Legal
GlowAI Privacy Policy
Effective Dec 1, 2024Updated Jun 6, 2026
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 all applicable data protection laws, including GDPR, CCPA/CPRA, COPPA, and other global privacy regulations.
By using GlowAI, you acknowledge that you have read and understood this Privacy Policy.
2. Who Is Responsible for Your Data?
Data Controller
Munetic
Location
Armenia
Contact Email
munetic.studio@gmail.com
3. Information We Collect
Personal Information
- Email address and display name
- Account credentials (hashed passwords for email sign-in, or identifiers from Sign in with Apple / Google)
- User preferences and settings
Legal Basis: Contract performance (GDPR Art. 6(1)(b))
Profile & Health-Related Data
- Age, gender, height and weight
- Skin type and any allergies you enter
- 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
- AI-generated analysis results, including harmony/attractiveness-style scores and tier & archetype labels
- Skin feature observations
Legal Basis: Your explicit consent (GDPR Art. 6(1)(a))
Important: We process facial photos only to extract skin-related features and generate recommendations. We do not create biometric identifiers or perform facial recognition. Images are transmitted via encrypted channels, processed transiently by our AI provider, and stored only in your secure account history.
- We send face images only to Google Gemini AI for analysis. Google does not retain your face images; processing is transient and not stored on their systems.
- 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.
Usage & Technical Data
- App activity and interaction patterns
- Error logs and crash reports
- Device type, operating system, and identifiers
- Device timezone (not GPS location)
Analytics & 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/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 to keep the app stable and reliable; 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 & Products
- Your AI Coach chat messages and any images you attach
- Routines you build and your device timezone (to schedule reminders)
- Products you save, including any product photos you add
Legal Basis: Contract performance & your consent (GDPR Art. 6(1)(b), 6(1)(a))
Device, Notifications & Identifiers
- Push notification token, device name/model, OS and app version (for reminders and updates)
- A salted-hash analytics identifier (never your email or account ID)
- Your notification preferences, which you can change anytime in Settings
Legal Basis: Legitimate interests & your consent (GDPR Art. 6(1)(f), 6(1)(a))
4. How We Use Your Information
Core Services
- • Facial analysis and skincare recommendations
- • Account authentication and management
- • Analysis history and progress tracking
Service Improvement
- • Performance monitoring and debugging
- • Security and fraud prevention
- • Customer support and troubleshooting
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 — see “Analytics & diagnostics” above.
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/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 with an opt-out in Settings. None of this is collected from users under 13.
Safeguards: Data Processing Addendum; EU–US Data Privacy Framework / Standard Contractual Clauses for international transfers; encryption in transit & at rest
Face data handling: Your facial images and scan results are stored in Firebase Cloud Storage and Firestore for the duration of your account. Firebase does not use your face data for any purpose other than hosting it on our behalf. Data is encrypted in transit and at rest.
Google Gemini AI (Google LLC)
What we share: Face images for facial/skin analysis and generating recommendations; Coach chat messages and any attached images for generating responses.
Purpose: Facial/skin analysis and generating personalized recommendations.
Third party does not store face data: Google does not retain your face images. Processing is transient; images are sent only for the analysis request and are not stored on Gemini's systems (per API terms).
Safeguards: Secured API channels, encryption in transit. We do not share face data with any other third parties.
Mixpanel, Inc. (USA)
What we share: Bucketed, non-identifying product-usage events (e.g. “scan completed”, screen views) tied to a one-way salted hash. No face images, measurements, scores, age, name, or email.
Purpose: Product analytics to understand feature usage and reduce drop-off.
Collected only with your consent, and never from users under 13.
Safeguards: Data Processing Addendum; EU–US Data Privacy Framework / Standard Contractual Clauses for international transfers; encryption in transit.
International Data Transfers
Our analytics and AI processors (Google and Mixpanel) are based in the United States, so your information may be processed there. These transfers are protected by the EU–US Data Privacy Framework and/or Standard Contractual Clauses, together with the safeguards described above.
Affiliate & 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 (e.g. Amazon) that has its own privacy practices 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
Worldwide Rights
- • Access your data
- • Correct inaccuracies
- • Delete your data
- • Data portability
- • Withdraw consent
GDPR Rights (EU/UK)
- • Restrict processing
- • Object to processing
- • File complaints with authorities
CCPA/CPRA Rights (California)
- • Know data categories
- • Correct inaccuracies
- • Delete your personal information
- • Opt out of sale/sharing (we do neither)
- • No retaliation protection
7. How to Exercise Your Rights
Delete Your Account Immediately
You have complete control over your account and data. Delete your account instantly at any time:
Navigation Path:
⚡ Immediate Deletion
- • Your account is deleted immediately upon confirmation
- • All your data (photos, analysis results, personal info) is permanently erased
- • Your facial images are removed from all systems
- • This action is irreversible - there is no recovery option
Export Your Data
App → Profile → Privacy & Security → Export data
Get a complete, machine-readable (JSON) copy of your profile, scans, Coach chats, routines, and saved products — to keep or move elsewhere
Delete Individual Scans
App → History → Select Scan → Delete
Remove specific analysis results without deleting your account
Email Requests
For other data requests (access, correction, portability):
Email: munetic.studio@gmail.com from your registered email address
Response within 30 days. Identity verification may be required.
8. Data Security
9. Data Retention
Face images and analysis results are stored until you delete the individual scan or your account, so you can view your history and use results in the Coach.
✅ Immediate Account Deletion
When you delete your account via App → Profile → Privacy & Security → Delete Account:
- • Your account is deleted immediately - no waiting period
- • All personal data, facial images, and analysis results are permanently erased instantly
- • Your data is removed from all our systems in real-time
- • You lose access to the app immediately
- • This action cannot be undone
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 such information promptly. Parents or guardians can contact us at munetic.studio@gmail.com.
11. Contact Us
12. Governing Law & 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.
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