Privacy Policy

Last updated: 27 February 2026

The Short Version

  • We collect your email (only if you sign up), scan history, and basic device info.
  • Your camera is used on-device only — we never see, store, or transmit your photos.
  • We use Cloudflare Web Analytics, which sets no cookies and collects no personal data.
  • We never sell your data to anyone.
  • You can delete your account and all associated data at any time.

1. Who We Are

LuxSense ("we," "our," or "us") is operated by Bogdan Tudor, an Australian sole trader (ABN 40 878 968 233), trading as LuxSense. We provide a skincare ingredient scanning and analysis application and website (together, the "Service").

For the purposes of the General Data Protection Regulation (GDPR), Bogdan Tudor (trading as LuxSense) is the data controller — we decide how and why your personal data is processed.

Contact us:
Email: contact@luxsense.app
Subject line: "Privacy Inquiry"

2. What Data We Collect

Data you give us directly

  • Email address — when you join our waitlist or create an account.
  • Scan history — the products and ingredients you scan, including barcode data and ingredient lists extracted by OCR.
  • User contributions — if you submit corrections or new product data.
  • Support messages — any emails or feedback you send us.

Data collected automatically

  • Basic device information — device type, operating system version, app version. Used for compatibility and debugging.
  • Anonymous analytics — page views and general usage patterns via Cloudflare Web Analytics (cookieless, no personal identifiers).
  • IP address — processed by Cloudflare to route requests to the nearest edge server. We do not store raw IP addresses ourselves.

Data we do NOT collect

  • Camera images — all OCR processing happens on your device using Apple Vision. Images never leave your phone and are not stored or transmitted to our servers.
  • Location data — we don't request or store your precise location.
  • Payment data — if we introduce paid features, all payments will be processed through Apple's App Store. We never see your card details.
  • Health data — we don't integrate with Apple Health or collect medical information.

3. How We Use Your Data

Purpose Data Used Legal Basis (GDPR)
Provide the scanning and analysis service Scan history, device info Contract performance (Art. 6(1)(b))
Send waitlist updates and service communications Email address Consent (Art. 6(1)(a))
Improve our ingredient database User contributions, aggregated scan data Legitimate interest (Art. 6(1)(f))
Understand how the app is used (analytics) Anonymous usage data Legitimate interest (Art. 6(1)(f))
Respond to your support requests Email, message content Contract performance (Art. 6(1)(b))
Comply with legal obligations As required by law Legal obligation (Art. 6(1)(c))

4. Camera Usage & On-Device Processing

LuxSense uses your device camera to scan barcodes and ingredient lists. Here's exactly what happens:

  1. You point your camera at a product's barcode or ingredient list.
  2. Apple Vision (built into iOS) reads the text entirely on your device.
  3. The extracted text (ingredient names) is sent to our servers to look up safety data.
  4. The camera image itself is never stored, uploaded, or transmitted.

We have no access to your camera feed, photo library, or any images on your device. The camera permission is used solely for real-time scanning.

5. Who We Share Data With

We do not sell, rent, or trade your personal data. We share data only with:

  • Cloudflare, Inc. — our hosting and edge computing provider. Your requests are processed at the Cloudflare edge location nearest to you (typically within the EU). Cloudflare acts as a data processor under a Data Processing Agreement. Cloudflare's GDPR commitment →
  • Apple Inc. — manages app distribution and any future in-app purchases. Subject to Apple's Privacy Policy.
  • Law enforcement — only if legally required by court order or binding legal process.

6. International Data Transfers

Our backend runs on Cloudflare Workers, which process your requests at the edge location nearest to you. For EU users, this typically means your data is processed within Europe.

In cases where data may be transferred outside the EEA (for example, Cloudflare's global network), transfers are protected by:

  • The EU–U.S. Data Privacy Framework (where applicable)
  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Cloudflare's binding corporate commitments to GDPR compliance

7. How Long We Keep Your Data

Data Type Retention Period
Account data (email, preferences) Until you delete your account + 30 days for backup removal
Scan history Until you delete individual scans or your account
Waitlist email Until you unsubscribe or the waitlist closes
User contributions Indefinitely (becomes part of the open database, see Licenses)
Support correspondence 2 years after resolution
Analytics data Aggregated and anonymous — no personal data retained

After retention periods expire, we securely delete or irreversibly anonymize your data.

8. Your Rights Under GDPR

As an EU resident, you have the following rights over your personal data. You can exercise any of these by emailing contact@luxsense.app. We'll respond within 30 days.

  • Access — Request a copy of all personal data we hold about you.
  • Rectification — Ask us to correct inaccurate or incomplete data.
  • Erasure ("right to be forgotten") — Ask us to delete your personal data. We'll comply unless we have a legal obligation to keep it.
  • Restriction — Ask us to temporarily stop processing your data while we resolve a concern.
  • Data portability — Receive your data in a structured, machine-readable format (JSON) so you can transfer it elsewhere.
  • Objection — Object to processing based on legitimate interest. We'll stop unless we have compelling legitimate grounds.
  • Withdraw consent — If processing is based on your consent (e.g., marketing emails), you can withdraw it at any time. This doesn't affect processing that happened before withdrawal.

Right to lodge a complaint: If you believe we haven't handled your data properly, you have the right to complain to the supervisory authority in your EU member state.

9. Cookies & Tracking

We don't use cookies for analytics or tracking.

Our website uses Cloudflare Web Analytics, which is a privacy-first analytics service that:

  • Does not use cookies
  • Does not track users across sites
  • Does not collect personal information
  • Does not fingerprint devices

Because we don't set tracking cookies, you won't see a cookie consent banner on our site. The only data stored locally may be essential technical data (like keeping you logged in), which does not require consent under the ePrivacy Directive.

Email consent

When you join our waitlist or sign up, we ask for your explicit consent to send you emails. You can unsubscribe at any time via the link in every email, or by emailing us.

10. Children's Privacy

LuxSense is not intended for children under 13 years of age. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at contact@luxsense.app and we will promptly delete it.

Users aged 13–16 may use the Service with parental or guardian consent, in accordance with the age requirements of their EU member state.

11. Security

We take reasonable technical and organizational measures to protect your data:

  • All data in transit is encrypted with TLS 1.3
  • Data at rest is encrypted on Cloudflare's infrastructure
  • Access to personal data is restricted to authorized personnel only
  • We conduct regular security reviews of our systems
  • Camera images never leave your device — they can't be breached from our side

No system is 100% secure. If we discover a data breach that affects your personal data, we will notify you and the relevant supervisory authority within 72 hours, as required by GDPR.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will:

  • Update the "Last updated" date at the top
  • Notify you via email or in-app notification for material changes
  • Give you at least 30 days notice before changes take effect

We encourage you to review this page periodically.

13. Contact Us

For any questions, concerns, or requests regarding your privacy or this policy:

We aim to respond to all privacy-related requests within 30 days.