GlowAI Privacy Policy

1. Introduction

Welcome to GlowAI ("GlowAI," "we," "our," or "us"). We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use the GlowAI mobile application and related services. We comply with applicable data protection laws, including the GDPR, CCPA/CPRA and COPPA.

By using GlowAI, you acknowledge that you have read and understood this Privacy Policy.

2. Who is responsible for your data

The data controller is Moon Labs, based in Armenia. You can reach us at munetic.studiogmail.com.

3. Information we collect

Personal information

Your email address and display name; account credentials (hashed passwords for email sign-in, or identifiers from Sign in with Apple or Google); and your preferences and settings. Legal basis: contract performance (GDPR Art. 6(1)(b)).

Profile and health-related data

Age, gender, height and weight; skin type and any allergies you enter; and the goals and answers you give the AI Coach (skincare, hair, grooming, fitness, nutrition, sleep). We ask your age to enforce our 13+ minimum and to tailor analysis. Some of this is health-related; we use it only to personalize your results and coaching, never for advertising. Legal basis: your consent (GDPR Art. 6(1)(a)); for health-related data, Art. 9(2)(a).

Facial image data (sensitive)

Photos you upload or capture in-app; facial landmarks and geometric measurements derived from your photos; analysis results computed from those geometric measurements, including harmony and attractiveness-style scores and tier and archetype labels; and AI-generated skin feature observations with personalized recommendations. Legal basis: your explicit consent (GDPR Art. 6(1)(a)).

What actually happens to a photo: we process facial photos only to measure facial geometry, observe skin features, compute your scores from those measurements, generate your recommendations, and store your scans in your account history so you can view them and use the results in the Coach. GlowAI performs no facial recognition, and neither your photos nor your measurements are used to identify you. Images travel over encrypted channels, are processed transiently by our AI provider, and are stored only in your own account history.

We send face images only to Google Gemini AI for analysis. Google processes them as our data processor under its Data Processing Addendum and does not use them to train or improve its products. Under the Gemini API terms, Google keeps request logs for a limited time, only to detect abuse and to meet legal requirements. We store your face images and analysis results in your account until you delete the scan or your account, so you can view your history and use results in the Coach.

TrueDepth camera and face tracking (iPhone with Face ID)

On iPhones with Face ID, the scan camera uses Apple's ARKit face tracking with the TrueDepth camera. While the camera is open, the app reads your head angles, where your face is in the frame and how wide it looks, how far your face is from the camera, the distance between your eyes, and whether your eyes are open and whether you are smiling. GlowAI does not read depth maps, and it does not save or upload the 3D face mesh.

Most of these readings stay on your iPhone. They guide you to a good photo and take the photo automatically when you are in position, then they are discarded. Two readings are sent to our server with your photos, over an encrypted connection: your distance from the camera (in metres) and the distance between your eyes (in millimetres). We use them only to correct lens distortion in that scan's measurements, because a photo taken close to the camera makes the nose look larger and the sides of the face look narrower. The camera distance is saved as one number in that scan's record in Google Firebase Firestore, inside your account, and is deleted when you delete the scan or your account. The eye distance is used during the analysis and is not saved. On your iPhone, the two numbers from your latest capture stay in the app until your next scan or until you sign out.

TrueDepth readings are never sent to any AI provider, analytics tool or other third party. We never use them for advertising, marketing, sign-in or authentication, to identify you, or to build a profile of you. The photo the camera takes is an ordinary colour photo with no depth data, and it is handled as described above.

Usage and technical data

App activity and interaction patterns, error logs and crash reports, device type, operating system and identifiers, and your device timezone (not GPS location).

Analytics and diagnostics: we use Mixpanel and Google Firebase (Analytics, Crashlytics and Performance Monitoring) to understand which features are used, fix crashes, and improve performance. These tools receive only bucketed, non-identifying usage events and crash and performance diagnostics, tied to a one-way salted hash, never your email or account ID. We never send your face images, facial measurements, analysis scores, or age to any analytics tool. Usage analytics is collected only after you opt in. Crash and performance diagnostics are on by default once we know you are 13 or older, to keep the app stable; you can turn them off any time in Settings → Privacy. None of this is collected from users under 13. Legal basis: legitimate interests (GDPR Art. 6(1)(f)); for analytics, your consent (Art. 6(1)(a)).

AI Coach, routines and products

Your AI Coach chat messages and any images you attach; routines you build and your device timezone (to schedule reminders); and products you save, including any product photos you add. Legal basis: contract performance and your consent (GDPR Art. 6(1)(b), 6(1)(a)).

Device, notifications and identifiers

Your push notification token, device name and model, OS and app version (for reminders and updates); a salted-hash analytics identifier (never your email or account ID); and your notification preferences, which you can change anytime in Settings. Legal basis: legitimate interests and your consent (GDPR Art. 6(1)(f), 6(1)(a)).

4. How we use your information

Core services: facial geometry measurement, skin analysis and skincare recommendations; account authentication and management; and your analysis history and progress tracking. Service operation: performance monitoring and debugging, security and fraud prevention, and customer support.

We do not use your data for advertising, cross-app ad tracking, selling, or automated decisions with legal effects. We do use privacy-preserving usage analytics (bucketed and non-identifying) solely to improve GlowAI, as described in section 3.

5. Data sharing and disclosure

Google Firebase (Google LLC, USA)

Purpose: authentication, database, cloud storage, and, via Firebase Analytics, Crashlytics and Performance Monitoring, bucketed usage analytics, crash reporting and performance diagnostics. Analytics data shared: non-identifying usage, crash and performance events tied to a one-way salted hash; no face images, measurements, scores, age or email. Usage analytics is collected only with consent; crash and performance diagnostics are on by default once we know you are 13 or older, with an opt-out in Settings, and none of this is collected from users under 13. Face data handling: your facial images and scan results are stored in Firebase Cloud Storage and Firestore for the duration of your account; Firebase hosts them on our behalf and uses them for nothing else. Data is encrypted in transit and at rest. Safeguards: Data Processing Addendum, and the EU-US Data Privacy Framework or Standard Contractual Clauses for international transfers.

Google Gemini AI (Google LLC)

What we share: face images for facial and skin analysis and for generating recommendations, and Coach chat messages with any attached images for generating responses. Data processing: Google processes your face images as our data processor under its Data Processing Addendum and does not use them to train or improve its products. Under the Gemini API terms, Google keeps request logs for a limited time, only to detect abuse and to meet legal requirements. Safeguards: secured API channels and encryption in transit. We do not share your face photos with any other third party. The written parts of your results are produced from text about your scan by OpenRouter, described next.

OpenRouter, Inc. (USA), with the DeepSeek language model

What we share: text only, never your photos and never TrueDepth readings. To write your scan results and progress insights: your overall and per-area scores, your tier and archetype labels, plain-language descriptions of the facial features and skin concerns our analysis found in your photos, your score history, your age and gender, and the products you own. To build routines: your answers to the routine questions, the profile details you gave us (age, gender, height, weight, skin type, allergies and goals), and your saved products. In the Coach: your messages and the recent conversation, so we can understand what you are asking, title the chat and keep a short summary of it. The Coach's own replies are written by Google Gemini AI. Purpose: to write the text parts of your results, routines and Coach experience with the DeepSeek language model. OpenRouter passes each request to one of the companies that host this model for us: currently Cohere, Wafer, Together AI, CoreWeave and Parasail. These companies are based in the United States and may process data there or in other countries. We only allow hosts with zero data retention, which means they do not store your data or use it for training, and OpenRouter does not use it to train models. Safeguards: encryption in transit, and a contract with OpenRouter.

Mixpanel, Inc. (USA)

What we share: bucketed, non-identifying product-usage events (for example "scan completed" or a screen view) tied to a one-way salted hash; no face images, measurements, scores, age, name or email. Purpose: product analytics, to understand feature usage. Collected only with your consent, and never from users under 13. Safeguards: Data Processing Addendum, and the EU-US Data Privacy Framework or Standard Contractual Clauses for international transfers.

International transfers

Our analytics and AI processors (Google, Mixpanel and OpenRouter) are based in the United States, and the model hosts listed under OpenRouter may process data in the United States or other countries. These transfers are protected by the EU-US Data Privacy Framework and/or Standard Contractual Clauses, together with the safeguards above.

Affiliate and outbound links

Some product suggestions are affiliate links (including the Amazon Associates program); if you buy through them we may earn a commission at no extra cost to you. Tapping a product link takes you to a third-party site with its own privacy practices, which we do not control.

GlowAI does not sell your personal information, and does not share it for cross-context behavioral advertising, for monetary or other valuable consideration.

6. Your privacy rights

Wherever you live, you can access your data, correct inaccuracies, delete your data, take a copy of it with you, and withdraw consent. In the EU and UK, you can also restrict or object to processing and lodge a complaint with your supervisory authority. In California, you additionally have the right to know the categories of data we hold, to opt out of sale or sharing (we do neither), and to be free from retaliation for exercising any of these rights.

7. How to exercise your rights

Delete your account: in the app, open Profile, then Privacy & Security, then Delete Account. Deletion is immediate on confirmation: all personal data, facial images and analysis results are permanently erased, and the action cannot be undone. The step-by-step detail lives on the account deletion page.

Export your data: in the app, open Profile, then Privacy & Security, then Export data, for a complete machine-readable (JSON) copy of your profile, scans, Coach chats, routines and saved products.

Delete a single scan: open History, select the scan, and choose Delete.

Everything else (access, correction, portability questions): email munetic.studiogmail.com from your registered address. Replies usually come within 48 hours, and formal data-rights requests are completed within 30 days as the GDPR provides. We may need to verify your identity first.

8. Data security

Data is protected with HTTPS encryption in transit, AES-256 encryption at rest, strict access controls with multi-factor authentication, and regular security review of the systems that store it.

9. Data retention

Account data is retained for the lifetime of your account. Scan history, including facial images, is kept until you delete the individual scan or the account, so your history and Coach stay useful. Coach chat history is kept until the account is deleted. Aggregated usage analytics and diagnostics, which cannot identify you, are kept for up to 14 months and then aggregated further or deleted.

When you delete your account, deletion is immediate: your personal data, facial images and analysis results are permanently erased on confirmation, you lose access at once, and the action cannot be undone. If you leave a guest account that has an active subscription, we keep only a minimal purchase record, with no photos or scan data, so the purchase can move to your other account. It is deleted when the subscription ends.

10. Children's privacy

You must be at least 13 years old to use GlowAI. GlowAI is not directed to children under 13. During sign-up we ask for the user's age and block accounts under 13, and we do not knowingly collect personal information, or any behavioral analytics, from anyone under 13. If we become aware that we have collected personal information from a child under 13, we will delete it promptly. Parents or guardians can contact us at munetic.studiogmail.com.

11. Governing law and jurisdiction

This Privacy Policy is governed by the laws of Armenia, without regard to conflict-of-law principles. All disputes arising from or relating to this Policy shall be resolved exclusively in the competent courts of Armenia.

12. Contact

Email munetic.studiogmail.com. Every message is read by the founder, and replies usually come within 48 hours.