Legal

Privacy Policy

Last updated: 22 September 2026 · Effective: 22 September 2026

1. Who we are

Facely is a mobile application that analyses photos of your face to produce an aesthetic score, builds a daily improvement routine from that score, and lets you track changes over time. This policy explains what the app does with your information.

The app is operated by Awale Hussein, an individual based in Ontario, Canada, operating as "Facely" ("Facely", "we", "us"). Awale Hussein is the data controller for the information described here. You can reach us at awalehussein2004@gmail.com.

This policy covers the Facely iOS app and these web pages. It does not cover any third-party service you reach from the app, such as the Apple App Store.

2. What we collect

Facely has no sign-up form. Everything below is either created by you using the app, or generated by the app as a result of you using it.

Photos of your face

When you take a scan, the app captures or lets you select two photos — one front-facing and one side profile. If you generate a "potential" preview, your front photo is used again. See section 3 for exactly what happens to them.

Scan results

For each scan we store, against your anonymous account: an overall score (0–100); four sub-scores — eye area, skin, jawline and cheekbones — each with a short written rationale describing the features the model observed; a "most fixable issue" note; and the date and time of the scan. The photo itself is not part of this record.

Profile answers you give during onboarding

A display name if you choose to enter one, gender, date of birth, height, weight, what you most want to improve, your current skincare routine, how much time you can commit daily, where you heard about Facely, and what has held you back before.

Routine and progress data

The daily tasks generated for you, the date each belongs to, its category and text, whether you completed it, and whether a monthly streak protection was applied. Your streak, weekly recap and habit progress are all derived from these records rather than stored separately.

AI Coach conversations

The messages you send to the AI Coach and the replies it sends back, grouped into conversation threads, with timestamps.

Feedback you choose to send

If you submit written feedback in the app, we store the message text.

Your account identifier

Facely signs you in anonymously. Our systems hold a randomly generated account ID and the dates the account was created and last seen. That ID is not linked to your name, email address, phone number, Apple ID, advertising identifier or any other real-world identity.

Information stored in the app on your device

The app keeps the following in its own private storage on your phone, where we cannot read it: your scan photos and any generated potential image, your display name, whether you have finished onboarding, and your reminder preferences and scheduled reminder identifiers. Because the photo files are kept in the app's Documents storage, iOS may include them in an iCloud or encrypted Finder/iTunes backup, depending on your device settings. Those backups are controlled by Apple and your device; Facely does not receive or manage them.

Subscription and paywall information

When the subscription screen appears, our paywall provider (Superwall) records that it was shown and what you did with it — dismissed it, started a free trial, or subscribed — along with your device model, operating system version, app version, locale, and an identifier its software generates for your installation of the app. If you subscribe, it records which product you bought and whether your subscription is active, so the app knows what to unlock.

That identifier is separate from your Facely account ID, and we do not connect the two. Superwall receives no photos, no scores, no routine data and no coach conversations.

Technical and diagnostic information

Our hosting provider records ordinary server logs when the app talks to our backend, including IP address, timestamp and the request made. These are used for security, abuse prevention and debugging, and are retained for a short period.

App update checks

When the app opens, it checks our app-update provider, Expo (EAS Update), for bug fixes and small improvements, which it downloads in the background. That request includes your IP address, your platform, the app version and update channel, the identifiers of the updates already installed, and an identifier Expo's software generates for your installation of the app. It contains no photos, scores, routine data, coach messages or Facely account ID, and we do not connect that identifier to your account.

Apple may also provide us with aggregated App Store analytics and crash reports. Whether Apple shares these depends on the settings on your device, and they are not linked by us to your Facely account.

3. What happens to your photos

The full journey of a scan photo is:

1. You take or select two photos. They stay on your device.
2. The app resizes and compresses them on your device to reduce their size.
3. The app saves its own copy into Facely's private storage area on your phone, so you can review past scans and build before/after comparisons offline.
4. The app sends the two images over an encrypted connection to our scoring service, which holds them in memory only.
5. Our service forwards them to the Google Gemini API for analysis, and receives back scores and written rationales.
6. We save the scores and text to your account. The images are discarded when the request ends — they are never written to disk or to a database.

The "potential" image follows the same path: your front photo goes to Google's Gemini image model, the generated portrait comes back, and the app saves it on your device. Neither the input photo nor the generated image is stored on our servers.

The scan fingerprint

So that the same pair of photos always produces the same score rather than drifting between runs, we store a one-way cryptographic hash (SHA-256) of the two images alongside the resulting scores. A hash is a short irreversible fingerprint: it cannot be turned back into your photo, and it does not visually resemble it. This record contains no account identifier and is not linked to you.

Photos you save or share yourself

If you save a score card or a before/after card to your photo library, or send it through the iOS share sheet, that is your action and the resulting file is governed by whichever app or service you send it to. We are not involved in that transfer and receive no copy.

4. AI processing and the providers we use

Facely could not function without AI analysis. Three features send your information to Google's Gemini API (Google LLC / Google Ireland Limited), operating at generativelanguage.googleapis.com:

Feature	What is sent to Google	What comes back
Face scan	Your front and side photos, plus our scoring instructions. No name, account ID or profile answers.	An overall score, four sub-scores with written rationales, and a "most fixable issue" note.
Potential preview	Your front photo, plus our image-editing instructions.	An edited version of your photo showing a plausible improved result.
AI Coach	Your message, up to your last 20 messages in that thread, your most recent scan's scores and notes, and your most recent day of routine tasks. No photos are sent to the Coach.	A short written reply.

All three calls are made by our own backend, never directly by the app, so your data travels to Google through us and our API credentials are never present on your device.

Google processes this data as our service provider in order to return a result. Google states that content submitted through its paid Gemini API is not used to train its models and is retained only transiently for abuse monitoring. Google's handling of that data is governed by its own terms — see the Gemini API Terms of Service and the Google Privacy Policy.

The specific Gemini models we use may change as Google releases new versions. The categories of data described above will not change without an update to this policy.

5. How we use your information

• To score your scans and show you your results and history.
• To build your daily routine — your weakest sub-scores determine which tasks you get.
• To power the AI Coach, so its answers reference your actual scores and tasks instead of being generic.
• To generate your potential preview, when you ask for one.
• To track your progress — streaks, weekly recaps, habit graduation and before/after comparisons.
• To send you local reminders, if you turn them on.
• To keep the service running and fair — preventing abuse, enforcing the limit of five scans per UTC calendar day, debugging faults and keeping costs sustainable.
• To manage subscriptions, where you purchase one.
• To respond to feedback you send us.

Where the UK and EU GDPR apply, our legal bases are: performance of a contract for the core scanning, routine, coach and subscription features; your explicit consent for processing photographs of your face (see section 7), which you may withdraw at any time by deleting your account; and our legitimate interests in securing the service and preventing abuse.

6. What we never do

• We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We have never done so.
• Facely contains no advertising SDKs and no tracking pixels, and we run no general-purpose analytics on how you use the app. The single exception is the paywall measurement described in section 2, which covers the subscription screen only. We do not track you across other apps or websites, and we do not use the Apple advertising identifier (IDFA) or ask for App Tracking Transparency permission.
• We do not send your photos, scores, routine or coach conversations to our paywall provider. It is told whether to show a paywall, not who you are.
• We do not use facial recognition, identity matching or face search. Facely never attempts to work out who you are.
• We do not collect your location. The app requests no location permission.
• We do not access your contacts, calendar, microphone, health data or messages.
• We do not read your photo library. You choose which images to give the app, through the standard iOS picker.
• We do not store your photos on our servers, and we do not use your photos to train any AI model — ours or anyone else's.
• We do not show your results to other users. Facely has no public profiles, no social feed and no leaderboard.

7. Facial data notice

A photograph of your face is sensitive information, and some laws — including the EU and UK GDPR, the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act, and the Washington My Health My Data Act — apply special rules to facial data. We want to be precise about what Facely does.

What Facely does: an AI model looks at your photo and describes and rates visible features — the shape of your jaw, the condition of your skin, the area around your eyes, your cheekbones — to produce a score and a routine.

What Facely does not do: it does not generate a faceprint, face template, face geometry scan or any other mathematical representation of your face used for identification. It does not compare your face to other users' faces or to any external database. It cannot recognise you in another photo, and it is not capable of identifying you from your face at all.

If facial data is nonetheless treated as biometric information where you live, then: we collect it only to provide the scanning feature you requested; we ask for your consent before your first scan, which the act of submitting photos to be scanned expresses; we never sell, lease, trade or otherwise profit from it; we disclose it only to the AI provider named in section 4, as necessary to deliver the result you asked for; and we retain the photographs for no longer than the duration of the request that processes them, which is a matter of seconds.

If you do not want your photographs processed this way, do not submit a scan. Facely's core feature cannot operate without it.

8. Who we share data with

We share your information only with the following service providers, only for the purposes described, and never for their own marketing:

Provider	Role	What they receive
Google (Gemini API)	AI analysis	Photos, scan results, routine tasks and coach messages, as set out in section 4
Supabase	Database, authentication and backend hosting	All data we store: your anonymous account ID, scan results, profile answers, routine records, coach messages, feedback, public.generation_log records and public.scan_quota daily counters. No photos.
Superwall	Presenting the subscription paywall and tracking whether your subscription is active	Device and app information, an identifier generated for your installation, which paywalls you were shown and what you did with them, and your purchase and subscription status. No photos, scans, routine data or coach messages.
Expo (650 Industries, Inc. — EAS Update)	Delivering bug fixes and small improvements to the app	IP address, platform, app version and update channel, the identifiers of installed updates, and an identifier generated for your installation. No photos, scans, routine data, coach messages or account ID.
Apple	App distribution, in-app purchases and, if you allow it, crash reporting	Purchase and subscription information, which Apple handles under its own privacy policy. Apple never receives your scans or photos from us.

We may also disclose information if we are legally required to, or where it is necessary to investigate abuse, fraud or a threat to someone's safety. If Facely is ever acquired or merged, data may transfer to the acquiring entity, which would remain bound by this policy or give you notice of any change.

9. Storage, retention and deletion

Data	Where	Kept for
Face photos	Your device and, depending on your Apple backup settings, iCloud or encrypted Finder/iTunes backups; in memory on our servers during a request	On your device until you delete them or the app; Apple backup copies follow Apple's backup retention and deletion controls; on our servers, seconds
Scan scores and history	Our database	Until you delete your account
Profile answers	Our database	Until you delete your account
Routine and streak records	Our database	Until you delete your account
AI Coach messages	Our database	Until you delete your account
Usage and rate-limit records (public.generation_log and public.scan_quota)	Our database	Until you delete your account
Scan fingerprint (hash) and score	Our database, unlinked to any account	Indefinitely, as it contains no personal identifier
Server logs	Our hosting provider	A short period, for security and debugging

Deleting your account

Open Profile → Delete my account. This permanently deletes your account and everything attached to it — your scan history, profile answers, routine records, coach conversations and feedback — and cannot be undone. The app also clears the data held on your device, including your locally stored scan photos and potential image, and cancels any scheduled reminders. It does not itself remove copies already captured by Apple backups; manage those through Apple's device and backup controls.

The only thing that survives is the anonymous scan fingerprint described in section 3, which holds no identifier that could connect it to you or to your deleted account.

Signing out

Because Facely accounts are anonymous and there is no way to sign back in, signing out is permanent. It clears the app's data on your device and you will start fresh as a new user. Your previous account data is not recoverable by you or by us. The same applies if you delete the app or lose your device.

10. Security

• All traffic between the app, our backend and our AI providers is encrypted in transit with TLS.
• Database access is protected by row-level security, so one account cannot read another's scans, routines, conversations or profile.
• AI-generated records — your scores and coach replies — are written only by our backend services, never directly by the app, so a client cannot fabricate or alter results.
• Our AI provider credentials exist only on the server. They are never included in the app.
• The app holds your photos in its own private storage area, which other apps on your device cannot read.

No system is perfectly secure, and we cannot guarantee absolute security. Because accounts are anonymous, anyone with access to your unlocked device has access to your Facely data — please protect your device with a passcode or biometric lock.

11. Your rights and choices

In the app

You can view all of your stored results in the app, change your reminder preferences, and delete your entire account at any time.

If you are in the EEA, UK or Switzerland

You have the right to access, correct, delete, restrict and object to the processing of your personal data, the right to data portability, and the right to withdraw consent at any time. You also have the right to lodge a complaint with your local data protection authority.

If you are in California

Under the CCPA/CPRA you have the right to know what personal information we collect, use and disclose; the right to delete it; the right to correct it; the right to opt out of sale or sharing; and the right to limit the use of sensitive personal information. We do not sell or share personal information, so there is nothing to opt out of. We use the sensitive information we collect — photographs of your face — only to provide the feature you requested, which is a use that does not require an opt-out under the CPRA. We will not discriminate against you for exercising any right.

Other US states

Residents of states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah and Texas, have comparable rights of access, correction, deletion, portability and opt-out. We honour those requests on the same terms.

If you are in Canada

We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. You have the right to access the personal information we hold about you, to ask us to correct it, and to withdraw your consent to our processing at any time — which you can do immediately by deleting your account in the app. Because Facely accounts are anonymous, the verification limits described below apply.

If you are not satisfied with how we have handled a privacy concern, you may contact the Office of the Privacy Commissioner of Canada, or your provincial privacy commissioner.

Making a request

The fastest route is the in-app delete, which fulfils a deletion request immediately. For anything else, email awalehussein2004@gmail.com. Please note an important limitation: because accounts are anonymous and we hold no email address or name, we usually cannot connect an email request to an account. We may have to ask you for information from inside the app to locate your records, and if we cannot verify that the account is yours we may be unable to act — a safeguard that prevents anyone else acting on your account either.

12. Children

Facely is not intended for, and may not be used by, anyone under 13. We do not knowingly collect information from children under 13. If you are between 13 and the age of majority where you live, you may use Facely only with the consent and supervision of a parent or guardian.

Because Facely rates appearance, we consider it unsuitable for younger teenagers regardless of legal minimums, and it is rated accordingly on the App Store. If you believe a child has provided us with information, contact awalehussein2004@gmail.com and we will delete it.

13. International transfers

Facely is operated from Ontario, Canada. Its data is stored and processed in facilities that may be located outside your country — and outside Canada — including in the United States, where our hosting, AI, paywall and app-update providers operate. Information stored outside Canada may be accessible to the courts and law enforcement of that country under its laws. Where we transfer personal data out of the EEA or the UK, we rely on the European Commission's Standard Contractual Clauses, or an equivalent lawful transfer mechanism, in our agreements with our providers.

14. App Store privacy summary

For reference, this is how the data described above maps to Apple's privacy categories. Nothing in Facely is used for tracking or for third-party advertising.

Category	Collected?	Linked to you?	Used for tracking?
Photos (face scans)	Yes — processed, not stored by us	No	No
Health & fitness (height, weight)	Yes	Linked to an anonymous ID only	No
Other user content (coach messages, feedback)	Yes	Linked to an anonymous ID only	No
User ID	Yes — randomly generated, anonymous	N/A	No
Purchases	Yes — billed by Apple, recorded by Superwall	No	No
Product interaction (subscription screen only)	Yes	No	No
Device ID (installation identifiers used by the paywall and app updates)	Yes — randomly generated	No	No
Diagnostics	Yes — server logs and optional crash reports	No	No
Contact info, location, contacts, browsing history, search history, advertising data	No	—	—

15. Changes to this policy

We will update this policy when the app changes. The "last updated" date at the top always reflects the current version. If a change materially affects how we handle your information — for example, a new category of data or a new provider — we will give notice in the app before it takes effect. Continuing to use Facely after a change means you accept the updated policy.

16. Contact us

Questions, requests or complaints about privacy: awalehussein2004@gmail.com.

Facely is operated by an individual rather than a company, so we do not publish a business address. If you need a postal address for a formal legal or regulatory request, email us and we will provide one.