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Draft — pending attorney review

Aamey Privacy Policy

Provided by Joorus Inc. Address: 250 Consumers Road, Suite 719, Toronto, ON M2J 4V6, Canada GST/HST Registration: 712534965RT0001 Contact: [email protected] — Privacy Officer / DPO: [email protected] Effective date: 2026-05-11 Version: 1.0.0 Last reviewed: 2026-05-11

DRAFT — pending licensed-attorney review (Canada, US, EU/UK at minimum). Do NOT publish before attorney sign-off.


1. Overview

This Privacy Policy explains how Joorus Inc. collects, uses, shares, and protects your personal information when you use Aamey. Read it alongside our Biometric Privacy Notice (for face data) and the AI & Likeness Consent (for the magazine).


2. Information we collect

2.1 Information you provide

  • Account: email, name, password (passkey or none), pronouns (optional), preferred name
  • Profile (optional): skin tone, undertone, skin type, skin concerns, hair type, eye color, lip tone, allergies, current products, budget band, style preferences, occasions, language, cultural style preferences (optional), religious/dietary preferences (optional)
  • Location: country, region, city (only with consent)
  • Address: shipping addresses for orders
  • Content: chats, photos, videos, looks saved or tried, reviews
  • Pro details: for MUAs / instructors / B2B admins — professional credentials, business information

2.2 Information collected automatically

  • Device: model, OS, app version, device identifiers
  • Usage: features used, screens viewed, dwell time, in-app actions
  • Diagnostics: crash logs, performance metrics
  • Network: IP address, approximate geolocation derived from IP

2.3 Biometric information

  • Face geometry / face mesh and derived embeddings — collected only with your explicit prior written consent. See the Biometric Privacy Notice for details, retention, and your rights.
  • Dermatoscope / multi-spectral images — collected only via paired professional devices, with consent.

2.4 Payment information

Payment-card data is handled by Stripe. Joorus does not store full payment-card numbers, CVVs, or expiry dates.

2.5 Information from third parties

  • Sign in with Apple / Google: basic profile (name, email)
  • Marketplace Partners: order status, tracking info, refund status
  • MUAs and Institutes: information you ask them to share with us

3. How we use information

Purpose Lawful basis (GDPR)
Provide and operate Aamey, fulfil orders, support Contract
Personalize recommendations, AR try-on, magazine Consent (face data); contract or legitimate interest (text-only personalization)
AI training on likeness Explicit consent only
Marketing communications Consent
Fraud detection, security Legitimate interest
Comply with law, tax, regulatory obligations Legal obligation
Cross-border transfers (e.g., Anthropic in US) SCCs + your consent where required

We do not sell personal information. We do not use personal information for behavioral advertising on third-party platforms.


4. Sharing

We share information only as described:

4.1 Sub-processors

Sub-processor Purpose Region
Anthropic PBC AI features (Claude API; ZDR agreement) US
Stripe Inc. Payments, payouts, tax US/EU
Hetzner Online GmbH Infrastructure hosting Germany
Cloudflare Inc. CDN, edge security Global
Apple Inc. App distribution, Sign in with Apple, push US
Google LLC Play Store, FCM, Sign in with Google US
(TBD) GDPR EU Representative EU representation EU
(TBD) Fractional DPO Privacy oversight EU

A current sub-processor list is published at aamey.com/legal/subprocessors.

4.2 Marketplace Partners

When you order a product, we share with the relevant Marketplace Partner only what is necessary to fulfill the order (recipient name, shipping address, order details). We do not share your face data, profile, or other Aamey data with marketplaces.

4.3 Professional users

When you book an MUA or enroll in an institute, you may choose to share your profile (and optionally face mesh) with that professional or institution. You can revoke this access at any time.

4.4 Legal

We may disclose information if required by law, court order, or to protect Joorus's, Users', or the public's rights and safety.

4.5 Business transfers

In the event of a merger, acquisition, or asset sale, we may transfer information to the successor entity, subject to this Privacy Policy.


5. International transfers

Aamey infrastructure is currently hosted in Germany; AI processing happens in the US (Anthropic). Where data is transferred internationally, we rely on Standard Contractual Clauses (SCCs) and additional safeguards as required by applicable law.

Quebec residents may request data residency in Canada; we will notify you of progress in establishing a Canadian region.


6. Retention

Data Retention
Account Until you delete your account or after 5 years of inactivity
Face mesh and embeddings 24 months max from last refresh, or until you revoke (≤ 24-hour deletion SLA)
Chat history 24 months
Orders and tax records 7 years (legal requirement)
Audit log 7 years
Magazine renders 5 years on hot storage, then cold tier; deletable on request within 24 hours
Kiosk anonymous sessions 24 hours unless converted to account; 13 months as pseudonymous aggregate
Marketing analytics 13 months

After retention expires, data is hard-deleted; some backups may retain content for up to 30 additional days before being overwritten.


7. Your rights

Depending on your jurisdiction, you may have the following rights:

  • Access your information
  • Rectify inaccurate information
  • Delete your information ("Right to be Forgotten")
  • Restrict processing
  • Port your information (machine-readable export)
  • Object to processing for marketing or legitimate-interest purposes
  • Withdraw consent at any time (no effect on prior lawful processing)
  • Avoid solely-automated decisions with significant effects (request human review)

Exercise rights via in-app Settings → Privacy & Data or by emailing [email protected]. We respond within 30 days (extendable to 60 days for complex requests).

California residents (CCPA/CPRA): in addition, you have the right to opt out of "sale" or "sharing" of personal information. Joorus does not sell information; affiliate sharing is disclosed in section 4.2.

Illinois residents: see the Biometric Privacy Notice for BIPA-specific rights.

Canadian residents: access requests under PIPEDA / Quebec Law 25 are handled by the Designated Privacy Person at [email protected].


8. Children

Aamey is not directed to children under 13. We do not knowingly collect data from children under 13. If you believe a child under 13 has provided data, contact [email protected] for prompt deletion.

Users aged 13–18 require verifiable parental or guardian consent.


9. Security

Joorus uses industry-standard safeguards including TLS 1.3 in transit, encryption at rest, role-based access, audit logging, regular penetration testing, and incident-response procedures. We will notify affected Users and regulators of data breaches within 72 hours of becoming aware, where required by law.


10. Changes to this Privacy Policy

We will post material changes at aamey.com/legal/privacy and notify Users at least thirty (30) days in advance via email or in-app message.


11. Contact

Privacy Officer / DPO: [email protected] General support: [email protected] Address: Joorus Inc., 250 Consumers Road, Suite 719, Toronto, ON M2J 4V6, Canada

(Phone number not published; available on counter-signed commercial agreements where required.)

EU Representative: [to be appointed before EU launch] Office of the Privacy Commissioner of Canada: priv.gc.ca Quebec Commission d'accès à l'information: cai.gouv.qc.ca


End of Privacy Policy.

Joorus Inc. · 250 Consumers Road, Suite 719, Toronto, ON M2J 4V6, Canada · GST 712534965RT0001
Questions? [email protected]