Draft — pending legal review. This document is a working draft and is not yet in effect.
Privacy Policy
Effective: [Effective date] · FofX Digital LLP
FofX Digital LLP (“we”) operates TheLookIQ and is responsible for your personal data. This policy explains what we collect, why, and your choices. Contact us at [email protected].
What we collect
- Account: email address, optional name, password (stored only as a secure hash), language and time zone. Your date of birth is used once to confirm you are 18 or older and is not stored.
- Photos: the facial and optional outfit photos you upload, and photos of another adult if you request a report for them. Location and camera metadata are removed when photos are uploaded.
- Your answers: goals, preferences and optional questionnaire answers, which may include skin concerns you choose to tell us about.
- Reports, simulations, plans and check-ins created for you.
- Purchases: what you bought and when. Card details are handled by Paddle, not by us.
- Technical data: security and error logs, kept without photos or answers.
We use only a strictly necessary sign-in cookie. We do not use advertising cookies, and photos and answers are never sent to analytics or advertisers.
How we use it
- To produce your report, simulations and plan, with your explicit consent to process your photos (you can withdraw it at any time).
- To run your account, process purchases and provide support (to perform our contract with you).
- To keep the service secure and prevent abuse (our legitimate interests).
- To keep financial records as required by law.
We do not sell your data. We do not create face templates for identifying you, and we do not infer your age, ethnicity, health or personality.
Who processes your data
- AI providers (OpenAI) analyse photos and generate recommendations and simulations, under data-processing terms that do not allow use of your data to train their models.
- Hosting and storage (Render, Cloudflare) store the app, database and photos in private, encrypted storage.
- Payments (Paddle, our merchant of record) process orders and taxes.
- Email delivery (our transactional email provider) sends account and report emails.
Some providers are located outside your country, including in the United States. Where required, transfers are covered by appropriate safeguards such as standard contractual clauses.
How long we keep it
- Photos: deleted 30 days after the report they were used for, unless you choose to keep them for before/after comparisons. You can delete them at any time.
- Reports and account data: until you delete your account.
- Purchase records: for as long as tax and accounting law requires, even after account deletion.
Deletion from backups and from providers' systems may take additional time within their retention limits.
Your rights
You can access and export your data, correct it, delete photos or your whole account, and withdraw consent — most of this directly in your account settings. You may also object to processing or ask us to restrict it, and complain to your data protection authority. For requests, or as our grievance contact, email [email protected].
Children
TheLookIQ is only for adults. We do not knowingly process photos of anyone under 18 and will delete them if we learn of it.
Changes
We will notify you of material changes to this policy.