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Glowdays Privacy Policy

Effective date: 15 October 2026 · Version: en-1

This policy explains how your personal data is handled when you use the Glowdays mobile app and the glowdays.app website. If anything is unclear, write to support@glowdays.app.

Summary

1. Who is responsible (controller)

Controller: Halil İbrahim Kes (natural person, Türkiye). Contact: support@glowdays.app. We have not appointed an EU or UK representative (GDPR Art. 27) because the app is not yet offered in the EU / EEA or the UK; if that changes, this section will be updated before launch there. We have not appointed a Data Protection Officer because we are not required to; privacy questions go to the address above.

2. What data we process

2.1 Data that stays on your device (never sent to us)

We do not see or process this data; it is kept in the app's storage on your device:

"Matches my profile" results, the compatibility score and the pregnancy filter are calculated on your device; your skin profile is not sent for them.

Your phone's own backup: on Android, Glowdays data is not included in the phone's Google backup. On iPhone, if iCloud Backup is on, this data is included in your phone's backup; that backup lives in your Apple account and Glowdays cannot access it.

2.2 Data sent to us when you use the app without an account

These requests are not linked to an account. Server logs keep the request address and IP address for at most 30 days. To limit abuse, request counts are kept per IP address and email; the address and email are stored in the counter only as a one-way hash, and each counter is deleted when its window (at most one day) ends.

2.3 If you create an account

2.4 If you contribute (account required)

Uploaded photos are re-encoded on our server and metadata such as location (GPS) and device details is removed. Face or skin photos are not allowed in reviews or community posts (product, packaging and shelf photos only).

2.5 Planned features

3. Why we process it and our legal basis

PurposeDataGDPR legal basis
Showing and searching product and ingredient information, analysing ingredient listssearch text, barcode, filters, IDs, ingredient text, IPperformance of a contract (Art. 6(1)(b))
Creating and running your account, signing you inemail / provider ID, nickname, sessionperformance of a contract (Art. 6(1)(b))
Saving your skin profile to your account and syncing your dataskin profile, safety answers (health data)explicit consent (Art. 6(1)(a) and Art. 9(2)(a))
Publishing and reviewing reviews, posts and product submissionsyour content, photos, nickname, tagsperformance of a contract (Art. 6(1)(b))
Security: preventing abuse, spam and illegal content; moderationIP, request logs, reports, rate-limit counterslegitimate interests (Art. 6(1)(f)) — keeping the service safe and usable
Proving consent and deletion requests, legal obligationsconsent records, request correspondencelegal obligation (Art. 6(1)(c)); legitimate interests (Art. 6(1)(f))
Finding and fixing errors (Sentry)technical error reportslegitimate interests (Art. 6(1)(f))

If you choose to share your skin type, age range or a skin experience publicly in a review or post, you make that information public yourself (Art. 9(2)(e)). Think twice before sharing; you can delete it at any time.

We do not use your data for advertising, marketing profiling or data sales. Health data is used only to give you recommendations and to store it in your account. The compatibility score and "Matches my profile" are suggestions, not automated decisions with legal or similarly significant effects on you (Art. 22 does not apply).

Providing data is voluntary. Without an account you can use the core features; to write reviews, post or submit products you need an account; without consent your skin profile simply stays on your device.

4. Who we share it with and international transfers

We share data only with service providers (processors) needed to run the service, under contract and only as far as necessary:

ProviderPurposeLocation
Render Services, Inc.server and database hostingGermany (Frankfurt); US-based company
Cloudflare, Inc.domain, firewall, photo storage (R2)global network; US-based company
Google LLC (Gmail)sign-in / verification emailsUS
Apple / Google"Sign in with Apple" / "Sign in with Google" (if you choose)US; their own privacy policies apply
Functional Software, Inc. (Sentry)error reports (no personal data, IP not stored)Germany (EU data region); US-based company
RevenueCat, Inc.subscription status (receipt, random identifier)US

Our data is hosted in the EU (Germany). Where a provider may access it from outside the EU / EEA or the UK (for example the United States), the transfer is protected by the EU Standard Contractual Clauses (and the UK Addendum) and, where the provider is certified, the EU-U.S. Data Privacy Framework. Because we are based in Türkiye, data may also be accessed from Türkiye. Türkiye has no EU adequacy decision; this access is covered by Standard Contractual Clauses and, where applicable, is necessary for the contract with you (Art. 49(1)(b)). You can ask us for a copy of the safeguards.

We may also disclose data where we are legally required to (court order, request from a competent authority).

Public content: your reviews and community posts can be seen by anyone using the app, with your nickname and, if you chose them, your skin type and age range.

Open Beauty Facts: part of our product database comes from Open Beauty Facts (ODbL licence). The app does not contact Open Beauty Facts on your behalf; if you tap "Open source", your browser opens their website.

5. How long we keep it

DataRetention
Data on your deviceuntil you delete it or uninstall the app
Account, skin profile, routine / shelf syncwhile your account is open; deleted immediately when you delete the account
Reviews and community contentuntil you delete them or your account; may be removed if they break the rules
Product submissionsif approved, the product stays in the catalogue (the link to you is removed when you delete your account)
Consent recordswhile your account is open; deleted with your account
Security records (sign-in, password, session)90 days; records linked to your account are deleted immediately when you delete it, the record of the deletion itself (email hash, part of the IP) stays 90 days
Server logs (requests, IP)at most 30 days
Database backupsat most 14 days; deleted data disappears from backups after this period
Correspondence about your requests3 years after the request is closed (to prove we handled it)

If you withdraw consent, your skin profile and health data are deleted from our servers; whether to delete the copy on your device is up to you.

6. Your rights

Under the GDPR you have the right to:

You can do much of this yourself in the app: delete on-device data (Settings > "Delete my data on this device"), delete your reviews and posts, and delete your account with all server-side data (Settings > "Delete account"; if you cannot access the app, use https://glowdays.app/en/delete-account).

To exercise a right, email support@glowdays.app from the address linked to your account (so we can verify it is you). We reply within one month, free of charge; for complex requests we may extend by up to two further months and will tell you why.

Users in Türkiye also have the rights in Article 11 of the KVKK; see the Turkish version of this policy.

7. Security

All communication with our servers is encrypted (HTTPS). Your session token is kept in secure storage on your device. Photo metadata is removed. Access to the admin panel is protected by additional authentication. No system is perfect; if a personal data breach occurs, we will notify the competent authority and affected users as required by law.

8. Age limit

Glowdays is for people aged 18 and over. If you are under 18, do not use the app. If we learn that someone under 18 has given us personal data, we will delete it.

9. Health notice

Glowdays is a cosmetic skincare guide; it does not diagnose, does not recommend treatment and is not a medical device. If a skin problem persists, see a dermatologist.

10. Changes

We may update this policy. For significant changes (a new type of data, a new purpose, a new transfer) we will notify you in the app, and where consent is required we will ask for it again. Each version is archived with its date and version number.