Privacy Policy
Last updated: July 7, 2026
This Privacy Policy explains how My Glow Up ("the App," "we," "us," or "our") collects, uses, shares, and protects your personal information when you use our mobile application.
My Glow Up is operated by Ingrid Victória Santos Borges ("the Controller"), based in Montes Claros, Minas Gerais, Brazil. If you have any questions about this policy or your data, contact us at admin@z21.com.br.
By using My Glow Up, you agree to the practices described in this policy. If you do not agree, please do not use the App.
Quick summary
We want you to understand this in plain language, so here's the short version. The full details are below.
- We ask you to upload a photo of your face so our AI can generate your color, glow-up, and facial analyses. We ask for your explicit consent before you upload it.
- Your photo is processed by artificial intelligence providers that work on our behalf to create your results.
- We never sell your photo. We never use it to train our own AI models. We never use it for advertising. Our AI providers process it only to create your results, under terms that restrict training their foundation models on your data.
- You can delete your account and all your data at any time from Settings.
- You have rights over your data, including access and deletion, under Brazilian (LGPD), European (GDPR), and California (CCPA) law.
- The App is intended for users 16 years or older.
1. Who is responsible for your data
The data controller responsible for your personal information is Ingrid Victória Santos Borges, operating the My Glow Up application, located in Montes Claros, Minas Gerais, Brazil.
For any privacy-related request or question, contact: admin@z21.com.br.
2. What information we collect
We collect the following categories of information:
Photos of your face. When you start an analysis, you choose to upload or take a photo of your face. This is the core of how the App works. Because facial images can be considered sensitive / biometric data, we treat them with special care and only process them after you give explicit consent (see Section 4).
Information you provide in the quiz. During onboarding, you may tell us your age, gender, beauty goals, skin concerns, product preferences, ethnicity, and skin type. You provide this to personalize your experience and recommendations.
Usage and analytics data. We collect information about how you use the App — such as screens viewed, features used, and events like starting a scan or viewing the paywall — to understand and improve the product.
Device and technical data. We collect technical identifiers and diagnostic information (such as device type, operating system, app version, and crash reports) to keep the App working and fix problems.
Purchase information. When you subscribe, the purchase is processed by Apple or Google. We receive confirmation of your subscription status (active, expired, etc.) but we do not receive or store your full payment card details — those are handled entirely by Apple and Google.
A basic account. When you first open the App, we create an anonymous account for you so your data and progress can be saved. You are not required to provide an email or name to use the App.
3. How we use your information
We use your information to:
- Generate your color analysis, glow-up, and facial analysis results from your photo;
- Personalize recommendations based on your quiz answers;
- Provide, maintain, and improve the App;
- Process and manage your subscription;
- Understand how the App is used and diagnose technical issues;
- Communicate with you about your account or important updates;
- Comply with legal obligations.
We rely on your consent to process your facial photo, and on our legitimate interest and the performance of our service to you for the other processing described above, as permitted by applicable law.
4. Your photo and biometric data
Because your facial photo is the most sensitive information we handle, this section explains exactly how it works.
We ask for your consent first. Before you upload any photo, the App shows you a consent step where you must actively agree that your photo will be processed by AI to generate your analysis. If you do not agree, you cannot proceed, and no photo is processed.
What we do with your photo. Once you consent and upload a photo:
- It is stored securely in our storage infrastructure;
- It is sent to specialized artificial intelligence providers that process it on our behalf to generate your results (see Section 5 for who they are and exactly what each receives);
- Some analyses derive characteristics from your photo — for example, an estimated face shape, eye shape, undertone, or skin tone — solely to produce your personalized results.
What we never do with your photo. We do not:
- Sell your photo or any data derived from it;
- Use your photo to train, develop, or improve our own AI models;
- Use your photo for advertising or marketing;
- Share your photo with anyone other than the processors listed in Section 5, who act only under our instructions.
Our AI providers process your photo solely to generate your results, under contractual terms that restrict the use of your data to train their underlying foundation models.
Deletion. You can delete your account at any time, which permanently deletes your photos and all associated data (see Section 9).
5. Who processes your data (service providers)
We work with a small number of trusted service providers ("processors" or "subprocessors") who process data on our behalf and under our instructions. They are not permitted to use your data for their own purposes. We organize them here by the type of data they handle.
Providers that handle your photo:
| Provider | What it does | What it receives |
|---|---|---|
| Supabase | Secure storage and database | Stores your photo and account data |
| Anthropic | AI analysis (color and facial analysis) | Receives your photo to generate the analysis text |
| Replicate (running models by Black Forest Labs) | AI image generation (glow-up) | Receives your photo to generate your glow-up image |
Providers that handle usage, device, or subscription data (not your photo):
| Provider | What it does |
|---|---|
| Mixpanel | Product analytics (how the App is used) |
| Sentry | Crash and error monitoring |
| RevenueCat | Subscription management |
| Expo | Push notifications |
| Apple / Google | Payment processing and app distribution |
This list may change over time as our service evolves. The current, up-to-date list of providers is always available in this policy, and the "Last updated" date at the top reflects the most recent change. Material changes will be communicated as described in Section 12.
6. How we share your information
We do not sell your personal information.
We share information only:
- With the service providers listed in Section 5, who process it on our behalf;
- When required by law, legal process, or a valid government request;
- To protect the rights, safety, or property of our users or ourselves;
- In connection with a business transfer (such as a merger or acquisition), in which case we will notify you and this policy will continue to apply to your information.
7. Data retention
We keep your personal information only as long as necessary to provide the App and for the purposes described in this policy.
- Your photos and account data are retained until you delete your account, or after 3 years of account inactivity, whichever comes first, after which they are deleted.
- When you delete your account, your photos and associated personal data are permanently deleted from our systems (see Section 9).
- Some limited records may be retained longer where required to comply with legal obligations, resolve disputes, or enforce our agreements.
8. How we protect your information
We take reasonable technical and organizational measures to protect your information, including access controls that restrict each user's data to that user, encrypted connections, and storage with a trusted infrastructure provider.
No method of transmission or storage is 100% secure, but we work to protect your information and to promptly address any issues that arise.
9. Your rights and how to delete your data
You have rights over your personal information. Depending on where you live, these may include the right to:
- Access the personal data we hold about you;
- Correct inaccurate data;
- Delete your data ("right to erasure");
- Port your data to another service;
- Object to or restrict certain processing;
- Withdraw consent at any time (which does not affect processing already carried out).
Deleting your account and data. The fastest way to delete everything is directly in the App: go to Settings → Delete Account. This permanently deletes your account, your photos, your analyses, and your associated data. This action cannot be undone.
Note: deleting your account does not automatically cancel your subscription. Manage or cancel your subscription in the App Store or Google Play.
You may also exercise any of your rights by contacting us at admin@z21.com.br. We will respond within the timeframe required by applicable law.
These rights are provided under Brazil's Lei Geral de Proteção de Dados (LGPD), the European Union's General Data Protection Regulation (GDPR), and California's Consumer Privacy Act (CCPA), among other applicable laws.
10. International data transfers
We and our service providers may process your information in countries other than your own, including the United States. Where we transfer personal data internationally, we take steps to ensure it receives an adequate level of protection consistent with applicable law.
11. Children's privacy
My Glow Up is intended for users who are 16 years of age or older. We do not knowingly collect personal information from anyone under 16. If you believe someone under 16 has provided us with personal information, please contact us at admin@z21.com.br, and we will take appropriate steps to delete it.
12. Changes to this policy
We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top and, where appropriate, provide additional notice within the App. Your continued use of the App after changes take effect means you accept the updated policy.
13. Contact us
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, contact us at:
Ingrid Victória Santos Borges Montes Claros, Minas Gerais, Brazil Email: admin@z21.com.br