Privacy
Privacy Policy
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At Elumea, privacy is a design choice: the app works without an account and offline, and your photos never leave your iPhone. This policy explains what data is processed, why, by whom, and how to exercise your rights. It applies to the Elumea app and to the elumea.app website.
1. Who is responsible for your data?
Elumea is an iPhone app published by Nuvela Beauty, the controller of the data processing described in this policy:
- Nuvela Beauty, operated by Lucie Bonino ([à compléter]);
- address: 28 rue de l’Amphithéâtre, 84400 Apt, France;
- registration: [à compléter];
- contact: support@elumea.app.
Further legal information is available in the legal notice (in French).
2. The principle: most of your data stays on your iPhone
Elumea is designed to work locally. Your questionnaire answers, program, sessions, skin journal (text and photos), scans, favorites, routine and reminder settings are stored on your device. Sessions, the timer, voice guidance, the routine, the journal and the scanner all work offline.
Some features do go through our server, even without an account:
- product search, which sends your skin profile and scan scores;
- the routine banner on the Lock Screen, which sends your reminder times and tokens issued by Apple;
- subscription management, through RevenueCat.
Without an account, this data is tied to an installation identifier: a random code created by the app the first time it runs, which contains neither your name, nor your email address, nor any advertising identifier. It is erased when you delete the app.
3. The camera, the scanner and your photos
The app uses your iPhone’s camera for two purposes:
- the skin scanner: the photo is analyzed directly on your iPhone, using Apple’s Vision framework;
- your journal’s photo of the day, taken with the front camera or imported from your photo library.
These photos are never sent to our servers or to any third party, and are not synced. They are stored in the app’s storage on your iPhone, with iOS file protection. Only the scores produced by the scanner (hydration, shine, redness, texture, dark circles, fine lines, wrinkles, crow’s feet, pores, spots, evenness) are kept and, in the cases described below, transmitted.
Access to the camera and photo library is only requested when you use these features. You can revoke it at any time in iOS Settings.
4. The profile questionnaire
To build your program, the questionnaire asks for, among other things, your first name (if you wish to give it), your sex (you may choose not to answer), your age, your skin type, skin tone and skin thickness, any history of acne, your concerns, the condition of your eye area, your goal, the areas to work on and your preferred session length.
These answers are stored on your iPhone. They are copied to our servers only if you create an account (see synced data), and some of them are used for product search.
5. Amazon product search
Elumea suggests skincare products suited to your routine, with their image and a link to amazon.fr. The search runs at the end of the questionnaire, then from the Products tab whenever your profile or latest scan changes.
Data sent
- your questionnaire answers: sex, age, skin type, skin tone, skin thickness, acne history, concerns, eye area and goal;
- the scores of your latest scan (never the photo) and nothing else;
- the routine steps to find products for;
- your installation identifier.
Your first name, email address, journal and account are not sent. The search works without an account and is not linked to your account if you have one.
Processing
Our server forwards this information to OpenRouter, which routes it to one of the hosts of the DeepSeek V4.1 Flash artificial intelligence model. The model uses a web search limited to amazon.fr to select existing products. See also Artificial intelligence: your consent and our safeguards.
Suggestions obtained for an identical profile may be reused for 7 days to answer another person with exactly the same profile (age rounded to 5 years). Only the list of products is reused: no data about you is shared with that person.
Amazon images and links
Product images are loaded directly from Amazon’s servers: as with any online image, Amazon then receives your iPhone’s IP address and technical information about the request. Tapping a product opens its page on amazon.fr, which is subject to Amazon’s privacy policy.
Today, we earn no commission on these links. Should we join the Amazon Associates program, the links will carry our associate identifier, the app will say so and this policy will be updated: as an Amazon Associate, we would then earn from qualifying purchases, at no extra cost to you.
Retention
Your search profile and results are kept on our server for 30 days after the last search run with a changed profile, then erased automatically. You can erase them immediately in the app, under “Mes données”, with “Effacer les données de cet appareil” (erase this device’s data). As the search is not linked to your account, deleting your account does not erase it.
7. The optional account
You do not need an account to use Elumea. You can create one with “Sign in with Apple” to back up your data, find it on another iPhone and use the AI advisor.
When you sign in, Apple sends the app an identity token, which our server verifies. We then record:
- the unique identifier Apple associates with your account;
- your email address, if you agree to share it (it may be an Apple relay address);
- your name, if you agree to share it.
We never receive your Apple password.
8. Synced data
If you use an account, the following data is copied to our servers to be backed up and synced across your devices:
- your profile: first name, age, sex and questionnaire answers (see questionnaire);
- completed sessions;
- your skin journal entries: text and notes only, no photos are synced;
- your scan scores (never the images) for each scan;
- your favorites;
- checked routine steps;
- your reminder settings.
9. The AI advisor
The advisor answers your skincare questions. Answers to common questions are built into the app and available offline, without sending any data.
Asking any other question requires an account and a subscription. Your message, the latest exchanges of the conversation (up to 20 messages) and the skin context needed for the answer (skin type, concerns, areas, goal) are then sent, through our server, to OpenRouter, which routes them to one of the hosts of the DeepSeek V4.1 Flash model. Your age, sex and first name are not sent.
Your questions and the advisor’s answers are stored on our servers, with your account, so that you can find the conversation again and the advisor can take earlier exchanges into account. They are erased 90 days after they are sent, and immediately if you delete your account.
We recommend that you do not include information that could identify you, or information about your health.
10. Artificial intelligence: your consent and our safeguards
Product search and the advisor rely on an artificial intelligence model run by service providers. Before any data is sent to this model for the first time, the app explains what data is sent and to whom, and asks for your consent. Without it, these two features stay off; the rest of the app works normally. You can withdraw your consent at any time.
- No training: we ask OpenRouter to route our requests only to hosts that do not retain the data sent and do not use it to train their models (OpenRouter’s “data_collection: deny” setting).
- No photos: no image is ever sent to the model.
- Hosts: OpenRouter automatically picks the DeepSeek model host among its providers, which may be located outside the European Union and the United States (see transfers).
11. Subscriptions and purchases
Subscriptions are purchased through the App Store. Payment is handled by Apple: we never have access to your payment details.
We use RevenueCat to validate purchases and know the status of your subscription (active, renewed, expired). For this purpose, RevenueCat receives a pseudonymous user identifier (random without an account, your Elumea account’s identifier if you are signed in) and the transaction information provided by Apple (product purchased, dates, status).
12. Hosting and technical logs
Our server, its database and this website are hosted by Cloudflare. Like any host, Cloudflare processes technical data (IP address, request logs) needed to route traffic and secure the service. Our technical logs, used to diagnose errors, are kept for a few days.
13. No advertising, no tracking
Elumea contains no advertising tracker, no audience measurement tool and no marketing profiling, and we do not sell or rent your data. The elumea.app website sets only one functional cookie, elumea_locale, which remembers the language you chose for one year and is used for nothing else; its fonts are served from our own domain.
14. Purposes and legal bases
- Providing the app (program, sessions, scanner, routine, journal, routine banner): performance of the terms of use.
- Creating your account, backing up and syncing your data: performance of the terms of use, at your request.
- Managing your subscription: performance of the subscription contract.
- Suggesting products and answering through the AI advisor: your consent, given in the app, which also covers the transfers described below.
- Keeping the service secure and preventing abuse (for example the daily limit on product searches): our legitimate interest.
- Answering your support requests: our legitimate interest in helping you.
- Complying with our legal obligations: legal obligation.
15. Recipients and service providers
Your data is only accessible to the people at Nuvela Beauty who need it, and to the following services, solely for the purposes described:
- Apple: Sign in with Apple, App Store, payments and delivery of the routine banner (APNs);
- RevenueCat: subscription management;
- OpenRouter and the DeepSeek V4.1 Flash model host it selects: product search and the AI advisor’s answers;
- Amazon: display of suggested product images (IP address and technical data only);
- Cloudflare: hosting of the server, the database and the website.
We do not share your data with any other third party, unless required by law.
16. Transfers outside the European Union
Apple, RevenueCat, OpenRouter and Cloudflare are based in the United States. These transfers are covered by the safeguards provided by the GDPR: the European Commission’s adequacy decision for companies certified under the EU–US Data Privacy Framework, or standard contractual clauses adopted by the European Commission.
The DeepSeek model hosts to which OpenRouter routes product search and advisor requests may be located in other countries, including countries whose level of data protection has not been recognized as adequate by the European Commission. These transfers rely on your explicit consent (Article 49 GDPR), given in the app after being informed of this risk. The data concerned is described in the product search and AI advisor sections.
17. Retention periods
- Data stored on your iPhone: until you erase it in the app or delete the app.
- Account and synced data: for as long as your account exists. When you delete it, this data is erased from our servers, then from our technical backups within 30 days at most.
- Product search: 30 days after the last search run with a changed profile, or until you erase it in the app.
- Routine banner: see the routine banner section.
- Conversation with the AI advisor: 90 days after each message, and at the latest until your account is deleted.
- Subscription: for the duration of the subscription, then as long as needed to meet our legal and accounting obligations.
- Technical logs: a few days.
- Support requests: while we handle your request, then at most 3 years after our last exchange.
18. Security
We take appropriate technical and organizational measures to protect your data: encrypted connections (HTTPS), file protection on the iPhone, verification of identity tokens, restricted access to data and collection limited to what is strictly necessary.
19. Your rights
Under the GDPR and the French Data Protection Act, you have the right to access, rectify and erase your data, to restrict and object to its processing, the right to data portability, the right to withdraw your consent at any time, without affecting processing already carried out, and the right to set instructions for what happens to your data after your death.
Erasing your data from the app
- “Supprimer mon compte” (delete my account) erases your account, your synced data, your conversation with the advisor and the banner settings linked to the account.
- “Effacer les données de cet appareil” (erase this device’s data), under “Mes données”, erases the data stored on your iPhone and your product search on our server.
- Deleting the app also erases the data stored on your iPhone.
Deleting your account or data does not cancel your subscription, which is managed in your Apple Account settings.
Exercising your other rights
Write to us at support@elumea.app, ideally from the address associated with your account. We reply within one month. If you believe your rights are not being respected, you can lodge a complaint with the CNIL, the French data protection authority (www.cnil.fr), or with the authority of your country of residence.
20. Minors
Elumea is intended for people aged 16 and over: the questionnaire does not accept a younger age.
21. Changes to this policy
We may update this policy, for example when the app changes. The date of the last update appears at the top of the page; for any significant change, we will let you know in the app. If this translation differs from the French version, the French version prevails.
22. Contact
Nuvela Beauty, 28 rue de l’Amphithéâtre, 84400 Apt, France — support@elumea.app