FadeMax

Privacy Policy

Last updated: June 22, 2026

1. Controller

The controller for personal data processed through FadeMax is 03 Studios, operated by Manuel Thurner, Weinstraße 6, 39057 Girlan BZ, Italy, email contact@03-studios.com.

2. Scope of This Policy

This Privacy Policy covers the FadeMax iOS app, related account and purchase flows, backend processing, AI analysis and preview generation, and this public legal page. FadeMax is an iOS app for AI-assisted hairstyle, beard, and hair-color analysis and realistic try-on previews.

3. Categories of Personal Data We Process

Authentication and account data. To use account-based features, you may sign in with Sign in with Apple or Google Sign-In through Supabase Auth. We process identifiers such as your Supabase user ID, session state, access-token-related authentication data, and email address where provided by the identity provider.

Uploaded photos and user content. Users voluntarily capture or select front and optional side-profile photos. We also process onboarding answers, selected style preferences, generated analysis results, and preview images needed to provide the requested hairstyle, beard, and hair-color experience.

Purchase, credit, and entitlement data. FadeMax processes purchase history, consumable credit balances, credit ledger records, StoreKit transaction state, restore and entitlement information, paywall interaction events, product interaction data, and related account identifiers needed to provide paid features and prevent abuse.

Device, diagnostics, and operational data. We may process device identifiers or installation identifiers, product interaction data, request metadata, logs, error reports, and other diagnostic data needed to operate, secure, debug, and improve the service. FadeMax does not use this data for cross-app or cross-website tracking.

Analytics and product interaction data. We may process usage events and Firebase Analytics data such as screen views, onboarding progress, selected style or category IDs, app language, audience preference, feature usage, analysis and try-on flow status, paywall and purchase flow events, restore events, settings changes, rating prompt events, timing information, diagnostics, and device or app-instance identifiers.

Support and contact data. If you contact us, we process the contact information and message content you provide so that we can respond and document the request.

4. Sources of Personal Data

  • directly from you when you sign in, answer onboarding questions, upload photos, request previews, make purchases, use credits, or contact us;
  • from Apple or Google as identity providers through Supabase authentication flows;
  • from Apple StoreKit and Superwall for purchase, paywall, restore, entitlement, and product interaction flows;
  • from Supabase and OpenAI when they return processing, account, credit, analysis, image editing, or generation results to us; and
  • from your device as part of ordinary app, network, local storage, and diagnostic operations.

5. Purposes and Legal Bases

  • Provide the service. We authenticate users, process voluntary photos and preferences, generate AI-assisted hairstyle, beard, and hair-color recommendations, create preview images, manage credits, and restore purchases. Legal basis: Article 6(1)(b) GDPR, performance of a contract or pre-contractual steps requested by you.
  • Maintain security and prevent abuse. We validate requests, manage account and credit ledgers, detect misuse, maintain operational logs, and protect the service. Legal basis: Article 6(1)(f) GDPR, legitimate interests in service security, fraud prevention, and infrastructure integrity.
  • Operate purchases and accounting records. We process purchase and entitlement information needed for consumable credits, refunds, restore flows, bookkeeping, tax compliance, and legal defense. Legal basis: Article 6(1)(b), 6(1)(c), and 6(1)(f) GDPR, depending on the context.
  • Improve app quality and product flows. We use limited analytics and diagnostics to understand aggregate feature usage, onboarding drop-off, analysis and try-on reliability, paywall outcomes, and app quality. Legal basis: Article 6(1)(f) GDPR, legitimate interests in improving and securing the service.
  • Handle support and legal requests. We answer support messages, deletion requests, and privacy rights requests, and preserve records where legally necessary. Legal basis: Article 6(1)(b), 6(1)(c), and 6(1)(f) GDPR.

6. Analysis and Automated Processing Disclosure

FadeMax performs automated styling analysis and image generation using AI systems. Users voluntarily provide front and optional side-profile photos so FadeMax can analyze visible styling characteristics such as face shape, profile balance, hairline, hair density, hair texture, beard area, and current hairstyle, and then generate hairstyle, beard, and hair-color suggestions and realistic preview images.

This processing is part of the core service you request. FadeMax does not identify people. Results are probabilistic, aesthetic styling suggestions and should not be treated as medical, legal, or otherwise binding decisions.

7. Analytics and Diagnostics

We use Firebase Analytics to understand how people use FadeMax and where important flows succeed or drop off. This may include custom events for onboarding steps, authentication outcomes, photo capture choices, analysis and try-on generation, style selection, saved or shared previews, paywalls, purchases, restores, settings changes, and rating prompt triggers.

Analytics events use stable IDs, counts, timing, source, status, and error-type values. We do not send your photos, email address, name, or free-form text as Firebase Analytics event parameters, and we do not use Firebase Analytics for advertising or cross-app tracking.

8. Face Data and Uploaded Media

FadeMax is an AI-assisted hairstyle, beard, and hair-color analysis and preview tool. Users may voluntarily capture or select front and optional side-profile photos so FadeMax can provide the requested styling analysis, recommendations, and preview images.

FadeMax does not collect biometric face data, biometric information, facial templates, faceprints, facial recognition identifiers, or permanent facial-geometry records.

FadeMax does not perform facial recognition, biometric identification, biometric authentication, face tracking, faceprints, facial templates, identity matching, or permanent facial-geometry extraction.

If a submitted photo contains a face, the face is processed only as part of the voluntary styling photo submitted by the user. FadeMax uses visible styling characteristics, such as face shape, profile balance, hairline, hair density, hair texture, beard area, and current hairstyle, only to provide the requested hairstyle, beard, and hair-color advice and preview generation.

FadeMax does not use photos, faces, or visible styling characteristics for advertising, tracking, sale, identity recognition, biometric profiling, analytics, or decisions unrelated to the requested styling analysis and preview generation.

Photos may be transmitted to Supabase Edge Functions and OpenAI only to perform the requested analysis, image editing, or preview generation. Uploaded and processed photos are not retained longer than necessary to complete analysis and generation, and temporary processing data is deleted after the requested processing completes.

Local history, generated previews, and related results may be stored on the user's device. Local device data remains under the user's control and can be removed through app features where available, by clearing app data where supported, or by deleting the app from the device.

9. Recipients and Processors

We disclose personal data only where needed to operate FadeMax, provide the requested analysis or preview generation, process purchases, comply with law, or protect legitimate interests.

  • Supabase supports authentication, sessions, user IDs, database storage, credit state, purchase and credit ledgers, account state, and Edge Functions used for backend processing.
  • OpenAI receives photos and related prompt context needed for AI photo analysis, image editing, and generation of requested hairstyle, beard, and hair-color previews.
  • Superwall supports paywall presentation, paywall events, product interaction flows, and related purchase orchestration.
  • Firebase supports analytics, app-instance identifiers, product interaction events, diagnostics, and usage statistics used to improve core app flows.
  • Apple supports App Store distribution, StoreKit purchases, consumable credits, purchase validation, restore and entitlement flows, Sign in with Apple, and iOS platform services.
  • Google Sign-In supports optional Google authentication where you choose that sign-in option.
  • Google Fonts or related font tooling may support website font delivery for the public landing page. Font processing is separate from FadeMax app photo analysis and does not receive uploaded photos.

10. Processor List

11. International Transfers

Several service providers used by FadeMax are established or operate infrastructure outside Italy or the European Economic Area, including in the United States. International transfers may therefore occur, in particular in connection with Supabase, OpenAI, Superwall, Firebase, Apple, Google Sign-In, and Google Fonts or related font tooling. Where required, such transfers must be covered by an adequacy decision, the EU-U.S. Data Privacy Framework where applicable, or appropriate safeguards such as the European Commission's Standard Contractual Clauses together with supplementary measures.

12. Retention

Photos and processing data. FadeMax does not store biometric face data, faceprints, facial templates, or facial recognition identifiers. Photos are transmitted to Supabase Edge Functions and OpenAI only as needed for analysis, image editing, or preview generation. Temporary photo and processing data is processed only as long as needed to complete the requested analysis or generation and is deleted after processing completes.

Local history and previews. Local history, generated previews, and related results may remain on the user's device under the user's control. Users can remove local data through app features where available, by clearing app data where supported, or by deleting the app from the device.

Account, purchase, credit, and ledger records. Supabase stores account, credit, purchase, and ledger data for as long as needed to operate the service, provide purchase proof, administer consumable credits, prevent fraud, comply with tax and accounting duties, and defend legal claims.

Apple purchase records. Apple may retain App Store and StoreKit purchase history according to Apple's own policies and legal obligations. Refunds, purchase history, and App Store billing records are managed through Apple.

Logs and support requests. Operational logs, diagnostic records, and support requests are retained for as long as needed for service operation, security, troubleshooting, support, legal compliance, or legal defense.

Analytics data. Firebase Analytics and product interaction data is retained according to Firebase retention settings and policies and is used only for measurement, diagnostics, and product improvement, not for advertising or cross-app tracking.

13. Deletion and Account Closure

The FadeMax app provides a Delete account function in Settings. Account deletion removes the Supabase account profile and associated app-side personal data where technically possible, unless continued retention is required for legal obligations, purchase proof, accounting, fraud prevention, security, or legal defense.

If you cannot access the app, you can request deletion through the public FadeMax account deletion page: https://03-studios.com/fademax/delete-account.

Account deletion does not necessarily delete App Store or StoreKit purchase history retained by Apple. Refunds, purchase records, and App Store billing issues must be managed through Apple. Local history and preview data on the device can be removed through app features where available, by clearing app data where supported, or by deleting the app.

14. Tracking, Sales, and Advertising

FadeMax does not sell personal information. FadeMax does not use uploaded photos, faces, or visible styling characteristics for advertising, third-party tracking, cross-app tracking, cross-website tracking, identity matching, biometric profiles, or analytics. Firebase Analytics data is used solely for app measurement, diagnostics, and product improvement. The iOS privacy disclosures for FadeMax are intended to reflect processing of Photos or Videos, Other User Content, Email Address, User ID, Purchase History, Product Interaction, Device ID, and Other Diagnostic Data, with no tracking where no tracking occurs.

15. Your Choices and Rights

You can choose not to provide photos, sign out, delete your account, remove local history where available, delete the app, or contact us about privacy requests. Some features may not work without the information required to provide them. Subject to applicable law, you may request access, correction, deletion, restriction, objection, portability, or withdrawal of consent where consent is the legal basis for processing.

16. Children

FadeMax is not intended for children under 13, and we do not knowingly collect personal information from children under 13.

17. Complaints

You have the right to lodge a complaint with the competent supervisory authority, including the Italian data protection authority (Garante per la protezione dei dati personali): https://www.garanteprivacy.it.

18. Changes to This Policy

We may update this Privacy Policy to reflect changes in the law, FadeMax, or our processor chain. The current version is published on this page with its effective date.

19. Contact

If you have questions about this Privacy Policy, contact us at contact@03-studios.com.