1. Introduction

Elle Kaen Ventures LLC. (“we,” “our,” or “us”) operates the VanityOS mobile application (the “App”).

This Privacy Policy explains how we collect, use, disclose, and protect your information when you use the App.

Where explicit permission is required, merely using VanityOS or reviewing this Privacy Policy does not grant that permission. VanityOS asks separately before sharing personal data with OpenAI.

2. Information We Collect

2.1 Information You Provide

You may provide the following information when using the App:

• Account Information: Name, email address, authentication credentials (Apple Sign-In / Google Sign-In)
• Profile Information: Date of birth, gender identity, ethnicity
• Skin and Health Information: User-provided skin-related and lifestyle information, including skin condition details, acne characteristics, treatments, and habits
• Photos: Facial images and food photos captured through the App
• Chat Data: Messages and optional images shared with the AI assistant
• Food Logs: Food entries, timestamps, and related data

2.2 Information Collected Automatically

• Device identifier (random UUID)
• Push notification token (if enabled)
• App preferences (e.g., language settings)

2.3 Information We Do NOT Collect

We do not collect:

• Location data
• Contacts or address book data
• Browsing history across apps or websites
• Advertising identifiers (IDFA/GAID)
• Payment or financial information (processed by Apple App Store or Google Play)
• Raw voice recordings

Voice input is processed on your device by your operating system; we receive only transcribed text.

3. How We Use Your Information

We use your information to:

• Provide AI-powered skincare insights and App features
• Generate personalized informational outputs
• Enable AI chat functionality
• Analyze food-related inputs
• Track user progress over time
• Authenticate accounts
• Send notifications (if enabled)
• Improve and maintain App functionality

We do not use your data for advertising or tracking purposes. We do not track users across third-party apps or websites.

4. Sensitive Data and Consent

The App collects data that may be considered sensitive, including:

• Skin condition data
• Facial images
• User-provided skin-related and lifestyle information
• Demographic data (e.g., gender identity, ethnicity)

We collect and process sensitive data only as described in clear in-app notices and with permission where required. Before VanityOS sends personal data to OpenAI, the App separately identifies OpenAI, describes what may be sent and why, and requires an explicit, unselected permission choice. Choosing Not Now prevents OpenAI-backed features from sending that data. This data is used solely to:

• Provide personalized App features
• Generate insights and track progress
• Enable AI-powered functionality

We do not sell sensitive data or use it for advertising purposes.

Important: VanityOS is not a medical device and does not provide medical advice.

4.1 OpenAI Data Sharing

After you explicitly allow AI data sharing, VanityOS may send the following data through the VanityOS backend to OpenAI, depending on the feature you request:

• Skin photos or food photos you select for AI analysis
• Messages and images you send to V, recent conversation messages, and relevant summaries from past conversations
• Relevant profile, skin-health, skin check-in, and recent food-log information used to personalize the requested feature

OpenAI processes this data to provide and personalize the skin analysis, food analysis, or V response you request and to create short conversation summaries that help V retain relevant context for later chats. VanityOS does not sell this data or use it for advertising.

You may choose Not Now, allow AI processing later, or withdraw permission at any time under Settings > AI Data Sharing. Without current permission, VanityOS blocks new personal-data transmissions to OpenAI and the OpenAI-backed features are unavailable.

4.2 Face Data

VanityOS collects face data only when you choose to take or upload facial skin photos during onboarding, skin check-ins, or when attaching an image to the AI assistant. This face data consists of the facial skin photos you provide (front, left side, right side, and closeup views) and photo-quality analysis metadata generated from those photos, such as whether a face is detected, photo angle, lighting quality, blur level, face size in the frame, and analysis confidence.

VanityOS uses face data only to validate that a photo is suitable for skin analysis, provide personalized AI skin analysis, track visible skin progress over time, and respond to photo-based skincare questions you choose to ask in the AI assistant. VanityOS does not use face data to identify you, authenticate you, verify your identity, perform facial recognition, create a faceprint or biometric template, or track you across apps or websites.

After you allow AI data sharing, selected face data may be processed by OpenAI for AI-powered skin analysis and photo-based V responses. Cloudinary hosts and stores selected skin check-in photos, and Railway hosts the VanityOS backend that transmits requests and stores account-related check-in records. Face data may also be stored locally on your device. We do not sell face data, rent face data, use face data for advertising, or share face data with data brokers.

Face data is retained for as long as your account is active to provide skin progress tracking and related app features. If you delete your account or request deletion, we will delete face data associated with your account within 30 days, except where retention is required by law.

5. How We Share Your Information

We do not sell or rent your personal data.

We share data only with service providers necessary to operate the App:

• OpenAI: To provide and personalize requested skin analysis, food analysis, V responses, and short conversation summaries used for continuity. Depending on the requested feature, OpenAI may receive selected skin or food photos; V messages and attached images; recent conversation messages; relevant summaries and structured memory from past conversations; and relevant profile, skin-health, check-in, and recent food-log context. Data is sent through the VanityOS backend only after you allow AI data sharing.
• Cloudinary: To securely host and store selected skin check-in photos and food-scan photos for progress history and persistent food logs
• Authentication Providers (Apple / Google): For account login
• Push Notification Services (Expo): To deliver notifications
• Railway: To operate the VanityOS backend and store account, profile, check-in, food-log, V summary, and structured-memory records

Data is shared only as necessary to provide App functionality. We may disclose information if required by law or to protect our legal rights and users.

6. Data Storage and Security

Storage

• Data may be stored locally on your device and on secure servers
• Certain data (e.g., images, account data) is stored on secure backend systems

Security Measures

We implement industry-standard safeguards, including:

• Encrypted data transmission (HTTPS/TLS)
• Authentication controls
• Secure storage practices

While we implement reasonable safeguards, no system can be guaranteed to be completely secure.

7. Data Retention

We retain data only as long as necessary to:

• Provide App functionality
• Comply with legal obligations

When you delete your account, personal data is deleted or anonymized within a reasonable timeframe (generally within 30 days, unless legally required otherwise).

V conversation summaries and relevant structured memory may be retained while your account remains active to provide chat continuity. Data processed by OpenAI is handled under our service-provider controls and OpenAI's applicable retention terms. Withdrawing AI permission stops future sharing; use Delete Account or contact us to request deletion of data already stored with your account.

8. Your Rights and Choices

You have the right to:

• Access your data
• Update your information
• Request deletion of your account and data
• Withdraw consent where applicable
• Disable permissions (camera, notifications, etc.) through your device settings

AI Data Sharing

You can choose Not Now when asked for AI data-sharing permission, allow it later, or withdraw it at any time under Settings > AI Data Sharing. When permission is not active, VanityOS blocks new personal-data transmissions to OpenAI.

Account Deletion

You can delete your account:

• Directly within the App, or
• By contacting: support@vanityos.app

9. Children's Privacy

The App is intended for users aged 13 and older. If you are under the age of majority in your jurisdiction, you may only use the App with the involvement and consent of a parent or legal guardian.

If you are under the age of majority, your parent or legal guardian is responsible for your use of the App and any data you provide. We do not knowingly collect personal data from children under 13. If such data is identified, it will be deleted.

10. International Data Transfers

Your data may be processed in countries outside your residence (including the United States). We implement appropriate safeguards to protect your data in accordance with applicable laws.

11. Third-Party Services

Third-party services integrated into the App operate under their own privacy policies. We confirm that each third party with whom VanityOS shares user data, including OpenAI, Cloudinary, Railway, Apple, Google, and Expo, provides the same or equal protection of user data as stated in this Privacy Policy and required by Apple's App Review Guidelines. We encourage you to review their privacy policies before using those services.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify users of material changes by:

• Updating the “Last Updated” date
• Providing notice within the App

If a change requires new consent or changes how personal data is shared with OpenAI or another third party, VanityOS will request permission before the affected processing or sharing occurs. Continued use of the App does not replace a required affirmative permission choice.

13. Contact Us

If you have questions about this Privacy Policy or your privacy rights, contact: support@vanityos.app