Privacy Policy
Last updated: July 2026 (v2) · applies to the GlowDiary app and this website
In short. Skin analysis happens entirely on your device. Your photo is never sent to us or to anyone else, and it is never stored. Only the resulting scores (e.g. “Clarity 76”) and your own journal entries are kept. You can delete your account and all its data at any time.
1. Controller
gx-systems
Owner: Danny Schmiedel
Pfaffenweg 16
04319 Leipzig
Germany
Email: glowdiary@gx-systems.de
2. Data we process
Account
Your email address and a technical user ID. If you sign in with Google or Apple, we receive your email address and an identifier from them. We never receive your password.
Skin analysis
For a scan you take or select a photo. The analysis runs entirely on your device. The image never leaves your phone and is discarded once the values are calculated.
What we store permanently are only the resulting values: overall Glow Score, clarity, hydration, radiance, evenness, a short note, the date, and whether it was a morning or evening scan.
Journal
Information you enter yourself: your skincare routine and products, plus entries on sleep, water intake and stress.
Subscription
If you subscribe, we process your subscription status. We never receive payment details — billing is handled entirely by Apple. We are only told whether a valid subscription exists.
Technical data
Log data such as access time, device type and error reports, used to keep the service running and secure.
3. Legal bases (GDPR)
| Purpose | Basis |
|---|---|
| Providing your account, syncing data, managing subscriptions | Performance of a contract, Art. 6(1)(b) |
| Analysing your skin on your device, storing the resulting scores | Performance of a contract, Art. 6(1)(b) |
| Keeping the service secure and preventing abuse | Legitimate interests, Art. 6(1)(f) |
Because the analysis runs locally, no consent to a data transfer is required for scanning.
4. Service providers and transfers
| Provider | Purpose | Location |
|---|---|---|
| Google Ireland Ltd. / Google LLC (Firebase) | Authentication, database, operations | Database in Frankfurt, Germany (europe-west3); support and operations may access from the USA |
| RevenueCat, Inc. | Subscription status management | USA |
| Apple Inc. | Distribution, payments, “Sign in with Apple” | EU / USA |
Transfers to third countries
Your scan photos are never transferred — they stay on your device. The remaining services (authentication, database, subscription status) may involve access from the USA, based on Standard Contractual Clauses and the EU-US Data Privacy Framework.
5. Retention
- Scan photos: never leave your device and are not stored.
- Scores and journal: until you delete them or your account.
- Account data: until you delete your account.
- Log data: typically a few weeks.
- Statutory retention obligations (e.g. tax law) remain unaffected.
6. Deleting your account
You can delete your account in the app under Profile → Settings → Delete account. This removes your scan results and journal entries. Alternatively, email glowdiary@gx-systems.de.
Cancel an active subscription in your Apple account settings — deleting your GlowDiary account does not automatically cancel it.
7. Your rights
- Access to your data (Art. 15)
- Rectification (Art. 16)
- Erasure (Art. 17)
- Restriction of processing (Art. 18)
- Data portability (Art. 20)
- Objection to processing based on legitimate interests (Art. 21)
- Withdrawal of consent with future effect (Art. 7(3))
You may also lodge a complaint with a supervisory authority (Art. 77). Ours is the Saxon Commissioner for Data Protection and Transparency, Devrientstraße 5, 01067 Dresden, Germany.
8. No automated decisions, not a medical device
No automated decision-making with legal effect within the meaning of Art. 22 GDPR takes place. The values shown are an assessment of your skin’s appearance for documentation purposes. GlowDiary is not a medical device, does not provide diagnoses, and does not replace medical or dermatological advice.
9. This website
When you visit this site, our host processes technically necessary access data. We use no analytics or advertising cookies and embed no tracking services.
10. Changes
As the app evolves or the legal situation changes, we will update this policy. The version published here is the applicable one.