Biometric Data Policy

This policy describes how OptiFlow (2, rue Jean Engling, L-1466 Dommeldange, Luxembourg) handles biometric information in the iOS app Blish ("the App"), including under the Illinois Biometric Information Privacy Act (740 ILCS 14), the Texas Capture or Use of Biometric Identifier Act, Washington RCW 19.375 and the Colorado Privacy Act. It supplements the Privacy Policy – Blish.

1. What We Mean by Biometric Data

The App can analyse the geometry of a face — points and outlines of the lips, eyes, brows and cheeks — to find where makeup is. This happens in three places, and only after you agree:

1. Decode: in photos and screenshots you choose to analyse (of yourself, or of people who agreed).
2. On Me and the colour profile: in the live front camera, to try colours on your own face and to estimate your skin's depth and undertone.
3. Styling: in a photo of yourself you choose, to show looks and single changes (lips, liner, blush, eyes) on it.

The App does not identify or recognise people, and it does not create face templates for identification.

Illinois: the App currently does not analyse face geometry for users in Illinois. There, it finds lips and eyes by colour, and you place or correct each area with a tap; On Me and Styling are not offered.

2. What We Do With It

• The analysis runs only on your iPhone. The face geometry exists only in your iPhone's memory during the analysis and is discarded immediately afterwards.
• It is never stored — not on your iPhone, not in backups, logs, crash reports or analytics — and never sent to us or anyone else.
• What leaves your iPhone after a decode are measured colour values and numbers (for example a lip colour in CIELAB), which cannot recreate a face.
• We do not sell, lease, trade or otherwise profit from biometric data, and we do not disclose it — we never possess it.

3. Retention and Destruction Schedule

Because face geometry is discarded the moment an analysis ends, there is nothing to retain: the retention period is the duration of a single analysis (seconds), or of a Styling session. Destruction happens automatically when the analysis completes, when you leave On Me or Styling, when the App goes to the background, or when the App closes — whichever comes first. We will never keep biometric data longer than that, and in no case longer than three years after your last interaction with the App.

4. Consent

Before the first analysis the App shows a dedicated screen that explains what is analysed, why and for how long, links to this policy, and asks you to confirm that you only analyse photos of yourself or of people who agreed. You consent by ticking the box and tapping "I agree". We keep a receipt of your choice (time, text version, language, storefront country) as evidence; the receipt contains no biometric data. Without consent the App still works: it finds lips and eyes by colour, and your colour profile comes from a short quiz.

5. Withdrawing Consent

In the App: Settings → Face analysis → Withdraw consent. Face analysis stops at once, and a receipt of the withdrawal is recorded. You can turn it on again at any time.

6. Security

Processing is local to your iPhone. The measured values sent to our server travel over TLS, and our server rejects any request that contains image or face-geometry data. We can switch face analysis off remotely, by country or US state, without an app update.