Privacy policy
1. Who we are
Facetry (the "app") is published by Cherry Pub LLP, registered office 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ, company number OC431055 ("we", "us").
We are the controller of the personal data described here. Contact: app@greentomatomedia.com. Greentomatomedia Limited, a member of Cherry Pub LLP, runs Facetry's servers and answers support emails on our behalf, as our processor: it uses your data only on our instructions.
This policy covers the Facetry apps for Android and iPhone and the website facetry.web.app. It does not cover other websites, or the App Store, Google Play and Google or Apple sign-in, which have their own policies.
2. The short version
- You sign in with Google, or with Apple on iPhone.
- Your selfie is sent only after you agree, and only when you make a face card or try a look. It goes to OpenAI, whose AI reads your features and makes your looks for us. OpenAI doesn't train its models on it and deletes it within 30 days.
- Our server never keeps your photo. Your face card and your looks are kept in the app on your phone, and we never use your face to identify you (section 4).
- There are no ads and no cross-app tracking. We never sell or rent your data.
- Usage statistics are off unless you say yes, and you can change your answer at any time in Account → Usage statistics.
- You can delete your account in the app at any time: Account → Delete account (section 9).
3. What we collect and why
3.1 Your account
You sign in with Google, or with Apple on iPhone. When you sign in with Google, Google gives us your name, email address and profile picture. When you sign in with Apple, Apple gives us an email address (it can be a private relay address that hides your real one) and your name if you choose to share it. We keep them, with the styles you chose to see first (women's, men's or both), to run your account, and for nothing else. We don't send newsletters, marketing emails or notifications.
3.2 Your photo, your face card and your looks
The app asks for your permission before your first photo leaves your phone. After that:
- Face card. On your phone, the app finds the outline of your face and works out four proportions, such as how long your face is for its width. It sends a smaller copy of your selfie and those proportions to our server, which passes the photo to OpenAI's model, with a short note if your face is clearly longer or shorter than most. The model describes the features that matter for styling: your face shape, skin undertone, eye shape, brows, jawline, hair texture and similar. Our own stylist rules then score every style from that description, and your face card comes back to the app.
- Looks. For a look, the app sends your selfie and the style you picked to our server, which passes them to OpenAI's image model and sends the new image straight back to the app.
- Adult check. Facetry only works with photos of adults. When you make a face card, and the first time you use a photo for a look, OpenAI's model checks that the photo shows an adult (see section 11).
- Your best look and language changes. For "Your best look", and when you change the app's language, our server sends your face card's words, not your photo, to OpenAI's model, which picks a combination from our shortlist or translates the text.
We use your photo, and what is read from it, only to make your face card and your looks. We never use them to identify you or to recognise you in other photos, never to judge your ethnicity, health, attractiveness or age (apart from the adult check), and never for advertising. If you use a photo of another adult who has agreed to it, we handle their photo in the same way. Section 4 explains exactly what we keep, and for how long.
3.3 What stays on your phone
Your selfie, your face card and your looks are kept in the app's own storage on your phone. They leave it only as described above, or when you tap Save or Share: then they go to your gallery or to the app you choose, which handles them under its own terms. Deleting your account in the app, or uninstalling Facetry, deletes them from the phone. On iPhone, your selfie and your looks are kept out of iCloud and computer backups, but your face card can stay in those backups until they're replaced.
3.4 Facetry Weekly and Facetry Yearly subscriptions
Purchases are made and paid through the App Store or Google Play. We never see your card or bank details.
We use Adapty (Adapty Tech Inc., USA) to check whether your subscription is active. Adapty receives an Adapty profile ID, your Facetry account ID so your subscription follows your account, your purchase and subscription status and history from the store, and basic device information (such as model, operating system, app version, store country and language). Collection of the IP address and of the advertising IDs (IDFA, Android Advertising ID) is turned off.
We keep a record of each purchase: the plan, the price, the date and the store's transaction number.
3.5 Keeping the app working and secure
- Usage record. Our server keeps a record of the main things you do in Facetry, linked to your account: signing up, making a face card (with the face shape it found and its top style), trying a look (and which style), buying, renewing or cancelling a plan, and what each face card and look cost us to make. If you allow usage statistics (section 3.6), it also records the screens you open and what you tap. We use this record to run Facetry, keep it fair and affordable, and fix problems.
- Crash reports (Firebase Crashlytics). If the app crashes, it sends a technical report: your device model, system version and app version, a random ID for the app on your phone, and what went wrong. It contains no photos, no name and no email address.
- Server logs. Like any online service, our hosting provider logs technical data such as your IP address and the time of each request, to keep Facetry secure and fix errors. We do not use them to identify you.
3.6 Usage statistics (Google Analytics for Firebase)
To understand how Facetry is used and make it better, the app can send usage statistics to Google Analytics for Firebase, run by Google as our processor, and record the same events in our usage record.
What is sent: the screens you open and how long you stay on them, and what you try, such as making a face card, picking a style or trying a look; device and app information (device model, operating system, app version, language); your approximate country and city, which Google derives from your IP address without storing the address; and a random app-instance identifier.
What is never sent: your photos, your name, your email address, your account ID, anything about your face (including your face shape), or your advertising ID. The app turns off Google Analytics' advertising features, and the data is not used for advertising.
Your choice: after the photo permission, the app asks whether you'd like to share usage statistics. Nothing is sent unless you say yes, and you can change your answer at any time in Account → Usage statistics.
Retention: up to 14 months in Google Analytics, and 24 months in our usage record (section 5).
3.7 Support and reports
If you email us, we receive your message, your email address and anything you choose to send. If a face card or a look seems wrong or offensive, you can report it in the app: a report sends us the reason and which look or face card it was, never the image. We use this to answer you, to make Facetry's results better and to enforce our Terms.
3.8 Camera and photos
The camera is used only on the selfie screen, and only while it's open. If you pick a photo instead, your phone's photo picker gives Facetry only the photo you choose.
3.9 What we do not do
We do not collect your phone number, contacts, precise location or advertising ID. We do not show ads, use advertising cookies, track you across other companies' apps or websites, or sell or share your personal data for advertising.
4. Your face data
Some laws give information about a person's face extra protection, and some US states, such as Illinois, Texas and Washington, have rules for "biometric" data. This section is our policy for face data, wherever you live.
- What it is. The four face proportions the app works out on your phone; your selfie, when you make a face card or try a look; and the features read from it (face shape, skin undertone, eye shape and similar), which make up your face card.
- Your permission first. The app asks for your permission before your first photo leaves your phone. Without it, Facetry can't make face cards or looks.
- Why we use it. Only to make your face card and your looks, to refuse photos of children, and to check that face cards read faces well. We never use it to identify you or to recognise you, we don't create face templates or faceprints (the kind of data used to recognise people), and we never use it for advertising.
- Who receives it. Only the companies that process it for us (section 6): OpenAI, which reads your photo and makes your looks, and Google, whose cloud runs our server and stores the records below. OpenAI doesn't use your photo to train its models, and our requests don't store it with OpenAI. OpenAI keeps it for up to 30 days only to check for abuse, unless the law requires it to keep it longer, and then deletes it. We never sell, rent, lease or trade face data, and we never share it with anyone else unless the law requires it.
How long we keep it:
- Your photo. Our server never keeps it. OpenAI deletes it within 30 days.
- Your face card. Kept with your account, in the app on your phone, and deleted with your account. Our usage record notes the face shape each face card found; when you delete your account it's no longer linked to you, and it's deleted 24 months after it was recorded.
- Four face proportions. Kept on our server without your account ID, with the face shape found and the type of phone (Android or iPhone), for up to 12 months, to calibrate how the app measures faces. Your face shape is never sent to Google Analytics.
- The adult check. A yes-or-no answer and a one-way fingerprint of the photo (it can't be turned back into the photo), kept with your account so children's photos stay refused and the same photo isn't checked twice. They're deleted with your account.
We permanently destroy face data when the reason we collected it ends, or at the end of the periods above, whichever comes first. We protect it at least as carefully as our other confidential data (see section 12).
5. Data table
| Data | Purpose | Where it is stored / who processes it | How long we keep it |
|---|---|---|---|
| Sign-in details: name, email address, profile picture, Google or Apple account ID | Sign you in and run your account | Firebase Authentication (Google, United States) | Until you delete your account; Google then removes them from its systems within 180 days. Sign-in logs with IP addresses: a few weeks |
| Your account: name, email address, picture, style choice, subscription status, fair-use counts | Run your account and your plan | Cloud Firestore (Google, EU, europe-west1) | Until you delete your account |
| Your selfie | Make your face card and your looks | Passed through our server, never saved there; OpenAI (United States) | Not kept by us; OpenAI deletes it within 30 days |
| Your face card: face shape and features | Show your face card and suggest styles | The app on your phone; the face shape also in our usage record | Until you delete your account or uninstall the app |
| Four face proportions, with the face shape and phone type, without your account ID | Calibrate how the app measures faces | Cloud Firestore (Google, EU, europe-west1) | 12 months |
| Adult check: yes or no, and a photo fingerprint | Refuse photos of children | Cloud Firestore (Google, EU, europe-west1) | Until you delete your account |
| Usage record | Run Facetry, keep it fair and affordable, fix problems | Cloud Firestore (Google, EU, europe-west1) | 24 months; no longer linked to you once you delete your account |
| Usage statistics, only if you say yes | Understand how Facetry is used and improve it | Google Analytics for Firebase (Google) | Up to 14 months; nothing new is sent once you turn statistics off |
| Crash reports | Find and fix crashes | Firebase Crashlytics (Google) | 90 days |
| Subscription status, purchase history, Adapty profile ID, account ID | Sell and check your subscription | Adapty (United States); Apple / Google | Until you delete your account (the Adapty profile is deleted with it); store records under Apple's and Google's policies |
| Purchase records: plan, price, date, the store's transaction number | Tax and accounting | Cloud Firestore (Google, EU, europe-west1) | 6 years after the purchase |
| Support messages and reports | Answer you, improve results | Our email, run for us by Greentomatomedia Limited; reports in our usage record | Emails: 2 years after your last message. Reports: as the usage record |
| Server connection logs: IP address, time, request | Security, reliability | Google Cloud / Firebase | 30 days |
| Visits to this website: IP address | Deliver the pages and stop abuse | Firebase Hosting (Google) | A few months |
7. Where your data is stored
Your account, the records described in this policy and our purchase records are stored by Google in the European Union (europe-west1, Belgium). Some providers process data in the United States or other countries: Firebase Authentication (run only from Google's US data centres), Firebase Crashlytics, Google Analytics for Firebase and Firebase Hosting (Google's infrastructure around the world), OpenAI and Adapty (United States), and Apple and Google for purchases. When a provider receives data from the UK or EEA outside those areas, we rely on adequacy decisions (such as the EU-US Data Privacy Framework and its UK extension where the provider is certified) or Standard Contractual Clauses.
8. Legal bases (EU and UK users)
- Contract: to run your account, make the face cards and looks you ask for, provide your subscription and its fair-use limits, and answer your emails.
- Consent: sending your photo to OpenAI and reading your features, which you agree to on the permission screen; usage statistics, which start only if you say yes; and the camera, which you allow through your phone's permission prompt. You can withdraw consent at any time (section 10); that doesn't affect what was done before.
- Legitimate interests: crash reports, the usage record, server logs, the adult check, the face proportions that calibrate the measurement, security and anti-abuse, and keeping the service reliable. You can object (section 10).
- Legal obligation: tax and accounting records for purchases, and answering lawful requests.
9. Deleting your account and data
In the app: Account → Delete account. On iPhone, if you signed in with Apple, you then confirm with Apple, and the app ends Facetry's access to your Apple Account. This immediately:
- deletes your account from our server: your name, email address, profile picture and style choice, your subscription status, your fair-use counts and your adult checks;
- deletes your sign-in account, and your subscription profile at Adapty;
- removes your selfie, your face card and your looks from the app on that phone;
- unlinks your usage record from you.
Without the app: email app@greentomatomedia.com from the address you signed in with and ask us to delete your account. We confirm within 30 days.
What remains, never with your name, email address or photos:
- Facetry Weekly and Facetry Yearly are billed by Apple or Google: deleting your account does not cancel your subscription. Cancel it in your App Store or Google Play settings. Apple and Google keep their own purchase records under their policies.
- Our purchase records (plan, price, date and the store's transaction number) are kept for 6 years after each purchase, for tax and accounting.
- The usage record, no longer linked to you, is deleted 24 months after each entry was recorded. Face proportions, which were never linked to you, are deleted within 12 months.
- Crash reports expire on their own after 90 days, and usage statistics in Google Analytics, which aren't linked to your account, after at most 14 months. Support emails are kept for 2 years after your last message.
- Google removes your deleted sign-in from its live and backup systems within 180 days.
- Uninstalling the app removes the data stored on your phone, but doesn't delete your account or cancel a subscription.
10. Your rights
Depending on where you live (for example the EU, UK, or US states such as California), you can ask us to: access your data or get a copy; correct it; delete it; restrict or object to processing based on legitimate interests; and withdraw consent at any time. We do not sell or "share" personal data for targeted advertising, and we do not use it for decisions with legal effects about you. We will not treat you differently for using your rights.
Most of this you can do yourself in the app: turn usage statistics on or off (Account → Usage statistics) or delete your account (Account → Delete account). To withdraw your permission to send your photo to OpenAI, stop making face cards and looks and delete your account, or email us. For anything else, email app@greentomatomedia.com. We answer within one month (45 days under US state laws). We may ask you to prove the account is yours, for example by writing from your sign-in email.
Your face card, the style scores, Your best look and the adult check are produced automatically, by AI and our stylist rules. They only decide which styles to suggest and which photos Facetry can use, and none of them has a legal or similarly significant effect on you. If you think a photo was refused by mistake, email us.
You can also complain to your data protection authority, for example the UK Information Commissioner's Office (ico.org.uk) or the authority in your EU country.
11. Children
Facetry is for people aged 18 and over, and we do not knowingly collect personal data from anyone under 18. The app refuses photos that look like a child's; this check is automatic and can be wrong. If we learn that an account belongs to someone under 18, we delete it. If you think someone under 18 has given us personal data, contact us and we will delete it.
12. Security
All data travels over encrypted connections (HTTPS/TLS), and Google stores it encrypted. Database rules stop the app from reading our database directly: only our server can. Our service keys are kept in Google Secret Manager, and our server never stores your photos. Access to our consoles is limited to the people who run Facetry. No system is perfectly secure, and we will notify you and the authorities of a breach when the law requires it.
13. If you live in the United States
- What we collect. In the last 12 months we collected identifiers (name, email address, account and device IDs), the photos you chose, the features read from them (face data, which some states treat as biometric or sensitive information), purchase records, how you use the app and, if you allow usage statistics, your approximate location. They come from you, your phone, Google or Apple sign-in and the app stores, and we use them for the purposes in this policy.
- No selling or sharing. We don't sell your personal information or share it for cross-context behavioural or targeted advertising, and we haven't done so in the last 12 months. We use sensitive information, such as face data, only to provide Facetry, never to infer things about you.
- Do Not Track. Facetry doesn't track you across other companies' apps or websites, and doesn't let other companies do so through Facetry, so it doesn't respond to Do Not Track signals. We treat a Global Privacy Control signal as a request not to sell or share your data, which we don't do anyway.
- Your rights. Section 10 explains your rights and how to use them. You can use an authorised agent, and if we refuse a request, you can appeal by replying to our answer.
- Face data (Illinois, Texas, Washington and other states). Section 4 is our written policy for face data: what we collect, why, how long we keep it and when we destroy it. We collect it only after you agree on the permission screen, we never sell, lease, trade or otherwise profit from it, and we disclose it only to the companies that process it for us to provide Facetry, or when the law requires it.
- Changes. We'll tell you about important changes as section 15 says.
14. Our website
facetry.web.app uses no cookies, no analytics and no trackers, and its fonts come from our own site, not from Google's font servers. Firebase Hosting, which serves the site, sees your IP address to deliver the pages and keeps it in its logs for a few months to stop abuse. When you follow a link to another site, such as Google Play, the App Store or Apple's licence agreement, that site's own privacy policy applies.
15. Changes to this policy
We will update this page when our practices change and change the date at the top. For important changes, we will also tell you in the app before they take effect, and ask for your permission again where we need it.
16. Contact
Cherry Pub LLP
71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ
Email: app@greentomatomedia.com
Help and support: https://facetry.web.app/#support
See also our terms of use.