Privacy Policy
Last updated: September 21, 2026
Glowtrack is built on one simple principle: your skin stays on your phone. Skin analysis runs entirely on your device — your photos are never uploaded to any server, ours or anyone else's.
This policy explains what information Glowtrack handles, where it lives, what little of it ever leaves your device, and the choices you have. It applies to the Glowtrack iOS app, named “Işılda” on Turkish-language devices and in the Turkish App Store ("Glowtrack", "we", "us"). Because the app analyses a photo of your face, section 2 is devoted entirely to face data — what is collected, every use of it, sharing, retention, and how to withdraw consent and delete it.
1. Who we are
Glowtrack is developed and operated by the Glowtrack team. For any privacy question or request, contact us at vistalabs.dev@gmail.com. We are the data controller for the limited processing described in this policy under applicable data-protection laws, including the EU/UK GDPR and Türkiye's KVKK (Law No. 6698).
2. Face data
Glowtrack's skin analysis looks at a photo of your face, so this section sets out in one place exactly what face data the app collects, every use we make of it, who it is shared with, how long it is kept, and how you withdraw your consent and delete it. The short version: face data never leaves your device. Every step below happens on your iPhone or iPad. No selfie, no facial landmark and no measurement derived from them is transmitted to us or to anyone else, at any time, for any purpose.
2.1 What face data we collect
- A selfie. The photo you take in the app, or pick from your photo library, after you choose to start a scan. Nothing is captured in the background: the camera is live only while you are on the scan screen, and only if you granted camera access.
- Facial landmarks — in memory, for one analysis only. While the scan is being analysed, Apple's on-device Vision framework locates the face in the photo and the outlines of facial regions (forehead, cheeks, nose, chin, and the brow, eye and lip areas, which are excluded from measurement) so that readings are taken from skin rather than from hair, eyes or background. These landmark coordinates exist only in the device's working memory for the few seconds the analysis takes and are discarded when it ends. They are never written to storage and never transmitted.
- Skin measurements derived from the photo. Inside those regions the app computes non-identifying image statistics — brightness, redness, tone and texture variance, shine — and converts them into your skin scores (overall score, estimated skin-appearance range, hydration, texture, tone evenness, and a per-region summary).
- What is actually saved. Only the selfie itself and those numeric scores, and only to the app's private database on your own device, so that you can look back at a scan and compare your progress.
2.2 How we use face data — the complete list
- To measure the visible condition of your skin in the photo you just provided, and turn it into that scan's result.
- To show you that result, your scan history and your before/after comparisons inside the app, on your device.
- To choose which routine steps, tips and product suggestions the app shows you, on your device.
Those are all of the uses, and there are no disclosures. Face data is never used for advertising, marketing, analytics, profiling, identity verification, security, law enforcement, research, or to train, fine-tune or improve any machine-learning model — ours or anyone else's. It is never combined with data from other sources, and it is never used to build a profile of you outside the app.
2.3 Sharing face data
We do not share face data with any third party. Your selfies, your facial landmarks and your scan images are never sold, rented, licensed, disclosed or otherwise made available to any third party — no service provider, advertiser, analytics provider, partner or affiliate — and they are never uploaded to any server, including our own. They are not included in any network request the app makes. In particular, the Premium AI coach transmits text only: section 4 lists every field that leaves your device for any feature, and no image, landmark or face measurement appears in that list.
Because no third party ever receives face data, no third party processes, stores or retains it. Should this ever change, we would obtain your explicit consent first, update this policy before the change took effect, and require by written contract that any such third party provide protection for the face data that is the same as or equal to the protection stated in this policy — including the limits on use, the prohibitions on identification, advertising and model training, and the deletion rights set out here. We have no plans to do this.
2.4 How long face data is retained
- On our servers: never received, therefore never retained. There is no server-side copy of your face data to keep, back up, log or archive — not for a day, not for a second.
- On your device: a selfie and its scores remain in the app's local database until you delete them in one of the ways below. Nothing expires on its own, because the history exists purely so that you can see your own progress; you decide how much of it to keep.
- Facial landmarks: retained in memory only for the duration of a single analysis, then discarded. They are never persisted.
2.5 Withdrawing consent and deleting your face data
You consent to this processing by choosing to take or select a photo and start a scan — the app never scans on its own initiative. You can withdraw that consent at any time, with no effect on the rest of the app: scanning is optional, and your routine, logs, products and reminders all work without it.
- Stop any further collection. Simply stop scanning, or revoke the app's access in iOS Settings → Privacy & Security → Camera and → Photos (or Settings → Glowtrack, shown as Işılda on Turkish-language devices). With access revoked, Glowtrack cannot obtain a photo of your face at all.
- Delete all of it, inside the app. Open your profile from the avatar on the Today screen and tap "Delete all my data" ("Tüm verilerimi sil") under Data, then confirm. This immediately and permanently erases every selfie and every scan result from the device, together with your profile, routine history, daily logs, experiments and coach conversation. It cannot be undone.
- Delete a guest's scans. Scans taken by someone else in Guest mode are listed under Profile → Guest scans and can be deleted individually by swiping.
- Delete the app. Removing Glowtrack from your device deletes its entire container, including every selfie, scan and derived score.
Because we hold no copy of your face data, deleting it on your device is complete deletion: there is no request to send us, no account to close, and no server copy that could outlive it. If you would like written confirmation of this, or have any question about face data, email vistalabs.dev@gmail.com and we will respond within the timelines required by law.
3. Information that stays on your device
Everything listed below is stored only in the app's local database on your device. It is never transmitted to us or to third parties.
4. Information that leaves your device
A small number of features contact external services, always with the minimum data needed for that feature and never with your photos or scan images. The Premium coach is the one feature that also sends skin and lifestyle details about you; the table below lists exactly what:
| Feature | What is sent | To whom |
|---|---|---|
| Climate-aware tips | The city name you typed and its coordinates | Open-Meteo (UV, humidity and air-quality data). No identifiers are included. |
| Product barcode check | Only the scanned barcode number | Open Beauty Facts (ingredient information). Nothing else is transmitted. |
| AI coach (Premium) | Your chat messages; the context the coach needs to answer — your name, age range, skin type, goal, concerns, the weakest area of your last scan, sensitivities, your routine steps, streak, your latest check-in and your water, sleep and stress levels; and a random identifier created when you install the app. If you marked yourself as pregnant or breastfeeding, that fact is included too, so the coach can refuse to suggest retinoids and other actives that are postponed in this period. No photos or scan images are ever included. | First our own function hosted on Supabase (servers in Frankfurt, EU), which holds the API key and counts your daily messages, and from there Anthropic (Claude API) to generate the reply. Your photos and scans are never included, and your messages are not used to train models per Anthropic's commercial terms. |
| Catalog contributions (optional) | Only when you switch on "Suggest for the catalog" while saving a product: the product name, brand, routine step, the ingredient text read from the label, the barcode if you scanned one, and the random install identifier. The front-of-pack photo is sent only if you also switch on "Also send the front photo". Your selfies, skin analyses and profile are never included. | Our own function hosted on Supabase (servers in Frankfurt, EU). We use the contribution to add the product to the shared catalog so that other people's scans find it. Nothing is shared with third parties. |
| Subscriptions | Device identifier and purchase/transaction information | Adapty, solely to validate and manage your subscription status. Your health data, photos and profile answers are never shared with Adapty. |
5. Purchases and payments
Premium subscriptions and one-time purchases are processed by Apple through the App Store. We never see or store your payment details; those are governed by Apple's privacy policy. Subscription state (active / expired / trial) is validated through Adapty as described above.
6. What we don't do
- No accounts — Glowtrack works without sign-up, so there is no server-side profile of you anywhere.
- No analytics, advertising or tracking SDKs of any kind.
- No selling, renting or sharing of your data for marketing purposes.
- No profiling of your behavior across apps or websites.
- No faceprints, face templates or biometric identifiers, no facial recognition and no identity matching — see section 2.
- No uploading of your selfies, scan images or scan history — these never leave your device, for any feature. Your daily log stays on your phone as well; only the current values listed in section 4 are passed to the coach, and a product's front-of-pack photo is uploaded only if you switch that on while contributing to the catalog.
A second correction. Until September 2026 the section above claimed that no feature sends your health data or identity. That was wrong: the Premium coach has always sent your name and the skin and lifestyle details listed in section 4, including whether you marked yourself as pregnant or breastfeeding. This section also said daily logs never leave the device, while the coach has always received your current water, sleep and stress levels. Nothing about the app changed — the description did. Section 4 now lists every field that leaves your device.
One honest correction. Until August 2026 this policy said we operate no servers at all. That is no longer true: the Premium AI coach passes your messages through a small function we run, so that the key it needs is never shipped inside the app. That function stores no message content — only a random install identifier and how many messages it saw that day, to enforce the daily limit. Everything else in the app still runs entirely on your device.
7. Data retention and deletion
Face data has its own retention and deletion rules, set out in sections 2.4 and 2.5: we retain none of it, ever, because it never reaches us, and you can erase the copy on your device at any time.
The only record we hold on a server is the coach message counter described in section 4: a random install identifier, a date and a number. It contains no message content and is deleted automatically after 30 days. To have it removed sooner, email us — the identifier is shown nowhere, so include the approximate dates you used the coach and we will locate and delete it.
Catalog contributions are the second kind of server record. The text part (name, brand, routine step, ingredient list, barcode, install identifier) is kept so we can add the product to the catalog and trace what was added. A front-of-pack photo, if you chose to send one, is deleted as soon as the contribution is processed and in any case within 90 days. To have a contribution removed, email us with the product name and the approximate date.
Because your data lives only on your device, you are in direct control of it:
- Deleting the app permanently deletes all your data — selfies, analyses, profile, routines, logs, cycle information and chat history. There is no server copy to remove.
- Guest scans can be deleted individually inside the app, and your profile details can be edited at any time.
- Data included in your device backups (iCloud or local) is governed by Apple's backup encryption and your own backup settings.
8. Security
Your data is stored in the app's private container, protected by iOS sandboxing and your device's encryption. Network calls the app does make (listed in section 4) use HTTPS. We hold no copy of your photos, scans, profile or logs anywhere, so the most effective protection — keeping your data on hardware you control — remains the default. The one server-side record we do keep (the coach message counter) sits behind row-level security and is reachable only by our own function, never by the app.
9. Your rights
Under the GDPR, KVKK and similar laws you have rights to access, correct, delete and object to the processing of your personal data. Because Glowtrack keeps your data on your device, you can exercise access, correction and deletion directly inside the app or by deleting it. For anything else — including questions about the limited third-party processing described above — contact us at vistalabs.dev@gmail.com and we will respond within the timelines required by law. You also have the right to lodge a complaint with your local supervisory authority.
10. Children's privacy
Glowtrack is not directed at children under 13 (or the higher minimum age in your jurisdiction) and does not knowingly collect data from them. If you believe a child has used the app, deleting the app removes all of their data.
11. Third-party links
The app and this site link to third-party services (Apple, Anthropic, Supabase, Adapty, Open-Meteo, Open Beauty Facts). Their handling of data is governed by their own privacy policies, linked throughout this page.
12. Changes to this policy
When this policy changes, we will update this page and revise the date at the top. Material changes will additionally be announced inside the app before they take effect.
13. Contact
Questions, privacy requests, GDPR/KVKK applications: vistalabs.dev@gmail.com