1. EXECUTIVE OVERVIEW & PRIVACY COMMITMENT

Welcome to ZEYGLOW (referred to as “ZEYGLOW”, “we”, “our”, or “us”). ZEYGLOW is a premium iOS mobile application designed to offer state-of-the-art, personalized makeup, styling, and beauty recommendations based on advanced facial analysis.

We recognize that your privacy is just as important as your personal aesthetic. Therefore, ZEYGLOW has been engineered from the ground up under a strict "Privacy-by-Design" and "Zero-Retention" framework.

This comprehensive Privacy Policy document outlines our transparent practices regarding data processing, secure third-party Artificial Intelligence (AI) transmissions, and the absolute protection of your facial data.

By downloading, installing, accessing, or using the ZEYGLOW mobile application, you explicitly acknowledge and agree to the terms, conditions, and processing activities detailed in this document.

2. SUMMARY OF CORE PRIVACY PRINCIPLES

Before diving into the detailed legal and technical sections, we wish to highlight our core promises to you:

• NO ACCOUNT REGISTRATION REQUIRED: You can use ZEYGLOW completely anonymously. There are no forms, sign-ups, or login credentials required.

• NO PERSONAL DATA EXTRACTION: We do not read your contacts, track your precise GPS location, or scrape your device identifiers.

• ENCRYPTED AI TRANSMISSION: Any data required to perform style recommendations is transmitted solely over enterprise-grade, encrypted secure sockets layer (SSL/TLS) connections.

• ZERO SERVERSIDE DATA RETENTION: Your images and face geometry coordinates are never saved, persisted, or logged on any permanent physical drive.

• ABSOLUTE TRAINING PROHIBITION: Your personal face features are never fed into machine learning training datasets.

3. DETAILED DATA COLLECTION AND USE PRACTICES

Unlike conventional apps that harvest and monetize user data, ZEYGLOW practices strict Data Minimization. Below is an exhaustive breakdown of what we process, how we process it, and why:

3.1 Photos and Camera Uploads (Facial Analysis)

To provide personalized styling recommendations, the ZEYGLOW application requires access to your device's camera or photo library. This is a voluntary action initiated solely by you.

• Encrypted Transmission to Google Gemini AI: When you capture a selfie or select a photo from your camera roll, the image file is securely uploaded via an encrypted, SSL-protected Firebase Vertex AI connection directly to the Google Gemini AI service.

• Zero-Retention Processing in Volatile Memory (RAM): Google Gemini AI processes your image entirely inside volatile random-access memory (RAM). The image is never written to a non-volatile physical storage medium (hard drive or solid-state drive).

• Immediate Destruction Protocol: The instant the facial analysis is finished and the makeup recommendations are returned to your local device, the image is permanently, automatically, and irreversibly deleted from Google's volatile memory.

• No AI Training/Model Fine-Tuning: We guarantee that your photos, facial shapes, and geometric measurements are NEVER used by ZEYGLOW, Google, or any sub-processor to train, retrain, improve, or fine-tune artificial intelligence models or machine learning algorithms. Your data remains strictly private.

3.2 Biometric Data Clarification

Under various global regulations (including GDPR, CCPA, and COPPA), biometric data is defined as unique physical measurements used to identify an individual (such as Face ID or fingerprint templates).

• NO Biometric Identification: ZEYGLOW does NOT collect, store, or process biometric data or unique face templates.

• Only 2D Geometric Evaluation: Our integration only evaluates temporary 2D facial feature alignments (e.g., distance between eyes, mouth curvature) to recommend cosmetic products and application styles. It cannot, and will never, be used to identify your unique identity or bypass biometric locks.

3.3 Subscription and In-App Purchase Data

• RevenueCat & Apple App Store Integration: When you purchase ZEYGLOW Premium, transaction details are securely processed by Apple App Store Connect and managed in real-time via RevenueCat.

• Minimal Data Access: We only receive non-identifying purchase metadata (e.g., active entitlement status, transaction time, expiration date) to unlock premium drawer features. We never see your credit card details, billing address, or actual banking credentials.

4. LEGAL BASIS FOR PROCESSING (FOR EEA & UK USERS)

If you reside within the European Economic Area (EEA) or the United Kingdom (UK), our processing of your facial data is governed by the General Data Protection Regulation (GDPR).

• Explicit Consent (Article 6(1)(a) GDPR): We process your uploaded photos and facial features solely based on your explicit, affirmative, and voluntary consent.

• Onboarding Consent: You will be prompted to grant consent via our golden in-app checkbox prior to performing any facial analysis. You have the absolute right to withhold or withdraw this consent at any time simply by closing the screen or deleting the application.

5. THIRD-PARTY DATA PROCESSORS & INFRASTRUCTURE

To ensure elite security and performance, ZEYGLOW relies on industry-leading, compliant infrastructure providers. These third parties act strictly as Data Processors under our instructions:

1. Google Cloud Platform & Firebase Vertex AI: Used for secure, encrypted hosting, Firestore user-state synchronization, and Gemini AI processing. Google adheres to strict SOC 2, ISO 27001, and GDPR compliance frameworks.

2. RevenueCat: Used strictly for real-time validation of your premium subscription status.

We do NOT sell, rent, lease, or trade your data to third-party data brokers, advertising agencies, or marketing companies.

6. DATA SECURITY AND PROTECTION MEASURES

We employ robust technical and organizational security measures to protect your data from unauthorized access, alteration, disclosure, or destruction:

• End-to-End Encryption: All network requests are encrypted using industry-standard Transport Layer Security (TLS 1.3 / HTTPS).

• Secure API Gateways: Restricts Vertex AI endpoints to authorized ZEYGLOW app requests only.

• Strict Access Control: No ZEYGLOW staff or developers can access, view, or download your uploaded photos, as they are instantly destroyed post-analysis.

7. CHILDREN'S PRIVACY PROTECTION

ZEYGLOW is not directed to individuals under the age of 13. We do not knowingly collect or solicit personal data or facial scans from children under 13. If we discover that an individual under 13 has provided us with any data, we will immediately take steps to permanently delete it.

8. YOUR LEGAL RIGHTS

Depending on your geographical location (e.g., under GDPR or CCPA), you may have the following rights:

• Right of Erasure ("Right to be Forgotten"): Because we practice a strict zero-retention policy, we do not store your photos. Therefore, there is no physical photo database to erase.

• Right to Withdraw Consent: You can withdraw your consent for future analyses at any time.

9. CHANGES TO THIS PRIVACY POLICY

We reserves the right to update or modify this Privacy Policy at any time to reflect technical improvements, security updates, or legal changes. When we make updates, the revised "Effective Date" at the top of this document will be updated. We encourage you to review this page periodically.

10. CONTACT US & OFFICIAL SUPPORT

If you have any questions, yasal inquiries, compliance concerns, or general feedback regarding this Privacy Policy, please feel free to reach out to us directly via our official and monitored email address:

📧 destekzeyrot@gmail.com