Version 1.2 · Status: August 4, 2026 · applies to the NATURFACTOR App (iOS and Android)

1 Controller

The NF Cosmetics GmbH, Tannenweg 36, 85399 Hallbergmoos, Germany, is responsible for data processing in the NATURFACTOR App.
Data Protection Contact: dataprivacy@naturfactor.life

2 The Most Important in Brief

• Your data is stored in the EU (Supabase, Ireland region).
• The core of the app processes health data (e.g., skin condition, sleep). This happens exclusively based on 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 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 in the app and delete your account, including all data, yourself.

3 What data we process — and why

a) Account & Profile. When you register, we process your email address (login via email code) or the login data transmitted by Apple or Google (Sign in with Apple / Google Sign-In: email, possibly name). In your profile, you enter your date of birth (day, month, year) as well as information such as skin type. Purpose: Provision of your account and personalization of the app. Legal basis: Art. 6 para. 1 lit. b GDPR (user contract).

b) Skin & Well-being Information (Journal, Self-assessments). We process your information on skin type, skin condition, and well-being to create your skin quality score, your factors, and your personal app evaluations. The information is not used for medical diagnosis. Legal basis: your explicit consent (Art. 9 para. 2 lit. a GDPR), given during onboarding, revocable in the settings.

c) Height & Weight (optional). Used exclusively for calculating a general, non-medical hydration guideline; no comparison with medical reference values. Legal basis: explicit consent (Art. 9 para. 2 lit. a GDPR).

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

On iOS: If you allow it, the app reads data shared by you in Apple Health: (1) sleep data, (2) heart rate variability & resting heart rate, (3) body data — each individually activatable and individually revocable. The app does not send anything back to Apple.

On Android: Health Connect replaces Apple Health. The app exclusively requests read permissions there for six data types: sleep including sleep phases, heart rate variability, resting heart rate, heart rate, steps, and water intake. 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 measurements themselves are not stored. Permissions can be activated and revoked separately: sleep, heart values, as well as steps and water intake. 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 para. 2 lit. a GDPR) plus your permission 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 and include it 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. It is not used for advertising or movement profiles. Legal basis: consent (Art. 6 para. 1 lit. a GDPR).

f) Routines & Products. We process your care routines and stored products for display and evaluation within the Care Factor. Legal basis: Art. 6 para. 1 lit. b GDPR; if conclusions about the skin condition arise, your consent according to b).

g) Derived Values (Scores). From the aforementioned data, the app calculates your scores (e.g., Skin Quality Score, Age Factor). These are model-based lifestyle estimates, not medical findings. Legal basis: 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 purpose.

In addition, we can 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 conclusions about your person; we associate it with your account. Delivery is 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 para. 1 lit. b GDPR. You will only receive promotional push notifications with your separate consent (Art. 6 para. 1 lit. a GDPR), which you can revoke at any time.

4 Recipients & Processors

• Supabase (Database/Hosting, EU-West-1 region, Ireland) — Processor with 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 permission), login (Sign in with Apple) and delivery of push notifications.
• Google — login, if you use Google Sign-In (both platforms); on Android also delivery of push notifications via Firebase Cloud Messaging. Health Connect remains on the device; the app only reads with your permission 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 and the delivery of push notifications. No health data is transmitted in this process. This processing is based on adequacy decisions or EU standard contractual clauses.

5 Storage Period

We store your data as long as your account exists and the respective consent has not been revoked. Upon account deletion, all app data will be deleted immediately; backup copies will be purged within the documented backup period.

6 Consents & Revocation

All consents are given actively and individually (no blanket consent). You can revoke any consent at any time in the settings (Profile → Privacy & Consents). The revocation takes effect immediately: the affected processing stops, the associated data is deleted, and your values are recalculated without this data. The legality of the processing carried out until the revocation remains unaffected. The granting and revocation are logged with time and version status (duty of proof, Art. 5 para. 2 GDPR).

7 Your Rights

You have the right to information (Art. 15), rectification (Art. 16), erasure (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 complain to a data protection supervisory authority — for us, the Bavarian State Office for Data Protection Supervision (BayLDA), Ansbach, is responsible.

8 No Automated Decision-Making

Your scores are deterministic model calculations for information purposes — there is no automated decision-making with legal effect 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 advertising.

10 Changes to this Statement

We will inform you about changes in the app. Significant changes that require new consents will be actively requested. The currently applicable version can be viewed in the app (version number see above).