Legal review for start up app

SuppTally — LEGAL REVIEW BRIEF Prepared: August 18, 2026 Prepared by: App owner (for legal counsel review) App name: SuppTally Tagline: "Before you add." 1. WHAT SUPPTALLY IS SuppTally is a consumer wellness and organizational web application that helps users track the dietary supplements they already take and see where ingredients overlap across products. It is an educational and organizational tool, not a medical device, diagnostic tool, or treatment advisor. 2. WHAT SUPPTALLY DOES - Lets users build a personal list of the supplements they take (entered manually, scanned from a label photo, or looked up in the NIH Dietary Supplement Label Database). - Calculates deterministic arithmetic totals of ingredient amounts based on the user's own entered label data and servings-per-day. - Highlights ingredient overlaps — the same ingredient appearing in multiple products. - Compares a user's listed supplemental totals against verified reference values (e.g., tolerable upper intake levels) drawn only from approved, human-reviewed authoritative sources, and only when a verified rule applies to the user's population and intake source. - Provides educational content about ingredients, sourced from authoritative references and clearly labeled as demo/placeholder until verified. - Generates questions a user might ask their doctor at an appointment. - Exports a printable/PDF summary of the user's routine for their own use or to share with a clinician. 3. WHAT SUPPTALLY DOES NOT DO (IMPORTANT) - Does not diagnose any condition or disease. - Does not prescribe supplements or recommend specific products. - Does not recommend dosages — all amounts are user-entered label facts, not recommendations. - Does not provide medical, safety, or toxicity advice. It never labels an intake as "safe," "unsafe," or "toxic." - Does not estimate dietary intake from food; it only reflects supplemental amounts the user enters. - Does not perform drug-supplement or supplement-supplement interaction checking. (An interaction data structure exists in the database but is not surfaced to consumers.) - Does not use AI to perform calculations, diagnose, prescribe, or generate safety conclusions. AI is used only for: extracting label text from a user's photo (presented for user confirmation), suggesting canonical ingredient name matches (presented for user confirmation), generating plain-language explanations grounded strictly in already-verified records, and generating appointment questions. AI output is never treated as verified scientific evidence. - Does not substitute for professional medical advice and states this throughout the user interface. 4. DATA SOURCES - NIH Dietary Supplement Label Database (DSLD) — U.S. government public-domain (CC0) data, used for product search and label autofill. Attributed to the NIH in-app. No license fee required. - Evidence database — ingredient descriptions, reference values, and educational content are entered and human-reviewed by app administrators. Until a record reaches "Verified" status, it is not shown to consumers as authoritative fact. - User-entered data — supplement routines, demographics (age range, sex, life stage), and health goals. Stored per-user; not shared across accounts. 5. DATA HANDLING & PRIVACY - Users must register and log in; there is no anonymous access to personal data. - Each user sees only their own supplement routine (row-level security enforced server-side). - Analytics events are privacy-conscious: only anonymous event names and counts are tracked. No supplement names, ingredient names, or health details are included in analytics payloads. - The app does not sell or share user data with third parties. 6. AI USAGE DISCLOSURE SuppTally uses AI models for non-authoritative assistance only. Every AI-assisted output is: - Clearly labeled as AI-generated in the interface. - Logged in a separate audit log (never marked as verified evidence). - Subject to user confirmation before any AI-extracted label data or ingredient mapping is saved. - Grounded, where explanations are concerned, only in already-verified records — and explicitly states "verified information not available" when no verified record exists, rather than inventing information. 7. DISCLAIMERS CURRENTLY IN THE APP The following disclaimer appears throughout the app: "SuppTally is an educational and organizational tool. It does not diagnose conditions, prescribe supplements, or recommend dosages. Always talk with your physician, pharmacist, or registered dietitian before making changes." PDF exports include a disclaimer footer. Learn articles carry a "not individualized guidance" notice. 8. WHAT WE ARE ASKING COUNSEL TO REVIEW 1. Adequacy of the disclaimers for a consumer-facing dietary-supplement tracking tool under U.S. law (DSHEA, FDA guidance on supplement claims, FTC advertising rules). 2. Whether the app's scope and language risk being construed as medical advice or as a medical device, and if so, what changes would mitigate that risk. 3. The AI usage disclosure — whether it satisfies any applicable transparency or consumer-protection requirements. 4. Privacy policy and terms of service — the app needs both; please advise on required provisions (data retention, user rights, no-medical-advice acknowledgment, age restrictions, etc.). 5. DSLD/NIH attribution — confirm the attribution language satisfies any public-domain data usage norms. 6. Any state-specific requirements for apps that touch health information (e.g., California, New York). 9. OUT OF SCOPE (NOT LEGAL ADVICE WE'RE SEEKING) We are not seeking review of: payment processing (the app is free), marketing claims (none made beyond the tagline), or employment matters. This brief describes the application as built. It is factual and does not constitute legal advice.