Biometric Data Policy

1. Scope

This Policy is our public written policy on biometric data. It applies to the face scan feature of the Nalumi web app and supplements our Privacy Policy. It is designed to meet the requirements of laws on biometric information, including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), Washington RCW 19.375 and similar laws.

Some of these laws treat a scan of face geometry as a “biometric identifier”. We do not use your face to identify you, but we apply this Policy to all face photos and face-derived data as if they were biometric data, wherever you live.

2. What We Collect

• Face photos you take in the app for a scan (a front photo and, optionally, side photos).
• Scan results derived from those photos: skin scores (such as tone evenness, redness, spots and texture), highlighted areas and a heat map of the skin.
• Facial geometry used temporarily. The face position guides shown while you take a photo are calculated on your device and never leave it. During analysis on our servers, our software maps the skin areas of the face; this geometry exists only in memory for the few seconds of analysis and is discarded immediately — it is never stored.

We do not create or keep a face template, faceprint or any data that could be used to recognise you or match your face with other images.

3. Why We Use It

We use face photos and scan results only to:

• show you a cosmetic analysis of what is visible on your skin;
• build and adjust your skincare routine;
• show how your skin looks over time when you compare scans.

We do not use them to identify or verify you, for advertising, for profiling unrelated to your skincare, or to train AI models. The scan is a cosmetic tool, not a medical diagnosis.

4. Your Consent

Before your first scan, the app shows a consent screen explaining what we collect, why, how long we keep it and that we never sell it, with links to this Policy and our Privacy Policy. Scanning is possible only after you actively agree. Your agreement is your written release under BIPA, given electronically; we record the date and time it was given and, if you withdraw it, when it was withdrawn.

You can withdraw consent at any time in the app. Withdrawing consent deletes all your face photos and scan results and turns the scan feature off until you consent again.

The face scan is available only to users aged 18 and over. Only scan your own face.

5. No Sale or Disclosure

We do not sell, lease, trade or otherwise profit from your face photos, scan results or any biometric data. We do not disclose them to anyone, except:

• to you;
• to infrastructure providers that host our servers and storage on our behalf, under contracts that require confidentiality and forbid any other use;
• where we are required to by law, a valid court order or subpoena.

Face photos are analysed only by our own software on our own servers; they are not sent to AI providers, analytics or advertising partners.

6. Retention and Destruction Schedule

We permanently destroy face photos and scan results at the earliest of the following:

• when you delete a scan in the app — that scan is deleted immediately;
• when you withdraw your consent — all your scans are deleted immediately;
• when you delete your account — all your photos and scans are deleted immediately;
• 1 year after your last activity in the Service — all your scans are deleted automatically;
• in any case, once the purpose of collecting them has been fulfilled, and never later than the maximum period allowed by applicable law (for example, 3 years after your last interaction under BIPA, or within 1 year of the purpose expiring under Texas law).

Destruction means the files and database records are permanently erased from our active systems. Any copies in encrypted backups are overwritten within 30 days.

7. How We Protect It

We store and protect face photos with at least the same care we use for our most sensitive information: encrypted connections, private storage that is not publicly accessible, short-lived signed links for viewing your own photos, and access limited to the systems that need it. Staff do not view your face photos except where strictly necessary to help you at your request.

8. Your Choices

• Use the Service without the face scan — your routine and product matches still work from your beauty profile.
• Delete individual scans, withdraw consent or delete your account in the app at any time.
• Ask us what face data we hold about you, or ask us to delete it, by emailing [email protected].

Contact

Questions about this Policy, or a request to access or delete your data? Write to us — we reply within 30 days, and sooner where the law requires.