Version 1.4 · As of: August 24, 2026 · applies to the NATURFACTOR App (iOS and Android)

1 Controller

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

2 The essentials 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 happens solely on the basis of your explicit consent — each category individually, revocable at any time.
• No advertising with your data: We use no advertising SDKs, no third-party tracking, and never share health data for advertising or analytics purposes. Data from Apple Health and from Health Connect is never used for marketing, in line with the requirements of Apple and Google.
• 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 (sign-in via email code) or the sign-in data provided by Apple or Google (Sign in with Apple / Google Sign-In: email, name if provided). In your profile you provide your date of birth (day, month, year) as well as details such as skin type. Purpose: providing your account and personalizing the app. Legal basis: Art. 6 (1)(b) GDPR (user agreement).

b) Skin & well-being entries (journal, self-reports). We process your entries about skin type, skin condition, and well-being to generate your Skin Quality Score, your factors, and your personal in-app insights. These entries are not used for medical diagnosis. Legal basis: your explicit consent (Art. 9 (2)(a) GDPR), given during onboarding and revocable in the settings.

c) Height & weight (optional). Used solely to calculate a general, non-medical hydration reference value; no comparison with medical reference ranges. Legal basis: explicit consent (Art. 9 (2)(a) GDPR).

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

On iOS: with your permission, the app reads the data you have shared in Apple Health, in four categories: (1) sleep data, (2) heart rate variability, resting heart rate and heart rate, (3) body data (height, weight), (4) steps, hydration and time in daylight — each can be enabled and withdrawn individually. Heart rate is only used if your device does not provide a resting heart rate; the individual values are not stored in this process. The app sends nothing back to Apple.

On Android: Health Connect takes the place of Apple Health. There, the app requests read permissions only, for four data types: sleep including sleep stages, heart rate variability, resting heart rate and heart rate. Heart rate is read only if your device does not provide a resting heart rate of its own; a resting heart rate is then derived from it — the individual measurements themselves are not stored. Permissions are granted and revoked separately: sleep and heart values. The app writes nothing back to Health Connect.

Purpose in both cases: calculating your Recovery Factor and your Age Factor within the NATURFACTOR lifestyle model. The app does not derive any medical assessment from this data and never uses it for advertising. Legal basis: explicit consent (Art. 9 (2)(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 factor it into your Environment Factor. We only send rounded coordinates through our own server function to the weather service (OpenWeather) — never your name, never your exact address. Your location is not used for advertising or movement profiles. Legal basis: consent (Art. 6 (1)(a) GDPR).

f) Routines & products. We process your care routines and saved products to display and evaluate them within the Care Factor. Legal basis: Art. 6 (1)(b) GDPR; where inferences about skin condition arise, your consent under b).

g) Derived values (scores). From the data above, we calculate your scores (e.g., Skin Quality Score, Age Factor) 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 you set in the app are scheduled locally on your device; no data is transmitted to us for this.

In addition, we may send you push messages from our servers — for example, information about your account or your membership. For this we store a device identifier (push token) issued by your operating system, which on its own does not identify you; we associate it with your account. Delivery is handled by the Apple Push Notification service (iOS) or Firebase Cloud Messaging (Android). If you turn off 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 messages with your separate consent (Art. 6 (1)(a) GDPR), which you may withdraw at any time.

i) Memberships & purchases. Purchase and billing of memberships are handled through your Apple account (in-app purchase on iOS) or through your Google Play account (in-app purchase on Android). We receive no payment data from Apple or Google — only transaction confirmations (e.g., subscription status) to unlock your membership. Legal basis: Art. 6 (1)(b) GDPR.

4 Recipients & processors

• Supabase (database/hosting, region EU-West-1, Ireland) — processor under 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 features (Apple Health stays on your device; the app only reads with your permission), sign-in (Sign in with Apple), purchase processing, and delivery of push messages.
• Google — sign-in, if you use Google Sign-In (both platforms); on Android additionally purchase processing via Google Play and delivery of push messages via Firebase Cloud Messaging. Health Connect stays on your device; the app only reads with your permission and transmits no health data to Google.
• Shopify — only if you use shop features (e.g., product data, Ritual membership). Health data is never transmitted to Shopify or OpenWeather.

Your account, health, and score data is processed and stored exclusively within the EU. Individual functions run through services that also process data outside the EU: Apple and Google for sign-in, purchase processing, and the delivery of push messages. No health data is transmitted in this context. Such processing is based on adequacy decisions or EU standard contractual clauses.

5 Storage period

We store your data for as long as your account exists and the respective consent has not been revoked. When an account is deleted, all app data is deleted immediately. It may persist in encrypted backups for up to 90 days; after that it is overwritten.

6 Consents & revocation

You give all consents actively and individually (no bundled consent). You can revoke any consent at any time in the settings (Profile → Privacy & Consents). Revocation takes effect immediately: the affected processing stops and the associated data is deleted. From the moment of revocation it no longer feeds into any calculation; the current day's value is recalculated without it. Daily values from earlier days remain — they are a result that came about lawfully at the time it was produced. The lawfulness of processing carried out before revocation remains unaffected. Granting and revocation are logged with timestamp and policy version (accountability, Art. 5 (2) GDPR).

7 Your rights

You have the right of access (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 may also request deletion of your account using this form. In addition, you may lodge a complaint with a data protection supervisory authority — competent for us: Bavarian State Office for Data Protection Supervision (BayLDA), Ansbach, Germany.

8 No automated decision-making

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

9 No tracking, no advertising

The app uses no advertising identifiers, no third-party advertising or tracking SDKs, and displays no third-party advertising.

10 Changes to this policy

We will inform you in the app about changes. For material changes requiring new consent, we will actively ask you. The current version is available in the app (version number above).