Last updated: 19 May 2026
1. Who we are
GlowdUp is a skincare analysis application operated by LifeReady ZA (the "Controller" under GDPR / the "Business" under CCPA / the "Responsible Party" under POPIA).
Contact: privacy@lifereadyza.co.za
Website: https://glowdup.lifereadyza.com
We do not have a formal EU/EEA establishment. EU/EEA users may direct inquiries to the contact address above; we will respond within the timeframes required by GDPR.
2. Information we collect
| Category | Examples | Purpose | Legal basis (GDPR) |
|---|---|---|---|
| Account identifiers | Phone number, device ID | Account creation & authentication via WhatsApp OTP | Contract performance |
| Profile data | Name, date of birth, skin type, concerns | Personalise your experience | Consent (you fill it in voluntarily) |
| Biometric / health-adjacent data | Selfie photos submitted for analysis | Generate skin-analysis scores | Explicit consent (required before each scan) |
| Scan results | Skin scores, concern metrics, skin-age estimate | Show history & trends in-app | Contract performance |
| Payment information | Order reference, amount, payment status | Process credit purchases | Contract performance |
| Push subscription token | Browser push endpoint & keys | Deliver scan & payment notifications (opt-in only) | Consent |
| Referral data | Referral code, visit timestamp | Attribute referrals; no PII shared with referrer | Legitimate interest |
| Usage data | Feature usage, app version, error logs | Improve reliability and user experience | Legitimate interest |
We do not collect precise GPS location, browsing history, or advertising identifiers. We do not sell your personal information.
3. How we use your information
- Provide and operate the skin-analysis service.
- Display your scan history and score trends.
- Send scan-result and payment-confirmation notifications (WhatsApp and/or push — opt-in only).
- Process payments and credit top-ups.
- Improve app performance and fix errors.
- Comply with legal obligations.
4. Third-party services
- Perfect Corp (YouCam) — processes your selfie to generate skin-analysis scores. Images are transmitted securely and are not retained by Perfect Corp after analysis is complete. Their processing is governed by Perfect Corp's Privacy Policy.
- WHAPI — delivers WhatsApp messages on our behalf. Your phone number is shared only to the extent required to send messages.
- Paystack — handles payment processing. We do not store card or banking details. Governed by Paystack's Privacy Policy.
All third-party processors are bound by data-processing agreements and are required to handle your data in accordance with applicable privacy laws.
5. International data transfers GDPR
Our servers are located in Germany (Hetzner Cloud). Skin-analysis processing by Perfect Corp may involve transfers to servers outside the EEA. Where such transfers occur, we rely on Standard Contractual Clauses (SCCs) or the recipient's adequacy decision to ensure your data receives equivalent protection.
6. Data retention
We retain your account data and scan history for as long as your account is active. Push-notification tokens are deleted when you disable notifications in the app or when the token is reported as expired by the push service. Anonymised, aggregated statistics may be retained indefinitely.
Upon account deletion or an erasure request, personal data is permanently deleted within 30 days.
7. Your privacy rights
All users
- Access — request a copy of the data we hold about you.
- Correction — request that inaccurate data be corrected.
- Deletion / Erasure — request permanent deletion of your data.
- Withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting prior processing.
EU / EEA residents GDPR
In addition to the above, you have the right to:
- Data portability — receive your data in a structured, machine-readable format.
- Restrict processing — ask us to pause processing while a dispute is resolved.
- Object — object to processing based on legitimate interest.
- Lodge a complaint with your local EU/EEA data-protection supervisory authority (e.g. find your authority here).
South African residents POPIA
- All rights in §23 of POPIA apply, including the right to complain to the Information Regulator of South Africa (inforegulator.org.za).
California residents CCPA
- Right to know — the categories and specific pieces of personal information collected about you.
- Right to delete — request deletion of personal information we have collected.
- Right to correct — request correction of inaccurate personal information.
- Right to opt-out of sale or sharing — we do not sell or share personal information for cross-context behavioural advertising. No opt-out mechanism is required, but you may contact us to confirm.
- Right to non-discrimination — we will not discriminate against you for exercising any CCPA right.
To exercise any of these rights, use the "Delete My Data" option in the app (More → Privacy → Delete My Data) or email privacy@lifereadyza.co.za. We will respond within 30 days (or within 45 days for CCPA requests where an extension is needed, with notice).
8. We do not sell your personal information CCPA
GlowdUp does not sell, rent, or share your personal information with third parties for their own marketing or advertising purposes. We do not engage in cross-context behavioural advertising.
9. Notifications
GlowdUp may send notifications via WhatsApp and/or browser push. You can opt out at any time using the Notifications toggle in the app (More → Notifications) or by revoking permission in your device settings. Opting out does not affect your ability to use the app.
10. Security
All data is transmitted over HTTPS (TLS 1.2+). Your account is protected by WhatsApp OTP verification. Skin photos are not stored beyond what is needed to produce your analysis report. We apply industry-standard controls to protect data from unauthorised access, disclosure, or loss.
11. Children's privacy
GlowdUp is intended for users aged 13 and older. We do not knowingly collect personal information from children under 13 (or under 16 where required by local law). If you believe a child has provided personal information without parental consent, please contact privacy@lifereadyza.co.za and we will delete it promptly.
12. Cookies and local storage
GlowdUp is a Progressive Web App and does not use advertising or tracking cookies. We use browser localStorage and sessionStorage solely to store your session token, scan history cache, and app preferences on your own device. This data never leaves your device unless explicitly sent to our API as part of normal app operation.
13. Changes to this policy
We may update this policy from time to time. The "Last updated" date at the top reflects the most recent revision. For material changes we will notify users via an in-app notice. Continued use of the app after an update constitutes acceptance of the revised policy.
14. Contact & complaints
LifeReady ZA — Privacy
privacy@lifereadyza.co.za
https://glowdup.lifereadyza.com
EU/EEA users may also lodge a complaint with their national supervisory authority. South African users may contact the Information Regulator at inforegulator.org.za. California users may contact the California Privacy Protection Agency at cppa.ca.gov.