Privacy Policy

Last updated: May 27, 2026

This Privacy Policy explains how Glowmate (“Glowmate,” “we,” “us,” or “our”) collects, uses, stores, and protects your personal information when you use our website, app, onboarding flow, skincare report, and related services.

Glowmate provides AI-assisted cosmetic skincare education based on user-submitted photos and questionnaire answers. Glowmate does not provide medical advice, diagnosis, treatment, prescriptions, or emergency healthcare services.

1. Controller

The data controller responsible for your personal information is:

Berk Topcu Wildenbruchstr. 46B 12435 Berlin Germany

Email: glowmateapp@gmail.com

2. Who can use Glowmate

Glowmate is intended only for users who are 18 years or older. We do not knowingly collect personal information from anyone under 18. If we learn that a person under 18 has used the service, we may delete the related information.

3. What information we collect

We may collect the following categories of information:

a) Account and contact information - Email address - Login or authentication information, if account access is enabled - Customer support messages

b) Photos and skincare-related inputs - Photos you upload for the purpose of generating your skincare report - Questionnaire answers, such as skin goals, skin concerns, skin type, sensitivity, current routine, product use, lifestyle factors, and skincare preferences - Information generated from your uploaded photos and questionnaire answers, such as your cosmetic skin profile, visible skin observations, routine suggestions, and report content

c) Consent information - Whether you consented to photo and questionnaire processing - Whether you acknowledged that Glowmate provides educational cosmetic skincare guidance only and not medical diagnosis or treatment - Whether you acknowledged that you can request deletion of your data - Consent timestamps and related technical records

d) Payment information Payments are processed by Stripe. We do not store your full card number. We may receive payment-related information from Stripe, such as your payment status, transaction ID, customer ID, billing email, country, and the product or plan purchased.

e) Technical and usage information - Device type, browser type, operating system, approximate location based on IP address, pages viewed, buttons clicked, session events, referral source, and timestamps - Error logs, security logs, and fraud-prevention information

4. How we use your information

We use your information to:

- Provide the Glowmate service - Generate your AI-assisted cosmetic skincare report - Process payments and manage access to paid content - Record and manage consent - Send transactional emails, such as payment confirmations or report access messages - Provide customer support - Improve, debug, and secure the product - Prevent fraud, abuse, and misuse - Understand basic product performance and usage - Comply with legal, tax, accounting, and regulatory obligations

5. Legal bases under GDPR

If GDPR applies to you, we rely on the following legal bases:

a) Performance of a contract We process information necessary to provide the service you requested, including generating and delivering your skincare report.

b) Consent Before you upload photos, we ask for your explicit consent to process your photos and questionnaire answers for the purpose of generating your personalized skincare report.

c) Legitimate interests We may process limited technical, security, support, fraud-prevention, and product-performance information to operate, improve, protect, and troubleshoot the service, provided that our interests are not overridden by your rights and freedoms.

d) Legal obligation We may process payment, tax, invoice, and accounting information where required by law.

6. Photos, skin information, and AI processing

Glowmate uses uploaded photos and questionnaire answers to generate cosmetic skincare observations and educational suggestions.

Before you upload photos, we ask for your explicit consent to process your photos and questionnaire answers for the purpose of generating your personalized skincare report. You also acknowledge that Glowmate provides educational cosmetic skincare guidance only and does not provide medical diagnosis, treatment, prescriptions, or emergency healthcare services.

Your photos and inputs may be processed by Google AI or other infrastructure providers that help us generate your report. These providers process data only for the purpose of providing the service to us, subject to their terms and data-processing safeguards.

Glowmate does not use uploaded photos for facial recognition, identity verification, or to create a biometric identity profile. We analyze uploaded photos only for visible cosmetic skin characteristics relevant to your skincare report.

7. No medical advice

Glowmate is a cosmetic skincare education tool. It is not a medical device and does not provide medical advice, diagnosis, treatment, prescriptions, or emergency healthcare services.

You should consult a dermatologist or qualified healthcare professional if you have concerns such as severe acne, painful irritation, rash, infection, allergic reaction, bleeding, sudden skin changes, changing moles, or any condition that may require medical attention.

8. Payments

Payments are processed by Stripe. Stripe may process your payment information as a service provider/data processor for us and, in some cases, as an independent data controller for its own legal, compliance, fraud-prevention, and payment-network purposes.

You can learn more in Stripe’s own privacy policy.

9. Service providers

We may share personal information with trusted service providers that help us operate Glowmate.

These currently include:

- Lovable, for app development and hosting-related functionality - Supabase, for database, authentication, storage, and backend infrastructure - Stripe, for payment processing - Google AI, for AI-assisted skincare report generation - Gmail, for customer support and communication

These providers may only access the information needed to perform services for us and must protect it appropriately.

10. Advertising and tracking

Glowmate does not currently use advertising pixels, marketing tracking tools, or third-party analytics tools such as Meta Pixel, TikTok Pixel, or Google Analytics.

We may still process basic technical information necessary to operate and secure the service, such as server logs, device/browser information, timestamps, error logs, and payment status events.

We do not intentionally share uploaded photos, questionnaire answers, skin concerns, generated skincare reports, or other report content with advertising platforms.

If we add advertising or analytics tools in the future, we will update this Privacy Policy and, where required, ask for consent before using non-essential cookies or tracking technologies.

11. Cookies and similar technologies

Glowmate may use cookies, local storage, or similar technologies that are necessary for the app to function, keep you logged in, remember your progress, process payments, secure the service, or deliver your skincare report.

Glowmate does not currently use non-essential marketing cookies or third-party advertising pixels.

If we add non-essential cookies or tracking technologies in the future, we will update this Privacy Policy and, where required, ask for your consent.

12. International data transfers

Because Glowmate is operated from Germany and may use service providers located in other countries, your information may be processed outside your country of residence, including in the United States.

Where required, we use appropriate safeguards for international transfers, such as data-processing agreements, standard contractual clauses, or equivalent legal mechanisms.

13. How long we keep your information

We keep personal information only as long as necessary for the purposes described in this Privacy Policy.

Our retention approach is:

- Uploaded photos: deleted within 7 days after account deletion or deletion request, unless we need to keep limited information for legal, security, or fraud-prevention reasons - Questionnaire answers and generated reports: kept for up to 90 days, unless deleted earlier by the user or required longer for legal, security, or payment-related reasons - Consent records: kept as long as reasonably necessary to demonstrate that valid consent was obtained and to comply with legal obligations - Payment and transaction records: kept as required for tax, accounting, fraud-prevention, and legal obligations - Support emails: kept as long as needed to resolve the issue and maintain reasonable business records - Technical logs: kept for a limited period needed for security, debugging, and product improvement

You may request deletion of your personal information by contacting glowmateapp@gmail.com.

14. Your rights

Depending on where you live, you may have rights regarding your personal information, including the right to:

- Access the personal information we hold about you - Correct inaccurate or incomplete information - Request deletion of your information - Object to certain processing - Restrict certain processing - Request a portable copy of your information - Withdraw consent where processing is based on consent - Lodge a complaint with a data protection authority

If you are located in the European Economic Area, you may contact your local data protection authority. In Germany, you may contact the competent state data protection authority.

To exercise your rights, email us at glowmateapp@gmail.com.

15. US privacy notice

If you are located in the United States, you may have additional rights depending on your state of residence. These may include rights to access, delete, correct, or receive information about certain personal information practices.

Glowmate does not sell uploaded photos, questionnaire answers, or generated skincare reports.

Glowmate does not currently share personal information with advertising platforms for cross-context behavioral advertising.

To make a privacy request, contact glowmateapp@gmail.com.

16. Data security

We use reasonable technical and organizational measures designed to protect your personal information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no online service can be guaranteed to be completely secure. You are responsible for using a secure device, secure internet connection, and protecting your login credentials if account access is enabled.

17. Third-party links

Glowmate may contain links to third-party websites or services. We are not responsible for the privacy practices, content, or security of third-party websites.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the “Last updated” date and, where appropriate, notify users through the app or by email.

19. Contact

For privacy questions or requests, contact:

Glowmate Berk Topcu Wildenbruchstr. 46B 12435 Berlin Germany

Email: glowmateapp@gmail.com