Privacy Policy

Introduction

Sylvan Labs Inc. (“we”, “our”, or “us”) operates the Vortex mobile application (“the App”). We are committed to safeguarding your privacy and complying with applicable data-protection laws, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”). This document explains what information the App collects, how it is used, and the rights available to you.

1. Information We Collect

1.1 Information You Provide

• Voluntary correspondence (e.g., support email inquiries)

1.2 Information Automatically Collected

• Device information: model, operating system version, unique device identifiers, and randomly-generated advertising identifiers (if enabled by your device).
• Usage data: session length, screen interactions, crash logs, and analytics events that help us improve usability.

1.3 Sensitive Permissions (Only if you elect to use applicable features)

• Camera access – required to provide real-time try-on services within the App.
• Photo-library access – needed if you choose to upload a still image for make-up visualization.

Neither permission is required to access basic App functions; you may decline and still use the majority of the App.

1.4 Location Data

We do not collect precise or coarse location data.

1.5 Children

The App is not intended for children under 18. We do not knowingly collect personal data from children under 18. If you believe a minor has provided us personal information, please contact us support@vortex.com and we will delete such data promptly.

2. How We Use the Information

We use collected data for the following purposes:

1. To deliver core mobile application services, such as virtual try-on.
2. To monitor, analyze, and improve performance, stability, and user experience.
3. To respond to customer-support requests and feedback.
4. To fulfill legal obligations and enforce our Terms of Service.

3. Legal Bases (EEA/UK users)

Our processing is based on:
• Contract – providing the service you request.
• Legitimate interests – improving and securing the App, provided these interests are not overridden by your rights.
• Consent – when we rely on optional permission prompts (e.g., camera).

4. Third-Party Service Providers

We may employ vendors that assist with hosting, analytics, and app diagnostics. These providers process information solely on our behalf under confidentiality requirements and are prohibited from using data for their own purposes.

5. Data Retention & Security

We retain usage-level analytics for up to twenty-six (26) months, after which it is automatically deleted or anonymized. Image data processed from the camera or photo library remains locally on your device unless you explicitly save it to your in-app portfolio; no images are stored on our servers. We employ industry-standard technical measures—including TLS encryption in transit and least-privilege access controls—to secure your data.

6. International Transfers

We are headquartered in the United States. If you use the App outside the U.S., you understand your data may be processed in the U.S. and other jurisdictions which may have data-protection laws that differ from your jurisdiction. We rely on lawful transfer mechanisms such as Standard Contractual Clauses where required.

7. Your Privacy Rights

Depending on where you live, you may have the right to:

• Access a copy of personal data we hold.
• Correct or update inaccurate data.
• Request deletion (subject to legal exceptions).
• Object or restrict processing for legitimate interests.
• Opt out of targeted advertising (done through device settings).
• Port personal data you provided to you or another company.
• Lodge a complaint with a supervisory authority.

To exercise any of these rights, email us at support@vortex.com. We will respond within thirty (30) days.

8. Changes to This Privacy Policy

We may update this policy occasionally. When we do, we will change the “Effective” date above and, where changes are substantial, provide an in-app notice or email. Continued use of the App after such changes constitutes acceptance of the revised policy.

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