Privacy Policy
Effective date: August 23, 2026 · Last updated: August 23, 2026 · Version 2.0
Your photos stay on your device. Facial landmark detection runs locally in your browser, and URATEN does not receive or upload your photos. You can receive informative Free Results without creating an account. For the analysis calculation, we receive numerical landmark coordinates and the analysis settings you select, as explained below.
1. Who We Are
URATEN ("we," "us," or "our") is a web-based facial analysis service operated by an individual data controller based in the Czech Republic.
This Privacy Policy explains how personal data is collected, used, disclosed, retained, and protected when you use uraten.ai and its related features (the "Service"). It also explains the choices and rights available to you under the EU General Data Protection Regulation ("GDPR") and other applicable laws.
For privacy questions or to exercise a data protection right, contact [email protected]. We respond within the periods required by applicable law. We may need information reasonably necessary to verify your identity and locate the relevant data before fulfilling a request.
This Policy describes our current practices. It does not limit any non-waivable right provided by applicable law or create a contractual right beyond those rights and our Terms of Service.
2. Key Definitions
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"Facial Landmark Data" means the numerical X, Y, and Z coordinates produced in your browser to represent points on a face. It contains no image pixels, colour, or texture and cannot reproduce the original photograph.
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"Analysis Data" means the measurements, ratios, angles, scores, rankings, detected presentation-related findings, and other results calculated from Facial Landmark Data and the analysis settings you select.
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"Protocol Questionnaire Data" means answers you voluntarily provide for the Improvement Protocol, such as age, body-fat category, skin type, and hair type.
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"Protocol Data" means the selected actions, phases, progression, completion status, and related context used to provide the Improvement Protocol.
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"Consultant Data" means messages and responses in the AI consultant, together with recent conversation context and the relevant Analysis Data and Protocol Data supplied to generate a response.
Depending on the jurisdiction and context, facially derived data or questionnaire answers may receive additional protection under privacy, biometric, or health-data laws. Our use of these categories is described below.
3. Data We Collect and Where It Goes
3.1 Photos and Facial Landmark Data
When you choose a photo, facial landmark detection runs locally in your browser. You can review and adjust the detected landmarks before requesting an analysis.
Your photo is not uploaded or sent to URATEN. Your browser sends Facial Landmark Data and the analysis settings you select to our server. The server uses them to calculate the requested results in memory. Raw Facial Landmark Data is not written to our application database and is discarded after the request is processed.
We do not use photos, Facial Landmark Data, or Analysis Data to identify or authenticate a person, perform facial recognition, search a face database, or match one person's face to another. We do not use them to train a facial-recognition or attractiveness model.
Your browser downloads the software components needed for local landmark detection. The providers serving those components may receive ordinary network request data, such as an IP address and request timestamp, but they do not receive your photo from the Service.
3.2 Free Results Without an Account
You do not need an account to receive Free Results. Free Results provide selected measurements and an informative summary, including the actual count of measurements crossing configured critical thresholds.
If you are signed out, URATEN does not save the resulting Analysis Data to an account or analysis-history database. The Service still records the consent evidence and limited technical logs described below. Data may also remain in your own browser as described in Section 3.5.
If you are signed in, the complete derived analysis may be saved to your account so it can support analysis history and eligible account features. The result displayed to you depends on your current access level.
3.3 Information Stored by the Service
Depending on how you use the Service, we may store:
| Category | Examples |
|---|---|
| Account and authentication data | Email address, optional display name, internal user ID, country information, and authentication metadata |
| Analysis records | Analysis Data, analysis identifier, time, view or analysis type, and selected analysis settings |
| Consent evidence | Account or browser-session identifier, IP address, consent choices, applicable policy or consent version, and timestamp |
| Protocol Questionnaire Data | The answers you voluntarily provide after the Protocol consent step |
| Protocol Data | Selected actions, phases, progress, completion state, and related analysis context |
| Consultant Data | Your messages, generated responses, recent conversation context, and links to relevant Analysis Data and Protocol Data |
| Subscription and Checkout data | Access tier, Stripe customer and subscription identifiers, billing country, subscription status, Checkout status, and records needed to reconcile payments, refunds, or duplicate purchases |
| Cancellation feedback | Optional reason and comment submitted when cancelling |
| Support and legal correspondence | Messages you send to our support, privacy, or legal contact addresses and records of our response |
| Security and operational data | Request and event records, fraud or abuse signals, error information, and records needed to protect the Service |
| Temporary Checkout account data | A temporary account identifier and browser-bound Checkout state used when an eligible signed-out customer begins a purchase |
URATEN does not receive or store your complete payment-card number. Payment details are collected and handled by Stripe.
3.4 Technical Data
When your browser communicates with the Service or one of its providers, technical data may be processed automatically. This can include IP address, request time, request method, a redacted or limited request path, response status, processing duration, browser or device information, referrer information, and security signals.
We use this information to deliver requests, operate infrastructure, prevent abuse, investigate errors, enforce limits, and protect accounts and payments. We design application logging to avoid recording photos, raw Facial Landmark Data, authentication secrets, full consultant messages, or complete payment details.
3.5 Data Stored in Your Browser
The Service uses browser storage, including IndexedDB, localStorage, and sessionStorage, for functions such as preserving a selected photo locally, analysis-session state, locally available results, authentication state, and browser-bound Checkout state.
Photos held in this browser storage remain on your device and are not transmitted to URATEN. Other locally stored data may be transmitted to us when needed for the functions described in this Policy. You can remove browser-stored data by using available reset or sign-out controls and by clearing site data for uraten.ai. Clearing site data may sign you out, remove locally available results, or interrupt an unfinished Checkout flow.
4. Why We Process Data and Our Legal Bases
We process personal data only for specified purposes and under an applicable legal basis. The bases most relevant to the Service are:
| Purpose and data | Legal basis under the GDPR |
|---|---|
| Create, authenticate, secure, and manage an account | Performance of a contract or steps requested before a contract, Article 6(1)(b) |
| Transmit and process Facial Landmark Data and provide Analysis Data | Consent, Article 6(1)(a) |
| Save Analysis Data for a signed-in user | Consent, Article 6(1)(a) |
| Collect Protocol Questionnaire Data and generate Protocol Data | Consent, Article 6(1)(a), and explicit consent under Article 9(2)(a) where the answers constitute data concerning health |
| Provide and save the AI consultant conversation | Performance of a contract, Article 6(1)(b); consent where applicable to special-category data, including Article 9(2)(a) when valid explicit consent applies |
| Begin Checkout, process payment, create or reconcile an eligible temporary account, and provide paid access | Performance of a contract or steps requested before a contract, Article 6(1)(b) |
| Maintain invoices, transaction records, tax records, and legally required records | Compliance with legal obligations, Article 6(1)(c) |
| Record and prove consent, prevent fraud and duplicate entitlements, enforce security limits, investigate abuse, protect legal claims, and keep the Service reliable | Our legitimate interests, Article 6(1)(f), and compliance with legal obligations where applicable |
| Respond to support, privacy, and legal correspondence | Performance of a contract, compliance with legal obligations, and our legitimate interests in resolving requests and protecting legal rights, as applicable |
| Review optional cancellation feedback and improve the Service | Our legitimate interests in understanding cancellations and improving the Service, Article 6(1)(f) |
Our legitimate interests include operating a secure and reliable service, preventing fraud and misuse, proving permissions and transactions, resolving technical problems, enforcing our Terms, and establishing, exercising, or defending legal claims. We consider the nature of the data, reasonable user expectations, safeguards, and potential effects on users when relying on legitimate interests. You may object to this processing as described in Section 8.
The AI consultant is not intended to collect medical records or unnecessary sensitive information. Do not include medical records, passwords, payment-card details, government identifiers, or other information that is not needed for your question. If a message includes special-category data, we process it only as permitted by applicable law and may restrict or delete it when an appropriate basis does not apply.
Withdrawing Consent
You may withdraw consent at any time by contacting [email protected]. Withdrawal does not affect processing that was lawful before withdrawal. We will stop the affected consent-based processing and delete or restrict the associated data unless another lawful ground permits or requires continued retention. Features that depend on that data may no longer work.
5. How We Use Data
We use the data described above to:
- provide on-device landmark detection and server-side calculation of Free and Pro results;
- create, authenticate, and protect accounts using one-time passcodes;
- save eligible analyses and provide account history;
- generate the Improvement Protocol from a fixed, server-controlled action catalog using validated Analysis Data and voluntary questionnaire answers;
- provide the AI consultant;
- create Checkout sessions, process subscriptions, reconcile payment events, prevent duplicate entitlements, and handle cancellations and refunds;
- create and safely remove temporary Checkout accounts when appropriate;
- maintain consent, transaction, accounting, and compliance records;
- respond to requests and provide customer support;
- enforce the Terms, rate limits, and access restrictions;
- detect, investigate, and prevent fraud, security incidents, technical failures, and misuse; and
- improve the reliability, safety, usability, and performance of the Service using appropriately limited operational data and voluntary feedback.
AI Consultant
The Improvement Protocol itself is selected deterministically from a fixed action catalog. It is not generated by an AI language model.
When you choose to send a message to the paid AI consultant, URATEN sends Google Gemini the message, a limited amount of recent conversation history, relevant scores and metrics from linked analyses, and available Protocol context needed to answer. Protocol context may reflect your questionnaire answers. URATEN does not send Gemini your photo or raw Facial Landmark Data.
Consultant conversations are saved to your account so the conversation can continue and be reviewed by you. AI responses may be inaccurate. Privacy choices do not change the medical and safety limitations in the Terms of Service.
No Sale, Advertising, or Unrelated Profiling
We do not sell personal data. We do not share personal data for cross-context behavioural advertising, serve third-party advertising, or use your data for marketing profiling. We do not rent or trade photos, Facial Landmark Data, Analysis Data, Protocol Questionnaire Data, or Consultant Data.
We do not currently send promotional marketing email. Authentication, payment, security, policy, support, and other service-related messages are not marketing communications.
6. Service Providers and Disclosures
We disclose personal data only as needed to operate the Service, comply with law, complete a transaction you request, protect rights and safety, or as otherwise described in this Policy.
Our principal provider categories are:
| Provider | Role and data involved |
|---|---|
| Supabase | Account authentication, application database, and related backend services |
| Hetzner | Application and server hosting |
| Cloudflare | Network delivery, security, DNS, protected access to our server, and Turnstile abuse-prevention checks |
| Stripe | Checkout, payment processing, subscription management, billing communications, refunds, and payment-risk controls |
| Resend | Delivery of authentication and other transactional email |
| Google Gemini | Generation of AI consultant responses using the Consultant Data described in Section 5 |
| Google MediaPipe, Google Fonts, and jsDelivr | Delivery of fonts, software, and model assets used by the site and for on-device facial landmark detection |
These providers process data under their applicable terms, contracts, and privacy obligations. A provider may act as our processor for some activities and as an independent controller for others, particularly where it must process information for its own legal, fraud-prevention, security, or payment-network duties. Stripe's own handling of payment data is described in its Privacy Policy.
We may also disclose information:
- to professional advisers, insurers, auditors, or authorities when reasonably necessary for legal compliance, risk management, or legal claims;
- in response to a valid legal process or enforceable governmental request;
- when reasonably necessary to protect users, URATEN, providers, or the public from fraud, abuse, or a credible threat;
- in connection with a proposed or completed reorganisation, financing, transfer, or sale of all or part of the Service, subject to appropriate confidentiality and applicable law; or
- with your direction or consent.
Provider identities and technical arrangements may change as the Service develops. We will continue to require protections appropriate to the provider's role and update this Policy when applicable law requires it.
International Transfers
Some providers or their personnel may process personal data outside the European Economic Area. Where the GDPR restricts a transfer, we use an available lawful transfer mechanism, such as an adequacy decision, the European Commission's Standard Contractual Clauses, and supplementary safeguards where appropriate. You may contact [email protected] for information about the safeguards applicable to a particular transfer.
7. Retention and Deletion
We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including providing the Service, meeting legal and accounting obligations, resolving disputes, preventing fraud, and establishing, exercising, or defending legal claims. The period depends on the nature of the data, the user's choices, the account or subscription state, legal limitation periods, and security needs.
| Data | Retention approach |
|---|---|
| Photos in browser storage | Remain on your device until removed by a reset, replacement, browser cleanup, or other local action; never stored in our application database |
| Raw Facial Landmark Data | Processed in memory for the requested analysis and not written to our application database |
| Signed-out Analysis Data | Not saved to an account or analysis-history database |
| Account and authentication data | Retained while the account is active and thereafter only as needed for deletion processing, security, legal obligations, or legal claims |
| Signed-in Analysis Data, Protocol Questionnaire Data, Protocol Data, and Consultant Data | Retained to provide account features until deleted following a valid request, consent withdrawal where applicable, or another appropriate lifecycle event, subject to lawful exceptions |
| Temporary Checkout records and accounts | Retained while needed to determine Checkout status, reconcile a purchase, protect entitlement ownership, prevent fraud, or recover a duplicate transaction; an account is removed as abandoned only after the relevant payment state can be verified as safe |
| Consent evidence | Retained for as long as reasonably needed to demonstrate valid consent, honour withdrawal, meet regulatory duties, or protect legal claims |
| Subscription, billing, refund, and transaction records | Retained as required for the transaction, accounting, tax, fraud-prevention, chargeback, and legal purposes that apply |
| Cancellation feedback and correspondence | Retained while useful to address the request, understand the feedback, meet legal duties, or protect legal claims |
| Security, request, and error logs | Kept for a limited period appropriate to operational, security, abuse-prevention, and incident-investigation needs |
Deletion from active systems does not always remove data instantly from backups, provider systems, or records that must be retained by law. Residual copies are isolated from ordinary use and deleted or overwritten according to the applicable backup or provider lifecycle. We may retain data in aggregated or irreversibly de-identified form where it no longer identifies you.
To request account or data deletion, contact [email protected]. We will verify and act on the request within the time required by applicable law. A deletion request does not require us to delete information that we are permitted or required to retain, including records needed for payments, tax, security, fraud prevention, consent evidence, dispute resolution, or legal claims.
8. Your Privacy Rights
Subject to applicable conditions, exceptions, and verification requirements, the GDPR may give you the right to:
- request access to personal data and information about its processing;
- request correction of inaccurate or incomplete personal data;
- request erasure of personal data;
- request restriction of processing;
- receive certain data in a structured, commonly used, machine-readable format and transmit it to another controller;
- object to processing based on legitimate interests;
- withdraw consent at any time, without affecting earlier lawful processing; and
- lodge a complaint with a competent supervisory authority.
The Service calculates informational aesthetic results automatically. It does not use automated decision-making that produces legal effects or similarly significant effects concerning you within the meaning of GDPR Article 22.
To exercise a right, contact [email protected]. We may ask for proportionate identity verification, clarification, or information needed to locate the data. We may refuse or charge a reasonable fee for manifestly unfounded or excessive requests where the law permits. We normally respond within one month and may extend that period where permitted due to complexity or the number of requests.
You may complain to the supervisory authority where you live or work or where an alleged infringement occurred. In the Czech Republic, the supervisory authority is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Praha 7, Czech Republic, uoou.gov.cz.
Additional Jurisdiction-Specific Information
Some jurisdictions may classify face-derived measurements as biometric information or certain questionnaire or consultant data as consumer health data. URATEN processes this information only to provide and protect the Service as described in this Policy. We do not sell, lease, or trade it, use it for identification, or disclose it for advertising.
The Terms of Service prohibit use by residents of Illinois and Washington State. If a biometric, consumer-health, or state comprehensive privacy law applies to particular processing, we will provide and honour the notices, consents, access, correction, deletion, withdrawal, appeal, authorised-agent, retention, and other rights required by that law, subject to its scope and exceptions.
Where an applicable biometric law requires a public retention and destruction policy, this Section and Section 7 constitute that policy. Raw Facial Landmark Data is destroyed after the requested computation. Other covered data is retained only while its original collection purpose remains, or for a shorter period required by law, and is then destroyed subject to lawful retention exceptions and backup lifecycles.
California residents may have rights to know, access, correct, delete, and limit or opt out of certain processing if the California Consumer Privacy Act applies to URATEN. We do not sell or share personal information as those terms are defined for cross-context behavioural advertising. Texas residents may have rights under applicable biometric or comprehensive privacy laws. Requests may be sent to [email protected].
9. Cookies and Similar Technologies
We use browser storage and strictly necessary or functional technologies to provide authentication, maintain security, remember session state, support Checkout, and operate the Service. Our providers may set or read similar technologies when supplying those functions.
We do not use third-party advertising cookies or marketing analytics. Because we do not sell or share personal data for cross-context behavioural advertising, there is no sale or advertising-sharing preference to opt out of through the Service.
Your browser controls can clear or block storage, but doing so may prevent authentication, saved local state, abuse prevention, Checkout, or other Service features from working correctly.
10. Children
The Service is intended only for people aged 18 or older. We do not knowingly collect personal data from a child. If you believe a child has provided personal data to the Service, contact [email protected]. We may request information needed to verify the report and will take appropriate action under applicable law.
11. Security
We use technical and organisational measures designed to protect personal data in light of its nature, the processing risks, available technology, and the scale of the Service. Measures include access controls, encrypted transport, provider security controls, separation of payment-card handling, limited logging, and keeping photos on the user's device.
No service, transmission, or storage system can be guaranteed completely secure. You are responsible for protecting access to your email account, one-time passcodes, authenticated devices, and browser sessions. If you believe an account or interaction with the Service is compromised, contact [email protected].
12. Changes to This Policy
We may update this Policy to reflect changes in the Service, providers, law, or our practices. The current version will be posted on this page with its effective or last-updated date. We may provide additional notice where appropriate or legally required.
If a change requires new consent, we will request that consent before beginning the affected processing. Continued use does not override a consent requirement or any non-waivable right.
13. Contact
For privacy questions, requests, or complaints:
Privacy and data protection: [email protected]
Legal and general enquiries: [email protected]
URATEN is based in the Czech Republic.