Privacy Policy

Controller (and Service Provider/Business)

1) What We Collect

2) Facial Image Processing and AI Analysis

When you use our facial analysis service, we process your photographs to provide AI-powered biological age estimation, beauty analysis, and skin health assessments. Here is exactly how we handle your images:

Image Storage and Security

• Secure Storage: Images are stored on our servers with cryptographically randomized filenames that cannot be guessed or enumerated. There is no public URL to any uploaded image.
• Authenticated Access Only: Images are served exclusively through an authenticated endpoint that verifies you are the owner. No one else -- including other users, search engines, or third parties -- can access your images.
• Encrypted Transfer: All image data is transmitted using TLS encryption (HTTPS) with modern cipher suites.
• Retention: Images are retained for the duration of your account to enable your analysis history and trend tracking. When you delete an individual analysis or your entire account, the corresponding image files are permanently erased from our servers (see Section 11).

AI Analysis Services

To provide accurate analysis, we use a combination of proprietary and industry-leading AI models -- including cloud-based vision services, large multimodal models, open-source on-device models, and specialized neural networks -- all operating under Data Processing Agreements (DPAs). Our analysis pipeline may employ multiple models simultaneously to cross-validate results. Key safeguards:

• All AI service providers are contractually prohibited from retaining your images after processing is complete.
• No AI provider uses your data to train or improve general-purpose models.
• Where possible, facial landmark detection is performed locally in your browser -- no image data leaves your device for that step.

Special Categories of Data (GDPR Art. 9)

Facial photographs used for analysis may constitute biometric data under GDPR Article 9 and similar laws (e.g., Illinois BIPA, Texas CUBI). We process this data based on:

• Explicit Consent (Art. 9(2)(a)): You provide explicit, informed consent before your first upload via a dedicated consent dialog. You may withdraw consent at any time by deleting your data.
• Purpose Limitation: Your facial images are used solely for providing you with biological age, beauty, and skin health analysis. They are never used for marketing, advertising, AI model training, facial recognition of third parties, or any other purpose.
• No Sale or Sharing: We never sell, license, or share your facial images with any third party beyond the analysis processors listed above, and only for the purpose of generating your personal results.

3) Biographical and Lifestyle Data

We offer an optional biographical questionnaire to provide you with a personalized anti-aging plan. This data may include health-related information and is treated with additional care:

• Entirely Optional: You can skip the questionnaire at any time and use the full service without providing any biographical data.
• Purpose: Used exclusively to generate personalized anti-aging recommendations based on peer-reviewed scientific literature.
• Health Data (GDPR Art. 9): Some biographical data (medical history, chronic conditions, medications) may constitute health data under GDPR. We process it based on your explicit consent when completing the questionnaire.
• Immediate Deletion: You can delete your biographical profile at any time from your account settings. Deletion is immediate and permanent.
• No Sharing: Biographical data is never shared with third parties, advertisers, or data brokers.

4) Why We Use Data (Purposes & Lawful Bases)

Where GDPR applies, we rely on Art. 6(1)(b) (contract), (c) (legal duty), (f) (legitimate interests), and (a) (consent) as appropriate. For special category data (facial images, health data), we rely on Art. 9(2)(a) (explicit consent).

5) "Do Not Sell or Share" (U.S. State Laws)

We do not sell your personal data -- including facial images -- for money or any other consideration. We do not share facial images or biometric data with ad networks, data brokers, or any third party for targeted advertising.

6) Your Rights

Request via info@dry-labs.com or use the self-service tools in your profile (Export Data, Delete Account). We respond within statutory timelines.

7) Children

Face Age is for 18+ only. We do not knowingly collect data from children under 13 (COPPA) or under 16 (GDPR). If you believe a child used the service, contact us immediately and we will delete all associated data including any uploaded images.

8) Cookies & Tracking

We use required cookies (security, auth) and optional cookies (analytics, performance, ads). Manage via the cookie banner/consent manager and your browser settings. We honor applicable EU ePrivacy/GDPR consent standards for non-essential cookies.

9) Data Sharing (Categories of Recipients)

10) International Transfers

We transfer data to the U.S. and other countries with appropriate safeguards (EU Standard Contractual Clauses / UK IDTA, Swiss addendum, and supplementary measures). Our AI analysis providers maintain industry-standard transfer mechanisms. Details available on request.

11) Your Right to Immediate & Complete Deletion

You have full authority over your data. We provide one-click, immediate, irreversible deletion of all your personal data -- no waiting period, no hidden copies, no trace.

12) Security

We employ administrative, technical, and physical safeguards designed to protect your personal data, including your facial images:

No method of transmission or storage is 100% secure. If you discover a vulnerability, please contact us immediately at info@dry-labs.com.

13) Data Retention

We retain different types of data for specific periods. You can delete all data immediately at any time (see Section 11).

14) Communications

15) Exercising Rights / Complaints

Submit requests to info@dry-labs.com or use the self-service tools in your profile. EU/EEA/UK users may also complain to their supervisory authority (e.g., CNIL, ICO, BfDI). We will not discriminate against you for exercising privacy rights.

16) Changes

We'll post updates here and, when material, notify you (email/in-product). Continued use after the effective date means you accept the changes. For changes affecting biometric data processing, we will seek renewed explicit consent where required by law.

Contact for Privacy Matters

For questions about data protection and privacy, please contact us: