This Privacy Policy describes how Rotenberg Softs (“we”, “us”), Bingen am Rhein, Germany, processes personal data in connection with the mobile application GlowFace – AI Face Rating & Glow Up (formerly published under the name “Looky”, the “App”).
1. Data Controller
Rotenberg Softs
Bingen am Rhein, Germany
E-mail: [email protected]
2. Data We Process
- Photos you submit: When you choose a photo for analysis, it is uploaded to our backend and processed by AI models solely to generate your analysis results. Submitting a photo is always your active choice and is subject to an in-app consent dialog.
- Analysis results: The scores and recommendations generated for your photos.
- Account and purchase data: If you make an in-app purchase, the purchase is processed by Apple App Store or Google Play. We do not receive your payment details.
- Usage and device data: App interactions, device type, operating system version, crash reports and approximate (IP-based) region, collected through the analytics and stability services listed below.
- Advertising data: If ads are shown in your version of the App, the advertising provider may process your advertising identifier in accordance with your consent choices.
3. Purposes and Legal Bases (GDPR)
- Providing the photo analysis you request – Art. 6(1)(b) GDPR (performance of contract) and, for the processing of facial images, your explicit consent, Art. 9(2)(a) GDPR.
- App stability, security and crash diagnostics – Art. 6(1)(f) GDPR (legitimate interest).
- Analytics and advertising – Art. 6(1)(a) GDPR (consent, where required).
- Processing purchases – Art. 6(1)(b) GDPR.
4. Service Providers We Use
- Supabase – backend infrastructure used to process photo analyses and store related data.
- Google Firebase (Analytics, Cloud Messaging, Crashlytics) – usage statistics, push notifications and crash reporting.
- Google AdMob – in-app advertising (where shown).
- Apple App Store / Google Play – distribution and in-app purchases.
These providers may process data outside the EU/EEA. Where this is the case, transfers are safeguarded by EU Standard Contractual Clauses or an adequacy decision (e.g. the EU-US Data Privacy Framework for participating US providers).
5. Storage and Deletion
Photos and analysis results are stored only as long as needed to provide the App's features. You can request deletion of your photos, results and any associated data at any time by contacting us at [email protected]; we will delete them without undue delay unless we are legally required to retain them.
6. Your Rights
Under the GDPR you have the right to access, rectify and erase your personal data, the right to restrict or object to processing, the right to data portability and the right to withdraw any consent at any time with effect for the future. You also have the right to lodge a complaint with a data protection supervisory authority, in particular the authority of your place of residence or ours (Landesbeauftragter für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz).
7. Children
The App is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can delete it.
8. Important Note on Results
Analysis results are generated by AI for entertainment and self-improvement purposes only. They are not medical, dermatological or psychological advice.
9. Changes to This Policy
We may update this Privacy Policy from time to time. The current version is always available at this address. Material changes will be communicated in the App.
10. Contact
Questions about privacy? Contact us at [email protected].
End User License Agreement: rotenbergsofts.de/en/eula