Privacy Policy

Last updated: October 10, 2026

This policy explains how the Clearu app (“Clearu”, “we”) handles your personal data under Brazil’s General Data Protection Law (Law 13,709/2018, “LGPD”). It covers the Clearu app for iPhone and Android and this website.

1. Data we collect

• Face photos, when you take a face scan. Each scan uses three photos (front, left and right).
• Product photos and barcodes, when you scan a product.
• Questionnaire answers, such as skin type, sensitivity, age range, cosmetic concerns and care habits.
• Scan results, your products, your routine and your care check-ins.
• Chat messages with the Clearu assistant and the product photos you send in it.
• Account data, if you sign in with Apple or Google: an account identifier and, when the provider shares them, your name and email.
• Subscription data: an anonymous identifier and your subscription status in the App Store or Google Play. We never receive card details.
• Usage and crash data: screens opened, actions completed and error reports, linked to your account and installation identifiers. They never include photos, answers, ingredients or skin scores.
• Settings: language, time zone and reminders. Reminders are scheduled on your phone.

Your face is located on your phone to guide the camera. Those points never leave the device. We do not use photos to identify you and do not perform facial recognition.

2. How we use data

• To produce the cosmetic skin and product analyses, your report, your product profile and your routine.
• To show your progress over time.
• To answer your chat messages.
• To run your account, check your subscription and provide support.
• To understand app usage, fix crashes and prevent abuse.

Clearu gives cosmetic appearance estimates. It does not provide medical diagnoses and does not replace a dermatologist.

3. Legal bases

• Consent (LGPD art. 7, I and art. 11, I): to analyze face photos and to use the chat. We ask on a dedicated screen before first use, and you can withdraw it in the app at any time.
• Performance of a contract (art. 7, V): to provide the service you signed up for, including your subscription.
• Legitimate interest (art. 7, IX): for usage metrics, security and crash fixing, never with photos or skin data.
• Legal obligation (art. 7, II), where applicable.

4. Who we share data with

We do not sell your data. We share it only with processors that help us run the service:

• Artificial intelligence provider (OpenAI, United States): receives face and product photos for analysis, and the answers, results, products and routine needed for your report, product profile and chat. It may keep requests for up to 30 days to check for abuse and does not use them to train its models.
• Supabase (servers in Brazil): database, sign-in and private photo storage.
• Hosting providers for our API.
• RevenueCat (United States), Apple and Google: subscription checks.
• Apple and Google: sign-in, when you choose one of them.
• PostHog (United States): usage metrics and crash reports.
• Open Beauty Facts: public barcode lookups. Only the product code is sent.

We may also share data when required by law or by a competent authority.

5. International transfers

Some processors are in the United States. These transfers follow LGPD art. 33 and rely on your specific consent and on the processors’ contractual safeguards.

6. How long we keep data

• Front photo of each scan: until you delete it or your account. Side photos and product photos are not kept after the analysis.
• Results, products, routine and chat: until you delete them or your account.
• Usage metrics: may be kept in pseudonymized form after account deletion.
• Data the law requires us to keep: for the legal period.

7. Your rights

You may request confirmation of processing, access, correction, anonymization, portability, deletion, information about sharing, and withdrawal of consent (LGPD art. 18). In the app, under You, you can delete your scan data or your whole account. For other requests, email admin@justclearu.com. You may also file a complaint with Brazil’s data protection authority (ANPD).

Deleting your account removes your photos, scans, products, routine, profile and chat, and ends the link with your Sign in with Apple login. It does not cancel your subscription: cancel it in your App Store or Google Play settings.

8. Minimum age

Clearu is intended for people aged 16 and over. We do not knowingly collect data from anyone under 16. If you know of such a case, contact us and we will delete the data.

9. Security

We use encrypted connections, private photo storage and restricted data access. No system is fully immune to incidents; if a relevant incident occurs, we will notify you and the ANPD as the law requires.

10. Changes

We may update this policy. We will announce material changes in the app, and the date at the top always shows the version in force.