Privacy Policy

Appinara s. r. o., Juskova Voľa 66, 094 12 Juskova Voľa, company ID (IČO) 57623252, registered: Commercial Register of the District Court Prešov, section: Sro, insert no. 52598/P.

Data protection contact: hello@miraskinlab.com.

No Data Protection Officer (DPO) is appointed — our processing does not require one under GDPR Art. 37.

Face photo (biometric / special-category data under GDPR Art. 9).

Email address (sign-in with a one-time code, receipts and access to what you bought, and — only if you ask — your free result by email).

Account emails: if you have an account, we use your address for a few emails about the service you bought: a reminder when a re-scan is due (week 8), plan check-ins in weeks 2 and 5, one request for a review ten days after your first purchase, a notice when a friend's purchase earns you a referral reward, and one reminder about a payment you started but did not finish. You can switch them off in your account or with the link in each of them.

Paying without signing in: when you enter your email at the payment step, we create an account for it, unverified until you sign in with a code. It holds your scan and a copy of your questionnaire answers. If the payment is not completed, the account is deleted together with the unpaid scan.

Questionnaire answers, including voluntarily supplied information about allergies, medication, pregnancy and skin concerns, used to prepare your plan.

Analysis results, score and plan.

Face points: to draw the face map and to line up two of your photos for comparison, your own browser finds points on your photo (eye corners, brows, lips, face outline). This runs on your device, the points are not stored or sent to us, and they are not used to identify you.

Complete assessment: if you buy it, you add three more photos (both sides of your face and the top of your head). With your explicit consent on that screen, they are sent with your first photo to Anthropic for the in-depth reading, stored encrypted in the EU with the scan, and deleted together with it — or on their own if the upgrade is refunded.

Questions to the report's AI assistant: what you type there is sent to Anthropic together with your report and your questionnaire answers (including any health information you gave, such as allergies, medication or pregnancy) to produce the answer. Your questions and the answers are stored with the scan and deleted together with it (or with your account).

Referral program: your personal invite code, and when a friend's first purchase comes through your link, a record of it — the discount the friend got and the reward you got. Neither of you is shown who the other is. If the friend deletes their account, the link to them is removed and your reward stays; if you delete yours, your code and rewards are deleted.

Payment data — processed directly by Stripe; we never see card details.

Gift vouchers: if you buy one, your email address (to send the code and receipt, and to tell you when the code has been redeemed — not by whom), and the name and message you choose to put on the gift card. The card itself never shows your name or email. If you ask us to email the code to the recipient on a chosen date, we also keep their email address for that one email and delete it 30 days after it is sent (or once the code is used, expires or is refunded, if sooner).

Reviews: if you answer our review request, your rating, your text and — only if you tick the box to let us publish it — the name you choose to show and the time of that consent. Whether you paid for the assessment yourself is recorded so a published review can say “verified purchase”. Nothing is published without that consent and a person reading it first; you can change your answer or withdraw consent with the link in the email for 60 days, or by writing to us at any time, and the review is deleted with your account.

Usage events: we record steps in the service (for example consent given, scan saved, payment completed or refunded) with a pseudonymous account ID — never your photo, questionnaire answers or email. They are pseudonymous, not anonymous: the ID links them to your account while it exists.

Technical data: strictly necessary cookies, basic logs, and cookieless traffic statistics that hold no identifier.

Face photo: your explicit consent (GDPR Art. 9(2)(a)). You can withdraw it at any time.

Health information you choose to give in the questionnaire (allergies, medication, pregnancy): your explicit consent (GDPR Art. 9(2)(a)), given on the consent screen before the photo step. Until then your answers stay on your device; nothing is sent to us before you agree. "None of these" is always an answer, and you can withdraw consent at any time.

Paid service: performance of a contract (Art. 6(1)(b)).

Your free result sent by email: your request (Art. 6(1)(b)). Skincare guides and offers: your consent (Art. 6(1)(a)), given with a separate, unticked box; withdraw it with the unsubscribe link in every such email.

Account emails (re-scan reminder, plan check-ins, review request, referral reward notice, unfinished-payment reminder): our legitimate interest in helping you get the result you paid for (Art. 6(1)(f)); where an email promotes our own similar services to you as a customer, the existing-customer exception for electronic mail (Art. 13(2) of Directive 2002/58/EC, as implemented in Slovak law). You can object at any time, free of charge: switch them off in your account or use the link in each email.

Referral program and gift vouchers: performance of a contract (Art. 6(1)(b)); keeping the purchase records: a legal obligation (Art. 6(1)(c)). A gift recipient's email address for a scheduled delivery: our and the buyer's legitimate interest in delivering the gift as asked (Art. 6(1)(f)).

Reviews: reading your answer, our legitimate interest in improving the service (Art. 6(1)(f)); publishing it with your name, your consent (Art. 6(1)(a)), which you can withdraw at any time.

Usage events: legitimate interest in understanding where the service fails people (Art. 6(1)(f)). Consent records: legal obligation to be able to demonstrate consent (Art. 7(1)).

Operation and security: legitimate interest (Art. 6(1)(f)).

Analysis and image generation use AI providers: Anthropic (analysis) and OpenAI (AI "after" image).

Payments: Stripe. Email: Resend. Photo storage: Cloudflare R2 (EU). Database: Turso (EU). Hosting and web delivery: Vercel — every request passes through its infrastructure, including the uploaded photo in transit.

In-app purchases (iOS/Android apps): Apple or Google process the payment as independent controllers; RevenueCat receives your account ID and purchase receipt to confirm the purchase.

Some providers (Anthropic, OpenAI, Stripe, Resend, RevenueCat, Apple, Google, Vercel) also process data in the USA. Transfers rely on Standard Contractual Clauses (SCC), or the EU-US Data Privacy Framework where the provider is certified.

Free mode: the photo is kept only during analysis and then deleted; only the text analysis is stored if you save it.

Paid mode: the photo is stored encrypted in the EU (Cloudflare R2, AES256) until you delete the scan or your account.

Unfinished payment: an unpaid scan and its uploaded photo are deleted automatically within about 3 days of the scan being created (at most 7, while a payment may still be completing). An account created at the payment step without signing in is deleted with it if it holds nothing else.

Text analysis, score and plan: for as long as your account exists; deleted promptly when you close it.

Refunded or disputed payment: access to the scan ends. Its photos, your questionnaire answers, the in-depth reading, the comparison and the AI assistant chat are deleted at once; the score, analysis and plan are kept as evidence in case the payment is contested and deleted 180 days later.

Free result by email: without the opt-in we do not keep your address after sending. With it, we keep your address and overall score until you unsubscribe; after that only your address and the dates of your consent and unsubscribe remain, so you are not emailed again. The record is deleted 12 months after the last email we sent you (or your last change), unless you have an account with the same address — then it is deleted with the account. Ask us and we delete it sooner.

Usage events: kept for 1 year, then deleted; when you delete your account, the account ID is removed from them. Consent records (your consent to photo processing, its link to your scan, your consent for the extra photos) are kept as long as the data they cover exists, and deleted with your account.

Gift vouchers: the name and message on the card are deleted 30 days after the code is redeemed, expires or is refunded. The purchase itself (code, amount, dates) is an accounting record we must keep for 10 years under Slovak law (Act No. 431/2002 Coll. on Accounting); if you delete your account, your email is removed from the gifts you bought.

You have the right of access, rectification, erasure (Art. 17), restriction, portability, objection, and to withdraw consent.

You can delete a scan or your whole account at any time from the Account page, or ask us at hello@miraskinlab.com.

You may also lodge a complaint with the supervisory authority: Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava 27 (dataprotection.gov.sk).

The photo analysis is fully automated — an AI model evaluates it, not a person. The model reads visible skin and hair care signals from the photo and combines them with your questionnaire answers to produce recommendations.

This is not a decision producing legal or similarly significant effects under GDPR Art. 22 — the result is an informational recommendation, not a decision about your rights. If you want human review of a result, or want to contest one, write to us.

The service is intended for people aged 18 and over. We do not knowingly process children's data. If we learn that we have, we delete it.

We use only strictly necessary cookies: your login session, a record that you agreed to photo processing (30 days), a cookie that ties a payment started without signing in to your scan (2 days), and two short-lived cookies that secure sign-in with Google. We use no analytics or marketing cookies, so we show no consent banner.

We measure traffic with Vercel Analytics, which uses no cookies and stores no identifier on your device. It records page views and funnel steps (e.g. “step 3 of 6”) without any identifier, only — never your photo, your email or your questionnaire answers.

We may update this policy. We will announce material changes on this page and, where needed, by email.