GlowAI Privacy Policy

Effective Date: December 1, 2024Last Updated: July 1, 2025

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)
  • User preferences and settings

Legal Basis: Contract performance (GDPR Art. 6(1)(b))

Facial Image Data (Sensitive)

  • Photos you upload or capture in-app
  • AI-generated analysis results
  • Skin feature extraction data

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.

Usage & Technical Data

  • App activity and interaction patterns
  • Error logs and crash reports
  • Device type, operating system, and identifiers
  • Device timezone (not GPS location)

Legal Basis: Legitimate interests (GDPR Art. 6(1)(f))

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, behavioral targeting, or automated decisions with legal effects.

5. Data Sharing and Disclosure

Google Firebase

Purpose: Authentication, database, cloud storage

Safeguards: Data Processing Addendum, encryption in transit & at rest

Google Gemini AI

Purpose: Temporary facial image analysis

Safeguards: No image retention, secured API channels

GlowAI does NOT sell or share your personal information 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 Rights (California)

  • • Know data categories
  • • Correct inaccuracies
  • • No retaliation protection

7. How to Exercise Your Rights

In-App

Settings → Privacy → Download Data / Delete Account / Delete Scan

Email

Send requests to munetic.studio@gmail.com from your registered email address

We respond to verifiable requests within 30 days. Identity verification may be required for certain requests.

8. Data Security

HTTPS encryption for data in transit
AES-256 encryption for data at rest
Strict access controls with MFA
Regular security audits and testing

9. Data Retention

Active accountsRetained for account lifetime
Scan historyUntil deleted by user
Deleted accountsErased within 30 days

10. Children's Privacy

Important: GlowAI does not include age verification mechanisms and is not specifically designed for children under 13. We do not knowingly collect personal information from anyone under 13.

If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information immediately. Parents or guardians can contact us at munetic.studio@gmail.com.

11. Contact Us

Email Support

munetic.studio@gmail.com

Response within 72 hours

In-App Support

Settings → Support

Direct help within the app

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.

© 2024–2025 GlowAI. All rights reserved.