This Privacy Policy ("Policy") describes how Aura Beauty App ("Aura", "we", "us", or "our") collects, processes, stores, and protects your personal data when you use our mobile and web application (the "App")..
We are committed to protecting your privacy and ensuring that your personal data is handled in accordance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL") and all applicable implementing regulations issued by the UAE Data Office.
This Policy applies to:
This Policy does not apply to third-party websites, applications, or services that may be linked from our App. We encourage you to review the privacy policies of any third-party services you visit.
Personal DataAny information that directly or indirectly identifies a natural person, as defined under Article 1 of the UAE PDPL.
Sensitive Personal DataData relating to racial or ethnic origin, health, biometric data, genetic data, or any other category designated as sensitive under the PDPL.
Biometric DataPersonal data resulting from specific technical processing relating to physical or physiological characteristics that allows unique identification of a person, including facial scan data.
ProcessingAny operation performed on personal data, including collection, storage, use, disclosure, or deletion.
Data ControllerThe entity that determines the purposes and means of processing personal data — in this case, Aura Beauty App.
Data ProcessorA third party that processes personal data on behalf of the Data Controller.
UAE Data OfficeThe competent supervisory authority responsible for overseeing the application of the UAE PDPL.
Sensitive Data Notice
The following data is classified as Sensitive Personal Data under the UAE PDPL and requires your explicit consent before collection.
Given the nature of our App, we collect and process biometric data and sensitive personal data including facial scans, skin tone, and skin health information. Under the UAE PDPL, such data requires heightened protection.
We will only collect and process your biometric and sensitive personal data after obtaining your freely given, specific, informed, and unambiguous explicit consent. This consent is collected through a dedicated in-app consent screen presented before your first facial scan. You may withdraw this consent at any time.
Your biometric and sensitive data will only be used for:
We will not use your facial scan data for identity verification, advertising profiling unrelated to beauty, or any other purpose without obtaining further explicit consent.
We collect only the minimum biometric data necessary to deliver our services. Facial scan images used for analysis are processed on-device where technically feasible, and only the derived skin analysis outputs (not the raw image) are transmitted to our servers, unless you expressly consent to cloud-based image storage for progress tracking.
Our Commitment
We do not and will never sell, rent, or trade your biometric data, facial scan images, or derived skin analysis data to any third party for commercial gain.
Skin tone data may be considered indicative of racial or ethnic origin under the PDPL. We treat this data as sensitive data accordingly. Skin tone data is used exclusively for the purpose of matching cosmetic products (such as foundation shades) to your complexion, and is never used to make inferences about your racial or ethnic background for any other purpose.
We process your personal data only where we have a valid legal basis to do so under the UAE PDPL:
ConsentFor all biometric and sensitive personal data; for marketing communications; and for optional features such as progress tracking. You may withdraw consent at any time without affecting the lawfulness of prior processing.
Contract PerformanceFor processing necessary to provide the core services of the App, including account management, skin analysis, and personalised recommendations.
Legitimate InterestsFor improving App functionality and security, fraud prevention, and aggregated analytics, where such interests are not overridden by your rights and interests.
Legal ObligationWhere processing is necessary for compliance with applicable UAE law, regulatory requirements, or court orders.
7.1 Data You Provide Directly
7.2 Data Collected Automatically
7.3 Data From Third Parties
8.1 Providing Core Services
8.2 Personalisation and Improvement
8.3 Commercial and Affiliate Operations
8.4 Communication
8.5 Legal and Security
We want to be fully transparent about how facial scanning technology works within Aura Beauty App.
9.1 How the Scan Works
When you initiate a skin scan, your device camera captures a series of images or a short video of your face. Our AI model analyses these to detect and measure:
9.2 Where Processing Occurs
Initial image processing is performed on your device where technically feasible. Derived data outputs (your Skin Profile scores) are transmitted to and stored on our secure servers. Raw facial images are not stored on our servers unless you explicitly opt in to the Progress Photo feature.
9.3 Progress Photo Feature
If you opt in to the Progress Photo feature, we will store timestamped facial images on our secure cloud servers to enable side-by-side comparisons over time. You may delete these images at any time via Account Settings. Opting out will not affect your ability to use the core skin analysis functionality.
9.4 AI Model Training
We may use anonymised and aggregated skin analysis data to improve the accuracy of our AI models. Your identifiable facial images will not be used for AI training without your separate, explicit consent, presented as a distinct opt-in request.
9.5 No Facial Recognition for Identity
Important Clarification
The facial scan feature is used exclusively for skin analysis and beauty recommendations. We do not use it to identify you, verify your identity, or match your face against any external database or government identity system.
We do not sell your personal data. We may share your data only in the following limited circumstances:
10.1 Service Providers and Data Processors
We engage trusted third-party companies to support our operations. These processors act on our instructions and are bound by data processing agreements compliant with the UAE PDPL. Categories include cloud hosting, analytics, customer support, email/notification services, and payment processing. All service providers are prohibited from using your data for their own purposes.
10.2 Affiliate and Commercial Partners
Aura Beauty App participates in affiliate marketing programmes including through DCM Network. The following may be shared with affiliate partners:
Your identifiable personal data, including your name, email address, facial scan data, or detailed skin analysis, is not shared with affiliate or brand partners without your explicit consent.
10.3 Legal Disclosures
10.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to a successor entity. We will notify you via in-app notification and email prior to such a transfer.
Aura Beauty App operates primarily within the UAE. Where your personal data is transferred internationally, we ensure such transfers are made only to countries recognised by the UAE Data Office as providing adequate data protection, or subject to appropriate safeguards such as standard contractual clauses or equivalent mechanisms.
Biometric data and facial scan images are stored on servers located within the UAE or in jurisdictions with equivalent data protection standards. We do not transfer raw biometric data to jurisdictions without adequate protection unless compelled by law.
You may request information about the safeguards in place for any specific international transfer by contacting our Data Protection Officer (see Section 19).
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law.
Data CategoryRetention PeriodAccount DataDuration of account + 12 months after deletion (for legal obligations)Skin Analysis Profile DataDuration of account, or until you delete your Skin ProfileFacial Scan Images (Progress Photos)Until you delete them or close your account; deleted within 30 days of closureRaw Facial Scan Processing DataNot retained after analysis is complete (unless Progress Photo is enabled)Affiliate and Purchase Data3 years from date of interactionCommunication and Support Records3 years from date of interactionLegal Compliance RecordsAs required by UAE law (typically 5–7 years)Consent RecordsDuration of account + 5 years
Upon expiry of the applicable retention period, your data will be securely deleted or anonymised in a manner that prevents re-identification.
As a data subject under the UAE PDPL, you have the following rights. Exercise any right by contacting our Data Protection Officer (Section 19). We will respond within 30 days.
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Right of Access
Request a copy of the personal data we hold about you, including your Skin Profile and account information.
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Right to Rectification
Request correction of any inaccurate or incomplete personal data we hold about you.
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Right to Erasure
Request deletion of your personal data where it is no longer necessary, where you withdraw consent, or where processing is unlawful.
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Withdraw Consent
Withdraw consent at any time, including for biometric data. Manage consents in your Account Settings.
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Restrict Processing
Request that we restrict processing of your data in certain circumstances, such as where you contest its accuracy.
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Data Portability
Receive your personal data in a structured, machine-readable format and transmit it to another controller where feasible.
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Right to Object
Object to processing based on legitimate interests or for direct marketing purposes.
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Lodge a Complaint
If dissatisfied, lodge a complaint with the UAE Data Office at www.dataoffice.gov.ae.
14.1 Technical Measures
14.2 Organisational Measures
14.3 Data Breach Notification
In the event of a personal data breach that poses a risk to your rights and interests, we will notify the UAE Data Office within the timeframe required by the PDPL and will notify affected users without undue delay where the breach is likely to result in a high risk to their rights.
Aura Beauty App is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13 without verifiable parental or guardian consent.
Users aged 13 to 17 may use the App only with the consent of a parent or legal guardian. Biometric data of minors requires explicit parental or guardian consent in addition to the minor's assent.
If you believe we have inadvertently collected data from a child under 13 without appropriate consent, please contact us immediately at privacy@aurabeautyapp.com and we will take prompt steps to delete that data
Cookies and Tracking Technologies
We use cookies and similar tracking technologies in the web version of the App. The types of cookies we use:
Strictly NecessaryRequired for the App to function correctly (e.g., session management, security). These cannot be disabled.
AnalyticsUsed to understand how users interact with the App to improve performance and user experience. Used with your consent.
PreferenceStore your settings and preferences, such as language and display options.
Affiliate & MarketingUsed to track affiliate referrals and measure the effectiveness of affiliate campaigns (e.g., via DCM Network). Used with your consent.
You can manage your cookie preferences at any time through the Cookie Settings panel in the App or your browser settings.
Aura Beauty App operates an affiliate marketing model. When you click on product links within the App, you may be redirected to third-party retailer websites. If you make a purchase following such a click, we may receive a commission from the retailer or through our affiliate network, including DCM Network.
Your personal data is not shared with brand partners or retailers for their independent marketing purposes without your explicit consent.
We may update this Privacy Policy from time to time to reflect changes in our data practices, the services we offer, or applicable law. Where we make material changes, we will:
Your continued use of the App after the effective date of any updated Policy constitutes your acknowledgement of the changes. If you do not agree, you may close your account at any time.
If you have any questions, concerns, or complaints about this Policy or the way we handle your personal data, please contact us:
DPO Email privacy@aurabeautyapp.com
Subject Line"Data Protection Inquiry — [Your Name]"
Response TimeAcknowledgement within 5 business days; substantive response within 30 calendar days
App Support support@aurabeautyapp.com
Website www.aurabeautyapp.com
UAE Data Office www.dataoffice.gov.ae
AddressIFZA Business Park, DDP, Dubai, UAE
