Privacy Policy

Effective date: April 1, 2026  ·  Last updated: April 1, 2026  ·  Version 1.0

Data We Do Not Collect

Purely does not collect or process any of the following:

• Location data
• Contacts or address book
• Photos or camera roll (the camera is used only to scan barcodes and is not saved)
• Advertising identifiers (IDFA or equivalent)
• Crash reports or diagnostic telemetry (no Sentry, Crashlytics, or equivalent)
• Analytics events (no Firebase, Amplitude, Mixpanel, or equivalent)
• Browsing history or search history outside the app
• Any data from users we know to be under 13 years old

Who We Are

Purely is an independent iOS application that helps you understand cosmetic ingredient safety under EU regulations (EC 1223/2009). The app is developed and operated by Jaden Maciel-Shapiro, an individual developer.

For privacy questions or data subject requests, contact us at: privacy@getpurelyapp.com

Data We Collect

Data Stored Locally on Your Device

The following data is stored using Apple's SwiftData framework on your device only. It is never transmitted to any Purely-operated server.

• Skin type - your selection from the onboarding quiz (e.g., oily, dry, sensitive)
• Skin concerns - up to four concerns you select (e.g., acne, aging, redness, dark spots)
• Scan history - barcode, product name, EU safety score, and ingredient list for products you have scanned
• Affiliate click records - which product and retailer you tapped (timestamp, no personal identifiers), used to process affiliate commissions

This data remains on your device and is deleted when you uninstall the app or use the data deletion option in Settings.

Data Collected by Third-Party Services

Purely uses a small number of third-party services that have their own privacy policies. Each service is described below.

Affiliate Link Tracking

When you tap an affiliate link in the app (e.g., to Amazon, Credo Beauty, iHerb, or Dermstore), you leave the Purely app and enter the retailer's website. The partner retailer may set their own cookies or track your click through their own systems. Purely does not control this tracking. Please review each retailer's privacy policy before completing a purchase.

How We Use Your Data

• To provide the ingredient scanning and scoring service
• To personalize alternative product suggestions based on your skin profile
• To process subscription payments and verify premium access via RevenueCat
• To generate AI skincare routines (premium users only, via OpenRouter)
• To attribute affiliate commissions to Purely (no personal information is passed to retailers)

Data Retention

All skin profile and scan history data is stored locally on your device indefinitely until you delete it. You can delete it by uninstalling the app or using Settings > Clear Data within the app.

RevenueCat retains subscription and purchase data according to their own privacy policy. OpenRouter retains AI query data according to their own retention policy - we recommend reviewing it before using the routine builder feature.

Your Rights (GDPR - EU/EEA Users)

If you are located in the European Union or European Economic Area, you have the following rights under the General Data Protection Regulation (Regulation (EU) 2016/679):

• Right of access (Article 15) - You may request a copy of the personal data we process about you.
• Right to rectification (Article 16) - You may request correction of inaccurate data.
• Right to erasure / "right to be forgotten" (Article 17) - Since your skin data is stored locally on your device, you can delete it by uninstalling the app or using Settings > Clear Data. For RevenueCat data, contact RevenueCat directly.
• Right to data portability (Article 20) - You may request your data in a structured, machine-readable format.
• Right to restriction (Article 18) - You may request that we restrict processing of your data in certain circumstances.
• Right to object (Article 21) - You may object to processing based on legitimate interests.
• Right to withdraw consent (Article 7) - Where processing is based on consent (e.g., storing your skin concerns), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of prior processing.

Lawful basis for processing: Processing of your skin profile data (including skin concerns, which may be health-adjacent under Article 9 GDPR) is based on your explicit consent (Article 6(1)(a) and, where applicable, Article 9(2)(a)). You provide this consent during the initial onboarding flow before any data is stored. You may withdraw consent at any time by deleting the data in Settings.

To exercise any of these rights, contact us at privacy@getpurelyapp.com. We will respond within 30 days as required by Article 12 GDPR.

You also have the right to lodge a complaint with your local data protection supervisory authority (e.g., your national DPA or the European Data Protection Board).

Your Rights (CCPA - California Users)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) grant you the following rights:

• Right to know - You may request information about the categories and specific pieces of personal information we have collected about you, as well as the purposes for collection and any third parties with whom we share it.
• Right to delete - You may request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to opt out of sale or sharing - Purely does not sell your personal information, and we do not share it for cross-context behavioral advertising.
• Right to correct - You may request correction of inaccurate personal information.
• Right to limit use of sensitive personal information - We do not use sensitive personal information for any purpose other than providing the service.

To exercise these rights, contact us at privacy@getpurelyapp.com. We will not discriminate against you for exercising any of your privacy rights.

Your Rights (UCPA - Utah Users)

If you are a Utah resident, the Utah Consumer Privacy Act (UCPA, effective December 31, 2023) grants you the following rights:

• Right to know - You may confirm whether we process your personal data and request access to it.
• Right to delete - You may request deletion of personal data you provided to us.
• Right to data portability - You may request a copy of your personal data in a portable format.
• Right to opt out - You may opt out of the sale of personal data or targeted advertising. Purely does not sell personal data or conduct targeted advertising.

To exercise these rights, contact privacy@getpurelyapp.com.

Children's Privacy

Purely is not directed at children under the age of 13 and does not knowingly collect personal information from children under 13. If you believe a child under 13 has used this app, please contact us at privacy@getpurelyapp.com and we will delete any associated data promptly.

EU Representative

As an individual developer based outside the EU who offers services to EU residents, Purely is evaluating the appointment of an EU representative under Article 27 of the GDPR. This section will be updated prior to the public launch of the app in EU markets. In the interim, EU data subjects may direct inquiries to privacy@getpurelyapp.com.

Changes to This Policy

We may update this privacy policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page. For significant changes affecting your rights, we will notify you via an in-app notice or by email (if we have your email address on file).

Continued use of the app after changes to this policy constitutes acceptance of the updated policy.

Previous Versions

This is version 1.0 of the Purely privacy policy (effective April 1, 2026). For prior versions, contact privacy@getpurelyapp.com.

Contact

For privacy questions, data subject requests, or concerns:

Email: privacy@getpurelyapp.com
App: Purely (iOS)
Website: getpurelyapp.com