Effective Date: August 8, 2026 | Last Updated: August 8, 2026
GlowPath ("we," "our," or "us") is a premium AI-powered skincare application operated by Oliver Kanyi Thairu, Tajpark Apartments, Riverside, Nairobi, Kenya.
This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use the GlowPath mobile application and any related services (collectively, the "Service").
By downloading, creating an account in, or using GlowPath, you acknowledge that we will process your personal information as described in this Privacy Policy. If you do not agree with these practices, do not use the Service.
This policy applies to all users of GlowPath worldwide. Where specific rights or obligations apply to users in particular regions — including the European Union, the United Kingdom, the United States (including California and Illinois), Canada, Australia, Kenya, Nigeria, and South Africa — those are addressed in dedicated sections below.
Account information: When you create a GlowPath account, we collect your first name, email address, and authentication credentials. If you sign in using Google or Apple, we receive the name and email address associated with that account.
Onboarding profile data: During onboarding, we collect your age range, biological sex, skin tone, primary skin concern, sensitivities, pregnancy or nursing status, water intake, sleep hours, climate type, current routine, skin goals, and time commitment.
Chat messages: When you use the AI chat advisor, we collect the content of your messages and responses.
Facial photographs: When you take a skin scan, the image is compressed on your device to a maximum of 800 pixels wide in WebP format before being transmitted. Only this compressed version is uploaded and stored. No full-resolution original is retained on our servers.
Derived skin health metrics: From your facial photographs, our AI extracts quantitative metrics including redness index, hydration score, texture variance, acne severity score, hyperpigmentation score, and an overall skin health score.
Product scan data: When you scan a skincare product, we process the ingredient list alongside your GlowProfile to generate a personalised compatibility and ingredient-risk assessment.
Important notice: Facial photographs and derived skin health metrics are sensitive personal data. In certain jurisdictions, including the United States (Illinois) and the European Union, facial data may be classified as biometric data under applicable law. We do not sell, license, or share your facial photographs or derived metrics with any third party for commercial purposes. We do not use your facial photographs or derived metrics to train AI models without your explicit, separately obtained consent.
Device information: Device model, operating system version, unique device identifiers, and mobile network information.
Usage data: Features used, scan frequency, session duration, and navigation patterns.
Log data: IP address, date and time of requests, and error logs.
Analytics and diagnostics: We use Firebase Analytics and Firebase Crashlytics to collect information about app usage, performance, and crashes. We configure these services to minimise personal data collection, but some device and usage data may be associated with your account depending on the exact configuration of these services.
GlowPath does not directly collect or store your payment card details. All subscription billing is processed by Apple (App Store) or Google (Google Play) and by RevenueCat, our subscription management provider. We receive confirmation of your subscription status, tier, trial status, and renewal events. We do not have access to your full payment card number, expiry date, or CVV.
Subscription cancellation: To cancel your subscription, use the Subscriptions section in the Apple App Store or Google Play Store. GlowPath cannot process cancellations directly.
For EU and UK users (GDPR / UK GDPR):
Automated decision-making: Our AI analysis involves automated processing of your facial data to generate skin health scores and personalised skincare recommendations. You have the right to contest automated decisions that significantly affect you by contacting us at support@glowpathskin.app.
We do not sell your personal data. We do not sell your facial photographs or derived skin metrics.
Service providers:
We may disclose information if required by law, court order, or to protect rights and safety. If GlowPath is acquired, your information may be transferred with notice.
Account data and GlowProfile: Retained for the duration of your active account. Deleted within 30 days of account deletion.
Facial photographs: Compressed to a maximum of 800 pixels wide in WebP format on your device before upload. Stored within your Firestore scan record for the duration of your active account to support scan history and progress tracking. Deleted upon account deletion or specific request. No full-resolution original is ever stored on our servers.
Derived skin health metrics: Retained for the duration of your active account to enable progress tracking. Deleted upon account deletion.
Product scan history: Deleted upon account deletion.
Chat conversations: Deleted upon account deletion.
Payment records: Retained for 7 years for compliance.
Log data: Retained for 90 days.
Right to access: Request a copy of your data.
Right to deletion: Delete your account via the app or by contacting us.
Right to correction: Update information directly in the app.
Right to withdraw consent: Withdraw consent for facial data processing. This will delete the data and disable scan features.
Opt-out of marketing: Use unsubscribe links or in-app preferences.
Additional rights: data portability, restriction of processing, objection to processing, and lodging complaints with supervisory authorities.
Rights: know, delete, non-discrimination. We do not sell your personal information. Facial data and derived skin metrics are sensitive personal information limited to the purposes for which it was collected.
We do not sell, lease, trade, or profit from your biometric data. We destroy biometric data within 3 years of your last interaction or when the collection purpose is satisfied, whichever comes first.
GlowPath is not directed to children under 13. We do not knowingly collect data from children under 13. If you are under 13, do not use the Service.
During onboarding, we collect your age range. We do not knowingly allow users under 13 to create an account or access any features of the Service.
GlowPath provides general skincare information and AI-generated recommendations for informational and cosmetic purposes only. It is not a medical device, does not diagnose medical conditions, and is not a substitute for professional medical advice, diagnosis, or treatment. Any skin health scores, acne severity ratings, ingredient-risk assessments, or product compatibility scores generated by GlowPath are intended for cosmetic and informational use only. Always seek the advice of a qualified healthcare provider or dermatologist for any medical concerns.
Measures include: TLS 1.2+ encryption in transit, encryption at rest, access controls, security reviews, API key protection, and rate limiting. No method is 100% secure. Contact us immediately if you suspect compromise.
Data may be transferred to countries outside your residence. For EU/UK users, transfers to Google LLC are subject to Google's Data Processing Amendment, which incorporates Standard Contractual Clauses approved by the European Commission. Available at cloud.google.com/terms/data-processing-addendum.
This policy does not apply to third-party websites or services linked within GlowPath.
We will notify you of material changes via in-app notice and email. Continued use constitutes acceptance.
Data controller: Oliver Kanyi Thairu, Tajpark Apartments, Riverside, Nairobi, Kenya
Privacy enquiries: support@glowpathskin.app
Data deletion: support@glowpathskin.app or use Delete Account in the app
Security concerns: support@glowpathskin.app
EU and UK data subject requests: We commit to responding within 30 days in accordance with GDPR Article 12. Contact support@glowpathskin.app.