Privacy Policy — NATURFACTOR App

Version 1.5 · Last updated: October 14, 2026 · applicable to the NATURFACTOR App (iOS and Android)

1 Controller

The controller responsible for data processing in the NATURFACTOR app is NF Cosmetics GmbH, Tannenweg 36, 85399 Hallbergmoos, Germany.
Data privacy contact: dataprivacy@naturfactor.life

2 Key points at a glance

  • Your data is stored in the EU (Supabase, Ireland region).
  • The core of the app processes health data (e.g., skin condition, sleep). This is done exclusively on the basis of your explicit consent—each category individually, revocable at any time.
  • No advertising with your data: We do not use advertising SDKs, no third-party tracking, and we never share health data for advertising or analysis purposes. Data from Apple Health and Health Connect is never used for marketing—in accordance with Apple and Google guidelines.
  • You can export your data within the app and delete your account, along with all data, yourself.

3 What data we process—and why

a) Account & Profile. During registration, we process your email address (login via email code) or the login information provided by Apple or Google (Sign in with Apple / Google Sign-In: email, and name if applicable). In your profile, you provide your date of birth (day, month, year) as well as information such as skin type. Purpose: Providing your account and personalizing the app. Legal basis: Art. 6(1)(b) GDPR (service contract).

b) Skin & Well-being Information (Journal, self-disclosures). We process your information regarding skin type, skin condition, and well-being to generate your skin quality score, factors, and personal app evaluations. This information is not used for medical diagnosis. Legal basis: Your explicit consent (Art. 9(2)(a) GDPR), given during onboarding, revocable in the settings.

c) Height & Weight (optional). These serve exclusively to calculate a general, non-medical hydration guideline; they are not compared with medical reference values. Legal basis: Explicit consent (Art. 9(2)(a) GDPR).

d) Health data from Apple Health or Health Connect (optional).

On iOS: If you grant permission, the app reads data shared by you in Apple Health across four categories: (1) sleep data, (2) heart rate variability, resting heart rate, and heart rate, (3) body data (height, weight), (4) steps, water intake, and time in daylight—each individually activatable and revocable. Heart rate is only used if your device does not provide a resting heart rate; the individual values are not saved. The app does not send anything back to Apple.

On Android: Health Connect replaces Apple Health. The app requests read permissions only, for four data types: sleep including sleep phases, heart rate variability, resting heart rate, and heart rate. Heart rate is only read if your device does not provide a ready-made resting heart rate; a resting heart rate is then derived from it—the individual measurement values themselves are not saved. Permissions can be activated and revoked separately: sleep and heart values. The app does not write anything back to Health Connect.

Purpose in both cases: Calculation of your Recovery Factor and your Age Factor within the NATURFACTOR lifestyle model. The app does not create a medical assessment from this and never uses this data for advertising. Legal basis: Explicit consent (Art. 9(2)(a) GDPR) plus your authorization in Apple Health or Health Connect.

e) Location & Environmental data (optional). With your consent, we use your location to retrieve local UV, weather, and air quality data to consider in the Environment Factor. We only send rounded coordinates via our own server function to the weather service (OpenWeather)—never your name, never your exact address. There is no use for advertising or movement profiles. Legal basis: Consent (Art. 6(1)(a) GDPR).

f) Routines & Products. We process your skincare routines and stored products for display and evaluation within the Care Factor. Legal basis: Art. 6(1)(b) GDPR; to the extent that inferences about skin condition are made, your consent according to b).

g) Derived values (Scores). We calculate your scores (e.g., Skin Quality Score, Age Factor) from the aforementioned data on our servers; the app displays the result. These are model-based lifestyle estimates, not medical findings. Legal basis: same as the underlying data (consent).

h) Notifications (optional). Reminders that you set in the app are scheduled locally on your device; no data is transmitted to us for this.

Additionally, we may send you push notifications from our servers, such as information about your account or membership. For this, we store a device identifier (push token) assigned by your operating system, which by itself does not allow for any conclusions about your person; we associate it with your account. Delivery is performed via the Apple Push Notification service (iOS) or Firebase Cloud Messaging (Android). If you deactivate notifications or delete the app, the token becomes invalid and is removed. Legal basis for service messages: Art. 6(1)(b) GDPR. You will only receive promotional push notifications with your separate consent (Art. 6(1)(a) GDPR), which you can revoke at any time.

i) Memberships & Purchases. Purchase and billing of memberships occur via your Apple account (in-app purchase on iOS) or your Google Play account (in-app purchase on Android). We do not receive any payment data from Apple and Google, but only transaction confirmations (e.g., subscription status) to unlock your membership. Legal basis: Art. 6(1)(b) GDPR.

j) Apple Watch (optional). If you use the NATURFACTOR app on your Apple Watch, your iPhone transfers your current display values (Skin Quality Score, Age Factor, factor values, history of the last days, current recording status) directly to your paired watch—via Apple's system function, not via our servers. The watch app itself does not connect to any server, read any data from Apple Health, or use location. On the watch, these values are stored in protected app storage, without your email address or account identifier; they are deleted when you log out in the app. Entries you make on the watch (e.g., water, routine, journal, breathing exercise) are transmitted to your iPhone and saved from there as an input in the app—the same purposes and legal bases apply as under b) and f). An entry that has not yet been transferred is assigned exclusively to the account under which it was created. App notifications can also appear on the watch according to your iOS settings. Values on the watch face are obscured when the watch is locked.

4 Recipients & Processors

  • Supabase (database/hosting, EU-West-1 region, Ireland) — processor with a data processing agreement.
  • OpenWeather (weather/UV/air quality data) — receives only rounded coordinates via our server function, no identity data.
  • Apple (iOS) — operating system functions (Apple Health remains on the device; the app only reads with your authorization), login (Sign in with Apple), purchase processing, and delivery of push notifications.
  • Google — login, if you use Google Sign-In (both platforms); on Android, additionally purchase processing via Google Play and delivery of push notifications via Firebase Cloud Messaging. Health Connect remains on the device; the app only reads with your authorization and does not transmit any health data to Google.
  • Shopify — only if you use shop functions (e.g., product data, Ritual membership). Health data is never transmitted to Shopify or OpenWeather.

Your account, health, and score data are processed and stored exclusively in the EU. Individual functions run via services that also process data outside the EU: Apple and Google for login, purchase processing, and the delivery of push notifications. No health data is transmitted during this process. This processing is based on adequacy decisions or EU standard contractual clauses.

5 Storage duration

We store your data as long as your account exists and the respective consent has not been revoked. Upon account deletion, all app data is deleted immediately. They may persist in encrypted backups for up to 90 days; afterwards, they are overwritten.

6 Consents & Revocation

All consents are granted actively and individually (no collective consent). You can revoke any consent at any time in the settings (Profile → Privacy & Consents). The revocation is effective immediately: the affected processing stops and the associated data is deleted. From the moment of revocation, they are no longer included in any calculations; the daily value of the current day is recalculated without them. Daily values from previous days are retained—they are a result that came into being lawfully at the time of its creation. The legality of processing carried out until the revocation remains unaffected. Granting and revocation are logged with time and version status (obligation to provide proof, Art. 5(2) GDPR).

7 Your rights

You have the right to access (Art. 15), rectification (Art. 16), deletion (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), and objection (Art. 21 GDPR). Implemented in the app: data export (Settings → Export data, machine-readable format) and account deletion (Settings → Delete account). You can also request the deletion of your account via this form. In addition, you can file a complaint with a data protection supervisory authority—responsible for us: Bavarian State Office for Data Protection Supervision (BayLDA), Ansbach.

8 No automated decision-making

Your scores are deterministic model calculations for information purposes—no automated decision-making with legal effect takes place within the meaning of Art. 22 GDPR.

9 No tracking, no advertising

The app does not use advertising identifiers, third-party advertising or tracking SDKs, and does not display third-party advertisements.

10 Changes to this declaration

In the event of changes, we will inform you within the app. We will actively obtain new consents for significant changes that require them. The currently applicable version can be viewed in the app (see version number above).