Privacy Policy
Last updated: October 2025
PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY. WHEN YOU USE THE LUVRA APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY.
IINTRODUCTION
Zintop LLC ("we," "us," or "our") takes your privacy seriously. This Privacy Policy ("Privacy Policy") explains our data protection policy and describes the types of information we may process when you install and/or use "Luvra" software application for mobile devices (the "App," "our App").
When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.
Privacy-First Design: Luvra is designed with privacy as a core principle. Unlike traditional apps that collect and store user data on remote servers, Luvra stores all your personal information locally on your device. This means you maintain complete control over your data at all times.
This Privacy Policy applies to all users of the App regardless of where they are located. For users located in specific jurisdictions (including the European Union, United Kingdom, California, and other U.S. states with comprehensive privacy laws), additional rights and protections may apply as described in the relevant sections below.
IIINFORMATION WE PROCESS
Information Stored Locally on Your Device
The following information is stored exclusively on your device and is never transmitted to our servers or any third parties:
- •Profile Information: Your skin type, skin concerns, allergies, sensitivities, and other personal skin profile data that you voluntarily provide within the App.
- •Scan History: Records of products you have scanned, including product names, ingredient lists, and your saved preferences.
- •Favorites and Saved Products: Products you have marked as favorites or saved for future reference.
- •App Preferences and Settings: Your customization choices, notification preferences, and other app settings.
- •Chat History: Your conversations with the AI skincare assistant, including questions you've asked and responses you've received.
Important: All of this information remains on your device and is encrypted using industry-standard security protocols. You can delete all locally stored data at any time through the App Settings.
Camera Access
We request permission to access your device camera for the following purposes:
- •To scan product barcodes for quick product identification
- •To capture photos of product ingredient labels for analysis
Photos taken with the camera are processed locally on your device or sent to our AI analysis service only when you explicitly initiate a product scan or analysis. Photos are never saved to your device without your permission.
Photo Library Access
We request permission to access your photo library to allow you to upload existing product images from your gallery for ingredient analysis. We only access images that you explicitly select. Uploaded images are processed for analysis purposes only and are not stored on our servers beyond the duration required for processing.
Information Processed Through Third-Party Services
When you use certain features of the App, limited information is transmitted to third-party services for processing:
Product Image Analysis
When you scan a product label or upload an image for ingredient analysis, the image is sent securely to our AI analysis service (powered by OpenAI) over an encrypted HTTPS connection. The AI service extracts and analyzes the ingredient list and returns the results to your device.
Important: Product images are processed for analysis only and are automatically deleted from our servers immediately after processing is complete. We do not store product images, and no personally identifiable information is transmitted with these images.
AI Chat Conversations
When you interact with our AI skincare assistant, your messages are sent to OpenAI's API for processing. The AI uses your message content and your skin profile information (if you've created one) to provide personalized skincare advice.
Important: Chat messages are processed in real-time and are not retained on OpenAI's servers beyond the time required for processing. Your complete chat history is stored only on your local device. We do not share your chat conversations with any other parties.
Barcode Scanning & Product Database Lookup
When you scan a product barcode, the barcode number is sent to third-party product databases (such as Open Food Facts or similar services) to retrieve product information including name, brand, and ingredient list.
Important: Only the barcode number is transmitted - no personal information or device identifiers are shared with these services.
No Account or Personal Identifiers Required
Unlike most apps, Luvra does not require you to create an account, provide an email address, phone number, or any other personally identifiable information. You can use all features of the App completely anonymously. We do not collect, store, or process any information that could be used to identify you personally.
Information We Do NOT Collect
To be absolutely clear, we do NOT collect, store, or process:
- ✗Your name, email address, phone number, or other contact information
- ✗Device identifiers (IDFA, Android ID, IMEI, etc.)
- ✗Your precise geolocation or location history
- ✗Tracking cookies or similar tracking technologies
- ✗Usage analytics or behavioral tracking data
- ✗Information from your contacts, social media accounts, or other apps
- ✗Advertising identifiers or cross-app tracking data
- ✗Payment information (the App is currently free with no in-app purchases)
IIITHE PURPOSES OF PROCESSING YOUR DATA
Our mission is to help you make informed decisions about skincare products. We use your information for the following specific purposes:
1. To Provide Core App Functionality
We process product images and barcode data to identify products, extract ingredient information, and analyze compatibility with your skin profile. This is the primary function of the App.
2. To Provide Personalized Recommendations
We use your locally stored skin profile information (skin type, concerns, allergies) to provide personalized ingredient analysis and product recommendations through our AI assistant.
3. To Improve Service Quality
We may analyze aggregated, anonymized usage patterns to improve our AI models and enhance the accuracy of ingredient analysis. This analysis is performed on non-identifiable data only.
4. To Ensure Security and Prevent Abuse
We implement reasonable security measures to prevent unauthorized access, fraud, and abuse of our AI services. This may include rate limiting and automated abuse detection mechanisms that do not involve collecting personal information.
5. To Comply with Legal Obligations
In the unlikely event that we are required by law to disclose information, we will comply with valid legal requests. However, because we collect minimal data and store most information locally on your device, we have very limited information that could be disclosed.
Legal Basis for Processing: Where applicable law requires a legal basis for processing, we process your data based on: (a) your consent (for optional features); (b) contractual necessity (to provide the App services you've requested); (c) compliance with legal obligations; and (d) our legitimate interests in providing and improving our services while respecting your privacy rights.
IVSHARING OF YOUR INFORMATION
We do not sell, rent, or share your personal information with third parties for marketing purposes.
The only third-party service providers we work with are essential for core App functionality:
| Service Provider | Purpose | Location | Data Shared |
|---|---|---|---|
| OpenAI, L.L.C. | AI-powered ingredient analysis and chat assistant | U.S.A. | Product images (temporary), chat messages, skin profile data (when relevant to queries) |
| Vercel Inc. | API hosting and infrastructure | U.S.A. | Technical data necessary for API operations (no personal data) |
| Product Database Services | Product information lookup via barcode | Various | Barcode numbers only (no personal data) |
OpenAI Data Processing
Luvra uses OpenAI's GPT-4 API for product analysis and AI chat features. When you use these features:
- •Product images and chat messages are sent to OpenAI's API over encrypted connections
- •We have configured our integration to disable data retention on OpenAI's servers
- •Data is processed and deleted immediately after analysis is complete
- •OpenAI does not use your data to train their models
- •No personally identifiable information is sent to OpenAI
For more information, please review OpenAI's Privacy Policy at:https://openai.com/policies/privacy-policy
Disclosure for Legal Reasons
We may disclose information if required by law, such as in response to a valid court order, subpoena, government investigation, or to protect our rights, property, or safety, or that of our users or the public. However, because we collect and store minimal data, there is very little information we could disclose even if legally required to do so.
Business Transfers
In the event that Zintop LLC is involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify users via prominent notice in the App or by email (if we have it) of any such change in ownership or control of personal information.
VINTERNATIONAL DATA TRANSFERS
Luvra is available to users worldwide. The third-party services we use (primarily OpenAI and Vercel) are based in the United States. When you use features that require AI processing, your data may be transferred to and processed in the United States or other countries where our service providers operate.
If you are located in the European Economic Area (EEA), United Kingdom, or other regions with data protection laws, please note that the United States and other countries may not have the same data protection laws as your jurisdiction. However:
- •We work only with service providers that implement appropriate security measures
- •Data transfers are encrypted and secured
- •We collect and transfer only the minimum data necessary for functionality
- •Most of your sensitive data never leaves your device
By using the App, you acknowledge and consent to the transfer and processing of your data in accordance with this Privacy Policy.
VIDATA RETENTION AND STORAGE
Data Stored on Your Device
All your personal data (skin profile, scan history, favorites, settings, chat history) is stored indefinitely on your device until you choose to delete it. You have complete control and can delete all locally stored data at any time using the "Clear All Data" option in App Settings.
Product Images
Product images sent to our AI service for ingredient analysis are automatically deleted immediately after processing is complete. We do not retain product images on our servers for any period of time.
Chat Messages
Chat messages sent to our AI assistant are processed in real-time and are not stored on our servers or OpenAI's servers beyond the time necessary for processing (typically a few seconds). Your complete chat history is stored only on your local device.
Aggregated Analytics Data
We may retain anonymized, aggregated data about product scans and ingredient analysis for the purpose of improving our service. This data cannot be used to identify individual users and is retained indefinitely for research and development purposes.
Deleting Your Data
You can permanently delete all your data from the App at any time:
- 1.Open the App and go to Settings
- 2.Scroll to the bottom and tap "Clear All Data"
- 3.Confirm your choice
This action will permanently delete your skin profile, scan history, favorites, and all other locally stored data. This action cannot be undone. Alternatively, uninstalling the App will also remove all locally stored data from your device.
VIIDATA SECURITY
The security of your personal information is highly important to us. We implement industry-standard security measures to protect your data:
Encryption
All data stored on your device is encrypted using platform-standard encryption (iOS Keychain, Android EncryptedSharedPreferences). All data transmitted to our servers and third-party services is encrypted in transit using HTTPS/TLS protocols.
Minimal Data Collection
The best way to protect data is not to collect it. We practice data minimization by collecting only the information absolutely necessary to provide our service, and by storing most data locally on your device rather than on our servers.
Secure Service Providers
We work only with reputable third-party service providers (OpenAI, Vercel) that implement appropriate technical and organizational security measures to protect data.
No Account System
By not requiring accounts, we eliminate the risk of account breaches, password leaks, and unauthorized access to user accounts.
Regular Security Reviews
We regularly review and update our security practices to address new threats and vulnerabilities.
Important Disclaimer: While we take reasonable precautions to protect your data, no method of electronic storage or transmission over the Internet is 100% secure. We cannot guarantee absolute security. In the unlikely event of a data breach affecting user data, we will promptly notify affected users and relevant authorities as required by applicable law.
If you have questions or concerns about the security of the App, please contact us at the email address provided in Section XIII below.
VIIIYOUR PRIVACY RIGHTS
Depending on your location and applicable privacy laws (including GDPR, CCPA, and other state/regional privacy laws), you may have the following rights regarding your personal data:
Right to Access
You have the right to request information about what personal data we process about you. For Luvra users: Almost all your data is stored locally on your device and accessible through the App Settings. We store minimal data on our servers.
Right to Rectification/Correction
You have the right to correct inaccurate or incomplete personal data. For Luvra users: You can update your skin profile and all other information directly in the App Settings at any time.
Right to Erasure (Right to be Forgotten)
You have the right to request deletion of your personal data. For Luvra users: You can delete all your locally stored data using the "Clear All Data" option in Settings. Since we don't store personal data on our servers, there's nothing for us to delete remotely.
Right to Data Portability
You have the right to receive your personal data in a structured, commonly used format. For Luvra users: Your data is stored locally on your device. If you would like an exportable copy, please contact us and we can provide guidance on accessing your device's local storage.
Right to Restriction of Processing
You have the right to request that we limit how we process your data. For Luvra users: You can stop using specific features (like AI chat or product scanning) at any time to prevent data processing for those purposes.
Right to Object
You have the right to object to certain types of data processing. For Luvra users: You control which features you use. Since we don't engage in marketing, profiling, or automated decision-making that produces legal effects, there is minimal processing to object to.
Right to Withdraw Consent
Where we process data based on your consent, you can withdraw that consent at any time. For Luvra users: You can revoke camera and photo library permissions through your device settings at any time.
Right to Lodge a Complaint
You have the right to lodge a complaint with a data protection authority about our processing of your personal data. For EU users, you can find your local data protection authority at:https://edpb.europa.eu/about-edpb/board/members_en
How to Exercise Your Rights
To exercise any of these rights or if you have questions about your privacy:
- •For locally stored data: Use the App Settings
- •For other requests: Email us at luvra [at] zintopllc [dot] com
We will respond to your request within the timeframe required by applicable law (typically 30 days). We may need to verify your identity before processing your request.
Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising your privacy rights. We will never deny you service, charge different prices, or provide a different quality of service because you exercise your privacy rights.
IXCHILDREN'S PRIVACY
Luvra is intended for general audiences and is not specifically directed at children. We do not knowingly collect personal information from children under the age of 13 (or the applicable age of digital consent in your jurisdiction, which may be 16 in some regions).
If we learn that we have collected personal information from a child under the applicable age without parental consent, we will take steps to delete that information as quickly as possible.
If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at luvra [at] zintopllc [dot] com so we can take appropriate action.
Note: Because Luvra does not require account creation and stores data locally on the device, we have no way to determine the age of our users. Parents and guardians are responsible for monitoring their children's use of the App.
XCALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information.
Categories of Personal Information
In the past 12 months, we have collected the following categories of personal information from California residents:
- •Category B: Personal information (none - we don't collect names, addresses, or contact information)
- •Category F: Internet or network activity (product images for analysis, chat messages)
- •Category K: Inferences drawn from personal information (skin type analysis, product recommendations)
Right to Know
You have the right to request disclosure of the personal information we collect, use, disclose, and sell about you. For Luvra: We collect minimal data and most is stored on your device.
Right to Delete
You have the right to request deletion of your personal information. Use the "Clear All Data" option in App Settings.
Right to Opt-Out of Sale
We do not sell your personal information. We have not sold personal information in the past 12 months and do not plan to in the future.
Right to Opt-Out of Sharing
We do not share your personal information for cross-context behavioral advertising.We do not use tracking technologies or share data with advertising networks.
Right to Limit Sensitive Personal Information
The skin profile data you provide could be considered sensitive. This data is stored locally on your device and is only shared with OpenAI when necessary to provide personalized recommendations. You can stop using AI features at any time to prevent this sharing.
Right to Correct
You have the right to correct inaccurate personal information. You can update your skin profile and other information in App Settings.
How to Exercise Your California Rights
To exercise your CCPA/CPRA rights:
- •Email: luvra [at] zintopllc [dot] com with the subject line "California Privacy Rights Request"
- •We will respond within 45 days
- •You may designate an authorized agent to make requests on your behalf
We will not discriminate against you for exercising your CCPA/CPRA rights.
Shine the Light Law
California's "Shine the Light" law (Civil Code Section § 1798.83) permits California residents to request information about our disclosure of personal information to third parties for direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.
XIEUROPEAN UNION & UNITED KINGDOM PRIVACY RIGHTS (GDPR)
If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, the General Data Protection Regulation (GDPR) and UK GDPR provide you with specific rights regarding your personal data.
Data Controller
Zintop LLC is the data controller responsible for your personal data. For the limited data that we process through third parties (OpenAI), these providers act as data processors on our behalf.
Legal Basis for Processing
We process your personal data based on the following legal bases:
- •Consent: Camera and photo library access (you can withdraw consent through device settings)
- •Contractual Necessity: Processing necessary to provide the App services you request (product analysis, AI chat)
- •Legitimate Interests: Improving our service through anonymized, aggregated data analysis; preventing fraud and abuse
Your GDPR Rights:
Right of Access (Article 15)
You have the right to obtain confirmation that we are processing your data and to access that data.
Right to Rectification (Article 16)
You have the right to have inaccurate personal data corrected. Update your profile in App Settings.
Right to Erasure/Right to be Forgotten (Article 17)
You have the right to request deletion of your data. Use "Clear All Data" in App Settings.
Right to Restriction of Processing (Article 18)
You have the right to request that we restrict processing of your data in certain circumstances.
Right to Data Portability (Article 20)
You have the right to receive your data in a structured, machine-readable format.
Right to Object (Article 21)
You have the right to object to processing based on legitimate interests or for direct marketing.
Rights Related to Automated Decision-Making (Article 22)
While we use AI to analyze products and provide recommendations, these do not constitute automated decision-making that produces legal effects or similarly significantly affects you.
Right to Withdraw Consent
Where we process data based on consent, you can withdraw consent at any time through device settings.
Right to Lodge a Complaint
You have the right to lodge a complaint with your local supervisory authority. Find your authority at:https://edpb.europa.eu/about-edpb/board/members_en
How to Exercise Your GDPR Rights
To exercise any of your GDPR rights, please contact us at luvra [at] zintopllc [dot] com. We will respond within one month (extendable by two additional months for complex requests).
International Data Transfers
Your data may be transferred to the United States (where OpenAI and Vercel are located). We ensure appropriate safeguards are in place through standard contractual clauses and by working with providers that comply with applicable data protection frameworks.
XIICHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes:
- •We will update the "Last updated" date at the top of this Privacy Policy
- •For material changes, we will provide prominent notice in the App
- •We encourage you to review this Privacy Policy periodically
Your continued use of the App after changes are made means you accept the updated Privacy Policy. If you disagree with the changes, please stop using the App and delete all your local data.
XIIIHOW TO CONTACT US
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
Zintop LLC
Email: luvra [at] zintopllc [dot] com
App: Luvra - Personal Skin Advisor
Website: https://zintopllc.com
We take all privacy inquiries seriously and will respond to your request within a reasonable timeframe as required by applicable law.
Privacy at a Glance
Local Storage Only
Your personal data stays on your device
No Account Required
Use the app completely anonymously
No Tracking
We don't use analytics or tracking cookies
Easy Data Deletion
Clear all data anytime in Settings
Offline Access
View your history without internet
Minimal Data Sharing
Only essential data for AI processing
© 2025 Zintop LLC. All rights reserved.
Luvra - Your privacy-first personal skin advisor