Privacy Policy

1. Introduction

Welcome to Freya ("we," "us," "our," or the "Company"). We operate the Freya mobile application (the "App"), a skincare guidance tool that provides personalized skincare routines and recommendations.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this Privacy Policy carefully. By using the App, you consent to the data practices described in this policy.

If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

2. Information We Collect

We collect several types of information to provide and improve our services to you.

2.1 Account Information

When you create an account, we collect:

• Email address (required for account creation)
• Display name (optional, can be set by you)
• Profile bio (optional, up to 150 characters)
• Profile visibility preferences (public/private setting)

2.2 Skincare Profile & Survey Data

During onboarding, we collect information you provide about:

• Demographics: Name, age, ethnicity
• Skin characteristics: Skin type, skin feel, main concerns
• Skin conditions: Including but not limited to acne, rosacea, eczema, dermatitis, scarring conditions
• Health status: Pregnancy or breastfeeding status (used solely to filter product recommendations for safety)
• Lifestyle factors: Skincare spending habits, current skincare journey stage
• Preferences: Product preferences (vegan, cruelty-free, fragrance-free, etc.)
• Psychological factors: How skin concerns affect your mood, confidence, and daily life

This information is used to personalize your skincare recommendations and is not shared with third parties for marketing purposes.

2.3 Facial Data & Photos

We take facial data very seriously. The App collects:

• Face photos: You may capture photos of your face (front, left profile, right profile) for skin analysis
• Daily progress photos: Optional photos to track your skincare progress over time
• Problem area photos: Optional close-up photos of specific skin concerns

How we use facial data:

• Photos are securely uploaded and processed using cloud-based AI technology to analyze your skin
• Analysis generates skin scores across multiple categories (hydration, complexion, texture, etc.)
• Photos are stored to allow you to track your skincare progress over time
• We may detect general demographic attributes (gender, ethnicity) to improve analysis accuracy
• Photos are processed securely and are not stored permanently by our AI processing services

Important: Facial data is NOT used for:

• Facial recognition or identification purposes beyond your own account
• Sharing with third parties for advertising
• Training models on your personal images without explicit consent
• Any purpose other than providing you with personalized skincare analysis

Retention: Your photos and analysis data are retained until you delete your account or specifically request deletion.

2.3.1 TrueDepth API & Face Tracking

When using the camera for skin analysis, our app utilizes Apple's TrueDepth camera and ARKit framework to provide a real-time face tracking overlay. This feature displays a 3D wireframe mesh on your face purely as a visual user interface element to help you position your face correctly during photo capture.

What TrueDepth data is collected:

• Face geometry (3D mesh vertices and texture coordinates)
• Face position and orientation in 3D space

Important: The face geometry data collected via the TrueDepth API:

• Is used solely for the on-screen visual overlay effect — it is NOT used for any skin analysis
• Is processed entirely on your device
• Is never transmitted to our servers or any third party
• Is never stored on your device beyond the active camera session
• Is discarded immediately when the camera view is closed
• Is not used for facial recognition or identification purposes
• Is not used for marketing, advertising, or data mining

What IS stored: Only the 2D photographs you capture are uploaded for skin analysis. We store the analysis information presented to you in the application (analysis of your skin attributes) for each photo along with the photo itself, for the purpose of allowing you to review your skincare progress and history over time and provide you recommendations for compatible skincare products. Like other personal data, this data is not shared with any third parties, is kept securely, and is removed upon account deletion or at your request.

The 3D face tracking data exists solely for the on-screen visual effect and serves no analytical purpose.

Before accessing the TrueDepth camera, we request your permission. You can revoke this permission at any time in your iPhone Settings.

2.4 Routine & Usage Data

We automatically collect information about how you use the App:

• Routine data: Your personalized skincare routine, products, and completion status
• Progress tracking: Daily routine adherence, streak data
• Interaction data: Features used, screens viewed, buttons tapped
• Session information: App opens, session duration

2.5 Device & Technical Information

We automatically collect certain technical information:

• Device type: iPhone model, operating system version
• App version: The version of Freya you are using
• Unique identifiers: Device identifiers for analytics and crash reporting
• Network information: Connection type (Wi-Fi, cellular)
• Crash logs: Information about app crashes to help us improve stability

2.6 Camera Access

We request camera permission solely to:

• Capture face photos for skin analysis
• Capture daily progress photos
• Scan product barcodes for product lookup

We do not access your photo library unless you explicitly choose to upload an existing photo. We do not access your camera in the background.

2.7 Advertising Identifiers & Attribution

With your consent, we collect advertising identifiers to measure the effectiveness of our marketing campaigns:

• IDFA (Identifier for Advertisers): Apple's advertising identifier, collected only if you grant permission via the App Tracking Transparency prompt
• IDFV (Identifier for Vendors): A device identifier used for attribution and analytics
• AppsFlyer ID: A unique identifier generated by our attribution partner to measure ad campaign performance

How we use this data:

• Measure which advertising campaigns lead to app installations
• Understand how users discovered Freya
• Optimize our marketing spend to reach people who may benefit from skincare guidance
• Attribute subscription purchases to marketing campaigns for performance measurement

Your Control: When you first use Freya, iOS will ask if you want to allow tracking. If you choose "Ask App Not to Track," we will NOT collect your IDFA and will not share data with advertising networks for cross-app tracking. You can change this setting anytime in iOS Settings > Privacy & Security > Tracking.

What happens if you opt out: Your experience in Freya remains unchanged. We simply cannot measure which ad (if any) led you to install the app.

3. How We Use Your Information

We use the information we collect to:

3.1 Provide Our Services

• Create and manage your account
• Generate personalized skin analysis and scores
• Process facial photos using clinical-grade AI analysis technology
• Create customized skincare routines
• Recommend compatible skincare products
• Track your skincare progress over time

3.2 Improve Our Services

• Analyze usage patterns to improve App features
• Debug technical issues and fix bugs
• Develop new features based on user needs
• Ensure the App functions correctly on different devices

3.3 Communicate With You

• Send important account notifications
• Respond to your support requests
• Send optional marketing communications (with your consent)

3.4 Safety & Security

• Detect and prevent fraud or abuse
• Ensure compliance with our Terms of Service
• Protect the rights and safety of our users

4. How We Share Your Information

We do not sell your personal information. We may share your information only in the following circumstances:

4.1 Service Providers

We work with trusted third-party service providers who assist us in operating the App:

• Firebase (Google): Authentication, database, file storage
• Google Cloud: Backend infrastructure
• Third-party AI services: Skin analysis and image processing (data processed securely, not stored permanently, using industry-standard services trusted by healthcare companies)
• RevenueCat: Subscription and payment management
• PostHog: Analytics and app improvement
• AppsFlyer: Mobile attribution and advertising measurement — helps us understand which marketing channels bring users to Freya and measure the effectiveness of our advertising campaigns

These providers are contractually obligated to protect your information and may only use it to provide services to us.

4.2 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Valid legal process (subpoena, court order)
• Government requests
• To protect our rights, privacy, safety, or property
• To enforce our Terms of Service

4.3 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice in the App of any change in ownership.

4.4 With Your Consent

We may share your information for other purposes with your explicit consent.

4.5 Advertising Measurement Partners

If you consent to tracking via Apple's App Tracking Transparency prompt, we share limited data with our advertising measurement partner (AppsFlyer) to understand our marketing effectiveness:

• Data shared: IDFA, IDFV, IP address, app install/purchase events
• Purpose: Attribute app installs and purchases to advertising campaigns
• NOT shared: Your name, email, photos, skincare data, or any health-related information

If you do not consent to tracking, we do not share your advertising identifier with any third parties.

5. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you services.

Specific retention periods:

• Account data: Retained until you delete your account
• Face photos & analysis: Retained until you delete your account or request deletion
• Usage data: Retained for up to 2 years for analytics purposes
• Support communications: Retained for up to 3 years

After account deletion, we may retain certain information as required by law (e.g., for tax, legal, or audit purposes) for a limited period, after which it will be permanently deleted.

6. Data Security

We implement appropriate technical and organizational security measures to protect your personal information, including:

• Encryption: Data is encrypted in transit (HTTPS/TLS) and at rest
• Access controls: Only authorized personnel can access personal data
• Secure infrastructure: We use industry-standard cloud providers with SOC 2 compliance
• Authentication: Secure authentication via Firebase Auth

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

7. Your Rights & Choices

Depending on your location, you may have the following rights regarding your personal information:

7.1 Access & Portability

You can request a copy of the personal information we hold about you.

7.2 Correction

You can update your profile information directly in the App or contact us to correct inaccuracies.

7.3 Deletion

You can request deletion of your account and associated data. To delete your account:

• Go to Profile > Delete Account
• Or contact us at support@freyaskincare.app

Upon deletion, we will remove your personal information from our active systems. Some data may be retained in backups for a limited period.

7.4 Opt-Out of Marketing

You can opt out of marketing communications by:

• Using the unsubscribe link in any marketing email
• Adjusting notification settings in the App

7.5 Data Processing Objection

You may object to certain types of data processing. Contact us to discuss your specific concerns.

To exercise any of these rights, please contact us at support@freyaskincare.app.

8. Children's Privacy

The App is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13.

If you are between 13 and 18 years of age, you must have parental or guardian consent to use the App.

If we learn that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information promptly. If you believe we have collected information from a child under 13, please contact us immediately.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States, where our servers and service providers are located.

These countries may have data protection laws that are different from the laws of your country. By using the App, you consent to the transfer of your information to the United States and other countries.

We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy.

10. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You can request information about the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You can request deletion of your personal information, subject to certain exceptions.
• Right to Opt-Out: You have the right to opt out of the "sale" of your personal information. Note: We do not sell personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at support@freyaskincare.app.

11. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

• Legal Basis: We process your data based on: (a) your consent, (b) performance of a contract, (c) legitimate interests, or (d) legal obligations.
• Data Portability: You can request your data in a structured, machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority.

12. Third-Party Links

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information to them.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new Privacy Policy in the App
• Updating the "Last Updated" date at the top of this policy
• Sending you an email notification (for significant changes)

Your continued use of the App after any changes constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: support@freyaskincare.app

15. Summary of Key Points

We do not:

• Sell your personal information
• Share your photos, skincare data, or health information with advertisers
• Use facial recognition for identification
• Collect data from children under 13