PRIVACY POLICY

Last Updated on February 16, 2025

At “GlowPro: Skin Care Routine” accessible via this link, one of our main priorities is the privacy of our users. This Privacy Policy document contains types of information that is collected and recorded by for “GlowPro: Skin Care Routine” Mobile Application (hereinafter referred to as “App”) and how we use it.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

“GlowPro: Skin Care Routine” is developed and published by:

Bigoen A.Ş.
Adalet Mah. Manas Bulvarı Folkart Towers A Kule No:47 B Kat:35 Daire: 3509
Bayraklı/İzmir

Definitions

• Personal Data (or User Data): Any information that directly, indirectly, or in connection with other information allows us to identify a natural person.
• Usage Data and Log Files: Information collected automatically through this App (or third-party services employed in this App), which can include: the IP addresses or domain names of the computers used by the App Users, the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the App) and the details about the path followed within the App with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
• User: An individual who uses the App and knowingly agrees to this Privacy Policy.
• Data Subject: The natural person to whom the Personal Data refers.
• Data Processor: The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this Privacy Policy.
• Data Controller (or Company): A company which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this App. The Data Controller, unless otherwise specified, is the Owner of this App.
• Service: The service provided by this App as described in the relative terms (if available) and on this site/app.

Introduction

At Bigoen A.Ş. ("we", "us" or "our"), we are committed to protecting your privacy. This Privacy Policy ("Privacy Policy") explains our data protection practices and describes the types of information we may process when you install and/or use the “GlowPro: Skin Care Routine” software application for mobile devices (the "App", "our App"). For the purposes of this Privacy Policy, "personal data" or "personal information" refers to any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.

It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.

This Privacy Policy applies to all Users of the App, and others who access the App (“Users”). Under the General Data Protection Regulation (GDPR), we are the data controller, unless otherwise specified.

PLEASE TAKE THE TIME TO READ THROUGH THIS PRIVACY POLICY, AS IT CONTAINS IMPORTANT INFORMATION REGARDING THE WAY YOUR PERSONAL INFORMATION MAY BE PROCESSED. BY USING THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO ABIDE BY THE TERMS OF THIS PRIVACY POLICY.

Log Files and User Data We Collect About You

"GlowPro: Skin Care Routine" operates in accordance with standard procedures for data collection, including the use of log files. This website analytics practice is commonly employed by hosting companies. The information gathered from log files includes internet protocol (IP) addresses, browser types, Internet Service Provider (ISP) details, date and time stamps, referring/exit pages, and potential click counts. It's important to note that this data is not personally identifiable. The purpose behind collecting this information is to analyze trends, administer the website, track user movement, and gather demographic data.

In addition to the data collection from log files, we also collect the following information when you use our App:

• Email Address: When you login to the App via Apple, Google, we record your email address and link it to your corresponding account. This enables us to keep track of your user profile, associated data, and provide access to the App's full range of functions. As a result, you may periodically receive newsletters containing plant cultivation tips, important App announcements, and other related content. You can unsubscribe from these emails at any time. For more details on how your data is handled when receiving newsletters, please refer to the "Email communications" subsection in our Privacy Policy.
• Registration Information: If you choose to register with the App by linking your Apple ID, Google we will process your chosen method of registration, email address, name, and, if applicable, the photo associated with your account. If you uninstall the App without deleting your account, the associated information will be stored for a certain period of time. Please consult the "Use of Your Data" section in our Privacy Policy for further information. If you decide to permanently delete your account within the App, the saved information pertaining to your account will be irrevocably erased, and you will no longer have access to such data. By logging out of your account, your history will be wiped from the device. You can regain access to your history by logging back into the same account.
• Other Identity data: Your personal identification data such as birth date, usernames, names and surnames, and a phone number.
• Access to Camera and Photos: The App requires access to your device's camera and photos for scanning face and skin condition. However, we do not collect, store, or utilize any data from your camera roll unless you choose to upload or share it within the App. With your consent, we may also retrieve your geolocation data to provide more precise search results that align with your location-specific requests.
• Content Information Sharing: In order to offer both basic and extended features, the App may receive content information, such as images.

Please note that if you delete your account, all associated information will be permanently erased and cannot be recovered. Logging out of your account within the App will delete your browsing history from the device, but you can retrieve the history by logging back in with the same account.

Automatic Processing of Information

With your consent, our App utilizes third-party automated data processing technologies, such as different API tools and advertising / analytics tools to analyze specific data transmitted by your device. Some of these integrated tools may initiate the automated processing of your personal data, including profiling. Profiling involves the automated processing of personal data to evaluate individual characteristics such as interests, preferences, behavior, location, or movements. Automatic data processing starts when you grant permission for our App to track your activities.

For purposes aligned with our legitimate interests, we may process certain data pertaining to your device and user activity. This data falls under the categories specified in the "Automatic Processing of Information" subsection and is generally non-personal in nature. This means that it does not directly identify any particular individual, and we access and analyze it in an aggregated form. We utilize this information to enhance our App and ensure our users receive the best possible experience.

When using our App on a mobile device (including tablets, phones, smartwatches etc.), certain device-related details are reported, including "device identifiers." These identifiers are small data files or similar structures that uniquely identify the device while keeping personal information anonymous. This enables us to offer generalized reporting and personalized content and advertisements from third parties.

Types of Processed Data:

• Device Information: This encompasses details about your device, such as its type, operating system and version, model, manufacturer, screen size and density, orientation, audio volume, battery information, and memory usage.
• Internet Connection Information: This refers to data regarding your internet connection, including mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, connection speed, and browser information.
• Location-Related Information: This pertains to details tied to your location, such as IP address, country, region, state, city associated with the SIM card or device, language settings, time zone, and nearby commercial points of interest like coffee shops.
• App Data Reporting: Our App may be subject to automated processing and analysis, which involves reporting its name, API key (a unique identifier for the application), version, and properties. Some services also record the list of installed or running applications and processes on your device.
• Cookies and Similar Technologies: When using our App, we may utilize cookies and comparable technologies, such as pixels, web beacons, and scripts. A cookie is a small text file stored on your device when you access the App, which is sent back to the server upon each subsequent App usage. Cookies assist us in making the App more effective by tracking user access to specific areas or features and monitoring link or advertisement clicks. This aggregated information helps us comprehend and optimize App usage, improve our marketing efforts, and deliver relevant content and features. Additionally, advertisers or partners may serve ads or provide services to the App using cookies or similar technologies.
• Ad viewing data: Information related to the ads you view may include the date and time the ad was shown whether it was clicked or if it resulted in a conversion event, the content of the ad offer, the ad type (e.g., text, image, video), the placement of the ad within the App, and your response to the ad.
• App Analytics: When using our App, analytics tools automatically record various events, such as taps, scrolls, screens visited within the App, tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, and methods used to limit user data processing.

Disclaimer Regarding Data Processing by Third Parties

Please note that we do not have direct control over the data automatically provided to API tools or advertising / analytics tools. Therefore, we cannot be held responsible for how this data is processed. It is important to understand that certain services may create personal data profiles and access information related to your identity and/or device using technologies beyond our control. We do not have jurisdiction over, cannot monitor, and do not provide guarantees about how third parties handle your personal data, which may be collected through methods unrelated to our App. If you have any inquiries concerning the disclosure of your personal data, kindly direct them to these third parties (refer to the "Sharing of Your Information" section).

Email Communications

If you log in to our App using Apple, Google, your email address associated with your respective account may be utilized to send you communications, such as newsletters, regarding special subscription offers, new features, and other App-related information. You may have the option to provide your email address in the App Settings or through a separate popup window to receive our newsletters. When signing in with Apple, you can choose to keep your personal email address private by selecting the "Hide my email" option, which generates a random email address that forwards messages to your personal inbox. You have the freedom to unsubscribe from receiving emails at any time by using the unsubscribe link provided in each message.

Sharing of Your Information

Your information will only be disclosed to third parties in accordance with our Privacy Policy. We comply with the U.S. Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment. Our partnerships are exclusively with third parties that have provided assurances of employing the necessary technical and organizational measures to safeguard your personal data. However, we cannot guarantee the security of any information transmitted directly from the App to these third parties, and we are not responsible for any accidental loss or unauthorized access to your personal data resulting from their actions.

We do not rent or sell your personal data to third parties. Nonetheless, we may share certain information obtained from tools such as log files, device identifiers, and location data with third-party organizations that offer automatic data processing technologies for the App. We have no control over these third parties' tracking technologies or their usage.

Please also note that facial and skin scanning technology is performed by a third party, which uses the images uploaded to provide detailed scan results, possible diagnoses and video/text recommendations on the relevant topic. All images that the user uploads to the Application are transferred to this third party, but the photo materials are stored on our servers. However, materials provided by the user are stored solely for the purpose of improving internal algorithms and the operation of the artificial intelligence system, that is, they are NOT sold or distributed further.

Please note that we do not use, publish and/or sell media content provided by the end users for scanning purposes. All materials provided by the end users are used only to improve the stability and operation of the mobile application algorithm and object recognition purposes. All user’s media content is deleted from our cloud storage systems within an hour of the completion of the scan and is only used to train the neural network running on the mobile App. The user can always view the history of their scans in their personal account. The history is available until the user decides to delete the data.

Furthermore, in order to provide us with the necessary infrastructure for delivery and improvement of our services, we may engage the following third-party service providers:

Entity Name	Services Performed	Country	Link to Privacy Policy
Azure Development Co.	API Services	U.S.A.	https://azure.com
ChatGPT (OpenAI)	An artificial intelligence chatbot	U.S.A.	https://openai.com
Google LLC	Analytics / ad management service provider	U.S.A.	https://policies.google.com/privacy?hl=en-US
Unity Technologies SF	Analytics / ad management service provider	U.S.A.	https://unity.com/legal/privacy-policy
Firebase Crashlytics (Google LLC)	Analytics service provider	U.S.A.	https://policies.google.com/privacy https://firebase.google.com/support/privacy
RevenueCat	Analytics service provider	U.S.A.	https://www.revenuecat.com/privacy/
Adjust (Adjust GmbH)	Analytics service provider	Germany	https://www.adjust.com/terms/privacy-policy/
Amplitude	Analytics service provider	U.S.A.	https://amplitude.com/privacy

Please note that the list of these partners is not limited to the companies mentioned above. It may be replenished and/or limited at any time without prior notice from us.

Data Usage

We use your data for the following purposes only:

• Collecting personal data: The primary reason for collecting personal data is to ensure the proper functioning of the "GlowPro: Skin Care Routine" App. This includes resolving technical issues, troubleshooting, and maintaining its up-to-date status.
• Compliance with the law: We may need to disclose personal data to law enforcement, regulators, or other entities if required by applicable laws, regulations, legal processes, or enforceable governmental requests. Whenever possible, we will strive to notify you in advance before disclosing your information in response to such requests.
• Gathering feedback: Personal data may also be utilized for communication purposes. We are open to hearing about your experiences, preferences, and concerns regarding the App. We may contact you via email or other communication channels specified in your account.
• Legal claims and fraud prevention: Personal data may be used to establish, exercise, or defend legal claims as well as for purposes related to the prevention or detection of fraud when necessary.

Please be aware that providing us with your personal data is entirely voluntary. However, it should be noted that failure to do so may impact the availability and functionality of the App.

In general, we keep your personal information for as long as necessary to provide our App's services and fulfill our legal obligations. If storage becomes necessary due to legal obligations (such as taxation, accounting, or audit) or to ensure safety and prevent fraud or malicious activities, the data may be retained for a specific period, but not longer than the required storage duration.

Data Collection and Use of Face Data

The App accesses your device's camera and photo gallery to perform skin analysis through facial scanning features. This is necessary to generate personalized insights and recommendations regarding your skin’s condition. All media (e.g., images) the user voluntarily uploads are processed for skin analysis purposes.

We store face and skin images temporarily (maximum 1 hour) to run analysis through artificial intelligence-based algorithms. After the analysis is complete, these images are automatically deleted from our storage systems.

Sharing of Face Data with Third Parties

To ensure accurate skin analysis and recommendations, uploaded face data is shared securely with trusted third-party partners. These partners process the data strictly for analysis purposes, and the data is deleted immediately after processing is complete.  
- Azure AI Services: Provides API services for face and skin analysis. (Privacy Policy)

We guarantee no third parties will store or retain face data for purposes beyond the processing scope described above.

Data Retention Policy

Face data and skin photos are temporarily stored for one (1) hour following their upload to ensure the accuracy of the analysis process. This retention period allows for the proper execution of algorithms and the generation of results. Once this duration ends, the data is permanently erased from our servers. Users may delete their stored analysis history in the App at any time.

Third Party Privacy Policies

If you want to learn more about the services and their privacy options (including the ability to opt-out), please consult the relevant websites and privacy policies. We are not liable for any misuse of your personal data by the aforementioned third parties that does not adhere to our instructions.

Our App may have links to third-party websites/services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.

We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:

• As required by law;
• When we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

Requests

To make a verifiable consumer request for accessing, transferring, or deleting personal data, kindly reach out to us using the contact information provided at the end of this Policy. 

When making your request, please be prepared to provide information that can reasonably verify your identity as the person for whom personal information was collected. This may include your name, address, city, state, zip code, and email address. We may also ask you a series of security questions using this information.

If you are making the request through an authorized agent, they must provide written authorization, or a power of attorney signed by you. Additionally, it is important to describe your request in enough detail for us to properly understand, assess, and respond to it.

In case we are unable to verify your identity or authority to make the request, or confirm that the personal information pertains to you, we will not be able to fulfill your request or provide you with personal information. To verify your identity, we may request additional information or documents, and may also conduct checks through third-party identity verification services. This is to prevent any fraudulent or misleading requests and protect your personal information. Any personal information provided for identity verification purposes will not be utilized for any other reason. We will retain it for the necessary duration and delete it once the purpose has been fulfilled.

We strive to respond to legitimate consumer inquiries within 45 days of receipt. If additional time is required, we will notify you in writing about the reason for the extension and its duration. Please note that we are only obligated to address two requests per customer within a 12-month period.

We do not sell any of your personal data to third parties.

Security

We prioritize the security of your personal information and strictly adhere to industry standards to ensure its protection. Whether your data is in transit or when received by us, we employ appropriate measures to prevent any loss, misuse, unauthorized access, disclosure, alteration, or destruction.

We go to great lengths to uphold the data-protection principles, implementing the necessary technical and organizational measures. These measures include data minimization and the incorporation of safeguards into our processing methods. To further enhance security, we encrypt your personal data using reliable and secure encryption algorithms whenever possible. Additionally, we employ hashing techniques for added protection.

While we take extensive precautions to safeguard your personal data, it is important to note that no method of transmission over the Internet or electronic storage is entirely foolproof. Therefore, we cannot guarantee absolute security. In the event of a security breach compromising your personal information, we will promptly notify you in accordance with applicable laws.

Charges and Payment

Our e-commerce providers are responsible for billing, processing and charging for in-app purchases, handle your personal information and keep it absolutely safe and secure. This information is processed as part of the performance of the contract between you and us. We cannot access or use your credit or debit card information.

Please note that we are not responsible for your subscriptions’ payments, since all the payment issues are handled by App Store only. If you have any questions about the payment, please contact App Store Support.

International Data Transfers

If you are residing in the European Union or any other region with data protection laws that differ from those in the United States, it is important to note that we may transfer information, including personal data, to a country or jurisdiction that does not have the same level of data protection as your own. Given that we operate globally and cater our App to users worldwide, this cross-border nature necessitates the potential transfer of automatically processed information by us, as well as third-party organizations and our advertising partners, to other countries or regions.

We will take all necessary measures to ensure that the recipient of your personal data provides adequate protection in accordance with current legislation on data protection. By using our App, you consent to the potential transfer of your personal information to a third country, specified sectors within that country, or to an international organization.

We are committed to ensuring that the recipient of your personal data maintains an appropriate level of protection for the information received, taking into consideration the relevant legislation. While the level of protection may not mirror that offered in your country, we undertake the necessary actions to safeguard your personal information.

Minors

In order to download, install, access or use the App, you must be eighteen (18) years of age or older. If you are under 18 years of age, please stop using our mobile application immediately. Any person under the age of thirteen (13) years is not permitted to download, install, access or use the App.

If you are under 18 years of age and would like to use our application, please ask your parent or guardian to contact us and carefully review these terms of use for the mobile application.

“GlowPro: Skin Care Routine” does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Manage your Usage Data and How to Opt Out

You have exclusive rights to send copies of your personal information, delete, amend, or update your personal data, restrict its use, or revoke your consent for its processing at any time. It is important to note that if you withdraw consent for the usage of personal data, the functionality of the app will no longer be accessible to you.

To exercise your rights in controlling your personal data, please reach out to us at{" "} software@bigoen.com.

In certain circumstances, if your personal information is processed automatically, you may have the right to object to such processing. If your personal information is used for direct marketing purposes, you can request that the processing of your data for these purposes be stopped. To exercise this right, please consult the third-party services mentioned in Section VI of our Privacy Policy. Instructions can be found on their respective privacy pages, along with additional options such as functional APIs.

Consent

By using our website, you hereby consent to our Privacy Policy and agree to its Terms and Conditions.

Changes to This Privacy Policy

We evaluate our privacy policies and procedures to implement improvements and refinements from time to time. If we make any material changes to how we process your data, we’ll provide you notice through this Privacy Policy and by publishing a notice in the App. If you object to any changes, you may stop using the App.

Contact

For any questions regarding this policy, please contact us:
Bigoen A.Ş.
Adalet Mah. Manas Bulvarı Folkart Towers A Kule No:47 B Kat:35 Daire: 3509
Bayraklı/İzmir

Email: software@bigoen.com