Glowberry Skin ID™ - Privacy Policy

Privacy Policy — Glowberry Skin ID™

 Last updated: 6 August 2026

🔒 Your photo is not stored Your face photo is used only at the moment of the analysis, to estimate the visible characteristics of your skin. It is never stored — it is deleted immediately once the analysis is complete. It is not used for facial identification.

1. Who we are

Glowberry Skin ID™ is a skin-analysis tool that runs on our online store, glowberry.gr. The data controller is GLOWBERRY IKE, GIAMPOULAKI 42, CHANIA 73134, Greece. For any data-protection matter: hello@glowberry.gr.

2. What data we process

  • Face photo — temporarily, only for the AI analysis; not stored (see above).
  • Skin assessment — skin type, indicators and needs (concerns) derived from the analysis.
  • Your quiz answers — goals, age range, routine size, and any flags (e.g. pregnancy/breastfeeding, sensitive skin, declared allergies).
  • The recommended routine (products) and your unique "Skin ID" code.
  • Email — only if you choose "email me my routine", so we can send you the plan and, if you consent, updates and skincare suggestions.
  • Purchase/order data — when you add recommended products to the cart, we link the cart/order to your Skin ID (via a code) to measure how helpful the recommendations are.
  • Language preference (Greek/English).

3. Local storage on your device For your convenience, your recent analyses (skin type, needs, recommended products — without the photo and without any contact details) are stored locally in your device's browser (local storage) so you can view them again. They remain solely on your own device, are not automatically sent to us, and you can clear them at any time via the "Clear history" button or by clearing your browser data.

4. Purpose & legal basis We process the above to recommend a personalised skincare routine. The legal basis for the analysis (and any special-category data that may result) is your explicit consent (Art. 9(2)(a) & Art. 6(1)(a) GDPR), which you give before the analysis. For sending marketing emails, the basis is also your consent. For fulfilling an order, the basis is the performance of a contract (Art. 6(1)(b)). You may withdraw your consent at any time.

5. Artificial intelligence & providers (processors)

  • Photo analysis: via an AI provider (OpenAI), acting solely on our behalf; the image is sent only to run the analysis and is not retained by us.
  • Store platform: Shopify (store hosting, cart, orders).
  • Email marketing: Klaviyo (if you provide an email and consent). Processing may involve transfers outside the EEA (e.g. the USA) with the appropriate safeguards required by GDPR (Standard Contractual Clauses).

6. Who sees your data Your data is processed by Glowberry and the above providers, solely for the purposes described. We do not sell your data and do not share it with third parties for advertising purposes.

7. How long we keep it The photo is not retained. The remaining data (assessment, answers, routine, order data) is kept for 24 months or until you request its deletion. Your email stays on our contact list until you unsubscribe. The analyses stored locally on your device are automatically deleted after ~30 days (or whenever you clear them).

8. Your rights You have the right of access, rectification, erasure, restriction and portability, as well as the right to object and to withdraw consent at any time. To exercise them: hello@glowberry.gr. You also have the right to lodge a complaint with the Hellenic Data Protection Authority (www.dpa.gr).

9. Minors The tool is intended for adults. For minors, the consent of a parent or guardian is required.

10. Not medical advice The analysis and suggestions are purely cosmetic/informational, constitute an estimate and not a medical diagnosis or treatment. For skin conditions, consult a dermatologist.

11. Security & changes We take reasonable technical and organisational measures to protect your data. We may update this policy; the current version is dated at the top.