FORMA

Privacy Policy

This Privacy Policy explains how Wellington Web Co ("Forma", "we", "us") collects, uses and protects your information when you use the Forma website and app (the "Service").

1. Information we collect

• Photos you submit. Images you upload or capture for facial analysis.
• Analysis results. The scores, measurements and plans generated from your photos.
• Account and contact data. Email address and any name or profile details you provide. If you create an account, your account details and your scan analysis data (scores, breakdowns and dates, never the photos) are stored securely so they sync across your devices.
• Purchase data. Records of single payments and subscriptions (handled by our payment processors; we do not store full card numbers).
• Usage data. Device type, app interactions and diagnostics used to operate and improve the Service.

How we collect it. Photos come only from your device camera or your photo library, and only when you choose to add them for a scan, after your operating system has asked for and you have granted camera or photo access. Account and contact details come only from what you type in. Purchase records come from Apple, Google or Stripe when you buy something. Usage data is collected automatically by the app and site as you use them. We do not buy personal data, and we do not collect it from third parties or from your contacts, camera roll at large, location, microphone or other apps.

2. How we use your information

• To generate and deliver your facial analysis and improvement plan.
• To create and manage your account and deliver your report.
• To process payments and provide customer support.
• To maintain, secure and improve the Service.
• To send you communications about the Service (and marketing only where you have consented; you can opt out at any time).

3. Your photos, face data and third party AI processing

Face data. The photos you submit are images of a face, which are a form of face data. Forma uses this face data for one purpose only: to compute the facial analysis, scores and improvement plan you asked for. We do not create, derive or store a faceprint, face template or any other biometric identifier, and we do not use face data to recognise, identify or track you or anyone else across sessions, apps or services. Your face data is never used for advertising and is never used to train AI models. It is never sold, and it is never shared with anyone other than the AI processors named below, who act only on our instructions to generate your result. We do not keep your face data on our servers to produce the analysis: the photos are sent to the AI processors named below, your results come back, and nothing is stored by us. The copy of each photo that the app keeps is stored on your own device only, so that your Progress gallery, before and after comparison and share card still work later, and it stays there until you delete your account or remove the app. Your face photos are never part of cloud sync or long term storage: only the analysis results (scores, breakdowns and dates) sync between your devices, never the images themselves.

Your permission comes first. Before any photo or message is sent to an AI provider for the first time, the app shows you exactly what will be sent, names each provider and the country it operates in, says what it is used for, and asks you to agree. Nothing is sent unless you do. You can withdraw that permission at any time in the app under Settings, Data, "Share photos with AI services". Withdrawing it stops scanning, Atlas and the ingredient checker, because those features cannot run without it. If we ever change which providers receive your data, we will ask you again rather than relying on your earlier agreement.

To produce your analysis, photos you submit are sent to third party AI providers, currently OpenAI and Google Cloud Vision, solely to compute your results. They are processed to generate your analysis, are not sold and are not used for advertising. We do not retain your photos on our own servers for the analysis itself.

If you choose to receive your report by email (an optional opt in), your photos are held securely only so we can prepare and verify that report. They are deleted automatically as soon as your report is sent, and in all cases within 72 hours, after which they are permanently removed. We never keep your photos longer than that, and never sell or share them.

4. Service providers we share data with

• OpenAI, Google Cloud Vision: facial analysis processing.
• Stripe: web payments.
• Apple App Store / Google Play / RevenueCat: in app subscriptions and purchases.
• Resend: sending your report by email, if you opt in.
• Vercel, Upstash: hosting, and server side storage. That covers the short term (maximum 72 hour) copy used to prepare an emailed report, the 12 month copy of a paid web report described in section 6, and counters keyed to your IP address used to stop abuse of the free tools.
• Google Fonts: the typefaces on this website are served by Google, which means your IP address reaches Google when a page loads, before and regardless of any cookie choice. No cookie is set and nothing else is sent.
• Open Food Facts: if you use the barcode scanner in the app, the barcode you scan is sent to their open database to look the product up. No photo and no account information is sent.
• Supabase: account authentication and encrypted database hosting for cross-device sync of your account and analysis data (never your photos).
• Google Analytics, PostHog: usage and traffic measurement. Neither ever receives your photos or your face data.

Each processes data only as needed to provide their function, under their own terms and privacy policies.

Equivalent protection. Every provider listed above is engaged as a data processor acting only on our documented instructions. Each is contractually bound, under their published data processing terms, to protect your data to a standard at least equivalent to the one described in this policy: to use it solely to deliver the function we have asked them to perform, not to sell it, not to use it for advertising, and not to use it to train their own models. Where a provider is outside the UK or EEA, transfers rely on Standard Contractual Clauses or an equivalent approved safeguard. We confirm specifically that OpenAI and Google Cloud Vision, the two providers that ever receive your photos, do not retain them for their own purposes, do not use them for advertising, and do not use them to train AI models.

4a. Cookies and measurement

We use Google Analytics and PostHog to count visits and understand which parts of Forma people use, so we can improve it. Both are used for measurement only, never for advertising, and neither is sent your photos or face data.

On this website neither script is loaded at all until you accept in the cookie notice, and declining leaves them off. You can change your mind at any time: clear this site's data in your browser settings and the notice will ask again on your next visit. In the app, usage events are recorded without cookies and never include your photos, your name or your email address. Scores are reported only as a broad band (for example 60-69) rather than an exact figure.

When we advertise, this website also uses the Meta pixel to measure which adverts led people to Forma. Like the above it is switched off until you accept the cookie notice, it never receives your photos or face data, and it records only that a page was viewed or a link to the app or the web scan was followed.

4b. Who is responsible, and on what legal basis

The data controller is Wellington Web Co Ltd, a company registered in Scotland, contactable at contact@wellingtonwebco.com. Where this policy says "we", it means that company.

Under UK GDPR we rely on these lawful bases:

• Your consent for sending your photos to the AI processors named above, for the optional score and report emails, and for the analytics and advertising measurement described in section 4a. You can withdraw consent at any time, and withdrawing it is as easy as giving it: photo processing under Settings, Data in the app, emails by replying to any one of them, and website measurement by clearing this site's data so the cookie notice asks again.
• Performance of our contract with you for creating your account, producing the analysis and plan you asked for, and syncing them between your devices.
• Our legitimate interests for keeping the service secure and preventing abuse, which is why we hold short lived counters keyed to your IP address.
• Legal obligation for records we are required to keep, such as transaction records.

Because face data is special category data, we ask for your explicit consent before any photo is sent for analysis, and nothing is sent unless you give it.

5. Your rights

Depending on where you live (including under UK GDPR and GDPR), you may have the right to access, correct, delete or export your data and to object to or restrict certain processing. You can delete your account and the data stored on your device at any time from the Profile screen in the app. To exercise any other rights, contact us at contact@wellingtonwebco.com.

Complaints. If you think we have handled your data wrongly, please tell us first at contact@wellingtonwebco.com so we can put it right. You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office, at ico.org.uk/make-a-complaint or on 0303 123 1113.

6. Data retention

We keep account and analysis data for as long as your account is active or as needed to provide the Service, then delete or anonymise it unless we are required to keep it for legal reasons.

Paid web reports. If you buy a one off report on the web, there is no account to hold it, so we store a copy of that report on our servers for 12 months from purchase and email you a private link to it. This is so you can open the report you paid for again, on any device, instead of losing it when you close the tab. The stored copy contains your scores, the written analysis and your plan. It does not contain your photos, which are removed before the copy is written and are still deleted on the timetable described above. The link is the only key to the report, so treat it as private and do not forward it to anyone you would not want reading your results. After 12 months the copy is deleted automatically. To have it deleted sooner, email us at contact@wellingtonwebco.com with the link.

Your score by email. When you enter your email address to scan, we send you one email containing your score once the scan finishes. This is the service you asked for rather than marketing, so it is not behind a tick box, and the scan page says so before you type anything. It is one email and never a series. Reply to it, or email contact@wellingtonwebco.com, and we will not email you again. Your address is kept only long enough to stop a duplicate being sent, then removed.

The email address you bought with is stored alongside that copy, so we can send you the link and, once, a reminder about two weeks later suggesting you scan again to see what has changed. That single reminder is about the report you bought rather than marketing, so it is not tied to the newsletter tick box, and it is sent only once. Reply to any Forma email to stop hearing from us, and the address is deleted with the report at 12 months.

7. Children

The Service is not directed to children under 16. We do not knowingly collect data from anyone under that age.

8. Security

We use reasonable technical and organisational measures to protect your data. No method of transmission or storage is completely secure and we cannot guarantee absolute security.

9. Changes

We may update this policy from time to time. Material changes will be posted here with an updated date.

10. Contact

Wellington Web Co, Edinburgh, Scotland. Questions: contact@wellingtonwebco.com.

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