Privacy Policy

I. Introduction

Denali Digital Bilişim Limited Şirketi ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how information may be collected, accessed, processed, used, stored, disclosed, and deleted when you download, install, access, or use the Beam Tan – UV Index, SPF mobile application ("App").

Beam Tan provides sun-awareness and personal care tools, including:

• Tanning Timer: Provides estimated sun-exposure guidance based on factors such as the user's location, local UV Index, selected skin-related information, time of day, and user preferences.
• Tan Analyzer: Allows the user to submit a photograph to receive an automated analysis of visible skin-tone characteristics.
• Location-Based UV Meter: Displays estimated hourly UV Index information for the user's selected or current location.
• Sun Lotion Routine: Allows the user to create reminders and routines for applying or reapplying sunscreen or sun lotion.

The App is intended to provide general informational, wellness, and personal-care assistance only.

The App is not a medical device and does not diagnose, prevent, monitor, treat, or cure any disease or medical condition. It does not provide medical advice and must not be used as a substitute for professional medical judgment.

For the purposes of applicable data-protection legislation, including the General Data Protection Regulation ("GDPR"), Denali Digital Bilişim Limited Şirketi acts as the data controller for personal information that we directly collect and control, unless otherwise stated.

By accessing or using the App, you acknowledge that you have read and understood this Privacy Policy.

II. Information We Process

The information processed by the App depends on the features you use, the permissions you grant, your device settings, and the services integrated into the App.

1. Location Information

The App may request access to your location to provide:

• Local and hourly UV Index information.
• Location-based weather and sunlight conditions.
• Tanning Timer estimates.
• Time-zone-appropriate recommendations and reminders.
• Location-relevant sun protection information.

Depending on the permission you grant, the App may process:

• Precise geographic location.
• Approximate geographic location.
• Latitude and longitude.
• City, region, and country.
• Device time zone.
• Local date and time.
• Location permission status.
• A location manually searched for or selected by you.

Location information is used only where necessary to provide location-based UV, sunlight, timing, and reminder functionality.

The App does not use your location to determine your home address, workplace, personal identity, or travel history.

Unless a feature expressly requires a saved location, location coordinates are processed only for the period reasonably necessary to retrieve the requested UV or environmental information.

We do not sell precise location information.

We do not use precise location information for targeted advertising.

You may deny or revoke location permission through your device settings. You may also be able to enter or select a location manually.

Disabling location access may prevent automatic local UV measurements and location-based Tanning Timer estimates from functioning.

2. UV Index and Environmental Information

To provide location-based sun information, the App may retrieve information from third-party weather, UV, or environmental-data providers.

This information may include:

• Current UV Index.
• Hourly UV Index forecast.
• Maximum daily UV Index.
• Sunrise and sunset times.
• Cloud cover.
• Temperature.
• Weather conditions.
• Geographic area associated with the forecast.
• Date and time of the forecast.
• Data-provider timestamps.
• Other environmental information used by the relevant feature.

Environmental data may be combined with your selected settings to provide general recommendations or estimates.

UV and weather information is supplied or calculated by third parties and may be delayed, incomplete, approximate, or inaccurate.

The App does not independently measure ultraviolet radiation through the device itself unless expressly stated within the App.

3. Tanning Timer Information

When you use the Tanning Timer, the App may process information such as:

• Current or selected location.
• Local UV Index.
• Time of day.
• Selected date.
• Visible skin-tone category or user-selected skin profile.
• Previous Tan Analyzer result, if you choose to use it.
• Selected tanning or outdoor-session preferences.
• Estimated exposure duration.
• Timer start, pause, completion, or cancellation status.
• Notification and reminder settings.
• Previous timer settings or history, where available.

This information is used to generate an estimated timer or general sun-awareness recommendation.

A Tanning Timer result is an automated estimate and does not mean that sun exposure is safe.

No duration of intentional ultraviolet exposure can be guaranteed to prevent sunburn, skin damage, premature skin aging, eye damage, or skin cancer.

Individual reactions to sunlight may vary based on factors the App cannot fully determine, including:

• Medical history.
• Medications.
• Skin conditions.
• Genetic factors.
• Previous sun exposure.
• Altitude.
• Reflective surfaces.
• Cloud conditions.
• Sunscreen application.
• Sweating or swimming.
• Clothing.
• Accuracy of third-party UV data.

You must stop sun exposure immediately if you experience redness, pain, burning, unusual warmth, irritation, dizziness, nausea, weakness, or any other concerning symptom.

4. Tan Analyzer Photographs

The Tan Analyzer allows you to voluntarily select or capture a photograph containing your face or visible skin.

The photograph may include:

• Your face.
• Visible skin areas.
• Skin-tone characteristics.
• Lighting and background information.
• Image metadata provided by the device or file.
• Image dimensions, format, and orientation.

The photograph is processed solely to provide the Tan Analyzer result requested by you.

The App does not require users to submit a government identification photograph or any other identity document.

You should submit only a photograph of yourself or a photograph that you are legally authorized to use.

5. Face Data

For purposes of this Privacy Policy, "Face Data" means information derived from or related to the visible face contained in a photograph submitted to the Tan Analyzer.

Depending on the technical implementation of the analysis, temporary processing may involve:

• Detecting whether a visible face or suitable skin area is present.
• Locating visible facial or skin regions.
• Evaluating apparent skin-tone characteristics.
• Evaluating brightness, contrast, shadows, or color balance.
• Separating relevant skin pixels from the background.
• Producing a general skin-tone or tanning-related result.

Purpose of Face Data Processing

Face Data is used exclusively to provide the user-requested Tan Analyzer result.

It is not used for:

• Identity verification.
• Facial recognition.
• Authentication.
• Surveillance.
• Tracking a person across services.
• Determining a person's name or identity.
• Matching the user against another photograph.
• Creating a biometric identifier.
• Advertising.
• Marketing profiling.
• Credit, insurance, employment, or eligibility decisions.
• Law-enforcement identification.
• Training artificial intelligence models.

No Facial Recognition or Biometric Identification

The App does not perform facial recognition.

The App does not determine or verify who a person is.

The App does not create, extract, store, or maintain:

• Face templates.
• Faceprints.
• Facial embeddings used for identity matching.
• Biometric identity profiles.
• Facial geometry records used for identification.
• Databases of faces.
• Lists associating faces with names, accounts, or identities.

The Tan Analyzer evaluates only the visible color-related characteristics necessary to provide the requested skin-tone analysis.

Face Photograph Storage

Face photographs submitted through the Tan Analyzer are not permanently stored in any Company database.

Face photographs are not added to a user profile.

Face photographs are not retained in a permanent cloud-storage archive.

Face photographs are not stored for future comparisons.

Face photographs are not used to build a history of the user's facial appearance.

Face photographs are not used to identify the user in later sessions.

Where processing occurs on the device, the photograph is processed temporarily by the App and is discarded after the analysis is completed or canceled.

Where temporary server-side processing is technically required, the photograph is transmitted securely, held only in temporary processing memory or temporary storage for the minimum period required to complete the requested analysis, and automatically deleted after the analysis is completed, fails, or is canceled.

The photograph is not intentionally retained in production databases, analytics systems, advertising platforms, customer profiles, or permanent backups.

Face Data Retention

The face photograph and temporary Face Data derived directly from it are retained only for the duration necessary to complete the Tan Analyzer operation.

They are deleted immediately after the analysis result has been generated or the processing request has failed or been canceled, subject only to unavoidable short-lived technical caching required to complete transmission or deletion.

We do not maintain a permanent retention period for Face Data because Face Data is not retained after the requested analysis.

The non-biometric analysis result, such as a general skin-tone category, may be displayed to the user or saved if the user chooses to save it.

A saved result does not contain the original face photograph, a faceprint, a facial template, or information capable of identifying the user by their face.

No AI Training

Neither the submitted photograph nor any Face Data derived from it is used to train, retrain, fine-tune, evaluate, benchmark, or improve any artificial intelligence, machine-learning, facial-analysis, image-generation, or recognition model.

The photograph is not added to an AI training dataset.

The photograph is not reviewed for general AI research.

The photograph is not reused to improve future Tan Analyzer results.

Any service provider involved in temporary image processing is contractually restricted from using the image or Face Data for its own model training, advertising, profiling, or unrelated purposes.

No Sale or Advertising Use

We do not sell, rent, license, trade, or monetize face photographs or Face Data.

We do not share face photographs or Face Data with advertising networks, data brokers, social media platforms, or marketing companies.

Face Data is not used for personalized advertising or cross-app tracking.

Third-Party Processing

If a technical service provider is used to perform the requested image analysis, it may receive the photograph only as necessary to complete that specific operation.

Such a provider acts on our instructions and is not permitted to:

• Retain the photograph permanently.
• Use it for advertising.
• Use it to identify the user.
• Sell or disclose it.
• Add it to a facial-recognition database.
• Use it for AI or machine-learning training.
• Use it for any purpose unrelated to the requested analysis.

If the technical implementation or service providers change in a way that materially affects Face Data processing, we will update this Privacy Policy before the new processing begins where required by applicable law.

User Control

Submitting a photograph to the Tan Analyzer is optional.

You may use other App features without using the Tan Analyzer, subject to the functionality available in the relevant version of the App.

You can cancel the image selection process before submitting the photograph.

You can deny or revoke camera and photo-library permissions through your device settings.

Revoking these permissions may prevent the Tan Analyzer from functioning but will not prevent the use of unrelated App features.

6. Camera and Photo Library Access

The App may request:

• Camera permission.
• Photo-library permission.
• Access to a specific photograph selected through the device picker.

Camera access is used only when you choose to capture a photograph for the Tan Analyzer.

Photo-library access is used only when you choose to select a photograph.

Where supported by the operating system, the App requests access only to the specific photograph selected by you rather than unrestricted access to your full photo library.

The App does not continuously access the camera.

The App does not record video through the Tan Analyzer.

The App does not access unrelated photographs without your action and permission.

7. Skin-Tone Analysis Results

The Tan Analyzer may generate a result describing visible skin-tone characteristics.

A result may include:

• A general skin-tone range.
• A visible undertone estimate.
• An apparent tanning-stage description.
• General sun-awareness information.
• Suggested sunscreen or routine categories.
• A confidence or quality indicator.
• A notice that lighting may affect the result.

The analysis is based on the photograph submitted and may be affected by:

• Camera quality.
• Lighting.
• Shadows.
• Makeup.
• Filters.
• Image editing.
• White balance.
• Screen capture.
• Background colors.
• Sunburn.
• Temporary redness.
• The visible area of skin.

The result is an automated cosmetic and informational estimate.

It is not a medical assessment of skin type, skin health, melanoma risk, cancer risk, sunburn risk, vitamin D status, or any dermatological condition.

The App does not infer or determine race, ethnicity, health status, identity, or genetic characteristics from the submitted photograph.

8. Sun Lotion Routine Information

When you create a sunscreen or sun-lotion routine, the App may process:

• Routine name.
• Product name entered by you.
• SPF value entered or selected by you.
• Application time.
• Reapplication interval.
• Reminder schedule.
• Notification status.
• Completion status.
• Notes voluntarily entered by you.
• Routine history.
• Location or UV information associated with the routine, where selected.

This information is used to create and manage the routine requested by you.

The App does not verify whether a sunscreen product is authentic, unexpired, properly applied, water-resistant, broad-spectrum, or suitable for you.

Routine reminders do not guarantee adequate sun protection.

You remain responsible for following the product label and advice from qualified healthcare professionals.

9. Notification Information

The App may request permission to send notifications for:

• Sunscreen application reminders.
• Sunscreen reapplication reminders.
• Tanning Timer completion.
• High UV Index alerts.
• Routine reminders.
• Product or service notices.
• Account or subscription notices.

The App may process:

• Notification permission status.
• Notification token or identifier.
• Selected reminder times.
• Notification delivery status.
• Whether a notification was opened.
• Device and operating-system information required for delivery.

You may disable notifications through your device settings.

Disabling notifications may prevent timers, high-UV alerts, or sunscreen reminders from being delivered.

10. Account Information

If the App requires or optionally offers account registration, we may process:

• Name.
• Email address.
• Account identifier.
• Authentication-provider identifier.
• Account creation date.
• Subscription status.
• Saved preferences.
• Saved routines.
• Saved non-biometric analysis results.
• Account settings.
• Account deletion requests.

If third-party authentication is offered, such as Sign in with Apple or Google Sign-In, we receive only the information made available according to your settings and the applicable provider's authorization process.

The App may also be usable without an account. Where no account is required, certain information may be stored only on your device.

11. Technical and Diagnostic Information

When you use the App, we or our technical service providers may automatically process limited technical information necessary to maintain, secure, and improve the App.

This information may include:

• Device type and model.
• Operating-system type and version.
• App version.
• Device language.
• General time-zone setting.
• Internet connection type.
• IP address.
• Crash reports.
• Error logs.
• Performance information.
• UV-data retrieval errors.
• Location-permission errors.
• Image-processing errors.
• Notification-delivery errors.
• Session start and end times.
• Anonymous or pseudonymous installation identifier.
• General feature-interaction information.

Diagnostic systems are not intended to receive or store submitted face photographs.

We seek to prevent face photographs and Face Data from being included in crash logs, analytics events, or diagnostic reports.

We use technical information to:

• Detect and resolve technical problems.
• Improve App reliability.
• Improve UV-data retrieval.
• Improve image-processing performance.
• Monitor system availability.
• Prevent fraud, misuse, and security incidents.
• Understand which features require improvement.

Where possible, technical information is processed in aggregated, anonymized, or pseudonymized form.

12. Usage and Analytics Information

If analytics technologies are used, we may process information about how users interact with the App, including:

• Features opened.
• Tanning Timer usage.
• UV Meter usage.
• Routine creation and completion.
• Whether a Tan Analyzer operation was completed or failed.
• General screen interactions.
• Subscription and purchase events.
• Errors and crashes.
• General retention and engagement information.

Analytics events must not contain:

• The submitted face photograph.
• Face Data.
• Faceprints.
• Facial templates.
• Precise skin images.
• Biometric identifiers.

Analytics information may be used to improve the App, measure feature performance, diagnose problems, and understand general usage trends.

13. Contact and Support Information

If you contact us by email or through a support form, we may process:

• Your name.
• Your email address.
• The content of your message.
• Screenshots or files you voluntarily provide.
• Device and App-version information.
• Other information included in your request.

We use this information to:

• Respond to your inquiry.
• Investigate technical problems.
• Process privacy requests.
• Provide customer support.
• Improve the App.

Please do not send face photographs, medical records, identity documents, or other sensitive information to customer support unless specifically requested and strictly necessary.

Any photograph voluntarily sent to customer support is handled separately from the Tan Analyzer's automatic deletion process and may remain in the support correspondence until the request is resolved. You may request its deletion by contacting us.

14. Purchase and Subscription Information

The App may offer subscriptions, premium functionality, or in-app purchases.

Payments are processed by the platform through which you obtained the App, such as Apple's App Store or Google Play.

We do not directly receive or store your complete credit card or debit card information.

We may receive limited transaction information such as:

• Product or subscription identifier.
• Purchase status.
• Subscription status.
• Expiration or renewal date.
• Country or storefront.
• Transaction identifier.
• Whether a purchase was restored.
• Whether a trial or promotional offer was activated.

This information is used to:

• Unlock purchased features.
• Verify subscription status.
• Restore purchases.
• Prevent fraudulent transactions.
• Provide purchase-related support.

Payment processing is subject to the privacy policy and terms of the applicable app marketplace.

III. Information We Do Not Collect or Retain

Unless expressly described in this Privacy Policy and required for a feature selected by you, the App is not designed to collect or retain:

• Permanent copies of face photographs submitted to the Tan Analyzer.
• Faceprints or biometric face templates.
• Facial-recognition identifiers.
• Fingerprints.
• Voiceprints.
• Contacts or address-book information.
• Private messages.
• Call history.
• Microphone recordings.
• Government identification numbers.
• Complete payment-card details.
• Medical records.
• Genetic information.
• Passwords for third-party services.

The App does not use the submitted photograph to identify you.

The App does not search for your identity online.

The App does not compare your face against other users, public figures, databases, or social-media accounts.

IV. Purposes of Processing

We may process information for the following purposes:

1. Providing Location-Based UV Information

We process location and environmental information to:

• Retrieve local UV Index data.
• Display current and hourly UV estimates.
• Provide local sunrise, sunset, or related environmental information.
• Generate location-aware timer estimates.
• Send optional high-UV notifications.

2. Providing the Tanning Timer

We process selected settings, UV information, and other inputs to:

• Calculate an estimated timer.
• Start and manage the timer.
• Notify the user when the timer ends.
• Display general sun-awareness information.
• Save timer preferences where requested.

3. Providing the Tan Analyzer

We temporarily process the photograph and relevant Face Data to:

• Identify a suitable visible skin area.
• Estimate visible skin-tone characteristics.
• Produce the requested result.
• Detect when the image cannot be analyzed reliably.

The image and Face Data are deleted after the requested processing and are not used for unrelated purposes.

4. Providing Sun Lotion Routines

We process routine and reminder settings to:

• Create sunscreen application schedules.
• Send optional reminders.
• Track routine completion where requested.
• Save user-selected product and timing information.

5. Improving Reliability and Performance

We may use technical, diagnostic, and analytics information to:

• Resolve crashes and errors.
• Improve location and UV-data retrieval.
• Improve image-processing reliability.
• Improve notification delivery.
• Monitor system availability.
• Test new functionality.
• Improve device and operating-system compatibility.

6. Security and Fraud Prevention

We may process limited information to:

• Protect the App and our systems.
• Detect fraudulent purchases.
• Prevent unauthorized access.
• Investigate abuse or prohibited activity.
• Enforce our Terms of Use.
• Comply with legal obligations.

7. Customer Support

We process contact and support information to respond to questions, investigate reported problems, and complete privacy-related requests.

8. Legal Compliance

We may process or retain information where necessary to:

• Comply with applicable laws.
• Respond to valid legal requests.
• Establish, exercise, or defend legal claims.
• Meet accounting, taxation, and audit requirements.
• Protect users, the Company, or third parties.

V. Legal Bases for Processing

Where the GDPR or similar legislation applies, we rely on one or more of the following legal bases:

Performance of a Contract

We process feature settings, routines, subscriptions, and other functional information to provide the services requested by you.

Consent

We rely on your consent where required, including for:

• Precise or approximate location.
• Camera access.
• Photo-library access.
• Processing a photograph through the Tan Analyzer.
• Notifications.
• Optional analytics or tracking technologies.
• Other device permissions.

You may withdraw consent through the App or your device settings.

Withdrawal does not affect processing that occurred before consent was withdrawn.

Because face photographs submitted to the Tan Analyzer are deleted after processing, we may no longer possess a photograph after the requested analysis has been completed.

Legitimate Interests

We may process limited technical and diagnostic information based on our legitimate interests in:

• Operating and improving the App.
• Maintaining security.
• Diagnosing technical problems.
• Preventing fraud.
• Providing customer support.

We balance these interests against your privacy rights.

Legal Obligations

We may process information where necessary to comply with applicable legal, regulatory, accounting, taxation, or consumer-protection obligations.

VI. Face Data Processing Summary

For clarity, our practices concerning Face Data are summarized below:

What Face Data is collected or processed?
A user-selected photograph may be temporarily processed to locate visible skin regions and evaluate apparent color-related characteristics necessary to produce a skin-tone analysis.

Why is it processed?
Only to provide the Tan Analyzer result requested by the user.

Is facial recognition performed?
No.

Is a biometric identifier created?
No.

Is the user's identity determined?
No.

Is the photograph stored in a permanent database?
No.

How long is the photograph retained?
Only for the temporary duration required to complete, cancel, or fail the requested analysis. It is deleted immediately afterward, subject only to short-lived technical transmission or deletion processes.

Is Face Data used for AI training?
No. Neither photographs nor derived Face Data are used to train, fine-tune, evaluate, benchmark, or improve AI or machine-learning models.

Is Face Data sold?
No.

Is Face Data used for advertising?
No.

Is Face Data shared with data brokers or social networks?
No.

Can a temporary processor access the photograph?
Only if technically necessary to complete the user-requested analysis and only under restrictions prohibiting retention, identification, advertising, sale, unrelated use, and model training.

Is the result a medical diagnosis?
No. The result is a cosmetic and informational estimate based on visible image characteristics.

VII. Sharing of Information

We do not rent or sell your personal information.

We may share limited information with service providers that help us operate, maintain, analyze, secure, or monetize the App.

These providers may include:

• Cloud-hosting providers.
• UV, weather, and environmental-data providers.
• Mapping or geolocation providers.
• Temporary image-processing providers.
• Notification-delivery providers.
• Crash-reporting providers.
• App analytics providers.
• Subscription-management providers.
• Authentication providers.
• Customer-support providers.
• Apple, Google, or other app-marketplace operators.
• Security and fraud-prevention providers.

Service providers may process information only for the purposes of delivering their contracted services, subject to contractual and legal privacy obligations.

We seek to limit information transmitted to service providers to what is necessary for the relevant function.

Face Data Restrictions

Any service provider that temporarily processes a Tan Analyzer photograph is prohibited from:

• Permanently retaining it.
• Using it for facial recognition.
• Associating it with an identity.
• Selling it.
• Using it for advertising.
• Sharing it with data brokers.
• Using it for AI training.
• Reusing it for another customer.
• Using it for an unrelated purpose.

Environmental Data Providers

When the App requests UV or weather data, the relevant provider may receive:

• Geographic coordinates or a selected location.
• Date and time.
• Technical request information.
• IP address.
• Device or application identifiers where technically required.

Such processing is also governed by the relevant provider's privacy practices.

App Marketplaces

Apple or Google may process information relating to:

• App downloads.
• Purchases.
• Subscriptions.
• Refunds.
• Device eligibility.
• Marketplace account activity.

Such processing is controlled by the applicable platform and governed by its own privacy policy.

Legal Disclosures

We may disclose information when we reasonably believe disclosure is necessary to:

• Comply with applicable law, regulation, legal process, or government request.
• Protect the rights and safety of users.
• Investigate fraud or security incidents.
• Enforce our agreements.
• Establish, exercise, or defend legal claims.

Because Tan Analyzer photographs and Face Data are not permanently retained, we ordinarily cannot disclose them after the temporary processing has ended.

Business Transfers

If Denali Digital Bilişim Limited Şirketi is involved in a merger, acquisition, restructuring, financing, bankruptcy, or sale of assets, information may be transferred as part of that transaction.

Face photographs and Face Data that have already been deleted cannot form part of such a transfer.

Where required, we will notify users of material changes affecting the control or use of their personal information.

VIII. Health, Wellness, and Sun-Safety Information

The App provides general informational and wellness features.

It is not intended to:

• Diagnose a skin condition.
• Assess skin cancer or melanoma risk.
• Detect sun damage.
• Determine a medically safe tanning duration.
• Recommend treatment.
• Replace a dermatologist or healthcare professional.
• Guarantee protection from ultraviolet radiation.
• Determine whether a sunscreen product is medically appropriate.
• Provide emergency warnings.

UV exposure can cause harm even before visible burning occurs.

A tan does not mean that the skin is protected from further UV damage.

The App's estimates may not account for all personal and environmental risk factors.

People who have:

• A history of skin cancer.
• Unusual or changing moles.
• Photosensitivity.
• Skin conditions.
• A history of severe sunburn.
• Medications that increase sun sensitivity.
• Recent cosmetic or dermatological procedures.
• Concerns about sun exposure.

should consult a qualified healthcare professional before intentionally increasing sun exposure.

Users should follow applicable public-health guidance, product labeling, and professional medical advice.

IX. International Data Transfers

We may provide the App to users in multiple countries.

Some service providers may process information in countries other than the country in which you live. Those countries may have different data-protection laws.

Where required, we use appropriate safeguards for international transfers, which may include:

• Adequacy decisions.
• Standard contractual clauses.
• Contractual data-protection requirements.
• Technical and organizational security measures.
• Data minimization.
• Pseudonymization.

If a photograph must be transmitted for temporary processing, it may be processed in another country depending on the location of the relevant service provider.

Regardless of processing location, the restrictions described in the Face Data sections of this Privacy Policy continue to apply.

X. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Face Photographs and Face Data

Tan Analyzer photographs and temporary Face Data are not permanently retained.

They are deleted immediately after:

• The requested analysis is completed.
• The analysis fails.
• The user cancels processing.

They are not stored in a permanent database, user profile, training dataset, advertising system, or permanent backup.

Saved Analysis Results

If the App allows you to save a general skin-tone result, that result may remain:

• On your device.
• In your account, where synchronization is offered.
• Until you delete the result.
• Until you delete your account.
• Until the applicable retention period expires.

A saved result does not include the original photograph, face template, or biometric identifier.

Location Information

Location data may be processed temporarily to retrieve UV and environmental information.

Saved locations or preferences may remain until:

• You delete them.
• You clear the App's data.
• You delete your account.
• The information is no longer required to provide the service.

We do not intend to maintain a continuous history of precise user movements.

Routines and Preferences

Sun Lotion Routines, reminder settings, selected locations, timer preferences, and similar settings may remain until:

• You modify or delete them.
• You clear the App's data.
• You uninstall the App.
• You delete your account.

Diagnostic Information

Crash reports and technical logs may be retained for a limited period necessary to investigate problems, improve the App, and maintain security.

Diagnostic records are not intended to contain face photographs or Face Data.

Support Communications

Support emails and related communications may be retained while your request is being handled and afterward where reasonably necessary for legal, security, or record-keeping purposes.

Purchase Records

Limited transaction information may be retained for the duration required to provide purchased services and comply with taxation, accounting, fraud-prevention, and legal obligations.

Information that is no longer required will be deleted, anonymized, or securely isolated.

XI. Your Privacy Rights

Depending on your location, you may have the right to:

• Request access to your personal information.
• Obtain a copy of your personal information.
• Request correction of inaccurate information.
• Request deletion of your personal information.
• Restrict certain processing.
• Object to certain processing.
• Withdraw consent.
• Request data portability.
• Opt out of direct marketing.
• File a complaint with a competent data-protection authority.

To exercise your rights, contact:

Email: support@denalidigital.co

Your request should clearly describe:

• The right you wish to exercise.
• The email address associated with your account, if applicable.
• Enough information for us to identify relevant records.
• Any additional details needed to understand your request.

We may request additional information where reasonably necessary to verify your identity and protect information from unauthorized access.

Information provided for identity verification will be used only to process and verify the request, unless otherwise required by law.

We will respond within the period required by applicable law.

Because Tan Analyzer photographs and Face Data are deleted immediately after temporary processing, we may not possess such data by the time we receive an access or deletion request.

Where information is stored only on your device and is not accessible to us, you may need to delete the relevant result, routine, or preference; clear the App's storage; revoke a permission; or uninstall the App.

XII. California Privacy Notice

This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), applies to our processing.

California residents may have the right to:

• Know the categories of personal information collected.
• Know the sources from which personal information is collected.
• Know the purposes for collecting, using, or disclosing personal information.
• Know the categories of third parties to whom information is disclosed.
• Request access to specific pieces of personal information.
• Request deletion of personal information.
• Request correction of inaccurate personal information.
• Opt out of the sale or sharing of personal information.
• Limit certain uses of sensitive personal information.
• Exercise privacy rights without unlawful discrimination.

Categories of Information

Depending on the features used, we may process:

• Identifiers, such as an email address.
• Commercial information, such as subscription status.
• Internet or electronic activity information.
• Device and technical information.
• Precise or approximate geolocation.
• Sun-care routines and preferences.
• Temporarily processed photographs.
• Temporarily processed visible facial and skin information.
• Saved non-biometric skin-tone results.
• Support communications.

Sensitive Personal Information

Location information and photographs containing a person's face may be treated as sensitive information under certain laws.

We use such information only to provide the feature requested by the user and for the limited purposes described in this Privacy Policy.

We do not use or disclose sensitive personal information to infer unrelated characteristics about users.

Sale and Sharing

We do not sell personal information in exchange for money.

We do not sell or share Face Data for cross-context behavioral advertising.

We do not knowingly sell or share personal information belonging to individuals under 16 years of age.

Submitting a Request

California residents may submit a privacy request by contacting:

support@denalidigital.co

Please write "California Privacy Request" in the email subject and describe the request in sufficient detail.

We may need to verify your identity before completing a request.

An authorized agent may submit a request on your behalf. We may require evidence of authorization and may also ask you to confirm the request directly.

We will not unlawfully discriminate against you for exercising an applicable privacy right.

However, deleting or restricting information required for a feature may prevent that feature from operating.

XIII. Managing App Permissions

You can manage App permissions through your device settings.

Depending on your device and the features you use, permissions may include:

• Precise location.
• Approximate location.
• Camera.
• Photo library.
• Notifications.
• Background processing.
• Network access.
• Tracking permission, if applicable.

Disabling a permission may affect related functionality.

For example:

• Disabling location may prevent local UV information from being displayed automatically.
• Disabling camera access may prevent you from capturing a Tan Analyzer photograph.
• Disabling photo-library access may prevent you from selecting an existing photograph.
• Disabling notifications may prevent sunscreen reminders, timer alerts, or UV alerts.
• Disabling background processing may delay scheduled reminders.

The exact names and locations of settings vary by device and operating-system version.

XIV. Security

We use reasonable technical and organizational measures designed to protect personal information against:

• Unauthorized access.
• Accidental loss.
• Misuse.
• Disclosure.
• Alteration.
• Destruction.

These measures may include:

• Data minimization.
• Encryption in transit.
• Restricted system access.
• Temporary image-processing controls.
• Automated image deletion.
• Service-provider restrictions.
• Security monitoring.
• Secure development practices.
• Regular software and dependency updates.

Face photographs are processed using temporary workflows designed to prevent permanent retention.

We seek to ensure that submitted photographs are not included in analytics, logs, permanent backups, or AI training systems.

No application, transmission method, or storage system can be guaranteed to be completely secure.

If we become aware of a personal-data breach that requires notification under applicable law, we will notify affected individuals and competent authorities as legally required.

Security concerns may be reported to:

support@denalidigital.co

XV. Children's Privacy

The App is not directed to children under the minimum age required to independently consent to data processing in their country.

Children and adolescents may be especially vulnerable to ultraviolet exposure and should not use the App to increase intentional sun exposure without the involvement of a parent, guardian, or qualified healthcare professional.

We do not knowingly collect personal information or face photographs from children without the authorization required by applicable law.

Parents or guardians who believe that a child has submitted personal information or a photograph may contact:

support@denalidigital.co

If we determine that personal information was collected from a child without the required authorization, we will take reasonable steps to delete it.

Because Tan Analyzer photographs are deleted immediately after temporary processing, the photograph may already have been deleted when a request is received.

XVI. Third-Party Links and Services

The App may contain links to third-party websites, weather providers, mapping services, marketplaces, healthcare information, or other services.

When you access a third-party service, that third party may process information according to its own privacy policy.

We do not control and are not responsible for:

• Third-party privacy practices.
• Third-party security.
• Environmental-data accuracy.
• UV forecast accuracy.
• Product claims.
• Sunscreen manufacturer instructions.
• Content or availability of third-party services.

Your use of third-party services is subject to their respective terms and privacy policies.

XVII. Changes to This Privacy Policy

We may update this Privacy Policy when:

• App features change.
• New permissions are introduced.
• UV or weather providers change.
• Image-processing technology changes.
• Service providers change.
• Legal requirements change.
• Our information-processing practices change.

We will not materially expand the use or retention of Face Data without updating this Privacy Policy and obtaining any consent required by applicable law.

When we make material changes, we may notify users through:

• An updated "Last Updated" date.
• A notice within the App.
• An App Store or Google Play update description.
• Email, where appropriate and available.

Your continued use of the App after an updated Privacy Policy becomes effective means that the updated policy applies to your subsequent use of the App, to the extent permitted by law.

XVIII. Contact Us

For questions, concerns, complaints, privacy requests, Face Data inquiries, or security concerns, contact:

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