Privacy Policy

Last updated: 12 October 2026

Glema ("we", "us") provides an AI-assisted skincare-routine app for iOS. This policy explains what personal information we collect, why we collect it, who we share it with, and how you can control it.

This is a draft prepared for App Store submission. The published version will be revised before public launch.

1. Who is the controller

The publisher of the Glema app is Sergey Zaturanov, the natural person operating the service. Contact: privacy@glema.app.

2. What we collect

Account data. When you sign in we receive an Apple identifier (from Sign in with Apple) and, if you choose the email option, an email address. If Apple relays a private email, that's what we store — we do not see your real address.

Profile and routine data. Information you enter to receive recommendations: your date of birth, skin type, concerns, the products on your shelf, and the routine calendar we generate from these inputs. We use your date of birth to confirm you are 18 or over and to tailor advice to your age; we never display an age back to you and never share it.

Skin photos. Photos you upload for analysis or history. Processing can include AI analysis by OpenAI or another configured AI provider and portrait background removal by fal.ai. An optional Deep Face Scan inside an AI consultation in the Expert section sends a face photo to Perfect Corp. Scan processing requires your explicit consent. See § 4. Your history remains available when you withdraw permission for new processing.

Device and usage data. App version, iOS version, device model, push notification token, language, time zone, and approximate location (only when you grant Location permission for UV-index advice). We log error events and explicit product events for diagnostics and product improvement.

Subscription data. If you purchase a Glow or Luxe subscription, Apple sends us your subscription status (not your card number). We never see your payment details.

We do not collect data from children. The service is intended for users 18 and over.

3. Why we use this data

To run the service: generate your routine, send reminders, sync state.
To improve recommendations: analyze patterns in usage, both aggregated and — for your own account — over your own history.
Optional model development. Only a separate, current training permission allows us to select or use your skin data to develop our own models. You can withdraw it in Me. No first-party training or training-export pipeline is currently running. Keeping technical history is independent of this choice (see § 6); processing a scan does not grant training permission.
To keep the service safe: detect abuse, debug crashes, monitor reliability.
To respond to legal obligations when we receive a valid request.

We do not sell your personal data and we do not use your data for advertising.

4. Who we share it with

We use third-party processors strictly to operate the service:

Amazon Web Services (US) — hosting, databases, file storage.
Apple (US) — Sign in with Apple, push notifications (APNs), in-app purchases, distribution via the App Store.
OpenAI — AI processing of skin images and text to produce assessments and recommendations. This service processing is separate from permission to train Glema's own models.
Anthropic via AWS Bedrock and Google Gemini — other configured AI processing paths; Google and SerpAPI also support web search for product information.
fal.ai — portrait background removal for face-photo displays and image processing for product photographs. Face-photo processing requires scan consent; product-label and barcode processing do not request training consent.
Sentry (US) — crash and error reporting (errors only, no replay).
PostHog (US) — product analytics on an explicit-events basis. Autocapture is disabled.

We share the data needed for each integration. These service-processing calls are separate from optional training use by Glema.

Perfect Corp. (YouCam AI Skin Analysis) — a separate case. If you start the optional Deep Face Scan inside an AI consultation in the Expert section, that face photo is sent to Perfect Corp., which analyses it and returns skin metrics (redness, moisture, pores and similar). It is sent only with your explicit consent, given in the app, and only for that scan.

Perfect Corp. processes the scan under its Terms of Service and Privacy Policy. Other face-processing paths can also send images to the providers named above; we do not claim that all regular face photos stay inside our infrastructure.

Provider-side retention and deletion depend on the applicable terms and account settings. We do not promise a specific unverified retention period or immediate cancellation or deletion of a request that has already been sent.

5. International transfers

Data is processed primarily in the United States (AWS us-east-1). If you use the app from outside the US, your data is transferred to the United States under standard contractual safeguards.

6. How long we keep your data

Account and routine data: as long as your account exists.
Skin photos: until you delete them or your account.
Error reports and explicit analytics events: under the applicable provider settings, for diagnostics and service improvement.
Backups: under the configured database recovery settings.

We keep your skincare data for the life of your account — we do not delete older records over time. That deliberately includes the results of every skin scan you have taken: the scores, the written description of your face that the analysis produces, and, if you entered it, your menstrual-cycle information, which is used to explain why a score moved. We hold this to see how skin changes over months and years. Optional model development requires the separate current permission described in § 3.

We also keep a second, separate copy of this data in cold storage, so a value you changed is not lost when the app overwrites it. That copy is not read in normal operation, is covered by the same retention as your account, and is deleted with it. This is a technical archive, not a training dataset.

Withdrawing training permission stops future training selection and use and removes any separate copies made only for training. Your technical archive and in-app history remain. Training withdrawal does not change scan-processing permission or delete operational error diagnostics. Full account deletion still purges the technical archive and any personal training copies.

When you delete your account we erase your personal data — from production and from that cold copy — within 30 days. Anonymized aggregate data may persist for analytics.

7. Your rights

You can:

Access and export your data from the app's Profile screen.
Edit or delete your profile, products, and routine entries at any time.
Delete your account from Profile → Account → Delete account.
Contact privacy@glema.app for any other request, including under the GDPR, UK GDPR, or CCPA where applicable.

We respond to verified requests within 30 days.

8. Security

We encrypt data in transit (TLS) and at rest. Access to production systems is restricted to the publisher. We do not store passwords for the in-app account — Sign in with Apple and the email code flow do not require one.

9. Changes to this policy

We will update this page when the service or applicable law changes. Material changes will be highlighted in the app or by email when we have one.

10. Contact

privacy@glema.app