Privacy Policy

Last updated: March 7, 2026

This Privacy Notice for True Eve ("we," "us," or "our"), operated by Mattheos (individual owner), explains how and why we may access, collect, store, use, and share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use the True Eve mobile application.
• Use AI features such as face scan analysis, personalized appearance recommendations, and progress tracking.
• Engage with us in related ways, including support, product updates, and communications.

Questions or concerns? Contact us at hello@trueeve.app.

Summary of Key Points

• What we process: account information, onboarding details, face photos/scans, derived facial metrics and scores, app activity, and device diagnostics.
• Sensitive data: facial imagery and face-analysis data may be treated as sensitive or biometric in some jurisdictions and is processed only to provide core app features.
• AI provider: for face-analysis features, data is sent to Google Gemini (Google LLC) after user consent in-app.
• How we use data: to operate, improve, secure, and legally comply with the Services.
• How we protect data: we use technical and organizational safeguards, but no system is 100% secure.
• Your rights: depending on your location, you may request access, correction, export, or deletion.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On?
4. When and With Whom Do We Share Information?
5. AI-Based Products and Third-Party AI Processing
6. Biometric and Face Data
7. International Data Transfers
8. How Long Do We Keep Information?
9. How Do We Keep Information Safe?
10. Do We Collect Information From Minors?
11. Do-Not-Track and Tracking Controls
12. What Are Your Privacy Rights?
13. US State Privacy Rights
14. Updates to This Notice
15. How to Contact Us
16. How to Review, Update, or Delete Your Data

1. What Information Do We Collect?

We collect personal information you provide directly, such as email, authentication data, age range, gender, and face photos used for scan analysis. We also collect derived face-analysis outputs (for example, facial scores, metrics, and scan history) and app usage/technical data (for example, app version, device type, crash diagnostics, and approximate IP location signals).

If you enable permissions, we may access camera, photo library, and notifications for app functionality. You can manage permissions in your device settings.

2. How Do We Process Your Information?

• Provide face analysis, insights, and personalized plans.
• Maintain accounts, subscriptions, and app functionality.
• Improve product quality, reliability, and performance.
• Prevent abuse, fraud, and security incidents.
• Comply with legal obligations and enforce terms.

For AI face-analysis features, we obtain in-app user consent before face photos and required related inputs are transmitted to our third-party AI provider.

3. What Legal Bases Do We Rely On?

Depending on your location, we process data based on consent, performance of a contract, legitimate interests, and legal obligations.

4. When and With Whom Do We Share Information?

We do not sell personal information. We may share data with service providers that help operate the app, including:

• Google LLC (Gemini): receives face photos and required related profile inputs when you use AI face-analysis features, only after in-app consent.
• Supabase: backend infrastructure and account-related data storage/sync.
• RevenueCat / Apple: subscription and purchase processing.

We may also share information where required by law or to protect rights, safety, and security.

5. AI-Based Products and Third-Party AI Processing

True Eve uses AI to generate appearance-related analysis and recommendations. Outputs may vary and are informational only; they are not medical or mental-health advice.

For face-analysis features, True Eve sends the following to Google Gemini (Google LLC):

• Front and side face photos submitted by the user.
• Required related profile inputs (such as age range, gender, and selected method preferences) needed to generate personalized outputs.

This transfer is used only to generate requested analysis results and personalized routine recommendations.

6. Biometric and Face Data

If facial imagery or face-analysis outputs are classified as biometric or sensitive data under applicable law, we process that data solely to provide core features (scan analysis, metrics, and progress history).

• Purpose: scan analysis, personalized guidance, and progress tracking.
• Disclosure: face-analysis data may be processed by Google Gemini (Google LLC) to generate requested AI outputs.
• Retention: kept while your account is active and for a reasonable period afterward unless deletion is requested or law requires longer retention.
• Deletion: you can request deletion via in-app account settings or email.

7. International Data Transfers

Your data may be processed in countries other than your own. Where required, we apply reasonable safeguards for transfers.

8. How Long Do We Keep Information?

We keep data as long as needed to provide the Services, meet legal requirements, resolve disputes, and enforce agreements.

9. How Do We Keep Information Safe?

We use technical and organizational safeguards, but no internet-based service can guarantee absolute security.

10. Do We Collect Information From Minors?

The Services are intended for users age 13 and older. If you are under the age of majority in your jurisdiction, you must use the Services with parent/guardian permission and supervision where required.

11. Do-Not-Track and Tracking Controls

Some browsers offer Do-Not-Track (DNT) controls. Because there is no consistent industry standard for DNT signals, we do not currently respond to DNT signals in a standardized way. You can still control permissions and notifications in device settings.

12. What Are Your Privacy Rights?

You may have rights to access, correct, export, restrict, or delete personal data, and to withdraw consent where applicable.

13. US State Privacy Rights

US residents in certain states may have additional privacy rights under applicable laws.

14. Updates to This Notice

We may update this notice from time to time. The latest version date will appear at the top of this page.

15. How to Contact Us

Privacy questions: hello@trueeve.app

• Controller/Owner: Mattheos (individual owner, True Eve)
• Country: Moldova
• Postal address: available upon verified legal request via email (for security/privacy reasons)

16. How to Review, Update, or Delete Your Data

You can request account/data actions via in-app settings or by emailing us at hello@trueeve.app.

This policy should be reviewed by qualified legal counsel before production at scale.