Privacy Policy

This Privacy Policy explains how Facely ("Facely," "we," "us," or "our") collects, uses, discloses, and protects information when you use our website and AI facial analysis service (the "Service"). By using the Service, you consent to the practices described in this Policy.

We collect the following categories of information:

• Uploaded photographs. The facial image you submit for analysis.
• Analysis results. The score, metrics, and recommendations generated from your photograph.
• Payment information. If you purchase the full report, our payment processor Stripe collects billing details (such as name, email, and card information) necessary to process the transaction. Facely does not receive or store full card numbers.
• Usage and device data. Technical information such as browser type, device type, IP address (used transiently for request handling and fraud prevention), and general interaction data with the Service, collected via privacy-respecting analytics.
• Communications. Information you provide when you contact us for support.

We use the information described above to:

• Generate and deliver your AI-based facial aesthetics Analysis;
• Process payments and deliver the full report you purchased;
• Operate, maintain, secure, and improve the Service;
• Detect, investigate, and prevent fraud, abuse, or violations of our Terms of Service;
• Respond to your support requests; and
• Comply with legal obligations.

We do not use your photograph or Analysis results for advertising or marketing purposes without your explicit consent.

When you upload a photograph, it is transmitted securely to an AI model provider for processing in order to generate your Analysis. The photograph and derived facial measurements are used solely to produce your Report and, unless you separately agree otherwise, are not used to build a persistent biometric identification profile, matched against other individuals, or used to identify you across other services.

We do not sell your photograph or any biometric or facial-geometry data derived from it. Where your jurisdiction's law (for example, biometric privacy laws such as Illinois' BIPA, or the EU/UK GDPR's rules on special-category biometric data) requires specific consent or disclosures for processing facial data, by uploading your photograph you provide that consent to the processing described in this Policy, and you may withdraw it at any time as described in Section 11.

Purchases are processed by Stripe, our payment processor. Facely — not Stripe — is the seller and merchant of record for your purchase. Stripe collects and processes your payment details directly under its own privacy policy. Facely receives limited transaction metadata from Stripe (such as confirmation of payment, the amount charged, and a payment reference) to unlock your report, but does not receive or store your full card number.

We use two analytics tools to understand aggregate usage of the Service: Vercel Web Analytics and PostHog. Neither tool is active by default. On your first visit, a banner asks you to accept or refuse analytics; your choice is stored locally in your browser and can be changed at any time using the "Cookie preferences" control in the site footer. If you refuse, or have not yet made a choice, neither tool is initialized and no analytics data is captured. If you accept, both tools may then collect information such as pages viewed, device/browser information, and general interaction data with the Service; PostHog also uses its own locally-stored identifier once active. Vercel Web Analytics is designed to avoid persistent cross-site tracking cookies. We do not currently use third-party advertising trackers. If this changes, we will update this Policy.

Photographs. Uploaded photographs are currently subject to an automated technical process that deletes them after a configured retention period, currently set to 30 days from upload. This period is a technical configuration, not a legally validated duration, and may be adjusted.

Analysis results. The results of your Analysis (score, metrics, and recommendations) and related payment-status information are not currently subject to the same automatic deletion process, and remain stored after the photograph itself has been deleted, unless removed through other means.

You may request earlier deletion of your photograph and associated Analysis at any time by emailing support@tryfacely.com with details sufficient to identify your submission (such as the approximate date/time of upload and, if available, your order/transaction ID). We will honor verified deletion requests within a reasonable time, except where we are required to retain limited records (such as transaction records) for legal, tax, or accounting purposes.

We share information with the following categories of third-party service providers, solely to operate the Service:

• Payment processing: Stripe (checkout and billing).
• AI processing: our AI model provider(s), used solely to generate your Analysis from the photograph you submit.
• Hosting and infrastructure: Vercel Inc., which hosts the Service.
• Database hosting: Supabase, which stores your Analysis results and payment status information.
• Analytics: Vercel Web Analytics and PostHog, subject to your cookie consent choice as described in Section 6.
• Rate-limiting infrastructure: Upstash, which processes your IP address on a transient basis to help protect the Service against abuse.

These providers are contractually restricted from using your information for purposes other than providing services to Facely. We do not sell your personal information.

Some of the third-party processors listed in Section 8 may process information in countries outside your own, including the United States. Where a processor transfers personal information outside the European Economic Area (or your own jurisdiction), such transfers are carried out under the safeguards recognized by applicable data protection law for that processor — for example, an adequacy decision, or standard contractual clauses — as put in place by that processor under its own privacy terms. We have not independently negotiated a separate transfer mechanism with these processors beyond what they offer under their own privacy policies.

The Service is not directed to, and is not intended for use by, individuals under 18 years of age. We do not knowingly collect personal information, including photographs, from children. If you believe a child has provided us with personal information, contact us so we can delete it.

Depending on your jurisdiction (for example, under the EU/UK GDPR or U.S. state privacy laws), you may have the right to: access the personal information we hold about you; request correction or deletion of it; object to or restrict certain processing; request a portable copy of it; and withdraw consent where processing is based on consent (such as processing of your facial image), without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, email support@tryfacely.com. We may need to verify your identity before fulfilling certain requests. As the data controller, Services Numériques (Entrepreneur individuel / EI) is established within the European Union; no separate Article 27 GDPR representative is required or has been appointed. You also have the right to lodge a complaint with your local data protection supervisory authority.

We use commercially reasonable administrative, technical, and physical safeguards designed to protect your information, including encryption of data in transit. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the "Last updated" date above, and, where required by law, we will provide additional notice.

For any privacy-related questions or requests, contact us at support@tryfacely.com.

Data controller: Services Numériques, Entrepreneur individuel (EI), registered in France. SIRET: 104 232 533 00018.