Privacy Policy

1. Information about the Collection of Personal Data and Contact Details of the Controller

1.1 General Information

We are pleased that you are using our application Glamy (hereinafter referred to as the “Application” or “App”).

In the following provisions, we explain how personal data may be processed when you use our Application and related services.

Personal data means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or other characteristics specific to their identity.

1.2 Controller

The controller responsible for data processing within the meaning of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 is:

Unlock Futurix Ltd
71–75 Shelton Street
Covent Garden
London
WC2H 9JQ
United Kingdom

Email: support@unlockfuturix.com

The controller is the natural or legal person who determines the purposes and means of processing personal data.

1.3 Security and Encryption

For security reasons and to protect the transmission of personal data and other confidential content, the Application uses industry-standard security measures, including encrypted connections such as TLS/HTTPS where data is transmitted.

No method of electronic transmission or storage can guarantee absolute security.

2. Categories of Data Processed

2.1 Account and Authentication

A Glamy account is required to use the App. Glamy does not require you to create a separate username or password. Instead, your account is created and authenticated through Sign in with Apple.

When you use Sign in with Apple, Apple authenticates your identity and provides Glamy with information necessary to create and identify your Glamy account.

Depending on the information you choose to share through Apple, this may include:

• A unique Apple-provided user identifier
• Your name, where provided
• Your email address, where provided
• A private relay email address if you choose Apple's “Hide My Email” feature

We do not receive or store your Apple ID password.

Your Glamy account allows us to associate relevant app data and cloud-stored content with your account, including saved content, preferences and other functionality available within the App.

Authentication through Sign in with Apple is subject to Apple's own privacy practices.

2.2 Photos, Screenshots and Nail Designs

Glamy allows you to capture, upload, import, save, and process images containing nail designs.

Depending on the feature you use, this may include:

• Photos taken using your device camera
• Photos of your hand or nails
• Photos of another person's hand or nails that you choose to upload
• Screenshots
• Nail inspiration images
• Images imported from other apps or websites
• Images shared with Glamy through your device's sharing functionality
• Nail designs extracted or generated from submitted images

You are responsible for ensuring that you have the right to upload or process images you submit to Glamy, particularly where an image contains another identifiable person or content belonging to a third party.

2.3 Camera and Photo Library Access

Certain Glamy features require access to your device's camera or photo library.

Camera access may be used to capture images of your hand or nails for features such as nail design try-on.

Photo library access may be used to select nail inspiration, screenshots, hand photos, or other images that you choose to use within the App.

Glamy only receives images that you choose to capture, select, import, or otherwise provide through the relevant functionality.

You can manage camera and photo permissions through your device settings.

3. AI Features and Third-Party AI Processing

3.1 Use of Artificial Intelligence

Glamy uses artificial intelligence technologies to provide certain features.

Depending on the feature, AI may be used to:

• Detect or identify nails within an image
• Extract a nail design from an uploaded image
• Analyse visual characteristics of a nail design
• Adapt or transform a nail design for use within Glamy
• Generate or modify visual content
• Apply or simulate nail designs on images of hands or nails
• Produce realistic nail try-on results
• Perform other image-processing functions requested by you

3.2 Images Sent to Third-Party AI Providers

Some AI features are provided using third-party artificial intelligence services.

When you choose to use such a feature, the image or other content necessary to perform your request may be transmitted to a third-party AI provider for processing. This means that AI processing is not necessarily performed solely on your device or by Unlock Futurix Ltd.

The AI provider processes the submitted content in order to generate or return the requested result.

We aim to send only the information reasonably necessary to provide the requested AI functionality.

The current AI provider is OpenAI (operating under entities such as OpenAI, Inc. and OpenAI Global, LLC).

3.3 Third-Party Processing

Where an AI feature requires external processing, your submitted content may be processed on infrastructure operated by a third-party AI service provider.

Such providers may process:

• Uploaded images
• Camera images submitted for processing
• Nail inspiration images
• Images of hands or nails
• Technical request information
• Generated or processed outputs
• Other information technically necessary to perform the requested operation

The exact processing depends on the feature and the AI provider used.

Third-party providers operate their own technical infrastructure and may process information in accordance with their applicable contractual terms, security practices, and data-processing arrangements.

3.4 No Responsibility for Independent Third-Party Services

Where third-party services act independently from Unlock Futurix Ltd, their processing of information may be governed by their own privacy policies and terms.

Unlock Futurix Ltd does not control the independent data practices of third-party services.

However, where a third-party provider processes personal data on our behalf, we take reasonable steps to use providers with appropriate privacy and security protections and to put appropriate contractual safeguards in place where required by applicable law.

3.5 AI Accuracy

Artificial intelligence and image-processing systems may produce inaccurate, incomplete, inconsistent, or unexpected results.

AI-generated or AI-processed results are provided as part of Glamy's creative and visualisation functionality and should not be considered a guarantee that a physical manicure, nail colour, design, shape, finish, or other result will appear exactly the same in real life.

3.6 Legal Basis

Where AI processing is necessary to provide a feature that you have specifically requested, processing may be based on Article 6(1)(b) UK GDPR (performance of a contract or steps taken at your request).

Where consent is required by applicable law for a particular type of processing, we will rely on Article 6(1)(a) UK GDPR.

4. Storage of Nail Designs, Images and App Data

4.1 Local and Cloud Storage

Glamy uses a combination of on-device storage and cloud-based storage to provide its features.

Depending on the feature and type of content, information may be stored locally on your device, in our cloud infrastructure, or both.

This may include:

• Nail inspiration images you save or import
• Nail design images
• Images of your hands or nails that you choose to save
• Extracted nail designs
• AI-generated or AI-processed results
• Try-on results
• Saved favourites
• Collections
• Titles, categories, tags, colours and other organisational information
• Technical information necessary to associate and manage stored content

Some information may remain only on your device, while other information may be uploaded to cloud storage where this is necessary to provide Glamy's functionality.

4.2 Cloud Infrastructure — Supabase

We use Supabase to provide database, storage and backend infrastructure for certain Glamy features.

Where cloud functionality is used, information processed through Supabase may include:

• Saved nail designs and associated information
• Images and generated content
• Collections, favourites, tags and other organisational data
• App-generated identifiers
• Technical information required to store, retrieve and manage your content

The exact information stored depends on the Glamy features you use.

Supabase processes this information on our behalf as an infrastructure service provider.

We do not sell information stored through Supabase or use your private images for advertising.

4.3 On-Device Storage

We have both cloud and on device storage and all data is synced for offline access.

Local data may include app preferences, saved information, cached content and other information required for Glamy to operate efficiently.

Locally stored information generally remains on your device until you delete it through Glamy, clear the relevant App data, or uninstall the Application, subject to your device's operating system and backup settings.

4.4 Cloud Data and Deletion

Information stored in Glamy's cloud infrastructure may remain after the Application is removed from your device. Uninstalling Glamy does not necessarily delete information that has already been stored in the cloud.

Where Glamy provides functionality for deleting saved cloud content, you can use that functionality to remove the relevant content.

You may also contact us at support@unlockfuturix.com regarding deletion of personal data associated with you where we are able to identify that data.

Certain information may be retained where necessary to comply with legal obligations, resolve disputes, prevent fraud or abuse, maintain security, or establish, exercise or defend legal claims.

5. Third-Party Services and Infrastructure

To operate Glamy, provide its features, maintain security and reliability, understand how the App is used, and manage subscriptions and authentication, we use selected third-party service providers.

These providers process only the information relevant to the services they provide, subject to their respective data-processing arrangements and applicable law.

5.1 Cloud Database and Storage — Supabase

We use Supabase to provide cloud database, storage and backend infrastructure for Glamy.

Depending on the features you use, Supabase may process or store information such as:

• Saved nail designs and inspiration
• Images and generated content
• Try-on results
• Collections, favourites, tags, colours and related organisational information
• App-generated identifiers
• Account-related identifiers where applicable
• Technical information necessary to store, retrieve and manage your content

Glamy uses a combination of on-device and cloud storage. Accordingly, some information may remain only on your device, while other information may be stored or synchronised using Supabase.

We use this infrastructure to provide Glamy's functionality, securely store and retrieve content, and maintain the operation of the App.

We do not sell information stored through Supabase or use your private images for advertising.

Legal basis: Article 6(1)(b) UK GDPR where processing is necessary to provide functionality requested by you, and Article 6(1)(f) UK GDPR where processing is necessary for our legitimate interests in securely operating and maintaining the App.

5.2 Authentication — Sign in with Apple

Where available, Glamy allows you to use Sign in with Apple to authenticate and access account-related functionality.

When you use Sign in with Apple, Apple authenticates your identity and provides Glamy with information necessary to create or identify your account.

Depending on the choices you make when signing in, this may include:

• A unique Apple-provided user identifier
• Your name, where provided
• Your email address, where provided
• A private relay email address if you choose Apple's “Hide My Email” functionality
• Authentication information necessary to verify your sign-in

We do not receive your Apple ID password.

Apple independently processes information associated with your Apple ID and authentication in accordance with Apple's own privacy practices.

Information received through Sign in with Apple may be associated with your Glamy account or app data where necessary to provide account, synchronisation or related functionality.

Legal basis: Article 6(1)(b) UK GDPR — processing necessary to provide account and authentication functionality requested by you.

5.3 Crash Reporting — Sentry

We use Sentry to help maintain the stability, security and technical performance of Glamy.

Sentry may process technical information such as:

• Crash reports
• Error logs
• Device model
• Operating system version
• App version
• Performance diagnostics
• Technical identifiers

We do not intentionally send your nail images or other user-generated visual content to Sentry as part of crash reporting.

This information is used to diagnose errors, improve reliability, and maintain the security and performance of the App.

Legal basis: Article 6(1)(f) UK GDPR — our legitimate interest in ensuring technical stability, security and reliability.

5.4 Product Analytics — Amplitude

We use Amplitude to understand how Glamy is used and to improve the product.

Amplitude may process information such as:

• Feature usage events
• Screen views
• App interactions
• Device and operating system information
• App version
• Anonymous or pseudonymous installation identifiers
• General usage and performance information

We use this information to understand product usage, identify problems, evaluate features and improve the user experience.

We do not intentionally send your uploaded nail images or hand photos to Amplitude.

We do not use Amplitude to analyse the visual contents of your private images for advertising purposes.

Legal basis: Article 6(1)(f) UK GDPR — our legitimate interest in understanding and improving our product.

5.5 Subscription Management — RevenueCat and Apple App Store

We use RevenueCat to manage subscriptions, purchases, entitlements and subscription status within Glamy.

RevenueCat may process information such as:

• Subscription and entitlement status
• Purchase and transaction information
• Product identifiers
• Renewal and cancellation events
• Trial events
• Anonymous or pseudonymous app user identifiers
• Technical device and app information necessary to manage purchases and subscriptions

Purchases and subscriptions made through the iOS version of Glamy are processed by the Apple App Store.

Apple processes your payment information and transaction in accordance with its own terms and privacy practices.

We and RevenueCat receive information necessary to verify purchases, determine subscription status and provide the features or credits associated with your purchase.

We do not receive or store your full payment card details.

Legal basis: Article 6(1)(b) UK GDPR — processing necessary to manage purchases, subscriptions and provide purchased functionality.

6. Contact and Support

If you contact us through email, support chat, feedback forms, or another support channel, we may process information including:

• Your name, if provided
• Your email address
• Your message
• Screenshots or attachments you provide
• Technical information relevant to your support request

We use this information to respond to your request, investigate issues, and provide support.

Please avoid sending sensitive personal information that is not necessary for us to handle your request.

Legal basis: Article 6(1)(f) UK GDPR — our legitimate interest in responding to inquiries and providing support.

Where the request relates directly to a contract or subscription, Article 6(1)(b) UK GDPR may also apply.

7. Legal Bases of Processing

Depending on the relevant activity, we may process personal data on the basis of:

• Article 6(1)(a) UK GDPR — Consent Where you have given consent to specific processing.
• Article 6(1)(b) UK GDPR — Contract performance Where processing is necessary to provide a service or feature requested by you.
• Article 6(1)(c) UK GDPR — Legal obligation Where processing is necessary to comply with applicable law.
• Article 6(1)(f) UK GDPR — Legitimate interests Where processing is necessary for legitimate interests such as improving Glamy, maintaining security, preventing abuse, diagnosing technical issues, and responding to support requests, provided those interests are not overridden by your rights and interests.

8. Retention and Deletion of Data

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy or as required by applicable law.

Content stored locally on your device remains there until you remove it, delete associated App data, or uninstall the Application, subject to the storage behaviour of your device and operating system.

Images or other content transmitted to third-party AI providers may be retained by those providers for the period necessary to process the request and in accordance with the applicable provider arrangements and retention policies.

Analytics, crash reports, subscription information, and other technical information may be retained according to the applicable service provider's retention settings and our operational requirements.

Support communications may be retained for as long as necessary to resolve your inquiry and maintain appropriate records, after which they may be deleted unless further retention is required by law.

9. Your Rights as a Data Subject

Under applicable UK data protection law, you may have the following rights:

• Right of access — Article 15
• Right to rectification — Article 16
• Right to erasure — Article 17
• Right to restriction of processing — Article 18
• Right to data portability — Article 20
• Right to object — Article 21
• Right to withdraw consent — Article 7(3)
• Right to lodge a complaint with the Information Commissioner's Office (ICO)

Glamy requires you to sign in with Apple. Some data, such as content stored only on your device or information processed by third-party providers, may not be directly associated with your Glamy account.

We may therefore be unable to locate or associate certain pseudonymous, locally stored, or third-party processed information with you without additional information.

10. International Data Transfers

Some of the service providers used by Glamy may process information outside the United Kingdom.

This may include providers of:

• Artificial intelligence and image processing
• Analytics
• Crash reporting
• Subscription infrastructure
• Customer support

Where personal data is transferred internationally, we take appropriate measures required by applicable data protection law.

Depending on the destination and provider, these measures may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or other legally recognised safeguards.

11. Automated Decision-Making

Glamy uses automated technologies and artificial intelligence to process images and generate visual outputs.

However, these systems are used to provide creative and product functionality requested by the user.

We do not use solely automated decision-making that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22 UK GDPR.

12. Children's Privacy

Glamy is not intended for children under 13.

We do not knowingly collect personal data from children under 13.

If we become aware that personal data has been collected from a child in circumstances where such processing is not permitted, we will take reasonable steps to delete the information.

13. Third-Party Content and Intellectual Property

Glamy allows users to import or submit nail inspiration from sources outside the Application.

Glamy does not claim ownership of third-party images, nail designs, trademarks, brand names, social media content, or other intellectual property merely because such content can be imported, saved, or processed using the App.

Users are responsible for ensuring that their use of content through Glamy complies with applicable laws and third-party rights.

The ability to import, save, extract, process, or try on a design does not imply that Unlock Futurix Ltd owns, endorses, sponsors, or is affiliated with the original creator, brand, platform, salon, or other rights holder.

14. Nail Polish Brands and Third-Party Services

Glamy may display names, trademarks, colours, products, or other information associated with nail polish brands, social media platforms, retailers, salons, or other third parties.

Unless explicitly stated otherwise, Glamy and Unlock Futurix Ltd are not affiliated with, endorsed by, sponsored by, or officially connected with these third parties.

Third-party trademarks and brand names remain the property of their respective owners.

Product colours and visual representations displayed in Glamy are for reference and visualisation purposes. Appearance may vary depending on lighting, photography, device displays, nail characteristics, application technique, product formulation, and other factors.

15. External Sources and Shared Content

Users may save or import inspiration discovered through social media, websites, screenshots, photographs, or other sources.

Glamy does not control the privacy practices, content, availability, or terms of external websites, apps, social media platforms, or other third-party sources.

Where you use another platform's sharing functionality to send content to Glamy, your interaction with that platform remains subject to that platform's own terms and privacy practices.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to Glamy, our service providers, technical functionality, or applicable legal requirements.

Where appropriate, we may provide additional notice of material changes.

The latest version will be published with an updated “Last updated” date.

17. Contact

For questions, requests, or concerns regarding this Privacy Policy or the processing of personal data, please contact:

Unlock Futurix Ltd
71–75 Shelton Street
Covent Garden
London
WC2H 9JQ
United Kingdom

Email: support@unlockfuturix.com