Privacy Policy

LooksMentor ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and safeguard your personal data when you use our AI‑powered personal style and self‑improvement coach application (the "Service").

By using the Service, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the Service.

1. INFORMATION WE COLLECT

a) Account Information

When you register, we collect your email address, username, and display name.

b) Profile Data

You may voluntarily provide details to build your personal profile, including height, weight, body fat percentage (optional), skin type, hair type, style preferences, goals, custom notes, age, sleep habits, water intake, and any other information you choose to share during onboarding or profile editing.

c) Chat Conversations and Uploaded Content

Messages you send to the AI coach ("LooksCoach"), including any images or files you upload for facial analysis, are collected. Facial analysis images are processed solely on our own servers and are not sent to external providers.

d) Usage Data

We automatically collect certain information when you access the Service: IP address, browser type, device type, pages visited, features used, and timestamps. This data is obtained through standard server logs and third‑party analytics scripts. All such scripts are disclosed in this policy.

e) Payment Information

We do not store full credit card details. For crypto payments, NOWPayments provides us only with a confirmation containing a subscription ID and payment status. Card payments are processed by Paddle in a PCI‑compliant manner; we store only a customer reference ID and subscription status.

f) Cookies and Similar Technologies

We use essential cookies to maintain your authenticated session (Supabase session token). Non‑essential tracking cookies for analytics or affiliate attribution are also in use, and you are offered choices regarding them as required by law.

2. HOW WE USE YOUR INFORMATION

• To create and maintain your account, provide the Service, and deliver weekly AI‑generated improvement plans.
• To power the LooksCoach chat and respond to your messages.
• To process subscription payments and manage account status.
• To send transactional communications (e.g., account confirmation, password reset, plan expiration notices).
• To personalise your experience and improve our algorithms and features.
• To monitor, debug, and enhance the technical performance and security of the Service.
• To aggregate and anonymise profile data for product research and trend analysis. Such aggregated data cannot be used to identify any individual.
• To market our own related services to existing users where permitted by law (you may opt out at any time).

3. FREE TIER DATA USAGE & AI TRAINING

Our free tier uses an AI model provided by a third‑party service. This service may collect, retain, and use your prompts to improve its own models. This data processing is a necessary condition of using the free tier – it cannot be opted out of while remaining on the free tier. If you are not comfortable with this practice, you must upgrade to a paid plan (Basic, Premium, or Business), where your requests are handled under the zero‑data‑retention commitments described in Section 4.

Separately, LooksMentor gives you the opportunity to help us improve our own AI. This is entirely optional and requires your explicit consent.

What it involves: With your consent, we will use your anonymised profile data and chat messages to train or fine‑tune the AI models that power LooksCoach and personalised plans. Before any such use, we strip direct identifiers (email, username) from the data, but chat messages may still contain personal details you have shared.

Consent mechanism: You will be asked to provide this consent through a clear opt‑in checkbox (“Help improve LooksMentor AI”) during onboarding or later in your account settings. You can change your choice at any time.

Effect of declining: Declining this consent does not affect your access to the free tier or any features. It only means your data will not be used for LooksMentor’s own model improvement.

Paid tier: We never use data from paid‑tier users for LooksMentor’s AI training without their separate, explicit consent.

Withdrawal: You can withdraw your consent at any time via your account settings or by contacting us at infolooksmentor@protonmail.com. Withdrawal does not affect the lawfulness of processing that happened before you withdrew it.

4. PAID TIER ZERO DATA RETENTION

All paid plans (Basic, Premium, and Business) route your LooksCoach requests exclusively through providers that adhere to a strict Zero Data Retention (ZDR) commitment. This means:

• Your prompts are processed in memory only and are never written to disk.
• No prompts or outputs are stored after the response is generated.
• Your data is never used to train or improve any third‑party AI model.

In short, when you are on a paid plan, the AI provider does not keep or learn from anything you send. Additionally, LooksMentor itself will never use your paid‑tier data for our own AI training unless you separately and explicitly give us permission to do so.

5. LEGAL BASES FOR PROCESSING (FOR EEA/UK USERS)

For individuals in the European Economic Area or the United Kingdom, we rely on the following legal bases:

• Performance of a contract: Processing necessary to provide the Service (e.g., account creation, generating plans, chat functionality).
• Consent: For optional activities such as the free‑tier AI training described in Section 3, and for non‑essential cookies or analytics.
• Legitimate interests: For fraud prevention, service improvement, direct marketing of related services to existing users (where permitted), and ensuring the security of our platform.
• Legal obligation: Compliance with applicable laws, such as responding to lawful requests from authorities or retaining payment records for tax purposes.

6. HOW WE SHARE YOUR INFORMATION

We do not sell your personal data. We share data only with trusted service providers who help us operate the Service:

• Supabase: Provides our database and authentication infrastructure, processing all user data (account, profile, chat history).
• Render: Hosts our application servers and may log IP addresses and request metadata for operational purposes.
• AI Model Providers: To generate AI responses, we transmit profile snippets and chat messages to AI models through a secure API gateway. These providers receive only the data necessary to generate responses and are contractually prohibited from using your data for their own training purposes, except as described in Section 3 for free‑tier users.
• NOWPayments: For crypto transactions, NOWPayments receives only the order ID and amount.
• Paddle: For card payments, Paddle collects and processes the personal data necessary to complete the transaction and comply with tax laws. We store only a customer reference ID.
• Facial analysis: Any image you upload for facial analysis is processed exclusively by a script on our own Render servers. The image is not transmitted to any third party.

We may also disclose information if required by law, to protect our rights, or in the event of a business transfer.

7. DATA RETENTION

• Account and profile data: We retain your data for as long as your account remains active. If you delete your account, we will delete all associated personal data from our active systems within 30 days, except for data we must keep to comply with legal obligations or anonymised logs that no longer identify you.
• Chat history and plans: Stored until you delete your account; you can also manually clear your chat history from within the app at any time.
• Payment records: Retained for the period required by applicable tax and accounting laws.
• Free‑tier AI training data: If you consented, anonymised data may be used in training runs and retained in the trained models even after account deletion. We cannot remove your data from a model that has already been trained on it, but we will delete the source datasets associated with your account upon deletion, and we will not use it in future training.

8. YOUR RIGHTS AND CHOICES

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request a copy of the data we hold about you.
• Rectification: Correct inaccurate or incomplete information.
• Erasure: Request deletion of your data ("right to be forgotten"), subject to legal retention requirements.
• Restriction: Ask us to limit how we process your data in certain circumstances.
• Objection: Object to processing based on legitimate interests, including direct marketing.
• Data portability: Receive your profile data in a structured, commonly used machine‑readable format (JSON).
• Withdraw consent: Where processing is based on consent, you can withdraw it at any time.
• Complaint: Lodge a complaint with a data protection supervisory authority in your region.

To exercise any of these rights, please email us at infolooksmentor@protonmail.com. We will respond within the timeframes required by law. We may need to verify your identity before processing your request.

9. INTERNATIONAL DATA TRANSFERS

Our servers (Render) and database (Supabase) are located in the United States. If you are located outside the US, your personal data will be transferred to and processed in the US.

For users in the EEA, UK, or Switzerland, we ensure that such transfers are protected by appropriate safeguards, namely Standard Contractual Clauses approved by the relevant authorities, or by relying on an adequacy decision where applicable. You may request a copy of the relevant safeguards by contacting us.

10. CHILDREN’S PRIVACY

The Service is not directed to individuals under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that a child under 13 has provided us with personal data, we will take steps to delete it promptly. If you believe a child has provided us with information, please contact us.

11. DATA BREACH PROCEDURES

In the event of a personal data breach, we will notify the affected users and the relevant supervisory authority within 72 hours of becoming aware of the breach, in accordance with applicable data protection laws. Our notification will describe the nature of the breach and recommend measures you can take.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. When we make material changes, we will notify you via email and/or a prominent notice within the application before the changes take effect. Your continued use of the Service after the effective date of the updated policy constitutes your acceptance of the changes. We encourage you to review this page periodically.

13. CONTACT US

If you have questions, concerns, or wish to exercise your data protection rights, please contact our privacy team:

Email: infolooksmentor@protonmail.com

The data controller for your personal data is LooksMentor. Our team operates internationally, with founding members in Kosovo and Jordan, and we operate under a parent company for payment processing. For all privacy matters, please use the contact email above.