Privacy Policy

Last updated: 27 July 2026 · Français

ACUENCE analyzes the appearance of your skin 100% on your device. No raw face photo and no biometric data leave your iPhone. The reference policy is available in the application; this page reproduces its content.

1. Data controller

Guillaume Velé

Email: contact@acuence.app

2. Data collected

2.1 Account data (optional)

Sign in with Apple identifier (anonymized by Apple)
First name (if provided through Sign in with Apple)
Email (if provided through Sign in with Apple)

Legal basis: Consent (GDPR Article 6.1.a)

2.2 Product scan data

Photos of cosmetic products (barcodes, labels)
History of scanned products
Personal notes and verdicts

Legal basis: Performance of the contract (GDPR Article 6.1.b)

Retention: your scan history and your personal notes stay on your device. The photo of a product, and the name or barcode you search, are sent to identify the product: see section 2.6. Your face photos are never sent.

2.3 Skin analysis data (special category)

Face photos for the analysis of the skin's appearance
Cosmetic indicators: redness, shine, grain and texture, under-eye circles, and a radiance index built from appearance
Skin profile: skin type, concerns, sensitivities
History of analyses

Legal basis: Explicit consent (GDPR Article 9.2.a)

Retention: face photos and detailed indicators are stored locally on your device. No raw face photo is sent to a server.

Processing: the photo observation of the face is performed on your device. Servers may receive score and synchronization metadata, never raw face photos nor detailed skin measurements.

2.4 Usage data

Language and appearance preferences
Beauty routine (morning/evening products)
Product library

Legal basis: Performance of the contract (GDPR Article 6.1.b)

2.5 Subscription data

ACUENCE subscription status. Managed exclusively by Apple through StoreKit. We have no access to your payment data.

2.6 Data sent to our servers

For transparency, here is the only data that may pass through our secure servers (HTTPS, hosted in the EU):

Product catalog: your searches (name, brand, barcode) are sent to query our product database.
Photos of cosmetic products: sent only to identify the product or extract the INCI list (never the face).
INCI analysis: the ingredient list of a product is sent to generate a verdict.
Weather (optional, only when you turn it on): your approximate location is read on the device and sent to Apple Weather (WeatherKit) for the weather markers, never to any other third party.

No raw face photo and no biometric data are transmitted. The Acu assistant runs entirely on your device (an embedded base of frequent questions, then Apple Foundation Models on iOS 26 and later): your messages with Acu never leave the device and are sent to no server.

Legal basis: Performance of the contract (GDPR Article 6.1.b)

2.7 Technical performance data (local only)

To analyze slowdowns in the application, ACUENCE keeps locally on your device, for 14 days at most, the performance reports provided by iOS through the MetricKit framework:

Application launch time
Peak memory use
Scrolling smoothness (scrollHitchTimeRatio)
Hang reports and crash reports

These MetricKit reports are stored in the system cache (/Caches, excluded from iCloud backups) and contain no photos, no INCI lists and no scan payloads. Any crash events transmitted are redacted and exclude skin data.

Collection only starts after your explicit consent (the GDPR banner). You can delete this data at any time by uninstalling the application.

Legal basis: Consent (GDPR Article 6.1.a): collection is only enabled after the GDPR consent banner

3. Purposes of processing

Analysis of cosmetic ingredients (INCI)
Analysis of the appearance of the skin and wellness recommendations
Personalization of product recommendations
AI skincare coach (Acu)
Beauty routine tracking

4. Data sharing

We neither sell nor rent any personal data to third parties for commercial purposes.

Processors (GDPR Article 28)

Apple Inc., StoreKit (ACUENCE payments), Sign in with Apple (authentication). Framework: Apple App Store Connect contractual clauses.
ACUENCE API (verdictbeauty.app), product catalog, INCI OCR, INCI analyses. The Acu assistant goes through none of these servers: it runs 100% on your device. Hosted in the European Union, HTTPS only, deletion on request atcontact@acuence.app.
Apple Weather (WeatherKit, Apple Inc.), weather requests from an approximate location, only if skin weather is enabled. Framework: Apple Developer terms.

No transfer to advertising third parties, data brokers or social networks.

5. Transfers outside the EU

The ACUENCE backend (product catalog, INCI OCR and analysis, opt-in statistics) is hosted in the European Union.

Apple services (StoreKit, Sign in with Apple, Apple Weather) may involve processing outside the EU by Apple Inc. (United States). These transfers are covered by the safeguards of Apple's contractual frameworks for developers, including Standard Contractual Clauses (GDPR Article 46).

To identify certain products or ingredients, the application may query public reference services operated outside the EU: the PubChem chemical database (National Institutes of Health, United States); the Open Beauty Facts product database; and, when an ingredient list cannot be found otherwise, a web search through DuckDuckGo (United States), in which case the application may also open the first few result pages directly, on third-party sites it does not control. These requests contain only the name, brand, barcode or ingredients of the product being looked up, never your identity, your account or your skin data; like any internet connection, they expose the device's IP address to the service being queried. These occasional transfers are necessary to perform the service you request (GDPR Article 49.1.b).

No advertising or data broker transfer takes place.

6. Retention periods

In line with the minimization principle (GDPR Article 5.1.e), each category of data has its own retention period:

Skin data (photos, indicators): local only, kept for as long as the application is installed. Deleted by uninstalling the application or from Profile > Manage my data.
Product / routine history: local, until uninstallation or manual deletion.
MetricKit reports: local, 14 days at most, then automatic rotation.
Sign in with Apple account: kept for as long as you do not delete your account from Profile > Manage my data.
Server logs (catalog, OCR): 30 days for quality analysis, then automatic purge. The Acu assistant generates no server log (processing runs 100% on the device).

You can exercise your right to erasure (GDPR Article 17) at any time from Profile > Manage my data, or by uninstalling the application.

7. Your rights (GDPR Articles 15 to 22 and 77)

You have the following rights:

Right of access to your data (Art. 15)
Right to rectification (Art. 16)
Right to erasure / right to be forgotten (Art. 17), available in one tap from Profile > Manage my data
Right to restriction of processing (Art. 18)
Right to data portability (Art. 20), JSON export on request at contact@acuence.app
Right to object (Art. 21)
Right to withdraw your consent at any time (Art. 7.3)

To exercise these rights: contact@acuence.app. We reply within 30 days (GDPR Art. 12.3).

Right to lodge a complaint (Art. 77): Commission Nationale de l'Informatique et des Libertés (CNIL, the French data protection authority), 3 Place de Fontenoy, 75334 Paris Cedex 07 - www.cnil.fr.

8. Security

Local data is stored on your device and protected by Apple's hardware encryption mechanisms.

The observation of appearance is performed on the device; no image of the face is transmitted over the internet.

9. Cookies and trackers

The application uses no cookie, no advertising tracker and no attribution SDK: nothing follows you from one application to another.

No analytics, attribution or crash-reporting SDK receives data: crash reports go through Apple's own mechanisms, with no external SDK. The public reference services the application queries to identify a product are listed in section 5.

10. Minors

The application is accessible at all ages (4+ rating). No data specific to minors is collected.

11. Continuous improvement (opt-in)

With your explicit agreement (off by default), ACUENCE may send once a week, over Wi-Fi only, an aggregated, pseudonymous statistic about your usage, in order to improve product scores, the coverage of Acu questions and the recognition of INCI lists.

A hashed install identifier, renewed monthly, accompanies the sending. No photo and no plain-text query leaves your device.
Each send is capped at 5 KB, aggregated over several days, with a k-anonymity threshold of 5.
No product identifier, brand or barcode is transmitted, only generic categories (cleanser, serum, sunscreen, and so on) and score ranges.
Retention: raw server data 30 days, aggregates 2 years.

You can give or withdraw this consent at any time in Profile > Settings > “Help improve Acuence”. Withdrawing immediately erases the data not yet sent.

Legal basis: GDPR Article 6.1.a, explicit consent.

12. Changes

We reserve the right to change this policy. You will be informed in the application in case of a substantial change.