Privacy Policy

1. Who We Are & Scope

This Privacy Policy ("Policy") explains how Ourskin, Inc., doing business as "GRLY" ("GRLY", "we", "us", or "our"), collects, uses, shares, and protects your personal information when you use the GRLY mobile app, the website at grlyapp.co, and the GRLY store at grly.co (together, the "Services"). Ourskin, Inc. is the data controller responsible for your personal information.

This Policy meets the EU and UK General Data Protection Regulation (GDPR / UK GDPR), the Swiss Federal Act on Data Protection (FADP), the California Consumer Privacy Act as amended by the CPRA (CCPA/CPRA), and other applicable laws. Region-specific rights are in Sections 15–17.

Legal entity: Ourskin, Inc., a Delaware corporation
Registered address: 1111B South Governors Ave, Dover, DE 19904, USA
Privacy contact: connect@grlyapp.co

2. Information We Collect

Information you provide

Account information — your name and email address, and (if you register with a password) a securely hashed password. If you sign in with Google or Apple, we receive your name and email from that provider. If you sign in with Google, Google's sign-in software in the app may also collect your approximate location (estimated from your IP address, to help prevent fraud), details about your device, and how you use sign-in. Google handles that information under its own privacy policy.
Wellness & supplement data (health information) — the supplements you track; dosages, schedules, and reminders; your intake history (taken/skipped, dates, and any notes you add); your onboarding answers (such as age range, goals, and preferences); your weekly check-in answers (mood, sleep and stress); your journal entries; what you take each supplement for, which can include pregnancy or fertility; and streak/progress data. Under GDPR/UK GDPR this is special-category health data, and under the CPRA it is sensitive personal information. We process it only with your explicit consent (Section 5).
Label scans — if you use the camera scanner, a photo of the supplement label is sent to our analysis service to identify the product. The image is not stored on your device and is retained only transiently for the analysis (Section 12).
Shared accountability (if you use it) — the people you pair with and the consent you gave for each; the daily summaries your phone sends for each plan (the day, whether you finished your part, and how many of the plan's supplements you took and were scheduled); which of your supplements you put in each plan, stored as encrypted references; your streak; when your phone last updated, whether you have paused sharing and the days you paused; and records of invites, nudges and blocks. Your phone also sends the coming days' schedule, so a partner's reminders still work when you haven't opened the app; partners only see days up to today.
Communications — anything you send us directly (e.g., support requests).
Android waitlist — if you join it on our website, your email address and when you confirmed it. We don't ask for anything else.

Information collected automatically

Device & technical data — a per-app device identifier and a push-notification token (used to deliver the reminders you enable and notifications from people you pair with), app version, time zone, and basic diagnostic information needed to operate the app.
Purchases — if you subscribe or buy Premium in the app, Apple takes the payment and sends us a record of the purchase: what you bought, when, and whether it renews, ends or is refunded. We check that the record comes from Apple, keep it with your account so Premium works, and note which screen in the app you bought from. We never receive your card or bank details.
Feature use — how many label scans you've used and nutrient detail pages you've opened each month, so the free plan's limits work, and which of your monthly Wrapped editions you've opened.

Information from the store

Order information — if you shop at our store (grly.co), we receive your order details (such as your name, shipping address and the products you bought) so we can fulfil the order. Store orders are not linked to your GRLY app account. Payments and checkout are handled by Shopify under its own privacy policy; we do not receive full payment card numbers.

What we do not collect: we do not collect your precise location, your contacts, or your photo library; we do not use advertising identifiers (such as Apple's IDFA or Google's GAID); and we do not ask for App Tracking Transparency permission, because we do not track you across other companies' apps or websites.

3. How We Use Your Information & Our Legal Bases

Create and manage your account — using your account data, on the basis of performance of a contract.
Provide the core features (supplement tracking, reminders, label analysis, insights, and keeping your own record: your check-ins, your journal and what you take each supplement for) — using your account, wellness/health, and label-scan data, on the basis of your explicit consent (Art. 9(2)(a)) for health data and performance of a contract for other data.
Share your progress with people you choose — using your shared accountability data, on the basis of your explicit consent, given separately for each partner.
Apply your plan's limits and provide Premium you've bought — using your purchase record and feature use, on the basis of performance of a contract.
Understand which parts of GRLY people choose to pay for — using which screen a purchase came from, on the basis of legitimate interests.
Fulfil your store orders if you shop at grly.co — using your order data, on the basis of performance of a contract.
Tell you when GRLY is on Android, if you join the waitlist — using your email address, on the basis of your consent.
Secure the Services, prevent abuse and fraud, debug, and improve the app — using your account and device/technical data, on the basis of legitimate interests.
Communicate with you about your account and notify you of changes — using your account data, on the basis of legitimate interests and legal obligation.
Comply with law and respond to lawful requests — on the basis of legal obligation.

Marketing. We send marketing email only to people who ask for it. Today that means our Android waitlist: if you join it, we send one email to confirm your address and then one more when GRLY is available on Android. Every waitlist email has a link to leave the list, or you can email connect@grlyapp.co; once you leave, we don't email you again and we delete your address. We do not send marketing push notifications. If we introduce other marketing, we will rely on your consent where required and always give you a way to opt out.

We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising (as those terms are defined under California law). We do not use third-party advertising networks, do not serve targeted ads based on your health data, and do not track you across other companies' apps or websites. The app contains no third-party advertising or analytics software. Our App Store page lists two things under “Analytics”: if you sign in with Google, Google's sign-in software may collect information under Google's own policy (Section 2), and we note which screen in the app a purchase came from, to understand what people choose to pay for (Section 3). Neither is used for advertising or to track you across other apps. Our website uses its host's cookie-free visit statistics and page-speed measurements, only to improve the website (Section 6); they do not identify you or follow you to other sites. We honor browser "Do Not Track"/Global Privacy Control signals where required by law.

Because GRLY helps you track supplement intake, we process information about your health. The law treats this as a special category requiring a higher standard of protection, and we will not process your health data without your explicit consent.

How we obtain consent. During onboarding, before the health questions, you are shown a dedicated consent screen explaining what health data we process and why. To proceed you must actively tick an unchecked box. We record the fact, time, and policy version of your consent.

Your journal. Entries you write in the journal are stored encrypted on our servers and on your device, and are shown only to you, in the app. We never sell them or use them for advertising, and we never send them to any artificial-intelligence service — no AI reads, writes or summarises your journal. If you dictate an entry, your device’s built-in speech recognition turns it into text on the device: no audio is sent to us, and none is kept. You can edit or delete any entry at any time; a deleted entry is permanently removed from our servers.

Withdrawing consent. You can withdraw at any time in the app (Settings → Health data processing) or by emailing connect@grlyapp.co. Because GRLY cannot track your supplements without processing this data, withdrawing consent deletes your account and the data in it (Section 12 explains how deleted data leaves our backups). The app tells you this and asks you to confirm before anything is deleted. If you withdraw by email, we stop processing your health data and delete your account as soon as we've confirmed the request is yours. Withdrawal does not affect processing carried out before you withdrew.

Sharing works differently. Your consent to share with a partner is separate from your health-data consent. You withdraw it by pausing, unpairing or blocking, and your account stays. Withdrawing your health-data consent deletes your account, which also ends all your sharing.

We share information only as needed to run GRLY, with service providers ("processors") who act on our instructions under a data-processing agreement and may use your data only to provide services to us. They are US-based unless noted:

DigitalOcean — cloud hosting and database for the Services.
OpenAI — analyzes the supplement-label image/text you scan to identify the product.
Google; Apple — sign-in, if you choose "Continue with Google/Apple".
Vercel — hosts our website (grlyapp.co), passes messages you send through its contact form on to us, and provides its cookie-free visit statistics and page-speed measurements, which we use only to improve the website. These record the page, the referring site, your browser, operating system and device type, your approximate location (country, region and city), which of our links and buttons you use (such as the App Store and shop links), and how quickly the page loaded and on what type of connection; they use no cookies, and the short-lived code Vercel uses to tell visits apart is discarded after 24 hours. They are not collected for visitors in the EU, Iceland, Liechtenstein, Norway or Switzerland, or when your browser sends a Global Privacy Control or Do Not Track signal, and you can turn them off on our Your data page.
Apple Push Notification service — delivers the reminders you enable and notifications from people you pair with.
Resend — sends transactional emails (e.g., verification, password reset), delivers messages you send through our website's contact form to our inbox, and keeps our Android waitlist and sends its emails.
Microsoft (Microsoft 365) — hosts our email inbox at connect@grlyapp.co, where your support requests and data requests arrive.
Sentry (in the EU, Germany) — receives crash and diagnostic reports from the app and our servers so we can fix faults, including a daily count of the times iOS closed the app. These reports carry technical details such as the app version and device model, and we filter them to keep your health information out.
Shopify — runs the GRLY store and processes checkout and orders.

We may also disclose information where required by law or to protect rights and safety, and to a successor entity in the event of a merger, acquisition, or sale of assets (subject to this Policy). These third parties process information under their own privacy policies, which we do not control; we encourage you to review them.

Sharing with someone you choose

Shared accountability is optional. You can pair with up to five people, either by inviting them or by accepting their invite with a single-use code. Nothing is shared until both of you have confirmed on screen and agreed to share with that specific person.

What your partner sees: your first name; for each day so far of the plan you share with them (plans run 7, 14, 30, 60 or 90 days), whether each of you finished your part that day (a rest day counts neither way), and how many of the supplements you put in that plan you've taken, shown as unnamed dots; your current streak; when your phone last updated; and whether you have paused sharing. Your partner never sees which supplements you take, your journal, or any other health information.

Notifications: people you pair with can send you a few preset nudges (up to three a day), and either of you may be notified about your pairing (for example, an invite accepted or a new plan started), a streak milestone, or a check-in still open in the evening. These notifications are delivered through Apple's push notification service and can appear on the other person's lock screen with your first name. We don't keep a copy of them.

How we store it and for how long: the daily summaries your phone sends are encrypted on our servers. We rely on your explicit consent, which you give separately for each partner. You can pause, unpair or block at any time, and pausing hides your information straight away. We delete your summaries and streak when your last partnership ends or you withdraw consent. We delete nudge records after 2 days, invite records 30 days after the invite ends, and ended partnerships after 30 days. If you block someone, we keep the block until either account is deleted, so it keeps working. When you delete your account, we delete all of it.

7. Cookies & Similar Technologies

The GRLY mobile app does not use advertising or third-party analytics cookies. Our website (grlyapp.co) sets no cookies, and its visit statistics are cookie-free. The only thing it stores in your browser is your choice to turn those statistics off, if you make that choice. Our store (grly.co) runs on Shopify, which sets its own cookies on the store's pages, including when you open the store in the app's Shop tab. Some are needed for shopping, cart and checkout; others are Shopify's own analytics and marketing cookies. Those are governed by Shopify's cookie and privacy policies. Where required by law, we will request your consent for any non-essential cookies. You can control cookies through your browser settings.

8. International Data Transfers

We operate from, and process data in, the United States. If you use GRLY from outside the US (including the UK, EU, or Switzerland), your information is transferred to and processed in the US. Where required, we rely on appropriate safeguards for these transfers — such as the European Commission's Standard Contractual Clauses, together with the UK International Data Transfer Addendum and the Swiss equivalent — in our agreements with service providers. You can contact us for more information about these safeguards.

9. Automated Decision-Making, Profiling & AI

We do not use your personal data to train large language models or other AI models, and our label-analysis provider does not use the label images we send it to train its models. We do not carry out automated decision-making that produces legal or similarly significant effects on you, and we do not build advertising or behavioral profiles about you. Any insights we show (for example, your monthly Wrapped or your Pulse trends) are based on your own data and do not involve solely-automated decisions about you.

10. How We Protect Your Information

We use technical and organizational measures appropriate to the sensitivity of the data, including:

Encryption in transit — all communication between the app and our servers uses HTTPS/TLS.
Encryption at rest — our managed database and your device's storage are encrypted at rest; authentication tokens are held in the iOS Keychain, and account passwords and password-reset tokens are stored only in hashed form.
Access controls & least privilege — access to personal data is authenticated and limited to what is needed to operate the Services; each account can access only its own data.
Data minimization — we collect only what we need, embed no advertising trackers anywhere, and embed no third-party analytics in the app.

No method of transmission or storage is completely secure, but we work to protect your information and continually improve our safeguards.

11. Data Breach Notification

We maintain procedures to detect, investigate, and respond to personal-data breaches. If a breach is likely to affect your rights, we will notify the relevant supervisory authority and, where required, affected users without undue delay and within the timeframes required by law (under the GDPR, within 72 hours of becoming aware of a notifiable breach).

12. Data Retention

We keep personal information only as long as needed for the purposes in this Policy, then delete or de-identify it. Indicative periods:

Account & wellness/supplement data — for the life of your account. On account deletion, removed from active systems immediately; residual copies in encrypted backups are overwritten on the normal backup cycle (typically within about a week).
Label-scan images & analysis — retained only transiently to perform the analysis and deleted shortly afterward (target: within 24 hours). Our analysis provider, OpenAI, may keep what we send it for up to 30 days to detect abuse, then deletes it; it does not use it to train its models.
Purchase records — for the life of your account, so Premium keeps working and refunds can be traced; deleted when you delete your account.
Feature-use counts — scan and nutrient-page counts for the current month only, reset each month; which Wrapped editions you've opened, for the life of your account.
Crash and diagnostic reports — kept by Sentry for up to 90 days, then deleted.
Phones registered for notifications — until the phone hasn't opened GRLY for 60 days, or you delete your account.
Shared accountability — your daily summaries and streak until your last pairing ends or you withdraw your consent to share; a finished plan's day summaries for 30 days after the plan ends; nudge records for 2 days; invite records for 30 days after the invite ends; ended pairings for 30 days; blocks until either account is deleted.
Consent records — for the life of your account plus a limited period afterward, as evidence that consent was given and/or withdrawn.
Support communications — for as long as needed to handle your request and a reasonable period afterward.
Android waitlist — if you don't confirm your address within 7 days, the link expires and you aren't added. Otherwise we keep your address until you leave the list or we've sent the email saying GRLY is on Android. We delete the whole list within 30 days of sending that email, or if we decide not to bring GRLY to Android.
Records required by law — as long as required for legal, security, tax, or accounting purposes.

13. Children

GRLY is not directed to children under 13, or under 16 where a higher age of digital consent applies (including parts of the UK and EU). You must be at least 16 years old to use GRLY. We do not knowingly collect personal information from children below the applicable age. If we learn that we have, we will delete it. If you believe a child has provided us information, contact connect@grlyapp.co.

14. Your Privacy Rights

Subject to your location and applicable law, you have the rights below. To exercise any of them, email connect@grlyapp.co; we may need to verify your identity. We respond within the time required by law — generally within one month under the GDPR/UK GDPR (extendable by up to two further months for complex requests, with notice).

Access & portability — request a copy of the personal information we hold about you.
Correction — ask us to correct inaccurate or incomplete information.
Deletion / erasure — delete your account in the app (Menu/Settings → Delete Account), which removes your account and associated data from our active systems, or ask us to delete your information.
Withdraw consent — at any time; because the app cannot work without it, this deletes your account (Section 5).
Restriction & objection — ask us to restrict or object to certain processing.
Manage device permissions — control notifications and camera access in the app or your device settings.

You will not be discriminated against for exercising these rights. If you are unhappy with our response, you may have the right to complain to your data protection authority (Section 16).

15. US State Privacy Rights

Depending on the state you live in (for example, Connecticut, Virginia or Colorado), you may have the right to confirm whether we process your personal data, and to access, correct, delete and get a portable copy of it. Those laws also give a right to opt out of the sale of personal data, targeted advertising and certain profiling; we do none of these. To make a request, email connect@grlyapp.co. Appeals: if we decline your request, you can appeal by replying to our decision or emailing connect@grlyapp.co with “Appeal” in the subject line. We answer appeals within 60 days. If we deny your appeal, you can contact your state Attorney General, including the Connecticut Attorney General’s office.

Residents of Washington and Nevada have a separate consumer health data privacy policy, linked from the foot of every page of our website.

California (CCPA/CPRA)

California residents may request to know, access, correct, or delete the personal information we hold, and may use an authorized agent. We do not sell or "share" personal information for cross-context behavioral advertising, so there is no opt-out needed in that respect. We collect the categories in Section 2, for the purposes in Section 3, and disclose to the service providers in Section 6. You have the right not to receive discriminatory treatment for exercising your rights. To make a request, email connect@grlyapp.co.

16. UK, EU & Swiss Users

This section applies if you are in the United Kingdom, European Economic Area, or Switzerland, and supplements the rest of this Policy. The controller is Ourskin, Inc.

Legal bases are in Section 3; we process your health data only on the basis of your explicit consent, which you can withdraw at any time.
Your rights include access, rectification, erasure, restriction, objection, data portability, and withdrawal of consent (Section 14).
Complaints — you may lodge a complaint with your supervisory authority: in the UK, the Information Commissioner's Office (ICO); in the EEA, your national data protection authority; in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC).
International transfers — see Section 8.

Our Article 27 representatives:

EU representative: to be appointed
UK representative: to be appointed

Until appointed, please direct all requests to connect@grlyapp.co.

17. Users in Other Regions

Wherever you use GRLY, this Policy applies to you, and you may have additional rights under your local privacy law — for example, Australia's Privacy Act and the Australian Privacy Principles, Canada's PIPEDA, or New Zealand's Privacy Act. To exercise any such rights, contact connect@grlyapp.co.

18. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will update the "Last updated" date above and, where appropriate, notify you in the app or by other means. If a change materially affects how we process your health data, we will ask you to review and re-confirm your consent.

19. Contact Us

For any question or request about this Policy or your personal information, contact us at connect@grlyapp.co, or write to Ourskin, Inc., 1111B South Governors Ave, Dover, DE 19904, USA.

This Policy is published in English, the language of the app, and is built to work with screen readers and other assistive technology. If you need it in another format, contact us.