Sugar Bye Privacy Policy
Revision prepared: 30 September 2026
1. Operator and contact details
The personal-data controller is IP Samokhin Konstantin Aleksandrovich (Individual Entrepreneur), Russia, operating as Sugar Bye.
- Russian taxpayer identification number (INN): 741706483691.
- Individual entrepreneur registration number (OGRNIP): 319784700098339.
- Correspondence address: 9B Antsiferovskaya Street, Pushkin, Saint Petersburg, 196602, Russia.
- Personal-data enquiries: ksamokhin@gmail.com.
- Support: @ksamokhinn, https://t.me/ksamokhinn.
This policy covers https://sugar-bye.com, the Telegram Mini App and @SugarByeBot, and the VK version of the service. It describes the operator's processing; platforms and providers also process data under their own terms.
2. Adult users and checking products for children
Accounts and the habit programme are intended for people 18 or older who have reached the age of majority under applicable law. Independent children's accounts are not offered.
The launch market is the United States. Before new label checks, plan creation or purchases, we record a versioned self-declaration of adulthood, agreement to the Terms and acknowledgement of this policy. We do not ask users to confirm their country. We store the account ID, declaration version and acceptance time, with marketing permission off. We do not collect a birth date, identity document or precise location for this declaration. It is not independent age verification. Previously recorded declarations remain valid for the retained age and document confirmations; their original version is preserved.
A parent or legal guardian may use their own adult account to check the ingredients of products they purchase for children. A child's name, birth date, photograph or medical information is not needed. Please do not submit this information.
A label-check result does not establish that a product is safe or suitable for an infant or child and does not replace individual professional advice. The habit programme is not intended to prescribe children's diets.
If you believe a minor has independently submitted data, contact ksamokhin@gmail.com so we can investigate and address access restrictions and deletion.
3. Information processed
- Account: internal identifier, Telegram or VK ID, available name and username, language, time zone, registration date, reminder preferences and VK messaging permission.
- Questionnaire: frequency of sweets and sweet drinks, product categories, craving situations, first habit selected and approach to change.
- Programme: generated plan, tasks, dates and completion records.
- Product checks: submitted image, thumbnail, technical image fingerprint for reusing results, product and brand names, readable ingredients, nutrition values, sugar estimates, explanations and product mass if entered.
- Payments: orders, Telegram Stars amount and currency, transaction identifiers, access periods and refund records. The service does not request or store full bank-card details.
- Support and bots: enquiry text, user and message identifiers, handling status, bot-contact and reminder-delivery events.
- Technical information: session and Mini App launch information, application events, error codes and request identifiers. Platforms and infrastructure providers may receive IP addresses and browser information when handling requests.
We do not request medical records, diagnoses, identity documents or precise geolocation to check labels. Your selected time zone controls the schedule rather than tracking your location.
4. Purposes and legal grounds
Information is used to authenticate and protect accounts; save and personalise the programme; check labels; manage allowances and access; provide reminders and support; handle payments and refunds; diagnose errors and prevent abuse.
Entering into and performing a contract may provide a basis for requested service features. Applicable legal obligations may provide a basis for mandatory records and lawful requests. Where consent is required for particular processing, it must be obtained separately; this policy does not itself constitute consent. The applicable grounds depend on the jurisdiction and data involved and must be confirmed before this revision is approved.
We do not sell personal data. Advertising messages are not currently planned. Communications are limited to service messages, support replies and reminders that users can disable.
5. AI processing
Label analysis sends an image, response language and analysis instructions to Google Gemini API. AI plan personalisation sends questionnaire answers, language and task structure. The code does not add your Telegram/VK ID, username or name to these AI requests. Personal information accidentally included in a photograph may nevertheless reach the provider: photograph packaging only, without faces or personal documents.
The operator has confirmed use of a paid Gemini project. Under the paid Gemini API terms, Google does not use prompts or responses to improve its products, but may retain them temporarily for security and legally required purposes. This is not a promise of zero retention by Google. Terms: https://ai.google.dev/gemini-api/terms.
The code also supports OpenAI as an alternative provider. Actual use and the corresponding processing description must be checked when production configuration changes; code support does not mean every provider receives data.
AI output may be wrong. It is informational, not a medical assessment or a decision about access to healthcare.
6. Recipients and access
The service uses:
- Telegram: authentication, bot messages, images, reminders and Stars payments.
- VK: authentication, community messages, images and reminders in the VK version.
- Vercel: website hosting and server-side request processing, including uploaded images.
- Supabase: profiles, questionnaires, plans, results and thumbnails, settings, payment and operational records.
- Google Gemini API: the processing described in section 5.
- Gmail: correspondence sent to the support email address.
On the operator's side, access is currently limited to IP Samokhin Konstantin Aleksandrovich. The bot may send the operator a new-user notification with the Telegram ID and available name/username, and a payment-support notification. These messages create separate copies in Telegram.
Before contractors receive access, their tasks, minimum necessary data, confidentiality obligations and processing arrangements must be established. Infrastructure providers may process data even though the operator has no staff with access.
7. Processing locations
The primary Supabase project database is in Ireland, region eu-west-1, verified in project settings on 30 September 2026. This does not mean all providers' data, logs and backups are stored only in Ireland.
Telegram, VK, Vercel, Google and the email provider may process data in other countries. The applicable agreements, processing locations and grounds for international transfers require separate verification.
The launch market is the United States, not worldwide. The operator remains registered in Russia; choosing the US market does not change the operator's location or the providers' processing locations. Applicable localisation, notification, international-transfer and provider-access requirements require separate assessment; this policy does not establish that those requirements have been fulfilled.
8. Retention and deletion
The current implementation works as follows:
- Original uploaded image: server code processes it in memory without saving a permanent original file. Images sent through a bot are also processed by that platform and the AI provider under their own rules.
- Thumbnails, results, questionnaires, tasks and progress: retained for history and programme continuity until account deletion. Ending the 30-day programme or paid access does not itself erase history.
- Profile deletion: after confirmation, questionnaires, plans, progress, scans and thumbnails, consent records, personal events, support requests and reminder history are removed from the active database. Reminders stop and old sessions lose access.
- Financial records: the selected operating schedule is five years after the end of the calendar year containing the latest payment, refund or resolution of the related dispute. Retain only the orders, receipts, refunds, payment audit and minimal closed-profile linkage needed for accounting and disputes. A documented legal obligation or unresolved claim may require a different period; the operator must review and document such exceptions.
- Closed profiles without financial records: the selected schedule is 90 days from account closure for preventing immediate account resurrection, followed by removal of the residual identifiers. Closure does not erase previously completed financial transactions.
- Operational events and reminder history: 90 days from the event, or earlier on account deletion where the deletion function covers them.
- Support correspondence: 12 months after case closure, unless a specific payment dispute or legal obligation requires preserving a minimal relevant extract under the financial-record schedule. Copies controlled by the operator in email and bot messages are included in this review.
- Archived photographs: an older stored original may require support assistance to coordinate removal of the file and database records.
- External copies: deleting the active database records does not automatically erase Telegram/VK/Gmail correspondence, operator notifications, logs, backups or AI-provider data. Their retention periods and removal procedures must be confirmed against provider settings and agreements.
Account deletion does not automatically issue a refund. Signing in again does not restore the deleted programme. Contact support about remaining data or refunds.
We do not promise deletion of all photographs and copies within 24 hours.
Scheduled expiration is an operator-managed procedure, not currently a fully automated deletion job. The operator must review expired records monthly and complete applicable cleanup within 30 days after the selected period ends. The original account-deletion function remains available separately. The selected schedule must be checked against applicable accounting and legal duties before financial records are destroyed. Provider-controlled backups, logs and AI records follow the providers' actual settings and terms; we cannot promise a uniform deletion deadline for those copies. Retention settings and deletion procedures for those copies remain part of the operational review.
9. Controls and requests
Profile controls let you change language and time zone, disable reminders, export data as JSON and confirm account deletion. Contact support if your embedded browser cannot download the export.
Depending on applicable law, you may request access, correction, a copy or deletion; request restrictions; object to processing; withdraw consent; and complain to a competent supervisory authority.
Email ksamokhin@gmail.com with your request and the account concerned. We may ask you to demonstrate control of that account. Do not send passwords, API keys or a passport without a separate justified request. Requests will be handled subject to applicable deadlines and permitted exceptions.
10. Session technologies and planned analytics
The service uses authentication cookies sg_session and, for VK, sg_vk_session with lifetimes of up to 30 days. sessionStorage may contain launch parameters, platform information and a VK token valid for up to 7 days. The language preference remains in localStorage until changed or cleared. Actual sessionStorage persistence depends on the browser and embedded app.
Yandex Metrica and Google Analytics are not yet integrated in the reviewed code. Their addition is planned separately. Before activation, the policy must be updated, applicable consent/refusal controls configured, and retention periods determined. Analytics events should not contain photographs, questionnaire answers, correspondence, Telegram/VK IDs or children's information. This is a requirement for the future integration, not a description of an already implemented analytics system.
11. Security and changes
The application uses session verification, server-side database access, restrictions on personal-data operations and deletion confirmation. Absolute security cannot be guaranteed.
Changes to processing require an updated policy and revision date. Any required separate notice or renewed consent must precede the relevant processing.
Contact: IP Samokhin Konstantin Aleksandrovich, INN 741706483691, OGRNIP 319784700098339; ksamokhin@gmail.com, support @ksamokhinn.