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Privacy Policy

FaceCoach — Last updated: May 6, 2026

Introduction

FaceCoach ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, process, store, and safeguard your information when you use the FaceCoach mobile application and related services.

Information We Collect

When you use FaceCoach, we may collect the following information:

  • Personal information: Information you voluntarily provide, such as your name or email address (if applicable).
  • Facial images & facial analysis data: Facial images (photos or camera captures) that you voluntarily upload or capture within the app for AI-powered facial analysis, and non-identifying analysis data derived from those images (such as facial proportions, symmetry metrics, skin features, and aesthetic indicators).
  • Analysis results: Your facial analysis scores, metrics, and generated action plans.
  • Device & usage information: Information about your device (device model, operating system version, app version) and app usage data (features used, time spent), collected to improve app functionality and stability.

How We Use Your Information

We use collected information solely to:

  • Provide AI-powered facial analysis features requested by the user
  • Process facial images to generate personalised appearance insights
  • Display analysis results within the app
  • Generate personalised improvement plans
  • Track your progress over time
  • Improve app performance and user experience
  • Maintain security and prevent abuse
  • Provide customer support and respond to enquiries

FaceCoach does not perform biometric identification, facial recognition, identity verification, or create biometric identifiers or biometric templates. Facial data is not used for advertising, tracking, profiling, or AI model training.

Face Data

This section consolidates all information about how FaceCoach handles face data, including collection, use, disclosure, sharing, retention, and deletion.

What Face Data We Collect

FaceCoach collects facial images (photos or camera captures) that you voluntarily upload or capture within the app. From those images, we derive non-identifying facial analysis data including facial proportions, symmetry metrics, skin quality indicators, and aesthetic scores. We do not collect face data automatically or passively — collection occurs only when you explicitly take or upload a photo for analysis.

How We Use Face Data

Face data is used solely to provide the facial analysis service you request. Specifically, we use it to: generate facial analysis scores and metrics, produce personalised improvement action plans, create before-and-after enhancement previews, and allow you to track your progress over time. FaceCoach does not perform biometric identification, facial recognition, or identity verification. We do not create biometric identifiers or biometric templates. Face data is never used for advertising, user tracking, profiling, or AI model training.

Third-Party Sharing of Face Data

Facial images are transmitted transiently to a third-party AI service provider (Google Gemini) solely to generate the analysis you request. The AI provider processes the image and returns results — it does not retain your facial images, does not use them for model training, and does not perform biometric identification. Images are stored temporarily on Cloudflare R2 (encrypted at rest) during processing, then deleted from our servers once cached locally on your device. FaceCoach does not sell, rent, or share face data with advertisers, data brokers, or any other third parties.

Storage and Retention of Face Data

Facial images are not retained on FaceCoach servers beyond the time needed for processing (typically seconds). After processing, images are deleted from our cloud storage and retained only locally on your device. Analysis results are stored locally on your device until you choose to delete them. FaceCoach does not maintain backups of deleted facial data. When you delete your data (via the "Delete All My Data" option in app settings), all facial images and analysis results are permanently and irreversibly removed.

User Consent & Control

Facial images are processed only after explicit user action (capturing or uploading an image). Users may withdraw consent and delete their facial images and analysis data at any time within the app. Core app functionality is not dependent on providing optional personal information.

Photo Privacy

We take the privacy of your photos seriously. Your photos are encrypted in transit and at rest. We do not share your photos with third parties for marketing or advertising purposes. You can delete your photos and analysis history at any time from within the app.

In-App Purchases

FaceCoach offers optional subscription purchases to unlock additional features. Purchases are processed entirely by Apple through the App Store. We use RevenueCat to manage subscription entitlements. RevenueCat may collect anonymous purchase data and device identifiers as described in their privacy policy.

Data Storage & Security

Your data is stored securely using industry-standard encryption. Photos submitted for analysis are stored on Cloudflare R2 with encryption at rest. We apply appropriate technical and organisational safeguards consistent with Apple's security and privacy standards. We retain your data only as long as necessary to provide the service or as required by law.

Third-Party Processing & Data Sharing

To perform AI-powered facial analysis, facial images are transmitted transiently to a third-party AI service provider solely to generate the requested analysis.

  • The AI provider processes facial images only to return analysis results
  • The AI provider does not retain facial images
  • The AI provider does not use facial images for model training, biometric identification, advertising, or profiling

FaceCoach also uses the following third-party services:

  • RevenueCat: For managing in-app purchases and subscriptions
  • Cloudflare R2: For secure image storage
  • TikTok App Events SDK: For advertising attribution and campaign measurement. The TikTok SDK may collect device identifiers (such as IDFA, with your permission), app events (such as installs, launches, and purchases), and purchase data. This data is used to measure the effectiveness of advertising campaigns and optimise ad delivery. TikTok does not receive facial images or facial analysis data. For more information, see TikTok's Business Products Data Terms.

FaceCoach does not sell, rent, or share facial data for marketing purposes. No facial data is shared with advertisers or data brokers. All third-party service providers are required to provide data protection and security standards equal to or greater than those described in this Privacy Policy.

Advertising & Tracking

FaceCoach uses the TikTok App Events SDK to measure the effectiveness of advertising campaigns. With your permission (via Apple's App Tracking Transparency prompt), the SDK may access your device's advertising identifier (IDFA) to attribute app installs and in-app events to advertising campaigns. You can opt out of tracking at any time by declining the tracking prompt or by going to Settings > Privacy > Tracking on your device. If you opt out, the SDK will continue to function but will not access your IDFA for ad attribution. Facial images and facial analysis data are never shared with advertising partners.

Data Retention & Deletion

FaceCoach does not retain facial images on its own servers beyond what is necessary for processing. Facial images and analysis data remain stored on your device and in your private cloud storage until deleted by you. Upon deletion, facial data is permanently removed. FaceCoach does not maintain backups of deleted facial images.

Your Rights

You have the right to:

  • Access the personal data we hold about you
  • Request deletion of your data
  • Export your data
  • Opt out of non-essential data collection

To exercise these rights, contact us using the details below.

Children's Privacy

FaceCoach is not directed at children under 13. We do not knowingly collect information from children. If you believe a child has provided us with personal information, please contact us immediately.

Changes

We may update this policy from time to time. Any changes will be posted on this page with an updated date. Continued use of the app after changes constitutes acceptance of the updated policy.

Contact

If you have questions about this policy, contact us at fred@frederickjames.net.