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Privacy Policy

Effective: 13 August 2026

Last updated: 17 October 2026

Applies to: the Mira app and mirafaceapp.com

Controller: CPLEX Management AG

Mira analyses facial measurements and photographs of your face. That is sensitive information, and this policy explains exactly what happens to it — what we collect, who processes it, where it is stored, how long it is kept, and how to have it erased.

1. Who we are

Mira ("Mira", "we", "us") is operated by CPLEX Management AG, a company registered in Baar, Canton of Zug, Switzerland. We are the data controller for the personal data described in this policy.

Contact: hello@miraanalysis.com

This policy covers the Mira iOS application and the website at mirafaceapp.com. It is written to meet the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR).

2. Age requirement

Mira is intended for users aged 16 and over. We do not knowingly collect personal data from anyone under 16. If you believe someone under 16 has created an account or uploaded photographs, email us and we will delete the account and its contents without delay.

3. What we collect

CategoryWhat it isWhere it comes from
AccountEmail address, display name, password credential or Apple sign-in identifierYou, at sign-up
Face dataDerived facial measurements, skin readings and scores, plus five photos per full-report scan. Daily scans save no photos. See §4You, during a TrueDepth camera scan using ARKit
QuestionnaireYour answers about goals, routine, sleep, skin and groomingYou, during onboarding
Analysis outputYour reports, scores, detected traits, daily plans and daily scan historyGenerated from your submissions
SubscriptionSubscription status, plan, renewal and cancellation eventsApple, via RevenueCat. We never receive your card details
Device and usageDevice model, OS version, app version, language, screens viewed, actions taken, crash diagnosticsAutomatically, in the app
Advertising identifiersApple's identifier for advertisers and related attribution signals — only if you allow trackingYour device, after the tracking prompt
NotificationsPush token for your deviceApple Push Notification service
SupportAnything you write to us by emailYou

4. Face Data (TrueDepth camera and ARKit)

4.1 What we collect

When you scan your face, Mira uses Apple's TrueDepth camera through the ARKit framework. On your iPhone, Mira reads the 3D geometry of your face (the ARKit face mesh), the position of your head, facial expression values (ARKit blend shapes), the camera image and the light level. Mira does not read depth maps. On your device, this is turned into facial measurements (for example facial symmetry, eye spacing, jaw-to-cheek ratio, facial thirds and lip ratio), skin readings (for example redness, evenness, texture and under-eye) and feature scores. When you request a full report, Mira also saves five still photos of your face taken during the scan (front, left and right). Daily scans do not save any photos. We do not use face data to identify you, to authenticate you, or to recognise you across apps or devices.

4.2 How we use it

Face data is used only to provide Mira's features to you: to guide the scan, to show your face as a 3D model in the app, to calculate your measurements and scores, to write your personal report and daily plan, and to show your progress over time. The raw face data (face mesh, head position, blend shapes) and your 3D face model stay on your iPhone. They are never uploaded to our servers, and they are excluded from device backups. The live 3D face on the Today screen is drawn on your device in real time and is not saved.

4.3 What we store and where

We store only your derived measurements, skin readings and scores, plus the photos from full-report scans, in your private Mira account. This data is stored with our hosting provider Supabase in the European Union (Ireland), is encrypted in transit and at rest, and is accessible only to your account. Nothing is uploaded before you subscribe and agree to AI processing.

4.4 Sharing

When you request a full report, and only after you agree on the in-app consent screen, we send your measurements, your questionnaire answers and two of your scan photos over an encrypted connection directly to our AI provider, Anthropic (Claude), which writes your report. Anthropic processes this data only to generate your report and does not use it to train its models. We do not share face data with anyone else. We never sell face data, never use it for advertising or marketing, and never send face data, measurements or photos to our analytics, crash-reporting or advertising partners.

4.5 Retention and deletion

We keep your measurements, scores and full-report photos for as long as your account exists, so you can track your progress. The raw face data and 3D model on your iPhone remain there until you delete the app. You can delete your account at any time in the app (You → Delete account). This immediately and permanently deletes your measurements, scores, scan photos, reports and account from our servers.

5. Other third-party processors

We share personal data only with service providers who process it on our behalf under written agreements. We do not sell personal data.

ProviderWhat it doesWhat it receives
SupabaseDatabase, file storage, authenticationAccount data, derived measurements, skin readings, scores, full-report photos, questionnaire, reports
Anthropic (Claude)Report generation (see §4.4)Facial measurements, questionnaire answers and two scan photos — only after consent
AppleDistribution, sign-in, payments, push deliveryPurchase and subscription data, push tokens
RevenueCatSubscription managementAccount identifier, subscription status
PostHogProduct analyticsAccount identifier, app events, device data — no face data
SentryCrash and error monitoringDiagnostic data — no face data, measurements or photos
BrevoAccount and service emailEmail address
Meta, TikTokAdvertising measurementAdvertising identifier and install or purchase signals — only with your consent

We may also disclose data where legally required, to enforce our terms, or to protect the rights and safety of our users. If our business is transferred, personal data may transfer with it, and this policy continues to apply until you are told otherwise.

Older app versions (1.x) also used Google (Gemini) to create illustrative renders; this is no longer part of Mira 2.0.

6. Why we are allowed to use your data

PurposeLegal basis (GDPR)
Processing your facial measurements and scan photosYour explicit consent — Art. 9(2)(a), given on the consent screen described in §4.4
Creating and running your account, delivering reports and scans you have paid forPerformance of a contract — Art. 6(1)(b)
Push notifications about your reportContract — Art. 6(1)(b), plus your device permission
Product analytics, crash reporting, fraud prevention and securityLegitimate interests — Art. 6(1)(f)
Advertising measurement and attributionYour consent — Art. 6(1)(a), via Apple's tracking prompt
Accounting, tax and legal claimsLegal obligation — Art. 6(1)(c)

7. Analytics and advertising

We use product analytics to see where the app confuses people — which screens are reached, which steps are abandoned. This is tied to a random account identifier, never to your email address, and never to your face data.

If you allow tracking when iOS asks, we and our advertising partners may measure whether an advert led to an install or a subscription. If you decline, no advertising identifier is collected and no advertising SDK is initialised. Change this any time in iOS Settings → Privacy & Security → Tracking.

We do not use your facial measurements, photographs, reports or scores for any advertising purpose, whether or not you allow tracking.

8. International transfers

We are based in Switzerland. Some providers are in the United States or other countries outside Switzerland and the European Economic Area. Where data is transferred, we rely on appropriate safeguards — the European Commission's Standard Contractual Clauses, the Swiss adequacy framework, or equivalent contractual protections. You can request a copy of the safeguards that apply.

9. Retention of other data

Face data retention is covered in §4.5. For everything else:

DataRetention
Account and questionnaireWhile your account exists; immediately deleted on account deletion
Analytics and crash dataUp to 12 months, then deleted or aggregated beyond identification
Billing and tax recordsAs required by Swiss law, normally 10 years. These contain no photographs
Encrypted backups of other dataPurged on a rolling schedule, within 30 days of deletion. Face data, measurements, scores, scan photos and reports are excluded; their deletion is immediate as described in §4.5.

10. Security

  • Data is encrypted in transit and at rest.
  • Storage is private per user; files are served only through short-lived signed links.
  • Database access is enforced row by row, so an account can only reach its own records.
  • Server credentials are held in a secrets manager and are never present in the app on your phone.
  • Diagnostic logs exclude face data, measurements and photos, and are scrubbed of email addresses, photograph paths and report contents.

No system is perfectly secure. If a breach affects your personal data we will notify you and the competent authorities as required by law.

11. Your rights

Under the GDPR and the FADP you may:

  • Access the personal data we hold about you
  • Correct data that is inaccurate or incomplete
  • Delete your data — immediately in the app (You → Delete account), or by asking us
  • Restrict or object to certain processing
  • Withdraw consent at any time, including consent to face-data processing and to tracking
  • Receive a copy of your data in a portable, machine-readable format
  • Not be subject to a decision based solely on automated processing producing legal or similarly significant effects

Email hello@miraanalysis.com to exercise any of these. We respond within 30 days, and may ask you to confirm control of your account email first.

Complaints. Tell us first and we will try to put it right. You can also complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC), or, in the EEA or UK, to your local supervisory authority.

12. What Mira is not

Not medical advice. Mira is a cosmetic and appearance analysis tool. It is not a medical device, it does not diagnose or treat any condition, and nothing in a report substitutes for a doctor, dermatologist or other qualified professional.

Scores are relative to you. A harmony score expresses progress toward your own realistic potential. It is not a universal rating, a ranking against other people, or a measure of your worth.

13. Changes to this policy

We update this policy when the app changes. The effective date at the top always shows the current version. If a change materially affects how we handle your face data, we will tell you in the app or by email before it takes effect, and where the law requires it we will ask for your consent again.

14. Contact

CPLEX Management AG
Baar, Canton of Zug, Switzerland
hello@miraanalysis.com

Questions about this policy, requests about your data, and reports of a suspected minor account all go to the same address, and a person reads them.