Our privacy policy SAFE FOOD ADVOCACY EUROPE (SAFE) is committed to protecting your personal data and to ensuring full compliance with data protection laws, including the EU General Data Protection Regulation (GDPR). Please find below the most important information on the measures we take to protect your personal data and privacy Data collection and use
SAFE collects personal information you provide to deliver bimonthly information newsletters mainly to SAFE`s members and information on campaigns (called hereinafter the Service). The data are collected based on SAFE’s legitimate interests to keep you updated of the SAFE’s activities. The personal information collected could be used to contact you via email, telephone or mail to keep you updated on SAFE campaigns, events, working groups, etc.
Storing data All personal data held by us is securely stored and treated confidentially. Sharing personal data with third parties We do not disclose your personal data to any third parties, except in the specific instances described above in the context of campaign actions.
Service Providers
SAFE may employ third-party companies and individuals due to the following reasons:
· To facilitate our Service;
· To provide the Service on our behalf;
· To perform Service-related services; or
· To assist us in analysing how our Service is used.
These service providers include: Microsoft, Mailchimp, Dropbox etc. We only choose third-party companies that are GDPR compliant. Please note that links to other websites are not governed by this privacy notice
Campaign actions We occasionally run campaign actions which require the user to submit their name, email address and countries information, if they wish to support the action. This data will only be used in the context of the action ie. to update you on its progress, and will be deleted at the latest by two months after the action is complete. Access to your personal information You are entitled to access and request the deletion of any of your personal information that we may hold. Please send any such request to communication@safefoodadvocacy.eu
Privacy Policy – BiteWatch
Effective Date: June 16, 2025
BiteWatch is an app that has been developed by Lizard Global by request of and through an agreement with Safe Food Advocacy Europe. BiteWatch was created as part of a project called Preventia, financed by the European Union in the framework of the EU4Health programme, to improve health literacy and help consumers make better informed and more nutritious choices when it comes to food.
As BiteWatch, we respect your privacy and are committed to protecting your personal data. This policy outlines what data we collect, how we use it, and your rights under EU Law, to ensure lawful, fair and a transparent privacy protection.
1. Definitions
BiteWatch: The Apps Name, henceforth the “App”.
Responsible Legal Entity: Safe Food Advocacy Europe, henceforth “SAFE”, an Non-Governmental Organisation representing consumers’ interests in the EU.
The Developer: “Lizard Global”, software development professionals. Will be referred to as “The Developer”.
General Data Protection Regulation: Henceforth, the “GDPR”.
Personal Data: Personal data corresponds to the definition in Art. 4(1) of the GDPR. Will simply be referred to as “Personal Data”.
Anonymised Data: Anonymized (usage) data refers to information about how users interact with the app where all personally identifiable information has been removed or transformed so that individual users cannot be identified, in line with Recital 26 of the GDPR. When data is anonymised, it is not personal data anymore and does not fall under the scope of the GDPR. Will simply be referred to as “Anonymised Data”.
Any other term which has not been defined, will have the meaning as attributed by the GDPR.
2. Do we collect Personal Data? No.
The App is designed to be used without creating an account or submitting personal information. Nor SAFE or The Developer will collect, store, or process any personally identifiable information (PII). Your personal data will thus not be collected.
3. We use Anonymous Analytics.
To improve the functionality and user experience of the App, The Developer uses the following analytics tools:
These tools collect anonymized usage data, such as:
- App interaction and screen views
- Device model, OS version, crash reports
- General location (e.g., country, not GPS)
The anonymised data is used solely to understand usage patterns, improve features, and monitor performance while respecting user privacy and regulatory requirements. For example, identifiers like IP addresses or device IDs are either excluded or anonymized, and the data is often aggregated to prevent tracing back to any individual user. The data will be anonymized as it is collected.
In other words, the data used for analytical tools is not linked to any individual and cannot be used to identify you.
4. What is our Legal Basis for Data Processing ?
The anonymisation required under point 3 constitutes a form of processing, known as “further processing”. The “further processing” is legally justified under Legitimate Interest, as it is reasonably necessary to ensure the functionality of the App and these interests do not outweigh yours or your fundamental rights. The legal basis is found in Art. 6(f) of the GDPR.
5. Limited Third-Party Data Handling.
There is no personal data being shared with third parties. The analytics services mentioned above can process anonymised data on the behalf of The Developer under strict confidentiality and data processing agreements as entered into by The Developer, and Google Analytics and UXCam respectively.
6. Your Rights.
Since no personal data is collected, most GDPR rights (e.g., access, correction, deletion) are not applicable. However, you always have the right to:
Opt out of analytics tracking via your device settings and object the “further processing”;
To lodge a complaint with a supervisory authority in line with Art.77 of the GDPR;
Contact us with questions about data protection or this policy (See point 10).
Before the anonymisation proceeded to for the analytical tools in Point 3, underlining how limited the data collected is, as well as the storage and the processing thereof, you have the following rights as ensured by the GDPR:
The right to access – You have the right to request the App for copies of your (limited) personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that the App corrects any information you believe is inaccurate. You also have the right to request the App to complete the information you believe is incomplete.
The right to erasure – You have the right to request that the App erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that the App restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to the App processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that the App transfer the data that we have collected to another organization, or directly to you, under certain conditions.
7. Data Security.
Appropriate and reasonable technical and organisational security measures designed to protect the security of all information collected have been implemented.
8. Changes to This Policy.
Changes to the policy will be communicated to you via the app.
9. Contact Us.
For questions or concerns about this policy or your rights, please do not hesitate to contact SAFE at:
Email: info@safefoodadvocacy.eu
Disclaimer: The App does not expose users to harmful or inappropriate content and services. Are excluded in any shape or form from the App any content or services related to child endangerment, financial services, Real-Money Gambling, Games, and Contests and Blockchain-based Content. The App does not contain misleading health claims that contradict existing medical consensus, or can cause harm to users. The App is a safe and respectful platform. The App complies with the applicable Intellectual Property Legal Regime.
Terms and Conditions (European Union)
PLEASE READ THE FOLLOWING:
Before using the App, each User must read the following Terms and Conditions (hereinafter, the “Terms and Conditions”) and the Privacy Policy, which form an integral part of the Terms and Conditions.
Your use of BiteWatch App indicates your acceptance of these Terms and Conditions in their entirety.
Please note that these Terms and Conditions may be revised without notice at any time.
Your continued use of the BiteWatch App will be deemed as irrevocable acceptance of any revisions.
The Terms and Conditions apply to Users in the European Union.
1. Definitions
The following definitions are used in the Terms and Conditions:
App: the BiteWatch App, henceforth “App”,and all its pages and screens.
Personal Data: Personal data corresponds to the definition in Art. 4(1) of the General Data Protection Regulation (GDPR). Will simply be referred to as “Personal Data”.
Database: the Open Food Facts database of food Products on the App.
Products: the food products referenced in the Database on the App.
Matching score: score developed by Open Food Facts providing an indicative information of the compatibility of the product with the selected User’s preferences.
User: the user of the App.
2. How the App works
2.1. Objective of the App
The BiteWatch app provides an orientation response to users who wish to have more information about the food products they consume, with specific reference to the composition and presence of additives.
In particular, BiteWatch provides details on the amounts of sugar, salt and saturated fat contained in products, as well as information on any additives they may include. In addition, the App indicates whether the product is vegan or vegetarian and, via the NOVA system, offers an indication of the degree of processing or transformation the product has undergone.
The use of BiteWatch makes it possible to obtain useful information to make informed and conscious purchasing choices, but it should be made clear that the mere use of the App does not ensure an improvement in the user’s health status, as general well-being is influenced by multiple factors. These include not only the quantity and frequency of product consumption, but also overall lifestyle factors, such as a balanced diet, regular physical activity, and the absence of issues related to stress, illness, addiction and environmental pollution.
The App is independent and is not influenced by the industry.
The BiteWatch app was created as part of a project called Preventia, financed by the European Union in the framework of the EU4Health programme, to improve health literacy and help consumers make better informed and more nutritious choices when it comes to food.
2.2. Levels of sugar/salt/saturated fat method and additives evaluation
The levels of sugar/salt/saturated fat for food products (high/moderate/low) used by the App are assessed according to the maximum daily intake recommended by the World Health Organization (WHO). Three levels have been defined: high (red), moderate (orange), low (green). A product’s sugar, salt, or saturated fat content alone does not determine its overall healthfulness or environmental impact. These elements must be considered alongside other factors, especially the amount and frequency of consumption, as well as the individual’s lifestyle and surrounding conditions.
Additives risk levels (potential risk/moderate potential risk/low potential risk) evaluation are indicative and based on scientific sources. Three levels have been defined: potential risk (red), moderate potential risk (orange), low potential risk (green). The additive evaluation method used by BiteWatch is independent and expresses the potential risk linked to the consumption of additives, drawing inspiration from the scientific studies indicated and leaving aside an assessment of the actual risk linked to the intake of the selected product. This evaluation method has not been approved by any health authority, nor is it intended to overlap with the concrete risk assessments of the use of the additive in the product as expressed by such authorities. The terms ‘potential risk’, ‘moderate potential risk’ and ‘low potential risk’ solely express BiteWatch’s opinion on the additive under evaluation, based on the scientific sources analysed and mentioned on the App. The terms do not refer to the selected product as such, nor to its intrinsic qualities.
The App does not provide medical advice and is not a substitute for consultation with healthcare professionals, including dietitians or doctors. The User must not rely on the App for medical purposes and must never ignore or postpone seeking medical attention because of information found within the App.
2.3. Matching score
Based on the information provided by the User through the completion of the “preferences” section, indicating the areas of greatest interest, the matching score aims to provide – through a percentage-based calculation – an indicative information of the compatibility of the product with those areas of interest. The matching score is calculated using data provided by Open Food Facts, an independent and publicly available food database. Open Food Facts has not published official technical documentation on its calculation methods. Based on available information, the score is determined by comparing the importance of levels assigned by the user to specific nutrients or labels with the corresponding data for each product.
The indicative information provided is not a substitute for the consumer’s own judgement, who, being aware of their overall eating habits and lifestyle, can opt for the optimal choice for him or herself.
The matching score is determined in a totally neutral and objective way.
3. Evaluation of the risks of ingredients and additives contained in the Products
BiteWatch does not warrant the completeness, relevance or accuracy of the risk assessments related to the ingredients and additives contained in the Products.
The App does not present itself as a scientific authority. It provides opinions on the potential risks of ingredients and additives based on its review of independent scientific studies from recognised institutions.
Any written notification about the BiteWatch app can be sent by email to the contact email: bitewatch@safefoodadvocacy.eu
