Glowtrack · Işılda

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

No faceprint, and no facial recognition. Glowtrack does not create, derive, store or use a faceprint, face template, face embedding, face signature or any other biometric identifier. It performs no facial recognition, identity verification or identity matching; it cannot recognise you, tell two people apart, or match a face against any database. It makes no emotion, demographic or age determinations, and it does not use ARKit, the TrueDepth camera, depth maps or Face ID data. The landmarks described above are geometric outlines used to place measurement zones on a single photo, and they are destroyed as soon as that analysis finishes.

2.2 How we use face data — the complete list

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

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.

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.

Selfies and skin analyses Skin analysis is performed on your device using Apple's on-device image processing (the Vision framework). Your selfies, analysis results (skin score, estimated skin-appearance range, hydration, texture and tone metrics) and your scan history are stored locally. No photo ever leaves your phone — not for analysis, not for backups, not for the AI coach. Section 2 covers face data in full.
Profile and routine Your onboarding answers (skin type, concerns, goals, sensitivities, habits, budget and similar preferences), your skincare routine, custom steps and product choices are stored on your device.
Daily logs and check-ins Routine completions, streaks, mood, water and sleep check-ins are stored locally and used only to show your own progress inside the app.
Cycle information If you enable cycle tracking, Glowtrack keeps exactly two data points: the start date of your last period and your average cycle length. We treat this as sensitive health information: it is stored only on your device, is never sent to any server, and is used solely to time gentle, cycle-aware skincare suggestions and optional local reminders. You can turn cycle tracking off at any time, and general trends shown around it are not medical advice.
Guest scans If someone else scans their face on your device as a "Guest", that scan is stored only on your device, is kept strictly separate from your own progress and comparisons, and can be deleted individually inside the app.
Coach conversations Your chat history with the coach is stored on your device so the conversation can continue where you left off. Note that the Premium AI coach also sends each message onward to generate a reply — see section 4.
Product label photos When you photograph an ingredient list, the photo is read on your device using Apple's Vision framework. The photo is not saved to our systems and is never uploaded — only you see it. Ingredient scoring also runs entirely on your device against a dictionary shipped inside the app.
Reminders Routine and cycle reminders are scheduled locally through iOS notifications. No notification content passes through our servers — we do not have any.

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:

FeatureWhat is sentTo 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

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:

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