Biometric Policy and Agreement
ONE EIGHT EIGHTEEN PTE. LTD., UEN 202644930W, operates Oleah. Our address is 160 Robinson Road, #14-04 Singapore Business Federation Center, Singapore 068914. Contact privacy@oleah.skin for face-data questions, requests or consent withdrawal.
This is our face-data notice, retention schedule and destruction policy. It supplements the Privacy Policy and Consumer Health Data Privacy Policy. Legal definitions of biometric information differ; describing a use as skin tracking does not remove any protection the law gives it.
1. What we collect and why
Face data includes scan photos and, to the extent such data qualifies as a 'biometric identifier' or 'biometric information' under applicable law, face geometry, expression readings, and skin measurements. It does not include generalized notes, product verdicts, or forecasts derived from these scans that are fully de-identified and cannot be used to identify a specific individual. It also includes face information in photos you submit through other features.
We use photos and skin measurements to analyse and track your skin, compare your scans, assess scan quality and provide the results and personalisation you request. Face measurements, including face-mesh coordinates, support alignment and comparison of your own scans. We use related data to answer requests, investigate faults and protect the service. With the appropriate permission, authorised people and AI tools may review results and related conversation information to improve Oleah.
Oleah and its service providers are not designed to, and do not intend to, use face data for identity recognition or to cross-reference your face against other individuals. Oleah does not use it to train general-purpose AI models. These statements do not exclude the provider safety processing described below. Scan only your own face.
2. Photos and recipients
Your face remains visible in images used for skin analysis. The image sent to an AI service can include the full photograph and areas outside the face. Masked copies and separately encrypted originals are different records. Encryption of a stored original is not a promise that an analysis provider cannot see the submitted photograph. Earlier records may have different image protections.
Cloud hosting stores face data for Oleah. Our primary storage is provided through Supabase on AWS in Mumbai, India. Google Gemini processes photos and relevant scan and profile information for skin readings and related AI features. Authorised personnel can access information for the purposes above.
Our service providers act strictly as our processors and are contractually prohibited from retaining, using, or disclosing your biometric data for any independent purpose. This can include improvement of safety systems. Our Privacy Policy explains provider processing and international transfers. Face-mesh coordinates are retained with scan records for alignment and comparison. This is separate from the photos submitted for AI analysis.
We disclose face data only with the required permission or another applicable legal authority. A buyer of Oleah does not receive face data without your consent; if you decline, we delete it subject to applicable legal requirements.
3. Consent and withdrawal
Before collecting a scan, we give you the purpose, retention and recipient information and request affirmative consent, including a written or electronic release where required. Terms acceptance alone does not give that permission. Permissions for unrelated optional purposes remain separate.
Your scan agreement. When you affirmatively select the scan permission in Oleah, you authorise ONE EIGHT EIGHTEEN PTE. LTD. to collect, store and use your face photos, face measurements and skin assessments to analyse your skin, align and compare your scans, maintain your history and personalise your requested features. You authorise disclosure to the hosting and AI providers described in section 2 for those purposes, subject to the retention limits in section 4. This agreement does not authorise optional product-improvement review without the separate permission required for that use.
You can withdraw consent by emailing privacy@oleah.skin. You may also delete your account through Privacy & my data. Withdrawal stops the processing that depended on the consent and may prevent scan-based features from working. We handle deletion of affected data under the schedule below. Withdrawal does not undo earlier lawful processing or cancel an App Store subscription.
4. Retention schedule
We retain face data while necessary to provide your requested skin history and comparisons, subject to the following limits. An open account does not extend a mandatory deadline.
| Trigger | Retention and deletion rule |
|---|---|
| Account deletion | Upon account deletion, encrypted original photos, other account data, and the analytics profile are deleted within 30 days. Backups age out within about 7 days after that. Signing in during those 30 days cancels account deletion but cannot recover deleted originals. |
| Withdrawal, a valid erasure request, or the end of the purpose | Stop processing that relied on the withdrawn consent. Withdrawing face consent deletes face data within 10 minutes. The analysis job is deleted after 48 hours. Delete affected face data without undue delay and within the applicable legal deadline, unless a specific lawful retention exception applies. The ordinary account recovery period does not postpone an earlier legal deadline. |
| Illinois, where BIPA applies | Permanently destroy covered biometric identifiers and information (including face scans, analyses, and photo files) when the original collection purpose is satisfied or within 3 years of your last interaction with Oleah, whichever occurs first. |
| Texas, where CUBI applies | Destroy covered biometric identifiers within a reasonable time and no later than one year after the collection purpose expires, subject to the statute's applicable exceptions. |
| Colorado, where its biometric provisions apply | Delete covered identifiers by the earliest of purpose completion, 24 months after your last interaction, or the earliest reasonably feasible date following an annual review finding that storage is no longer necessary, adequate or relevant. That review-based period is no more than 45 days, with a further period of up to 45 days only when legally permitted and reasonably necessary. |
The laws of other locations may require earlier deletion or additional limits. We do not retain covered data indefinitely merely because you have not closed your account. A legal hold applies only where law permits it and only to the records and period it permits; it is not a general exception to the biometric destruction rules.
5. Destruction and security
Deletion covers affected database records and stored files, including geometry, scan logs and derived results or notes. We arrange required downstream deletion, restrict backups pending expiry or erasure, and reapply deletions if a backup is restored. Upon a valid deletion request, account closure, or satisfaction of the initial collection purpose, Oleah will securely destroy your biometric data and contractually mandate that all integrated service providers permanently destroy all corresponding copies in their possession, in strict compliance with the timelines set forth in applicable biometric privacy laws.
We use reasonable safeguards appropriate to sensitive information, at least as protective as those used for our other confidential information. Access is restricted to authorised purposes. If a security incident affects face data, we investigate, contain it and provide notifications required by law. This notice does not promise that any system is risk-free.
6. Requests and changes
Email privacy@oleah.skin to request access, correction, a copy, deletion, withdrawal or recipient information. We may verify your identity. If a request is refused, you may appeal by replying with Appeal; we respond within 45 days or any shorter applicable period. You can complain directly to your privacy authority or state Attorney General.
We publish updates and give notice of material changes. A new notice does not retrospectively authorise earlier collection. We obtain fresh consent before a new use of existing face data that requires it. Your statutory rights remain unaffected.