Privacy Policy

1. Controller

The data controller under the GDPR is:

2. Overview

This Privacy Policy explains what personal data we process when you use the Sharp app, for what purposes, on what legal basis, and what rights you have.

In short:

• Sharp processes account data, quiz responses, face photos, product photos, and analysis results.
• Face and product photos are processed only transiently: they are sent to an AI service for analysis and deleted from our servers immediately afterwards.
• We collect pseudonymous usage statistics in our own database to improve the App. We do not use third-party analytics services such as Google Analytics or Mixpanel.
• Only if you allow it in Apple's tracking dialog ("Allow Tracking"), we use the Meta (Facebook) SDK to measure which of our ads led to your install and purchase. If you do not allow it, no data is sent to Meta.
• We do not sell your data and do not show ads inside the App.
• Sharp does not provide medical diagnoses.

3. What Data We Process

3.1 Account and Authentication Data

When you register or sign in, we process:

• email address and password (for email registration),
• authentication data from Sign in with Apple or Google (e.g. user ID, and name/email where you authorize it),
• session and security information (JWT/token).

Until you create an account (after your first scan result), the App runs on an anonymous account without email or name, so the scan and plan can be created. When you sign up, this anonymous account is converted into your regular account.

Provider: Supabase Auth
Purpose: account creation, sign-in, security
Legal basis: Art. 6(1)(b) GDPR (performance of contract)

3.2 Profile Data

• display name (optional, provided during onboarding),
• an optional creator code if you entered one or arrived via a creator's link (see Section 3.12).

Storage: Supabase database (profiles)
Legal basis: Art. 6(1)(b) GDPR

3.3 Onboarding Quiz and Skin Profile

The quiz may collect, among other things:

• skin concerns and priorities,
• age, skin type, existing routine,
• products used, shaving frequency,
• sleep, stress, SPF use, exercise,
• water intake, time budget, product budget,
• follow-up answers for specific concerns (e.g. affected area, patterns).

Storage: Supabase database (onboarding)
Purpose: personalization of analysis, plan, and recommendations
Legal basis: Art. 6(1)(b) GDPR

3.4 Face Photos and Scan Results

For cosmetic skin analysis, we process:

• face photos (JPEG, compressed to approx. 1080 px width before upload),
• scan week and timestamp,
• cosmetic scores across 6 dimensions (clarity, oil, redness, pores/texture, eye area, hydration),
• overall score (calculated on our servers),
• cosmetic findings (text, severity, location),
• AI model used.

Storage:

• photos: uploaded to a private, access-controlled storage bucket (face-scans) solely so the automated analysis can run. The photo is deleted from our servers immediately after the analysis has been performed, typically within seconds of upload. We do not store face photos at rest on our servers (see Section 7). Your before/after photos are stored only locally on your device.
• metadata and results (numeric scores and short cosmetic text findings, no facial imagery): Supabase database (scans)

Purpose: cosmetic skin analysis, progress tracking, plan adaptation
Legal basis: Art. 6(1)(b) GDPR; for processing of facial images, where applicable Art. 9(2)(a) GDPR (explicit consent), which you give by actively using the scan feature.

3.4a Face Data: Retention and Sharing at a Glance

Because face photos are sensitive, here is a plain-language summary of exactly how we handle them:

• Is face data retained? No. We do not retain face data. Face photos are processed transiently and are not stored at rest on our servers. We do not create face templates, faceprints, or any biometric identifiers, and we do not perform face recognition.
• Why is face data processed and stored at all? A face photo is uploaded for one single reason: to run the automated cosmetic skin analysis that computes your scores. There is no other storage purpose.
• How long is face data stored, and why this length? The uploaded photo remains on our servers only for the duration of the analysis itself, typically a few seconds, from upload until the analysis has been performed, and is then deleted automatically. We chose this minimal duration because the photo is needed solely as input for the score computation; nothing in the service requires keeping it afterwards. If an analysis cannot be completed (e.g. a network error), the residual upload is deleted automatically with your next scan and, in any event, when you delete your data or account.
• Which third parties is face data shared with? Two categories only: (1) Supabase Inc. (our hosting provider, as a processor) transiently handles the upload described above; (2) one AI vision provider per analysis, Google LLC (Gemini API) or OpenAI, L.L.C. (OpenAI API), depending on our server configuration. Face data is not sold and is not shared with anyone else, in particular not with Meta or any advertising partner.
• Why is face data shared with these third parties? Solely so the automated cosmetic analysis can be performed: Supabase provides the infrastructure that receives the upload, and the AI vision provider's model computes the cosmetic scores from the photo. No advertising, profiling, identification, or other purpose.
• Do these third parties store face data?
  • Supabase: only the transient upload described above, which we delete immediately after the analysis. Supabase does not use the data for any own purposes (processor under Art. 28 GDPR).
  • Google (Gemini API, paid tier): Google does not use API inputs or outputs to train its models. Google retains API prompts (including images) and outputs for up to 55 days solely to detect and prevent violations of its Prohibited Use Policy (abuse monitoring), after which they are deleted. See Google's Gemini API usage policies: https://ai.google.dev/gemini-api/docs/usage-policies.
  • OpenAI (API): OpenAI does not use API inputs or outputs to train its models. OpenAI retains API abuse-monitoring logs (which may include prompts such as images) for up to 30 days solely to enforce its usage policies and prevent harmful use, after which they are deleted. See OpenAI's API data controls and enterprise privacy commitments: https://openai.com/enterprise-privacy/.

3.5 Product Check (Product Photos)

With the product check, you can photograph a skincare product (e.g. its front or ingredient list) to see whether it suits your skin. We process:

• the product photo,
• the result: product name, brand, category, suitability score, verdict, short reasons, and flagged ingredients.

Storage: the photo is uploaded to a private storage bucket (product-scans) solely for the analysis, sent to the AI vision provider (Section 5), and deleted from our servers immediately afterwards. The result is stored in our database (product_scans) so you can see your history; the photo itself is kept only locally on your device. Product photos should not show your face or other people.
Purpose: product suitability check, history, plan personalization
Legal basis: Art. 6(1)(b) GDPR

3.6 Skincare Plans and Progress

• personalized 8-week plan (morning/evening routine),
• plan versions and adaptation reasons on re-scans,
• daily routine completion (e.g. completed steps, water intake) and the days you opened the App (for your streak),
• selected products (name, store, price, volume, affiliate flag) and, where you report it, whether and when you bought them.

Storage: Supabase database (plans, plan_adaptations, task_completions, user_products) and locally on your device
Legal basis: Art. 6(1)(b) GDPR

3.7 Subscription and Payment Data

Payment details (e.g. credit card) are not processed by us; they are handled exclusively by Apple through the App Store.

We store:

• subscription status (active/inactive),
• product ID (e.g. monthly or lifetime; earlier plans such as annual or weekly for existing subscriptions),
• subscription start and expiry dates,
• RevenueCat events for subscription synchronization.

Providers: Apple App Store, RevenueCat
Legal basis: Art. 6(1)(b) GDPR

3.8 Location (Optional)

If you grant location permission, we process:

• GPS coordinates temporarily to find nearby drugstores,
• a derived country code (stored locally),
• drugstore names, brands, and distances.

Location coordinates are not permanently stored on our servers. Store lookup uses the OpenStreetMap Overpass API; climate data (UV index, humidity, temperature, air quality) is fetched via Open-Meteo and stored locally on your device. Your location is never shared with Meta or used for advertising.

Legal basis: Art. 6(1)(a) GDPR (consent, revocable in device settings)

3.9 Local App Data

On your device, we store among other things:

• app settings (language, dark mode, reminders),
• local copies of scan and product photos in app storage,
• cached catalog and recommendation data,
• session data (Supabase Auth via AsyncStorage),
• a random installation ID for the usage statistics (Section 3.11).

Legal basis: Art. 6(1)(b) GDPR; for the installation ID Art. 6(1)(f) GDPR

3.10 Technical Log Data

On our servers, the following may be generated:

• AI usage logs (function name, timestamp) for abuse prevention,
• RevenueCat webhook events,
• standard server logs from our service providers.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in operation and security)

3.11 Usage Statistics (Our Own Analytics)

To understand how the App is used and to improve it (e.g. where users drop off in the onboarding, which screens confuse, whether a new version works better), the App records usage events in our own database. We do not use third-party analytics services. An event contains:

• the event name and context (e.g. "screen viewed", "quiz question answered" with the selected answer option, "paywall viewed", "purchase started/completed" with product and price, "routine block completed"),
• a random installation ID and session ID, and, once you are signed in, your account ID,
• app version and build, operating system version, device model (e.g. "iPhone15,2", never the device name you chose), and language/region setting,
• timestamp.

The events contain no photos, no location, and no free text you typed. Quiz answers are recorded as the predefined answer options you selected.

Storage: Supabase database (events). Only we can read this data; the App can only write it.
Retention: for as long as needed to evaluate App versions, at most 24 months. When you delete your account, the events are detached from your account and remain only under the random installation ID.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in improving the App and its onboarding). You can object at any time by email (Section 12); we will then delete the events linked to your account and installation ID.

3.12 Install Attribution and Advertising Measurement

To understand which of our marketing channels bring users and to measure our own advertising, we use the following. None of it is used to show you ads inside Sharp.

a) Apple Search Ads attribution. On first launch, the App requests an attribution token from Apple (AdServices framework, no advertising identifier needed) and our server exchanges it with Apple for the campaign that led to the install, if any. We store the campaign, ad group and keyword IDs and the country in your profile.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in measuring our marketing).

b) Creator links. If you open Sharp via a creator's referral link, our Creator Hub logs the click with a one-way hash of your IP address (not the IP address itself). On first launch, the App asks the Creator Hub whether a click from the same network happened in the previous 72 hours; if so, the creator's code is stored in your profile so the creator can be credited for a resulting subscription. Creators see only aggregated numbers, never your identity. You can also enter a creator code manually.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in crediting partners).

c) Meta (Facebook) advertising measurement, only with your consent. On first launch, iOS asks whether Sharp may track your activity across apps and websites owned by other companies (App Tracking Transparency). Only if you choose "Allow":

• the App starts the Meta SDK, which sends app events to Meta (such as app install and app opens), together with your device's advertising identifier (IDFA), a Meta anonymous ID, device and app information, and your IP address;
• our subscription provider RevenueCat forwards your purchase events (product, price, currency, time) with these identifiers to Meta via Meta's Conversions API;
• Meta uses this data to tell us which of our ads led to installs and purchases, and to optimize the delivery of our ads.

If you choose "Ask App Not to Track", the Meta SDK is not started and no data is sent to Meta. You can change your choice at any time in iOS Settings → Privacy & Security → Tracking; withdrawing consent stops all further transfers.

Recipient: Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, Ireland. For the collection and transmission of this data, we and Meta are joint controllers (Art. 26 GDPR); Meta's subsequent processing is Meta's own responsibility. Meta may transfer data to Meta Platforms, Inc. in the USA; Meta is certified under the EU-U.S. Data Privacy Framework and also uses Standard Contractual Clauses. Further information: Meta Privacy Policy, Meta Controller Addendum.
Legal basis: Art. 6(1)(a) GDPR and § 25(1) TDDDG (your consent).

Face photos, product photos, scan results, quiz answers, and your location are never shared with Meta.

3.13 What We Do Not Collect

• No third-party analytics services (no Google Analytics, Mixpanel, Firebase Analytics, etc.)
• No Meta data at all without your consent in the iOS tracking dialog
• No ads inside the App and no sale of your data
• No remote push tokens, reminders are local on your device only
• No microphone use, no audio is recorded despite any declared Android permissions

4. Camera and Photo Library

The App requires access to the camera to capture face photos for skin analysis and product photos for the product check. For positioning guidance, on-device face detection may be used; image data is not transmitted to us for this purpose.

Photo library permission may be used to select existing photos.

Legal basis: Art. 6(1)(a) GDPR (consent via the operating system)

5. AI Processing

We use artificial intelligence to analyze your skin and products and to generate plans and recommendations. Processing runs server-side via Supabase Edge Functions.

5.1 AI-Powered Features

5.2 AI Providers

Depending on server configuration, we use:

• Google Gemini (default, e.g. model gemini-2.5-flash), and/or
• OpenAI (e.g. model gpt-4o).

For image analysis, your photo is sent as a Base64-encoded JPEG to the respective vision service. Text data (quiz, scores) is sent to the text service.

Neither provider uses data submitted through their APIs to train their models. Google retains API inputs and outputs for up to 55 days solely for abuse monitoring (Gemini API usage policies); OpenAI retains API abuse-monitoring logs for up to 30 days (OpenAI enterprise privacy). After these periods the data is deleted. See Section 3.4a for the full face-data summary.

AI output is cosmetic assessment only, not medical diagnosis.

5.3 Rate Limits

To prevent abuse, per-user limits apply on our servers, including:

• skin analysis: 5 calls/day
• product check: 10 calls/day with Sharp Premium, 3 in total without
• plan creation: 3 calls/day
• product recommendations: 5 calls/day
• weekly re-scan: 3 calls/day

6. Recipients and Processors

We use the following service providers:

Where required, we conclude data processing agreements (DPAs) under Art. 28 GDPR with processors. For transfers to third countries (especially the USA), we rely on appropriate safeguards, such as the EU-U.S. Data Privacy Framework or EU Standard Contractual Clauses.

7. Retention

We retain personal data only as long as necessary for the purposes described:

• face photos and product photos: transient processing only; we do not store them at rest on our servers. An uploaded photo is kept on our servers only for the moment it takes to run the automated analysis and is deleted automatically as soon as the analysis has been performed, typically within seconds of upload. We use this minimal retention period because the photo is needed solely to compute the result; nothing in the service requires the server to keep it afterwards. In the rare case that an analysis cannot be completed (e.g. a network error), the residual upload is deleted automatically with your next scan and, in any event, immediately when you delete your data or account. The photos shown in the App (e.g. before/after comparison, product history) are stored exclusively locally on your device and never leave it except for the transient analysis described above,
• scan and product check results (numeric scores and short text findings; these contain no facial imagery and are not face data): for as long as your account exists, so the App can track your progress over time,
• account data, quiz, plans, attribution data: for as long as your account exists,
• usage statistics: at most 24 months (Section 3.11),
• subscription/webhook logs: as required by law and for technical necessity,
• data received by Meta (only with consent): according to Meta's own retention rules (see Meta Privacy Policy),
• local device data (including your photos for the before/after view): until you delete data in the App or uninstall the App.

8. Deleting Your Data

8.1 "Delete Data" in the App

Under Settings → Delete Data, you can permanently delete your data. After confirmation:

If you are signed in, we delete:

• your account (Supabase Auth),
• your profile, onboarding quiz, scan and product check results, plans, product selections, attribution data, and routine history from our database (via cascade delete),
• all face and product photos remaining in our private cloud storage (face-scans and product-scans buckets),
• your local data on the device (local photos, app state, and preferences).

Usage statistics are detached from your account and remain only under the random installation ID (Section 3.11). If you want them deleted as well, email us.

If you are not signed in, we delete local data on your device only (local photos and app state).

This action cannot be undone.

If deletion fails (e.g. no network connection), you will see an error message and your data will not be removed until deletion succeeds.

Data already transmitted to Meta with your consent is not deleted by this action; you can manage it via your Meta account or by contacting Meta.

8.2 Sign Out

Sign Out in Settings ends your session only. Your stored server data remains until you use Delete Data or request deletion by email.

8.3 Deletion by Email

You may also request deletion of your account and associated data at any time by emailing:

daybeeapp-privacy@web.de
Subject: "Sharp account deletion"

We will process your request within 30 days, unless legal retention obligations apply.

9. No Medical Diagnosis

Sharp is a cosmetic skincare tool. Analyses, scores, and recommendations:

• are not medical diagnoses,
• do not replace a visit to a healthcare professional,
• do not constitute treatment promises.

For skin conditions, severe reactions, or health concerns, consult qualified medical personnel.

10. Advertising

We do not show ads in the App and do not sell your data. We advertise Sharp on other platforms (e.g. Instagram and Facebook) and measure these campaigns as described in Section 3.12. Measurement through Meta only takes place with your consent in the iOS tracking dialog. Amazon affiliate links in product recommendations are for product linking only, not for tracking your browsing behavior.

11. Security

We implement appropriate technical and organizational measures, including:

• encrypted transmission (HTTPS/TLS),
• JWT authentication,
• private storage of photos (not publicly accessible),
• Row Level Security (RLS) in the database, users can access only their own data,
• server-side validation of AI output and upload paths,
• rate limiting for AI calls,
• hashing of IP addresses for creator link attribution.

Absolute security cannot be guaranteed.

12. Your Rights

You have the following rights against us:

• access (Art. 15 GDPR),
• rectification (Art. 16 GDPR),
• erasure (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• objection (Art. 21 GDPR), in particular to processing based on legitimate interest (usage statistics, attribution),
• withdrawal of consent (Art. 7(3) GDPR) with effect for the future, e.g. for tracking via iOS Settings → Privacy & Security → Tracking, or for location via the iOS location settings.

To exercise your rights, email daybeeapp-privacy@web.de. For data processed by Meta under joint controllership, you can also contact Meta directly.

13. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your residence.

In Germany, for example:

Federal Commissioner for Data Protection and Freedom of Information (BfDI)
https://www.bfdi.bund.de

Or the data protection authority of your federal state.

14. Requirement to Provide Data

Account data and face photos are required for core App features. Without registration and photos, analysis, plans, and progress tracking cannot be used. Location, product photos, reminders, and tracking consent are optional.

15. Minors

The App is intended for users aged 16 and older. We do not knowingly collect data from children under 16.

16. Changes to This Privacy Policy

We may update this policy when legal requirements, App features, or services change. The current version is available in the App and on this website.

We will notify you appropriately of material changes.

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