Legal

NovaGlow

Make-up analysis from a selfie

Privacy policy

Last updated: 5 September 2026

NovaGlow assesses your make-up from a selfie. The image is sent to our server and forwarded to the AI service Anthropic (“Claude”). So that the before/after history works, we store the overview photo together with the result on our server until you delete your account. A facial image is sensitive data — please read this section carefully.

1. Data controller

Company
Babala Özdemir (Einzelunternehmen)
Address
Unterer Rainweg 22
4414 Füllinsdorf
Schweiz
E-mail
info@babala.ch
Phone
076 222 45 99
Company ID
CHE-322.105.560
App identifier
iOS: ch.babala.novaglow
Android: ch.babala.novaglow

We have not appointed a data protection officer or an EU representative because we do not reach the relevant thresholds. Please address all requests to the contact above.

2. What data we process

Data Purpose Stored where Retention
Overview photo of your face Analysis and display in the history (before/after) Our server (EU data centre) and — for evaluation only — the AI service Until you delete your account
Crops of individual facial regions Detailed assessment by the AI service In memory only — not stored Seconds (duration of the analysis)
Analysis result, scores, colour type Display and history Our server Until you delete your account
Anonymous device identifier and access token Linking without a name or e-mail login Device and server Until you delete your account
Subscription receipt Verifying the term; statutory retention Our server; verified with Apple or Google 10 years (accounting obligation)

What we explicitly do not collect

3. Permissions on your device

The app requests only the following permissions. Each of them can be revoked at any time in your device settings; the app remains usable afterwards, with reduced functionality.

4. Legal bases

We process personal data under the Swiss Federal Act on Data Protection (revFADP). Where the GDPR applies, we rely on:

We process the facial image on the basis of your explicit consent, given by starting an analysis, which you may withdraw at any time by deleting your account.

5. Recipients and third parties

We do not sell data and do not disclose it for advertising purposes. Data is disclosed only to the following parties, and only where required for operation:

Recipient Location Purpose
Hetzner Online GmbH Gunzenhausen (Germany), data centre inside the EU Operation of our servers. Hetzner processes data solely on our behalf and is contractually bound to confidentiality.
Anthropic PBC («Claude») San Francisco (USA) Automated image analysis. The picture is forwarded by our server to the Claude API, analysed there and returned to us as a text result. Under its commercial terms Anthropic does not use API content to train models.
Apple Inc. / Apple Distribution International Ltd. Cupertino (USA) / Cork (Ireland) App Store distribution, processing of in-app purchases and subscriptions, and crash reports if you have enabled them with Apple.
Google Ireland Ltd. / Google LLC Dublin (Ireland) / Mountain View (USA) Google Play distribution, purchase processing via Google Play Billing, crash reports according to your Play settings.

Authorities and courts receive data only where we are legally obliged to provide it.

Transfers abroad

Some of the recipients listed above process data outside Switzerland and the EEA, in particular in the United States. We base such transfers on the European Commission’s Standard Contractual Clauses with the Swiss adaptations recognised by the FDPIC and, where applicable, on the EU-US Data Privacy Framework. We will provide information on the safeguards in place on request.

6. Retention and deletion

The overview photo and the corresponding result remain stored so that you can see your history. There is no automatic expiry. Individual entries currently cannot be deleted separately — the app offers no function for that. You remove photos and results by deleting your account: all image files and all evaluations are then removed immediately and irreversibly. Receipts for paid subscriptions are kept for 10 years (accounting duty); server logs expire after 14 days.

Step-by-step instructions are available at Delete data.

7. Children and young people

This app is not directed at children. We do not knowingly collect personal data from children under 16. If we learn that such data has been submitted without parental consent, we delete it without delay.

8. Data security

Wherever the app transmits data at all, connections are encrypted via HTTPS/TLS. On the server side we use access restrictions, tenant separation and regular backups. Nobody can, however, guarantee absolute security for data transmission over the internet.

Stored photos are kept under a randomly generated, unguessable file name. They are not listed in search engines and never shared with other users.

9. Your rights

An informal message to info@babala.ch or a call to 076 222 45 99. We normally respond within 30 days. To verify your identity we may request suitable proof. You may also lodge a complaint with a supervisory authority (Switzerland: FDPIC; EU: your competent authority).

10. Changes to this policy

We may adapt this policy when the app or the legal framework changes. The version published on this page, with the date shown above, is the applicable one. We announce material changes inside the app.

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