Privacy Policy

Last Updated: 27.04.2026

This Privacy Policy explains how personal data is collected, used, and processed in connection with the NailApp mobile application ("App", "Service"), operated by Rita Bohoslavska, Sole Proprietor, Bern, Switzerland ("we", "us", "our").

1. Data Controller

Rita Bohoslavska

Sole Proprietor

Bernstrasse 34

3018 Bern

Switzerland

Email: feedback@nailapp.app

EU Representative (Article 27 GDPR)

As the App is available to users in the European Union (EEA) and the United Kingdom, we are in the process of appointing a representative in the EU in accordance with Article 27 GDPR. Contact details will be updated once appointed.

2. Scope

This Policy applies to all users worldwide, including the European Union, Switzerland, the United Kingdom, and the United States.

By using the App, you agree to this Privacy Policy.

3. Eligibility

The App is intended for users aged 18 or older. We do not knowingly collect personal data from minors.

4. Categories of Personal Data Collected

4.1 Account Information

We may collect limited technical identifiers necessary to operate the app, such as:

- Anonymous user ID (Firebase UID)

- Subscription identifiers (RevenueCat)

- Internal support identifier (Support ID)

- Some basic technical information (such as device type or operating system) may be collected automatically by our infrastructure and third-party service providers.

These identifiers are used solely to provide the service, manage subscriptions, prevent abuse, and offer customer support, and are not used for advertising purposes.

4.2 User Content

Users may upload images of hands and nails.

We do not require facial images. Users should avoid uploading identifiable faces.

Uploaded images are processed solely to provide AI-generated nail design results.

Uploaded images are processed solely to generate results for the user. We do not intentionally use user data for training our own AI models.

4.3 Technical Data

We may collect limited technical data necessary for the operation of the app, such as:

- Anonymous identifiers (e.g., Firebase UID)

- Subscription and purchase identifiers (RevenueCat)

- Internal support identifier

- Error logs and diagnostic data

This data is used strictly to operate the service, maintain stability, manage subscriptions, prevent abuse, and provide customer support.

Some of this data may be processed by third-party service providers on our behalf.

5. Purpose of Processing

We process data strictly to:

- Provide AI-based image processing

- Manage subscriptions and credits

- Verify purchases

- Maintain account security

- Prevent fraud and abuse

- Comply with legal obligations

We do not sell personal data.

We do not perform automated profiling or make automated decisions about users that produce legal or similarly significant effects.

6. Third-Party Services & Infrastructure

We use trusted third-party service providers to operate and support the app. These providers may process limited data on our behalf:

- Firebase (Google LLC, USA) – authentication and anonymous user identification

- Supabase (Supabase Inc., USA) – database and storage infrastructure

- Seedream (provided via BytePlus Pte. Ltd., Singapore) – AI image processing services

- RevenueCat (RevenueCat, Inc., USA) – subscription and in-app purchase management

- Cloudflare, Inc. (USA) – content delivery network (CDN), security, and performance optimization

- Apple App Store and Google Play – payment processing and transaction management

These providers process data only as necessary to provide their services and in accordance with applicable data protection laws.

7. Payments, Subscriptions & Credits

Payments are handled exclusively through Apple App Store and Google Play.

We do not collect or store credit card details.

Subscriptions renew automatically unless canceled through platform settings.

8. Data Retention

8.1 Uploaded Content

Uploaded images and generated results are automatically deleted after a limited period (e.g., 3 days).

8.2 Account Data

Account and subscription data are retained while your account is active and as required by law.

9. Legal Basis (EEA & Switzerland)

Processing is based on:

- Contract performance

- Legitimate interests

- Legal obligations

- User consent where required

10. User Rights

Depending on your jurisdiction, you may have rights to:

- Access your data

- Correct inaccuracies

- Request deletion

- Restrict processing

- Data portability

- Withdraw consent

Right to lodge a complaint

You have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or place of the alleged infringement.

For Switzerland, the competent authority is:

Federal Data Protection and Information Commissioner (FDPIC)

https://www.edoeb.admin.ch

Requests can be sent to: feedback@nailapp.app

If you are located in the European Economic Area (EEA), you may also lodge a complaint with your local data protection authority.

11. Account Deletion

You may request account deletion by contacting: feedback@nailapp.app

Upon deletion:

- Account data will be removed

- Stored data will be deleted unless legally required to retain it

12. Data Security

We implement appropriate technical and organizational measures to protect your data.

However, no system is completely secure.

12.1 Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay, and where required, notify affected users directly via email or in-app notification.

13. International Transfers

Some of our third-party service providers (including Railway, Supabase, and RevenueCat) are based in the United States or other countries that may not provide the same level of data protection as Switzerland or the EEA. Where data is transferred internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or equivalent mechanisms, in accordance with Swiss revDSG and GDPR requirements.

14. Changes to this Policy

We may update this Privacy Policy at any time. When we do, we will revise the "Last Updated" date at the top of this page. We encourage you to review this Policy periodically. Continued use of the App after changes are posted constitutes your acceptance of the updated Policy. If changes are material, we will notify you via the App or email where possible.

15. Contact

If you have any questions, contact us at: