Privacy Policy
Last updated: April 29, 2026
1. Data Controller
PMC Baltic FZ-LLC (LICENCE NO: 45001684) (“we”, “us”, “our”) is the data controller responsible for your personal data.
Address: SFFO0507 Compass Building Al Shohada Road AL Hamra Industrial Zone-FZ Ras Al Khaimah United Arab Emirates Email: hello@Perfectela.com
2. What Categories of Personal Data Do We Collect?
We collect both data you voluntarily provide, for example, your email address, name, photographs, facial images, quiz answers, or profile information, and data generated automatically when you use Perfectela, for example, your IP address or device information.
2.1 Data You Provide
You provide personal data when you:
- register or create an account;
- complete quizzes, questionnaires, facial assessments, beauty assessments, or profile inputs;
- upload facial photographs, progress photographs, self-check images, or other visual content;
- purchase Perfectela;
- use facial analysis, Beauty Protocol, coaching, or personalized recommendation features;
- contact Customer Support;
- respond to our emails;
- submit feedback;
- report a technical issue.
2.2 Automatically Collected Data
How You Found Us
We collect information about how you arrived at Perfectela, including referral websites, advertising campaigns, or marketing links.
Cookies and Similar Technologies
We use cookies, local storage, and similar technologies to improve your experience. For more information, please see our Cookie Policy.
Browser and Device Information
We automatically collect technical information including:
- IP address;
- browser type;
- operating system;
- device model;
- language;
- time zone;
- referring URLs;
- usage information.
Payment Information
Payments are processed by our third-party payment providers. We do not store your complete payment card details.
Personal Data We Process
| Category | Fields | Purpose | Legal Basis | Retention |
|---|---|---|---|---|
| Email address | Create your account, deliver analysis results, and send transactional emails | Contract, Art. 6(1)(b); Consent, Art. 6(1)(a), where applicable | Active account or 90 days for abandoned sessions | |
| Quiz and assessment answers | quiz_answers, beauty concerns, skincare information, profile inputs | Generate personalized beauty insights, facial analysis, Beauty Protocols, and recommendations | Contract, Art. 6(1)(b); Consent, Art. 6(1)(a); Explicit consent, Art. 9(2)(a), where the information constitutes special-category personal data | Active account or 90 days |
| Facial and progress images | facial photographs, self-check images, progress photographs | Provide facial analysis, personalized recommendations, progress tracking, and comparison features | Contract, Art. 6(1)(b); Consent, Art. 6(1)(a), where applicable; Explicit consent, Art. 9(2)(a), where the processing involves special-category personal data | Duration of account or until deleted |
| Personalized result | result_segment, facial analysis, Beauty Protocol | Tailor skincare guidance, facial exercises, educational content, and plan activities | Contract, Art. 6(1)(b); Legitimate interest or Consent, where applicable | Active account or 90 days |
| Payment identifiers | solidgate_order_id, solidgate_subscription_id, saved-card token | Process payments, subscriptions, and refunds | Contract, Art. 6(1)(b) | 7 years |
| Order history | amount, currency, product, status | Accounting and purchase history | Contract + Legal obligation | 7 years |
| Progress data | completed lessons, routines, facial practices, progress status, self-checks, plan activity | Resume user progress and improve the experience | Contract | Duration of account |
| Coach interactions | questions, messages, consultation history | Provide personalized beauty guidance and respond to user questions | Contract | Duration of account |
| Login security | email, IP address, login attempts | Fraud prevention and security | Legitimate interest | 30 days |
| Usage analytics | events, pages or screens visited, metadata | Product improvement and analytics | Consent | Up to 2 years |
| Subscription access | subscription status, access level | Grant access to purchased content and features | Contract | Duration of account |
3. For What Purposes Do We Process Your Personal Data?
We process your personal data for the following purposes.
3.1 Service Provision
To provide access to Perfectela, personalized facial analysis, Beauty Protocols, skincare guidance, facial exercise programs, educational content, structured daily activities, expert guidance, progress tracking, and related features.
3.2 Product Personalization
To analyze the information and photographs you provide, generate personalized facial analysis results, create Beauty Protocols, and tailor skincare guidance, facial exercises, educational content, consultations, and plan activities.
Perfectela provides beauty, wellness, and educational guidance and is not intended to diagnose medical conditions or replace professional medical, dermatological, or aesthetic advice.
3.3 Research and Analytics
To understand how users interact with Perfectela and improve its functionality, content, and features.
3.4 Payment Processing
To process purchases, trial payments, subscriptions, renewals, cancellations, and refunds.
3.5 Fraud Prevention and Security
To detect unauthorized access, abuse, fraud, or other security incidents.
3.6 Communication
To send transactional emails, account notifications, analysis availability notices, customer support responses, and service-related communications.
3.7 Marketing
With your consent where required, we may send newsletters, promotional offers, Perfectela updates, skincare information, beauty guidance, facial exercise content, and educational materials.
3.8 Customer Support
To respond to questions, complaints, cancellation requests, refund requests, account issues, and technical problems.
3.9 Advertising
To measure advertising performance and personalize marketing campaigns where permitted by applicable law.
3.10 Legal Obligations
Where required by law, we may disclose information to governmental authorities, courts, regulators, or law-enforcement bodies.
4. Data Storage and Transfer
We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by applicable law.
When your account is closed or information is deleted, certain information may remain temporarily in backup systems or be retained where necessary for accounting, fraud prevention, dispute resolution, legal compliance, or the establishment, exercise, or defence of legal claims.
Where necessary, your personal data may be transferred outside the European Economic Area using appropriate safeguards. Depending on the recipient and circumstances, these safeguards may include Standard Contractual Clauses, adequacy decisions, the EU-U.S. Data Privacy Framework where applicable, or other legally recognized transfer mechanisms.
5. Third-Party Data Recipients
We share personal data only with service providers that help us operate Perfectela. They process personal data according to applicable law, contractual obligations, and, where acting as processors, our instructions.
| Service | Role | Data Shared | Location | Transfer Mechanism |
|---|---|---|---|---|
| Solidgate | Payment processor | Payment card details entered in the secure payment form, payment identifiers, email, purchase information | Service region | Appropriate safeguards, as applicable |
| Google Tag Manager, Google Analytics / Google Ads | Analytics and advertising | Analytics identifiers, usage information | USA | EU-U.S. Data Privacy Framework, SCCs, or other appropriate safeguards, as applicable |
| Meta Pixel / Conversions API | Advertising | Hashed email, device information, events | USA | EU-U.S. Data Privacy Framework, SCCs, or other appropriate safeguards, as applicable |
| ActiveCampaign | Email delivery | Email address, subscription status, communication activity | USA | Standard Contractual Clauses or other appropriate safeguards, as applicable |
| PostHog | Analytics | Session information, product events | EU | EU data residency or other appropriate safeguards, as applicable |
| Supabase | Database hosting and authentication | User accounts, subscriptions, product data, progress information, facial images, and submitted content | Project region | Appropriate safeguards, as applicable |
| Vercel | Website and app hosting; AI Gateway that routes analysis and coaching requests | Technical request information, facial images, assessment answers, and coach messages sent for processing | USA | EU-U.S. Data Privacy Framework, SCCs, or other appropriate safeguards, as applicable |
| Google (Gemini) | AI facial analysis, reports, and image generation | Facial images, assessment answers, and related analysis inputs | USA | EU-U.S. Data Privacy Framework, SCCs, or other appropriate safeguards, as applicable |
| OpenAI | AI coach | Coach messages and related profile context | USA | EU-U.S. Data Privacy Framework, SCCs, or other appropriate safeguards, as applicable |
| Resend | Transactional email delivery | Email address and email content | USA | EU-U.S. Data Privacy Framework, SCCs, or other appropriate safeguards, as applicable |
We may also disclose personal data to professional advisers, governmental authorities, regulators, courts, or law-enforcement bodies where required by law.
We never sell your personal data.
6. Your Rights
Subject to applicable law, you have the right to:
- access your personal data;
- correct inaccurate information;
- request deletion of your personal data;
- request deletion of facial images and progress photographs;
- restrict processing;
- object to certain processing activities;
- withdraw consent at any time where processing is based on consent;
- receive your personal data in a structured, commonly used format;
- lodge a complaint with your local supervisory authority.
Deleting certain information, including facial images, facial analysis data, or account information, may prevent us from providing some Perfectela features.
To exercise your rights, contact us at hello@Perfectela.com. We may request information reasonably necessary to verify your identity.
7. Contact Information
If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact us: