Privacy Policy

Last updated: June 2026

I. Introduction

SLNP OFFICE DOO (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, and process information when you access or use the mobile application (the “App”).

For the purposes of this Privacy Policy, “personal data” means any information relating to an identified or identifiable individual, directly or indirectly.

This Privacy Policy applies to all users of the App (“Users”).

Please read this document carefully. By using the App, you confirm that you have read, understood, and agreed to this Privacy Policy.

We do not sell your personal data to third parties.

II. Information We Collect

We may process different categories of information depending on how you use the App.

1. Information You Provide

We collect information that you voluntarily provide when using the App, including:

• Personal data such as your age, skin type, skin concerns, and facial yoga goals, if you choose to provide such data during onboarding or profile setup.
• Progress data such as photos taken within the App for transformation tracking, if you choose to use this feature.
• Contact information, including your email address and any content you provide when contacting support.

This information is used to personalize your experience and deliver the App’s core features.

Transformation photos are stored locally on your device. They are not transmitted to our servers unless you actively initiate a skin analysis or retouching feature. You can modify or delete this data at any time, and it will be removed upon uninstalling the App.

2. Face Data and AI-Based Skin Analysis

The App offers optional features that involve processing photos of your face:

a) Skin Analysis

When you choose to use the skin analysis feature, a photo of your face is temporarily transmitted over an encrypted HTTPS connection to OpenAI’s API (GPT-4.1-nano model) for analysis of visible skin characteristics such as hydration level, texture, and signs of aging. The analysis result is returned to your device and stored locally. The photo itself is not retained by our servers after processing is complete.

OpenAI may retain a copy of the request in accordance with its own data retention policy (up to 30 days). For more information, please refer to OpenAI’s Privacy Policy at https://openai.com/policies/privacy-policy.

b) Cosmetic Retouching

When you use the retouching feature, photo processing is performed entirely on our own servers to generate a visualization of how the user's face may look after completing facial yoga exercises. No photo data is transmitted to any external third-party service. A temporary image file is created during processing and deleted immediately after the task completes. The result is cached for up to 24 hours in our processing backend (Redis), then automatically deleted.

What face data we collect and how it is used:

• Type of data: photos of your face (JPEG), submitted voluntarily when you initiate a skin analysis or retouching session.
• Purpose: one-time skin condition assessment (hydration, texture, wrinkles) and/or visualization of potential facial yoga results through cosmetic retouching of the photo. The data is not used for personal identification, biometric profiling, or targeted advertising.
• Third-party sharing: photos are shared only with OpenAI for the skin analysis feature, solely for the duration of processing. No face data is shared with any other third party.
• Storage — on-device: selected transformation photos are stored locally until you delete them or uninstall the App. Non-selected photos from past sessions are deleted automatically.
• Storage — server-side: no permanent storage of face photos takes place on our servers. Temporary processing files are deleted immediately upon completion. Processing results are retained for up to 24 hours in our backend cache, then automatically purged.
• Storage — OpenAI: OpenAI may retain a copy of submitted requests for up to 30 days in accordance with their data retention policy.
• Biometric data: the App does not collect Face ID data, fingerprints, or any biometric identifiers. Face photos are used solely for visual skin assessment and cosmetic processing.

Use of the skin analysis and retouching features is entirely optional. You may use the App without activating these features.

3. Functional Information

To enable core App features, we may process:

• Data related to App usage, completed exercises, and skin care routines;
• Reminder and notification preferences;
• Streak and progress history.

4. Automatically Collected Information

When you use the App, certain data may be collected automatically. This data is typically aggregated and does not directly identify you.

We may collect:

• Device information: device type, operating system, model, screen characteristics, memory usage;
• Connection data: IP address, network provider, connection type, session duration;
• Location-related data: approximate location derived from IP, language, time zone;
• Identifiers: advertising IDs or similar device identifiers;
• Usage data: interactions with the App, session times, feature usage;
• Log data: technical logs related to App performance;
• Advertising data: information about ads displayed and interactions with them.

We may use third-party analytics and advertising services that process such data automatically, including profiling to better understand user behavior and preferences.

We do not control how third-party providers process data collected through their own technologies. For more information, please refer to Section IV.

5. Camera Access

The App may request access to your device’s camera for the transformation tracking feature (taking before/after photos) and for capturing photos used in the optional skin analysis or retouching features. Camera access is used only when you actively initiate one of these features. No camera data is processed in the background or transmitted without your action.

You can revoke camera access at any time through your device settings.

6. Payment Information

In-app purchases and subscriptions are processed by third-party platforms (e.g. Apple App Store).

We do not collect or store your payment details such as credit card information.

III. Purposes of Data Processing

We process your information for the following purposes:

• To provide the App functionality and deliver requested services;
• To personalize your facial yoga programs, skin care routines, and reminders based on your profile;
• To perform optional AI-based skin analysis and cosmetic retouching when you actively initiate these features;
• To improve and optimize the App, including performance monitoring and troubleshooting;
• To personalize content and advertising, where applicable;
• To communicate with you, including responding to inquiries and sending updates;
• To ensure security, prevent fraud, and enforce our Terms of Use.

If we introduce new purposes for processing, we will update this Privacy Policy accordingly.

IV. Sharing of Information

We may share your information only as described below:

• OpenAI — face photos are transmitted to OpenAI solely for the purpose of skin analysis when you choose to use this feature. OpenAI processes this data in accordance with its own Privacy Policy. No other face data is shared with OpenAI or any other AI provider.
• With service providers and partners (e.g. analytics or advertising providers) that support the operation of the App;
• When required by law or legal process;
• To protect our rights, safety, or property, or that of our users or others;
• In connection with a business transfer, such as a merger or acquisition.

We do not sell or rent your personal data.

While we carefully select partners that apply appropriate data protection measures, we are not responsible for their independent data processing practices.

The App may contain links to third-party services. We are not responsible for their privacy practices.

V. International Data Transfers

Your information may be transferred to and processed in countries outside your place of residence, including in connection with the use of OpenAI’s services.

These jurisdictions may have different data protection laws. By using the App, you consent to such transfers.

We take reasonable steps to ensure that your data is protected in accordance with applicable laws, including using encrypted connections and, where possible, minimizing the data transmitted.

VI. Data Retention

We retain your personal data only for as long as necessary:

• to provide the App’s functionality;
• to comply with legal obligations;
• to resolve disputes and enforce agreements.

With respect to face data specifically:

• Face photos used for skin analysis are not permanently stored on our servers. Temporary processing files are deleted immediately upon completion of the analysis.
• Processing results are retained in our backend cache for up to 24 hours, then automatically deleted.
• OpenAI may retain a copy of submitted requests for up to 30 days per their data retention policy.
• Transformation photos stored on your device are retained until you delete them or uninstall the App.

You may request deletion of your data where applicable.

Some data may be retained for a limited period where required for legal, security, or backup purposes.

VII. Your Rights

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

• Access your personal data;
• Correct or update inaccurate data;
• Request deletion of your data;
• Restrict or object to certain processing activities;
• Request data portability.

To exercise these rights, please contact us using the details provided below.

For data processed by third-party services such as OpenAI, you may need to contact those providers directly.

VIII. Your Choices (Opt-Out)

Advertising Preferences

You can limit personalized advertising by adjusting your device settings:

• On iOS: enable “Limit Ad Tracking” in your device settings.

You may still receive non-personalized ads.

Notifications and Reminders

You can manage or disable push notifications and daily reminders at any time through your device’s notification settings or within the App.

Camera Access

You can revoke camera access at any time through your device settings. This will disable the transformation photo, skin analysis, and retouching features.

AI-Based Features

The skin analysis and retouching features are entirely optional. You may use the App without activating these features, in which case no face data will be transmitted to our servers or to OpenAI.

IX. Data Security

We implement appropriate technical and organizational measures to protect your data from unauthorized access, loss, or misuse.

These measures include data minimization, encrypted HTTPS transmission, and immediate deletion of temporary processing files.

However, no system is completely secure. While we strive to protect your data, we cannot guarantee absolute security.

In the event of a data breach, we will notify you as required by applicable law.

X. Minors

We do not knowingly collect personal data from minors without parental consent. If we become aware that such data has been collected without appropriate consent, we will delete it promptly.

If you believe a minor has provided personal data without appropriate consent, please contact us.

XI. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Any changes will be reflected by updating the “Last updated” date. Continued use of the App after changes indicates your acceptance of the updated policy.

XII. Contact Information

If you have any questions about this Privacy Policy or your data, please contact us at help.direct@slnpoffice.com