Privacy Policy

Last updated: July 9, 2026

This Privacy Policy applies to GlowUp (the "App"), including the GlowUp iOS app, our website, and related services that link to this Privacy Policy. The App is operated by Aesthetic L.L.C-FZ ("we", "us"), with its registered address at Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E. Aesthetic L.L.C-FZ is the data controller. "GlowUp" is a product of Aesthetic L.L.C-FZ.

We are committed to protecting your privacy. This Privacy Policy explains what information we collect, how we use it, and who we share it with. If you do not agree with this policy, please do not use the App.

We do not sell your personal information, and we do not use your photos to train our AI models.

What information we collect

Photos you provide

To create your results, you provide photos (for example, from your camera or photo library). We process these photos to generate the images you request, as described in "How image generation works" below.

Account information

GlowUp creates an account automatically so your creations and subscription can sync to your device. This is an anonymous account identifier — you do not log in or provide an email address, and it is not designed to identify you personally. We retain this identifier so your creations and subscription stay associated with you, including if you reinstall the App.

Your creations

The images you generate are stored so you can access them in the App across sessions.

Usage and technical information

We collect limited information about how the App is used and the device you use it on — such as app version, device model, operating system version, language, and general interaction events. We use this to operate, secure, troubleshoot, and improve the App.

Subscription information

If you purchase a subscription, the purchase is handled by Apple through the App Store. We receive subscription status (for example, whether your subscription is active and which tier) from Apple and our subscription management provider so we can unlock the corresponding features. We do not receive your full payment card details.

How image generation works

GlowUp generates images using our own inference pipeline, running on our own infrastructure. To create your results, the photos you provide are processed by our models on our infrastructure. We do not send your photos to third-party AI providers to generate your results. Your photos and generated images are stored in our cloud storage (Google Firebase) so your creations remain available to you in the App.

Facial data

GlowUp is a creative photo tool. To generate certain results, our pipeline analyzes facial features in the photos you provide. We want to be clear about how this works:

This facial analysis happens on our own infrastructure, as part of generating the images you request.
We use it only to create the results you ask for — not to identify, verify, or recognize who you are, and not to build a profile of you.
We do not sell facial data, we do not use it to train our models, and we do not share it with third parties for their own purposes.
Where required by applicable law, we will ask for your consent before processing facial data, and you can withdraw it at any time.
You can delete your photos and associated data at any time using the Delete Account Data option in the App's settings (see "How long we keep your information").

How we use your information

We use the information we collect to:

Provide the App's core functionality — generating images from the photos you provide and saving your creations.
Create and maintain your account and sync your content and subscription.
Operate, secure, troubleshoot, and improve the App.
Process and manage subscriptions and unlock paid features.
Respond to your support requests.
Comply with legal obligations and enforce our Terms of Service.

Legal bases for processing (EEA / UK users)

If you are in the European Economic Area (EEA) or the United Kingdom, we process your personal information under the following legal bases:

Performance of a contract — to provide the App's core functionality, including generating images, saving your creations, and managing your subscription.
Legitimate interests — to secure, troubleshoot, analyze, and improve the App, and to prevent fraud and abuse, balanced against your rights and freedoms.
Consent — where we ask for it, such as access to your camera or photo library and, where required by law, the processing of facial data. You may withdraw your consent at any time.
Legal obligation — where processing is necessary to comply with applicable law.

How we share your information

We do not sell your personal information. We share information only with service providers who help us operate the App, and only as needed:

Cloud infrastructure (Google Firebase): hosts our backend and stores your account, photos, and generated images.
Apple: handles App Store purchases. Apple is the merchant of record for subscriptions.
Subscription management: our subscription management provider helps us validate and manage subscription status.
Analytics (Firebase Analytics and PostHog): help us understand in-app product usage so we can improve the App.
Attribution and measurement (AppsFlyer): helps us measure advertising performance. We do not send our own custom in-app events for this purpose; only purchase events (forwarded via our subscription provider) and the attribution SDK's standard events are processed.
For legal reasons: we may disclose information if required by law, or to protect the rights, safety, and security of our users, the public, or Aesthetic L.L.C-FZ.
Business transfers: if Aesthetic L.L.C-FZ is involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction.

Where we store your information

Your information is stored and processed on our cloud infrastructure (Google Firebase) and may be located outside the country where you live, including in the United States. These countries may have data-protection laws that differ from those in your country. We take reasonable steps to keep your information secure wherever it is processed.

How long we keep your information

We keep your account information, photos, and creations for as long as you maintain your account and as needed to provide the App. You can delete your photos and creations, or all of your data, at any time using the Delete Account Data option in the App's settings; when you do, the associated data is removed from our systems. We may retain limited information where necessary to comply with legal obligations or resolve disputes.

Your rights and choices

Depending on where you live, you may have the right to access, correct, delete, or export your personal information, and to object to or restrict certain processing. To exercise these rights, contact us at privacy@glowup.com. You can also delete all of your data at any time using the Delete Account Data option in the App's settings.

If you are in the EEA or the UK, you also have the right to lodge a complaint with your local data protection authority.

Notice for California residents

If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) provides you with certain rights regarding your personal information:

Right to know what personal information we collect, use, and disclose.
Right to delete the personal information we hold about you.
Right to correct inaccurate personal information.
Right to opt out of the "sale" or "sharing" of personal information. We do not sell your personal information for money. We use attribution and measurement providers to understand advertising performance; to the extent this is a "share" for cross-context behavioral advertising under California law, you can opt out by declining Apple's App Tracking Transparency (ATT) prompt.
Right to non-discrimination for exercising any of your rights.

The categories of personal information we collect are described in "What information we collect" above. To exercise your rights, contact us at privacy@glowup.com. You may also use an authorized agent to submit a request on your behalf.

Other U.S. state privacy rights

If you live in a U.S. state with a comprehensive privacy law (for example, Virginia, Colorado, Connecticut, Utah, or Texas), you have similar rights to access, correct, delete, and obtain a copy of your personal information, and to opt out of targeted advertising. To exercise these rights, contact us at the email above.

Security

We take reasonable technical and organizational measures to protect your information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Children's privacy

GlowUp is not directed at children under the age of 13 (or a higher age where required by local law). We do not knowingly collect personal information — including photos — from children. If you believe a child has provided us with personal information, please contact us at privacy@glowup.com and we will take appropriate steps.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, provide additional notice. Your continued use of the App after an update constitutes acceptance of the revised policy.

Contact

If you have questions, comments, or requests regarding this Privacy Policy, please contact us at privacy@glowup.com.