Effective 2026-09-08
Privacy Policy
Bella turns a short quiz and one selfie into personal colour and makeup recommendations, and shows those looks on your own face. That only works if you trust us with your photo. This policy explains, in plain language, what we collect, what we do with it, who else processes it and how you stay in control.
1. Who is responsible
The data controller for Bella (the website at bellabeauty.app and the Bella iOS app) is Omnio Group, MB, Sembos g. 7, LT-06283 Vilnius, Lithuania, company code 307600470. Write to us at support@bellabeauty.app for anything in this policy. We answer within 30 days.
2. What we collect
- Quiz answers. Your age range, goals, style, skill level, skin concerns, routine time and the occasions you dress for.
- Your selfie. The photo you take or choose. We use it for your colour analysis and to render looks on your face. We also keep the AI's written description of your colouring and features (for example "soft autumn, warm undertone, almond eyes").
- Generated previews. The images Bella creates from your selfie.
- Account. Email address and, if you sign in with Apple or Google, the name and email they share with us. We never see or store a password: sign-in is by a one-time email code or by Apple or Google.
- Purchases. Which plan you bought, when it renews or expires, and the App Store or Stripe transaction reference. Card numbers go directly to Apple or Stripe and never touch our servers.
- Usage and device data. Screens you visit, actions you take, app version, device model, operating system, language, approximate country from your IP address, and crash reports.
- Messages. Anything you send to support.
3. Your photo and face data
We treat your selfie as sensitive and handle it differently from everything else.
- No face recognition. Bella does not create faceprints, biometric templates or face geometry, and never tries to identify you or anyone else from a photo.
- AI processing by Google. Your selfie is sent to Google's Gemini API twice: once to read your colouring and features, and once for each look preview you request. Google processes the image only to return the result and, under the Gemini API terms for paid services, does not use it to train its models. No name, email or account identifier travels with the photo.
- Private storage in the EU. Photos and previews are stored in a private bucket in EU data centres. They are never public, never shown to other users and never used in marketing.
- Never for advertising or profiling. Face data is not used for advertising, sold, shared with data brokers or used to build a profile beyond your own beauty profile inside Bella.
- Automatic refusal. If the AI cannot produce a preview from a photo (for example when the safety system refuses it), we tell you and ask for a different photo. Nothing is generated.
- Your own photo only. Upload only photos of yourself. You must be at least 18 to use Bella; we do not knowingly process photos of minors and delete any we discover.
4. Why we use your data and on what legal basis
| Purpose | Data | Legal basis (GDPR art. 6) |
|---|---|---|
| Build your beauty profile and render looks | Quiz answers, selfie, generated previews | Consent you give before uploading a photo (art. 6(1)(a)); performance of our contract (art. 6(1)(b)) |
| Create and secure your account, sign you in | Email, sign-in provider details | Contract (art. 6(1)(b)) |
| Take payment and manage your subscription | Purchase and transaction data | Contract (art. 6(1)(b)); legal obligation for tax and accounting records (art. 6(1)(c)) |
| Send sign-in codes, receipts and service messages | Contract (art. 6(1)(b)) | |
| Remind you to finish a started analysis | Email you entered during the quiz | Legitimate interest (art. 6(1)(f)); opt out any time by emailing us |
| Understand how Bella is used and fix crashes | Usage, device and crash data | Legitimate interest (art. 6(1)(f)) |
| Measure advertising on the website | Cookie identifiers, page and conversion events | Legitimate interest (art. 6(1)(f)); you can object at any time (section 8) |
| Prevent abuse and enforce our terms | IP address, usage data, account data | Legitimate interest (art. 6(1)(f)) |
You can withdraw consent at any time by deleting your photo or your account (section 8). Withdrawing consent does not affect processing that already happened.
5. Who else processes your data
We run Bella on a small number of carefully chosen providers. Each one processes data only on our instructions, under a data processing agreement, and only for the purpose listed.
| Provider | What they do for Bella | Data involved | Where |
|---|---|---|---|
| Hetzner Online GmbH | Hosting for the Bella website, app services and database | All account data, in transit and at rest | Germany / Finland (EU) |
| Cloudflare, Inc. (R2 object storage, EU jurisdiction) | Private storage for photos and generated previews | Selfies, generated look previews, profile photos | EU data centres |
| Google LLC (Gemini API) | AI analysis of your selfie and generation of look previews | Your selfie and the look you chose; no name or email is sent | USA and EU; transfers covered by Standard Contractual Clauses and the EU-US Data Privacy Framework |
| Apple Inc. (App Store) and RevenueCat, Inc. | In-app subscriptions on iOS and subscription status | Apple transaction identifiers, product, renewal and expiry dates, an internal user id | USA; transfers covered by Standard Contractual Clauses |
| Stripe, Inc. / Stripe Payments Europe, Ltd. | Card payments and subscriptions bought on the website | Payment card details (never stored by us), email, billing country, amounts | Ireland and USA |
| Cloudflare, Inc. (Email Service) | Transactional email (sign-in codes, account and billing messages) | Email address and the message content | Global network; transfers covered by Standard Contractual Clauses |
| Resend, Inc. | Backup delivery for the same transactional email | Email address and the message content | USA; transfers covered by Standard Contractual Clauses |
| PostHog, Inc. (EU cloud) | Product analytics | Usage events, device and app version, an internal user id, email once signed in | EU data centres |
| Functional Software, Inc. (Sentry) | Crash and error reporting | Error details, device and app version, an internal user id | USA; transfers covered by Standard Contractual Clauses |
| Meta Platforms Ireland Ltd. (Meta Pixel, website only) | Measuring advertising on the website, on our legitimate interest (no cookie banner) — you can object at any time, see sections 8 and 9 of the privacy policy | Page views and conversion events, cookie identifiers | Ireland and USA |
We do not sell personal data and do not share it with advertisers or data brokers. We disclose data only when the law requires it, to protect our rights or users' safety, or as part of a merger or sale of the business, in which case this policy keeps applying.
6. International transfers
Our servers and photo storage are in the European Union. Some providers above are in the United States. Where data leaves the EEA we rely on the European Commission's Standard Contractual Clauses and, for providers certified under it, the EU-US Data Privacy Framework. You can ask us for a copy of the safeguards in place.
7. How long we keep things
- Quiz uploads without an account. If you take the quiz and upload a photo but do not create an account, the photo, the analysis and the preview are deleted automatically after 30 days.
- Photos and previews in your account. Kept while your account exists so your looks stay available. Replacing your photo replaces the analysis; deleting your account deletes every photo and preview immediately.
- Account and profile data. Kept while your account exists.
- Purchase records. Kept for as long as tax and accounting law requires after the transaction, even after account deletion.
- Usage, crash and server logs. Up to 12 months, then deleted or anonymised.
- Support messages. Up to 2 years after the conversation ends.
8. Your rights and controls
Under the GDPR you can, at any time:
- Access the personal data we hold about you and get a copy.
- Correct anything inaccurate.
- Delete your account and everything in it yourself: Settings → Delete account in the app, or Profile → Delete account on the web. It is immediate and permanent.
- Replace or remove your photo from Settings → Update photo & analysis.
- Restrict or object to processing based on legitimate interest.
- Port your data to another service in a machine-readable format.
- Withdraw consent for photo processing, and object to advertising measurement.
- Complain to a supervisory authority. Ours is the State Data Protection Inspectorate of Lithuania (vdai.lrv.lt); you may also contact the authority where you live.
To exercise a right that is not self-service, email support@bellabeauty.app from the address on your account. We may ask you to confirm your identity.
9. Cookies and analytics
The website uses strictly necessary cookies to keep you signed in and to remember your quiz progress. Product analytics (PostHog) runs on EU servers and uses a first-party identifier. The website also uses Meta Pixel to measure advertising; you can block it with your browser's tracking protection, a content blocker, or through Meta's ad settings. The iOS app contains no advertising trackers and does not request permission to track you across other apps.
10. Security
All traffic is encrypted with TLS. Photos are stored encrypted at rest in a private bucket and served through short-lived signed links. Access to production systems is limited to the people who operate Bella. No system is perfectly secure; if a breach affects your data we will tell you and the authorities as the law requires.
11. Children
Bella is for adults. You must be at least 18 years old to use it. We do not knowingly collect data from anyone younger, and we delete such data as soon as we learn of it. If you believe a minor has used Bella, contact us.
12. Changes to this policy
When we change this policy we update the date at the top. For material changes, such as a new purpose or a new provider that handles photos, we tell you in the app or by email before they take effect.
13. Contact
Omnio Group, MB
Sembos g. 7, LT-06283 Vilnius, Lithuania
support@bellabeauty.app · support@bellabeauty.app