | Send you one message when LyoLog is available on the App Store | Consent (Art. 6(1)(a)), which you give by joining the list | Until that message is sent, then deleted; in any case no more than 24 months after sign-up. You can ask us to remove you at any time |
What we do not process
- No special categories of data (Art. 9 GDPR): no health, biometric, ideological, religious or trade-union data.
- No GPS location. Country and city are free-text fields you fill in. Photographs are re-encoded on your device before upload, so the camera’s EXIF metadata, including location, is not transmitted: what is sent is a new image without it.
- No usage analytics in the app. The app contains no product-analytics tooling and sends no usage events to anyone. On the website, analytics runs only if you accept it: see the Cookie Policy.
- No advertising. We do not sell or share your data for advertising and we do not track you across apps or websites for advertising. We tell Microsoft Clarity that you have not consented to advertising use.
- No profiling with legal effects and no automated decision-making within the meaning of Art. 22 GDPR.
- No server-sent notifications. End-of-stage alerts are scheduled and displayed by the app on your own device; no push service and no third party is involved.
About photographs
Photographs are of product, trays and machines, not of people. Even so, a gloved hand or someone’s reflection may appear incidentally. We process that image on the basis of our legitimate interest, and yours, in keeping a record of your own production, in a private workspace and with minimal impact. We apply no facial recognition and no technique capable of identifying a person from an image.
Photograph your product, not people. If you upload an image of an identifiable person, it is for you to have their permission.
4. Who processes data on our behalf
We work with the providers below. Each acts as a processor under a contract meeting Article 28 GDPR and may only process your data on our instructions.
| Provider | Function | Where processing takes place |
|---|---|---|
| Supabase | Database, authentication, photo storage, server functions | AWS eu-central-1 (Frankfurt, Germany) — European Union |
| Resend | Delivery of transactional email: account verification, password reset, invitations, and communications about reports of shared recipes | Sent from Ireland (eu-west-1); message content and delivery logs are stored in the United States |
| Google Ireland Limited | The corporate email we answer you from; Google Analytics on the website, only if you accept analytics cookies | Ireland, with transfers to the United States |
| RevenueCat | Management of paid access entitlements, when you activate a subscription | United States |
| Cloudflare | DNS, content delivery and hosting of the website; tag management for website analytics (Zaraz); visit counting without cookies (Web Analytics); the iPhone waiting list; the register of reports of shared recipes; bot protection on the website’s forms (Turnstile); delivery to our own mailbox of a notice of each feedback message and of each report (Email Service) | Global; the waiting list and the register of reports are stored in the European Union |
The current list of processors is at lyolog.app/subprocessors.
People you give the link to. If you share a recipe, anyone with the link can see it, and whoever imports it gets their own copy. You choose those recipients; they are not our processors. Messaging apps and social networks where you paste the link, such as WhatsApp or LinkedIn, read the page to generate the preview.
Reports. We do not tell the person who shared the recipe who reported it, unless that is strictly necessary to assess the report, for example where the reporter claims their intellectual property rights are infringed.
Apple and Google, when you sign in with them or buy in their store
Apple and Google do not process this data on our instructions but as independent controllers, within your own relationship with them. They are involved only if you choose to sign in with their account or buy your subscription in their store.
| Third party | What it does | Where | Basis |
|---|---|---|---|
| Apple Distribution International Limited | Sign in with Apple, if you choose it; sale and collection of App Store subscriptions, as seller | Ireland, with transfers to the United States made by Apple | Apple processes this data as an independent controller, under its own privacy policy. When you sign in, we receive from Apple only an identifier and the email you choose to share, which may be an Apple relay address |
| Google Ireland Limited | Sign in with Google, if you choose it | Ireland, with transfers to the United States | Google processes this data as an independent controller, under its own privacy policy |
| Google Commerce Limited | Sale and collection of Google Play subscriptions, as seller | Ireland, with transfers to the United States | Independent controller, under its own privacy policy |
One third party is not our processor: Microsoft
We are telling you this separately because it works differently from everything in the table above, and the difference matters to you.
| Third party | What it does | Where |
|---|---|---|
| Microsoft Ireland Operations Limited | Microsoft Clarity: session recordings and heatmaps of the website, only if you accept analytics cookies | Ireland, with onward transfers to the United States by Microsoft |
Microsoft does not process this data on our instructions. Under its own terms, you and Microsoft — and we and Microsoft — are independent controllers: Microsoft decides for itself what it does with the data Clarity collects, under the Microsoft Privacy Statement, and we cannot direct it.
That is why this only ever happens with your consent, why you can withdraw it at any time under Cookie settings, and why nothing is sent to Microsoft unless you have accepted.
Clarity runs on our public website pages only. It is never loaded on the LyoLog app, on the signed-in console, or on the sign-in page. Microsoft receives nothing about what you record in LyoLog.
Cloudflare’s own use of Turnstile signals
When a form on our website (feedback, or reports of shared recipes) checks that you are not a bot, Cloudflare acts as our processor. Cloudflare also uses the same signals (your IP address, TLS fingerprint and user agent) to improve Turnstile’s bot detection. For that purpose Cloudflare is an independent controller, relying on its own legitimate interest, under its Turnstile Privacy Addendum. Cloudflare states that it cannot identify you from these signals and does not use them to profile or target anyone. Turnstile is loaded only on the pages of our forms.
Your data may also be disclosed to: the tax authority and our accountant, in relation to invoicing; and to courts or competent authorities where we are legally obliged to do so.
We do not sell your data. We do not share it with third parties for advertising.
We require by contract that every processor with whom we share personal data — service providers, SDKs, and any affiliated entity with access to it — provides the same or equal protection of that data as this policy states. Outside that arrangement are Microsoft, described above, which receives website data only, with your consent, and never anything from the app; Cloudflare, only for its own use of Turnstile signals to improve bot detection, also described above; and Apple Distribution International Limited, Google Ireland Limited (for Google sign-in) and Google Commerce Limited, also described above.
5. International transfers
LyoLog’s core infrastructure is in the European Union: the database, photo storage and authentication are processed in Frankfurt.
Transfers outside the European Economic Area occur in these cases:
| Provider | Destination | Safeguard |
|---|---|---|
| Resend | United States. Email is sent from Ireland, but the message content and delivery logs are stored in the United States | Standard contractual clauses approved by the European Commission, incorporated into its data processing addendum, together with supplementary measures |
| Google Ireland Limited (corporate email and Google Analytics) | United States | A European Commission adequacy decision and/or standard contractual clauses, together with supplementary measures |
| Apple Distribution International Limited, Google Ireland Limited (sign-in) and Google Commerce Limited | They are involved only if you choose their sign-in or their store. Transfers to the United States are made by them | Each company’s own safeguards as an independent controller, described in its privacy policy |
| RevenueCat | United States | Standard contractual clauses approved by the European Commission, incorporated into its data processing addendum, together with supplementary measures |
| Microsoft (Clarity) | We disclose to Microsoft Ireland Operations Limited, inside the EEA. Microsoft then transfers to the United States within its own group | The onward transfer is Microsoft’s own, made under safeguards Microsoft puts in place as an independent controller, described in the Microsoft Privacy Statement. Our own disclosure to Microsoft rests on your consent |
| Cloudflare | Global | Standard contractual clauses, together with supplementary measures |
You can ask us for a copy of the safeguards in place at support@lyolog.app.
6. How long we keep data, and what happens when you close your account
You can delete your account at any time from More → Account → My Data → Delete my account, or by emailing support@lyolog.app if you have already uninstalled the app. Full instructions at lyolog.app/delete-account.
Deletion runs immediately in most cases, and in any event within 30 days at the latest. If you signed in with Apple, deleting your account also asks Apple to revoke that sign-in, and we then delete the stored token. If Apple cannot be reached at that moment, your account is still deleted and we retry for up to 30 days; after that, we delete the token in any case. You can also remove LyoLog yourself under Sign in with Apple in your Apple Account settings.
Deleted: your identity, preferences, machines, batches, weights, stages, recipes, costs and scores, photographs, session data and organisation membership.
Encrypted backups are overwritten on their normal cycle, well inside 90 days. Where you have an active subscription, we also request deletion from the provider that manages paid access entitlements.
What survives deletion, and in what form:
| What | How long | Why |
|---|---|---|
| A record that the account was deleted, containing only a cryptographic hash (SHA-256) of the identifier — not your email, not your identifier in the clear | 5 years | Evidence that erasure was carried out (Art. 5(2) GDPR) |
| The record of your acceptance of the legal documents, detached from your identity | 5 years | Evidence of consent (Arts. 5(2) and 7(1) GDPR) and defence of claims |
| The record of a redeemed promotional code, with the person field emptied | While the code remains valid | Counting redemptions, without keeping who made them |
| Invoices and accounting records for direct purchases | 6 years from the end of the financial year | Art. 30 of the Spanish Commercial Code and tax law |
| Support correspondence | 3 years from closure of the matter | Legitimate interest in defending claims |
The record of your purchase on Google Play or the App Store is held by that store, not by us.
Two situations where deletion is not automatic
We say this plainly because it affects a right of yours:
- You own an organisation that still has members. Deletion stops until you transfer the organisation to another member or dissolve it. The app tells you so and you can do it there and then.
- Your account is recorded as the author of shared service content — for example categories, products or templates shared with other users. Deletion then requires us to reassign that content manually.
In neither case is your request lost: we complete it within the 30-day period stated above and confirm when it is done. If you need help, email support@lyolog.app.
Shared recipes. When you delete your account, your links are switched off and your recipes are removed from the community section. Copies other users imported are independent, don’t identify you and stay in their accounts. Nor can we recall PDF cards you sent. None of this requires manual reassignment.
7. How we protect your data
Not boilerplate — this is what we actually do.
- Encryption in transit using TLS on all communication between the app, the website and our servers.
- Encryption at rest for the database and file storage, provided by Supabase’s infrastructure on AWS.
- Isolation between accounts through row-level security policies in the database: every query is restricted to the authenticated user’s data at the engine level, not only in the application. Photographs are stored in per-user paths under the same restriction.
- Passwords stored only as a cryptographic hash. We cannot see them or recover them.
- Administrative access limited to the operator and protected by two-factor authentication.
- Backups encrypted, with limited retention.
- Access and security logs are generated by our hosting providers as a by-product of running the service. On our current plans, Supabase keeps them for 7 days, and Cloudflare keeps the website’s request logs, which include your IP address, for 7 days; Cloudflare’s own network logs are governed by its privacy policy. We do not maintain a separate, long-term record of your activity.
- Processors selected for their guarantees, each under an Article 28 data processing agreement.
No system is invulnerable. If a security breach occurs that is likely to result in a high risk to your rights, we will tell you without undue delay, and will notify the Spanish Data Protection Agency within 72 hours where required.
8. Information stored on your device
The app uses no cookies. It does store information on your device:
| What | Why | Consent needed? |
|---|---|---|
| Your batches and working data, so the app works offline | This is the service you asked for | No — strictly necessary |
| Your signed-in session | Keep you authenticated | No — strictly necessary |
| Language, units, date format, currency | Remember what you chose | No — personalisation you chose, used for nothing else |
| The end-of-stage alerts you schedule | Show you the alert at the right moment | No — strictly necessary. They are scheduled and shown on the device and never leave it |
Article 5(3) of Directive 2002/58/EC and Article 22.2 LSSI-CE apply to native applications, not only to browsers. All the storage described above falls within the strictly-necessary exemption.
We install no analytics or advertising SDK, so there is nothing to accept or reject inside the app.
Website cookies are covered in the Cookie Policy.
9. Shared workspaces
LyoLog lets you share your work with an organisation. It is worth understanding exactly how this works, because it decides who sees what.
Your records are yours, not the organisation’s. The batches and machines you record are attached to your account, not to the organisation. If the organisation closes or you leave it, your batches and machines stay in your account exactly as before. The organisation does not keep them, because they were never its own.
The organisation gets visibility, not ownership. An administrator of an organisation you belong to can see the batches you record, if you have the corresponding visibility setting turned on. You can turn it off. The administrator can see whether you have turned it on.
Not visible to the administrator: your personal settings, and any records you created outside the organisation.
If you were invited. When an administrator enters your email address to invite you, we obtain it from that organisation and not from you. We tell you so in the invitation itself, as Article 14 GDPR requires. If you do not accept within 30 days the invitation expires and we delete your address.
If you own an organisation with members, you cannot delete your account until you transfer or dissolve it (section 6).
Our role. Under this model we remain the controller of your data in relation to you: our contract is with you, and it is you who controls the visibility of your records. The organisation decides for itself what it does with what it sees, and answers for that itself.
10. Your rights
You can exercise the following at any time:
| Right | What it means |
|---|---|
| Access | Know what data of yours we process and get a copy |
| Rectification | Correct inaccurate or incomplete data |
| Erasure | Have your data deleted, subject to the limits in section 6 |
| Restriction | Have us stop using it temporarily while a dispute is resolved |
| Portability | Receive your data in a structured, commonly used format. You can export it yourself from the app |
| Objection | Object to processing based on our legitimate interest |
| Withdraw consent | Withdraw consent to website analytics or to the iPhone waiting list at any time — under Cookie settings, or by writing to us — without affecting what was processed before |
How: email support@lyolog.app from the address linked to your account. We respond within one month, extendable by two further months for complex requests, in which case we’ll tell you. It is free of charge.
If you wrote to us through the feedback form without an account, quote the reference code you received (LL-…) or the email address you gave, so we can find your message.
If we cannot reliably identify you, we’ll ask for more information before acting.
Complaints. If you believe we have not handled your rights properly, you can complain to the Spanish Data Protection Agency, C/ Jorge Juan 6, 28001 Madrid — www.aepd.es. If you live in Portugal, to the CNPD (www.cnpd.pt); in any other Member State, to the supervisory authority where you are habitually resident.
11. Minimum age
LyoLog is a professional tool. You must be 18 or over to create an account.
We do not direct the service at children and do not knowingly collect children’s data. If we find that an account belongs to a minor we will delete it and its data. If you believe a child in your care has created an account, email support@lyolog.app.
12. Changes to this policy
Each amendment produces a complete new version, identified by its number and date of entry into force. We do not publish amendment annexes.
Where a change is substantial we will tell you inside the app and ask you to accept the new version before continuing to use the service. We keep the full text of every published version.
13. Language versions
This policy is published in Spanish, English and European Portuguese, with identical substance. Each version has equal force for the user addressed in that language. Where a discrepancy is alleged before a Spanish court, the Spanish version prevails.
Controller: Jan Panek · NIF Y2362080V · Rotonda de Versalles 23, 28512 Villar del Olmo, Madrid, Spain · support@lyolog.app
Version 1.3 — in force from 29 October 2026