Privacy Policy

1. Who we are

Facely is a mobile application operated by Venby ("Facely", "we", "us", or "our"). Facely helps users upload or capture a face photo, answer onboarding questions, receive an AI-generated appearance report, manage suggested routines and to-do items, and chat with an AI Coach about face analysis, grooming, skin, hair, style, scan quality, and routines.

You can contact us at support@venby.co or by phone at +90 544 995 44 04.

2. Short version

• No account is currently required. Facely can be used without creating a login account in the app.
• We do not currently maintain our own cloud database for your face photos, reports, onboarding answers, chat history, or to-do items. These are stored on your device unless they are sent to OpenAI for AI processing after your consent.
• Your photo and onboarding answers are sent to OpenAI only after you accept AI analysis consent. This is needed to generate your face report.
• Your AI Coach messages are sent to OpenAI only after you accept AI Coach consent. We also send limited context, such as your recent messages and report, so the AI Coach can respond usefully.
• Deleting the app deletes locally stored Facely data from that device. This includes your saved photo, onboarding answers, reports, to-do items, reminder choices, and local chat history, unless your operating system or backup settings keep an app backup.
• Your subscription can remain valid after reinstalling. App Store, Google Play, and/or subscription infrastructure may be able to restore the subscription, but your local face data and reports will not come back if we did not store them in a cloud account or database.

3. Data we process

Depending on which features you use, Facely may process the following categories of data:

4. Local-only storage and no current Facely cloud account database

Facely currently stores the main app experience on your device using local app storage. This includes onboarding answers, selected photo metadata, local photo file, reports, progress reports, to-do tasks, reminder choices, AI consent flags, and AI Coach messages.

As currently implemented, we do not run a Facely-owned backend database that permanently stores your face photo, reports, onboarding answers, to-do list, or AI Coach history under a user account. This means:

• If you delete the app, your local Facely data is normally deleted from the device.
• If you reinstall the app, your local reports and saved face photo will normally be gone.
• If your phone is lost, replaced, reset, or restored without app data, your local Facely data may be gone.
• We cannot restore local report history if it was never stored in a cloud account or database.
• Operating system backups may behave differently depending on your iCloud, Google, device, or backup settings.

If we add an account system, cloud sync, analytics, or a server database in the future, we will update this Privacy Policy and, where required, request additional consent.

5. How we use OpenAI

Facely uses OpenAI API technology to generate face reports, progress comparisons, and AI Coach replies. OpenAI is a third-party AI service provider. When you use AI features, the app sends the relevant data through a Facely-operated Cloudflare Worker proxy to OpenAI so the model can process it and return a response. The proxy keeps the OpenAI API credential out of the mobile app.

5.1 What is sent to OpenAI for the first AI face report

• Your selected or captured face photo.
• Your onboarding answers, such as age, gender selection, goals, motivation, weakest attribute, blocking factor, chin projection preference, and routine commitment.
• A structured request asking OpenAI to generate a face analysis report in English.

5.2 What is sent to OpenAI for progress scans

• Your new face photo.
• Your previous AI report.
• Your onboarding answers.
• Your current to-do tasks when needed to decide whether tasks should be added or removed.

5.3 What is sent to OpenAI for AI Coach

• Your AI Coach message.
• Recent chat context so the AI can continue the conversation.
• Your onboarding answers and face report, when available, so the response is personalized.

5.4 Why OpenAI receives this data

OpenAI receives this data only to provide AI functionality requested by you: generating a report, comparing scans, or replying in AI Coach. Without sending the relevant data to an AI model, these features cannot work as intended.

5.5 OpenAI policies and retention

Facely sends OpenAI Responses API requests with server-side response storage disabled (store: false). OpenAI states that data sent through its API is not used to train or improve OpenAI models unless the API customer explicitly opts in. Facely has not opted in to share API data for model training.

OpenAI states that its default abuse-monitoring logs may contain prompts, responses, uploaded images, and related metadata and may be retained for up to 30 days. OpenAI may retain data longer when required by law or when reasonably necessary to protect its services or third parties from harm. Facely does not currently represent that its OpenAI project has Zero Data Retention approval.

You can review OpenAI's own privacy information at openai.com/policies/privacy-policy and enterprise/API privacy information at openai.com/enterprise-privacy.

6. AI consent and control

Facely requires explicit in-app consent before AI processing starts.

• AI analysis consent: Before your photo and onboarding answers are sent to OpenAI for the face report, the app shows an AI analysis consent notice. If you do not accept, the analysis does not start.
• AI Coach consent: Before your AI Coach message and context are sent to OpenAI, the app shows an AI Coach consent notice. If you do not accept, the message is not sent.
• Local consent record: Your consent choices are stored locally on your device so we do not ask every time.
• Resetting consent: Deleting the app or resetting app data removes the local consent record, and the app may ask again after reinstalling.

Do not upload or type information you do not want processed by AI systems. Avoid sending sensitive identity documents, medical records, passwords, financial information, precise location, or other highly private information.

7. Face data: collection, use, sharing, storage, and retention

7.1 Face data we collect and derive

When you choose to take or upload a scan, Facely processes the face photo you select. For purposes of this policy, "face data" means: (a) that selected or captured face photo; and (b) appearance observations generated from the photo, such as visible facial structure, symmetry, jawline and chin presentation, skin presentation, hair and grooming context, scan quality, feature scores, an overall score, and progress observations.

Facely does not create or store a face-recognition template, Face ID profile, identity embedding, facial landmark database, or biometric identifier used to identify or authenticate a person. Facely does not compare a face against a database of people.

7.2 Complete uses of face data

• Generate the initial AI appearance report and feature-level scores.
• Provide visible-feature, scan-quality, grooming, skin-presentation, hair, and style observations.
• Create personalized quick wins, routines, to-do suggestions, and 7/30/90-day guidance.
• Compare a new progress photo with the prior locally stored report and describe possible changes.
• Display the selected photo and generated reports locally inside the app.
• Use the generated report, but not the face photo itself, as optional context for AI Coach replies.

Face data is not used for advertising, tracking, eligibility decisions, identity verification, law-enforcement identification, or sale to data brokers.

7.3 Sharing and storage of face data

• On your device: The selected photo and generated report are stored in Facely's local app storage so you can view reports and progress history.
• Cloudflare: The photo and analysis request pass through a Facely-operated Cloudflare Worker acting as a transport proxy. The Worker has no KV, D1, R2, database, or other persistent storage binding, and the Worker code does not write face photos or request bodies to persistent storage or custom logs.
• OpenAI: The photo and relevant onboarding context are disclosed to OpenAI solely to generate the requested report or progress comparison. OpenAI returns the generated result to the app through the Worker.
• Other providers: Apple and RevenueCat process subscription information, but Facely does not send face photos or AI-derived face observations to them.

7.4 Retention and deletion of face data

• On-device face photo and reports: Retained until you delete the app, clear its app data, or the operating system removes the data. Device backups may retain app data according to your Apple or device backup settings.
• Facely Cloudflare Worker: Not intentionally retained in persistent storage by the Worker. The request exists transiently while it is forwarded and the response is returned.
• OpenAI API: Facely disables Responses API application-state storage. OpenAI may retain customer content, including image inputs, in abuse-monitoring logs for up to 30 days, unless longer retention is legally required or reasonably necessary to prevent harm.

Facely analyzes face photos to provide appearance-related feedback, including visible structure, grooming, skin presentation, hair/style context, scan quality, and routine suggestions. Facely is not designed to identify you, verify your identity, authenticate you, compare you against a database of people, or perform face recognition.

However, face photos can be sensitive personal data in many jurisdictions. You should only upload your own photo or a photo you have the right and permission to use. Do not upload a photo of another person without their permission.

8. Subscriptions, purchases, reinstalling, and what survives

Facely may offer paid subscriptions, such as weekly or yearly plans. Purchases are handled by the Apple App Store, Google Play, and/or subscription management infrastructure such as RevenueCat if enabled in the app.

8.1 What subscription providers may process

• Purchase status, entitlement status, renewal status, cancellation status, and restore status.
• Store transaction identifiers or app-user identifiers used to validate access.
• Device, app, and transaction metadata required for subscription operations.

8.2 What happens if you delete and reinstall the app

• Your subscription may still be valid and may be restorable through the app store or subscription provider.
• Your local Facely data, including photo, reports, AI Coach history, onboarding answers, and to-do items, will normally be gone if the app was deleted.
• A restored subscription does not automatically restore local face analysis data unless that data was separately backed up or synced.
• Because there is currently no required login account and no Facely cloud database for reports, we generally cannot recover deleted local reports for you.

8.3 Canceling a subscription

Deleting the app does not automatically cancel your subscription. You must cancel through the Apple App Store, Google Play, or the applicable purchase platform. Subscription billing and refund rules are controlled by the platform where you purchased.

9. Device permissions

9.1 Camera

Camera permission is used only when you choose to take a face photo inside the app. If you deny camera permission, you can use the photo library option if available.

9.2 Photo library

Photo library permission is used only when you choose to select a photo from your device. We do not scan your full library. We use the image you select.

9.3 Notifications

Notification permission is used to schedule reminders for routines, to-do items, or membership-related prompts if enabled. You can disable notifications in your device settings.

9.4 Local storage

The app stores data locally so your dashboard, report, chat history, and to-do list remain available after closing and reopening the app.

10. How we use data

We use data for the following purposes:

• To provide the core app experience.
• To generate AI face analysis reports.
• To generate AI progress comparisons.
• To provide AI Coach replies.
• To create and manage routine and to-do suggestions.
• To store your local report history on the device.
• To schedule local reminders if you enable notifications.
• To verify paid subscription access.
• To respond to support requests.
• To comply with legal obligations and protect the security, integrity, and lawful operation of the app.

11. Sharing and third-party processors

We do not sell your face photo, AI report, chat history, or onboarding answers. We may share or transmit data only as needed for the app features and operations described in this policy.

We may also disclose information if required by law, legal process, government request, enforcement of our terms, protection of rights and safety, fraud prevention, or business transfer such as merger, acquisition, financing, reorganization, or sale of assets.

12. Deletion, uninstalling, and data removal

12.1 Deleting the app

Because Facely currently stores the main app data locally, deleting the app normally removes locally stored Facely data from that device, including:

• Saved face photo.
• Onboarding answers.
• AI face reports and progress reports.
• AI Coach local chat history.
• To-do tasks, completion history, and reminder choices.
• Local consent choices.

Some device backups may preserve app data depending on your operating system and backup settings. You can manage those settings through Apple, Google, or your device provider.

12.2 Deleting data from OpenAI

When you consent to AI processing, relevant data is transmitted to OpenAI. Requests to delete or exercise rights over data processed by OpenAI may be subject to OpenAI's policies, controls, retention rules, and legal obligations. You can contact us and we will help route your request where possible, but we do not directly control OpenAI's systems.

12.3 Contacting us for deletion

Because we currently do not maintain a Facely cloud database for your local reports or photos, there may be no server-side Facely record for us to delete. If you contacted support, we may have the support message you sent us. You can ask us to delete support correspondence where legally permitted by emailing support@venby.co.

13. Retention

• Local app data: Kept on your device until you delete the app, clear its app data through operating-system controls, or your operating system removes it.
• Cloudflare Worker request data: Not intentionally stored by Facely's Worker. Request bodies are processed transiently without a configured persistent storage binding.
• OpenAI API processing data: Responses API application-state storage is disabled. OpenAI may retain abuse-monitoring logs containing customer content for up to 30 days, or longer when legally required or reasonably necessary to prevent harm.
• Subscription records: Retained by Apple, Google, RevenueCat, or similar services as needed for billing, tax, fraud prevention, accounting, customer support, and legal compliance.
• Support messages: Retained as long as needed to respond, maintain records, prevent abuse, resolve disputes, or comply with legal obligations.

14. International data transfers

OpenAI, app store providers, subscription infrastructure, email providers, and support tools may process data in countries other than where you live. Privacy laws in those countries may differ from your local laws. Where required, data transfers are handled under applicable legal mechanisms used by the relevant provider.

15. Your privacy rights

Depending on where you live, you may have rights to access, correct, delete, restrict, object to processing, withdraw consent, or receive a copy of certain personal data. You may also have the right to complain to a data protection authority.

Because most Facely data is stored locally on your device, the fastest way to remove it is usually to delete the app or reset app data. For support records or questions, contact us at support@venby.co.

If your request involves data processed by OpenAI, Apple, Google, RevenueCat, or another provider, you may also need to use that provider's privacy tools or contact channels.

16. Children and users under 18

Facely is not intended for children under 13. Users under 18 should use Facely only with permission and supervision from a parent or guardian. If you believe a child has provided personal data through Facely without appropriate permission, contact us at support@venby.co.

17. Security

We use reasonable technical and organizational measures appropriate for the app's current architecture. Local app data is stored using device app storage. However, no storage system, internet transmission, API provider, device, or operating system is perfectly secure.

You are responsible for securing your device, using device lock features, avoiding uploads of sensitive unrelated content, and keeping your operating system up to date.

18. AI limitations and user responsibility

AI-generated reports and AI Coach replies are probabilistic and may be incomplete, inaccurate, subjective, or affected by lighting, angle, image quality, facial expression, grooming, camera distortion, and other factors. Facely does not provide medical diagnosis, treatment, psychological counseling, professional dermatology advice, nutrition plans, or surgical recommendations.

You should not rely on Facely for medical, mental health, legal, financial, or safety decisions. If you have medical or mental health concerns, consult a qualified professional.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we may notify you in the app, on this page, or through another reasonable method. The effective date at the top shows when this policy became effective.

20. Contact

If you have questions, privacy requests, deletion requests, subscription privacy questions, or concerns about AI processing, contact us:

• Email: aslantassmehmet1@gmail.com
• Phone: +90 544 995 44 04