Privacy Policy
Last updated August 27, 2026
A Wise Approach LLC, DBA Fingertip Facelift ("we", "us") operates the Fingertip Facelift Custom Routine Builder app. This policy explains what we collect in the app, why, who processes it on our behalf, and your rights. This app is intended for adults 18 and older. Questions? Email help@fingertipfacelift.com.
We publish two additional policies that go into more detail on specific kinds of data. If either applies to you, please read it alongside this one:
- Consumer Health Data Privacy Policy, which covers the rights Washington, Nevada, and Connecticut residents have over health data
- Biometric Data Retention and Destruction Policy, which sets out how long we keep photo related data and how we destroy it
Information We Collect
- Account details you provide: name, email address, and (optionally) phone number
- Payment information, processed by our payment provider (we do not store card numbers)
- Your routine-builder answers and the routines you create and save
- Usage and analytics data (pages viewed, features used)
- Communication and marketing preferences
- Progress photos, only if you choose to upload them (see below)
- Skincare concern results, if you use photo analysis: text descriptions of visible concerns (for example, "puffiness" or "fine lines"). These are cosmetic preferences. We do not derive or store medical information, and we do not create a facial-recognition profile of you.
Progress Photos (optional)
You may optionally upload photos of your own face to track your progress over time. These are private to you. We store them securely so that only you can view them. Our staff cannot browse your progress photos, and they are never shown to other members. One thing is different, and it is your own choice: a photo you attach to an optional survey such as our beta outcomes study, which our team reads as part of that study. We keep them until you delete them or close your account, after which they are permanently removed, and in any case no longer than the outer limit in our Biometric Data Retention and Destruction Policy. You can delete any or all of your photos at any time from your account, and we only store them with your consent.
Using a photo just for one routine. This option arrives with photo analysis, which is not switched on yet. When it does, you will be able to choose "just use it for this routine" instead of saving it: your photo would be used to build your routine and then discarded right away, never stored, and it would never appear in your tracker.
Ask Allison-AI Chat
We are building an in-app chat that answers your questions in Allison's voice. It is not switched on for members yet. When we do turn it on, here is how it will work: the question you type is sent to Anthropic, our AI provider, so we can write an answer and point you to the right lesson. Anthropic acts as our service provider under a data-processing agreement and is contractually barred from using your questions to train AI models. We do not store a transcript of your chat. If we ever add another provider to this feature, we will name it here before it goes live. Please do not enter health information or other sensitive personal details into the chat.
Photo Analysis (only for a photo you tick)
Photo analysis is not switched on today. If we offer it and you choose to use it, we would use an automated image-analysis provider, Anthropic, to look at your photo and describe visible skincare concerns (such as puffiness or fine lines) so we can personalize your routine. Here is exactly what would happen, and what would not:
- Your photo is sent to Anthropic to return text descriptions of visible concerns. Anthropic acts as our service provider under a data-processing agreement and is contractually barred from using your photos to train AI models.
- We keep the resulting text concern results (and, if you saved the photo, the photo). We do not create a facial-recognition profile or "faceprint", we do not measure or store facial geometry, and we never use your photos to identify you.
- We never sell your images, and we never use your private photos for marketing unless you separately choose to share them with us (see below).
- Because a photo of your face is sensitive (special-category) personal data, we would only analyze it with your explicit, separate consent. You give that when you submit a photo, by ticking a box next to it, and it applies to that photo only. There is no setting to remember: if you do not tick it, nothing is analyzed, and deleting a photo removes anything we derived from it.
Our Biometric Data Retention and Destruction Policy sets out how long we keep this data and how we destroy it.
How We Personalize, and Your Right to Object
If you consent to personalization, we may use your concern results, connected to your account, to tailor the routines, suggestions, and product offers we show you. This is a form of profiling: we use your stated and detected concerns to decide what to recommend to you. It does not produce any legal or similarly significant decision about you. Personalized Suggestions is an opt-in choice in your account. You can object to this at any time, either from your account settings, or at any point by emailing help@fingertipfacelift.com, which always works. When you do, we stop using your concern results to target suggestions or marketing to you, and we remove you from tailored marketing audiences. You can also object to direct marketing at any time, and we will always honor that.
Sharing Your Photos With Us (optional)
Your progress photos stay private to you by default. Photo sharing is not switched on yet. When it is, you will be able to share specific photos with us using the "share" option in your account, and withdraw that permission again from the same place. If you share a photo this way, you are giving us permission to use that photo for marketing, testimonials, advertising, and before-and-after images, as described in our Terms (Section 46B). You can withdraw this permission at any time, which stops our future use of that photo. We may be unable to recall copies already published or shared with advertising platforms. Photos you email to us, and written testimonials sent to us outside the app, are covered by our Terms as submitted content, not by this in-app sharing option.
Live Programs Delivered on Telegram
Some of our live programs are run in Telegram groups, and some of those stay open afterwards as private channels so you keep access to what you bought. Joining is optional and always your choice. We share an invite link; we never add anyone to a channel ourselves, and we do not upload your phone number or your contact details to Telegram.
If you do join, Telegram is a separate company with its own privacy policy, and it is outside the EEA and the UK. What you post there, and the account you post it from, are handled by Telegram under their terms, not ours. Anything we would otherwise keep private about you stays out of those channels: we do not post your concerns, your progress photos, or anything you have told us in confidence.
If you close your account with us and you are in one of these channels, tell us and we will remove you from it, or you can leave at any time yourself.
Marketing Emails
When you join Fingertip Facelift or buy from us, we'll email you about the product: practice tips, new levels as they open, and the occasional offer. We say so at checkout and again when you set up your account, with a box right there if you'd rather not. Every email we send has an unsubscribe link, and you can switch marketing emails off any time on your account page. Saying no changes nothing about your access. You'll still get the essentials about your account, your billing, and your membership.
Emails tailored to the specific concerns you're working on are a separate thing, and we only send those if you switch on Personalized Suggestions in your account.
Service Providers Who Process Your Data
We use trusted providers to run the app. In the app specifically, these include:
- Clerk: account sign-in and authentication
- Stripe: payment processing
- Railway: application and database hosting
- Cloudflare R2: secure file and photo storage
- PostHog: product analytics and error monitoring
- Mailchimp: email communications
- Anthropic: the AI that will power the Ask Allison-AI chat (processing your questions) and, for a photo you tick for analysis, photo analysis
- Meta (Facebook / Instagram): measures ad performance through the Meta pixel and Conversions API, which share limited event data and hashed contact details for advertising. You can opt out (see "Cookies and Your Choices" below)
Two of these load parts of the page itself, before you make any cookie choice, because the page cannot render without them: Google Fonts supplies our typefaces and jsDelivr supplies some of our page scripts. Loading a file from them means your device's IP address and browser type reach those services, in the same way as requesting any image or stylesheet on the internet. They receive no account details, no answers, and no photos.
We also use Telegram and ordinary email to notify our own team internally, for example when someone shares a photo with us. Those notifications carry your name or email address and a link, never the photo itself.
Outside the app, a few more providers support our wider business. If you bought a course from us, or reached us through social media, your details may sit with these:
- Kajabi and Stan Store: our course and offer checkouts. They hold your name, email address, and what you bought
- ManyChat: conversations on social media, where you may have given us your email address
- Zapier: moves those details between the tools above and Mailchimp
- PayPal: an alternative way to pay. PayPal is an independent controller of the information you give it, meaning it decides for itself how that information is used rather than acting on our instructions, so its own PayPal Privacy Statement applies to it
How We Use Your Information
- Providing the app, building your routines, and fulfilling your subscription
- Customer service and communication
- Product development and improvement
- Analytics and reliability monitoring
- Personalizing your routines and suggestions (only with your consent; see above)
- Marketing (only where permitted, and you can opt out anytime)
- Legal compliance
What We Collect, Where It Comes From, and Who We Share It With
This table is here because some US state privacy laws ask us to set it out category by category. "Disclosed to" means the service providers listed above who handle that data for us, never a sale.
| Category | Where it comes from | Why we use it | Disclosed to | How long we keep it |
|---|---|---|---|---|
| Identifiers (name, email, phone, account ID) | You | Run your account, support, billing, email | Clerk, Stripe, Railway, Mailchimp | While your account is open, then deleted on closure |
| Commercial information (purchases, subscription, refunds) | You, Stripe | Fulfil your order and membership, tax and accounting records | Stripe, Railway | Kept after closure where tax and accounting law requires, with your name and email removed |
| Internet and usage activity (pages viewed, features used) | Automatically as you use the app. Behavioural analytics follow your cookie choice: in the EEA and UK nothing runs until you accept, and elsewhere it runs unless you opt out. We honor Global Privacy Control everywhere. A smaller set of records is kept either way, because the app cannot run without them: your purchases and subscription, the lessons and routines you complete, and any fault you report to us using an in-app button | Product analytics, reliability, improving the app | PostHog, Railway, Meta (advertising measurement only) | Deleted on account closure |
| Your routine-builder answers, routines, and practice history | You | Build and track your routines | Railway | While your account is open, then deleted on closure |
| Sensitive: progress photos of your face | You, only with your consent | Your private progress tracker, and analysis only for a photo you tick | Cloudflare R2. Anthropic only for a photo you tick for analysis | Until you delete them or close your account, and in any event no more than three years after your last activity with us |
| Sensitive: skincare concern results and concern selections | You, and photo analysis for a photo you tick | Personalize your routine and suggestions | Railway | Until you withdraw consent, delete them, or close your account. Results derived from a photograph also go when the photograph does, no more than three years after your last activity with us |
About sensitive personal information. We use the sensitive categories above only to provide the features you asked for, and never to infer characteristics about you. We do not sell sensitive personal information, and we do not use or disclose it for purposes that would give you a right to limit that use under California law. You can withdraw your consent, or delete this data, at any time from your account settings.
No financial incentive. Your price and your access are the same whether or not you share concern data, upload a photo, or accept non-essential cookies. We do not offer discounts or different service levels in exchange for personal information.
Data Sharing
We share data only with the service providers listed above (to operate the app), with legal authorities when required by law, and otherwise with your consent. We do not sell your personal data, and we never share your progress photos with anyone unless you choose to share them with us.
Security
- Encrypted data transmission (HTTPS) and encryption at rest for stored files
- Progress photos are stored privately and are accessible only to you
- Access to personal data is limited, and our staff cannot browse your progress photos. The only photos our team can open are ones you choose to send with an optional survey
- Secure payment processing through our payment provider
Your Rights
You can:
- Access, correct, or delete your personal data, including your photos and any analysis results
- Withdraw consent (for example, for photo storage, analysis, or personalization) at any time
- Object to profiling and opt out of marketing communications
- Request data portability, which means a copy of your data in a machine-readable file
- Appeal if we turn down a request (see below)
- File a complaint with your data-protection authority
You can delete your account and your data yourself, at any time, from your account settings. That removes your profile, your routines and practice history, and your photos, cancels your membership, and takes you off our email list. You can also download a copy of your data from the same place. To exercise any of your other rights, or if you would rather we did the deletion for you, email help@fingertipfacelift.com.
Verifying who you are. Before we act on a request to see or delete your data, we need to be reasonably sure it is really you asking, so we may ask you to confirm from your account email or to confirm details we already hold. We ask for more confirmation for requests involving your photos, because they are the most sensitive thing we hold. You can also use an authorized agent, in which case we will ask for proof that you gave them permission.
If we say no, you can appeal. If we turn down a privacy request, we will tell you why. You can appeal by replying to that response, or by emailing help@fingertipfacelift.com with "Appeal" in the subject line. A different person than the one who made the first decision will review it, and we will give you a written answer within 45 days. If we turn down your appeal, we will tell you how to contact your state Attorney General to complain.
For EEA/UK Residents (GDPR / UK GDPR)
You have the rights to be informed, of access, rectification, erasure, restriction, data portability, and to object to processing, plus rights relating to automated decision-making. Our legal bases for processing are contract fulfilment, legal obligations, legitimate business interests, and your consent. For sensitive/special-category data (analyzing a photo of your face), our legal basis is your explicit consent, which you can withdraw at any time without affecting the app's core features.
For Residents of Canada and Quebec
Who is responsible for your information. The person in charge of protecting personal information at A Wise Approach LLC holds the role of Privacy Officer. You can reach the Privacy Officer at help@fingertipfacelift.com. Quebec's Law 25 requires us to publish this, and it is also how we identify the person accountable under PIPEDA. If you need a postal address for a formal request, email us and we will provide one.
Your rights. You can ask what we hold about you, ask us to correct it, ask us to delete it, withdraw a consent, and ask us to stop using your information to tailor what we show you. Quebec residents also have the right to data portability and the right to ask us to stop distributing information about you. Use your account settings where a control exists, or email the Privacy Officer.
Where your information goes. Your information is stored and processed in the United States. That means it may be accessible to authorities there under laws that differ from Canadian ones. We use written agreements with our providers, including standard contractual protections, to hold them to the commitments in this policy.
Automated and AI Features
When you are dealing with an AI, we tell you so. Any feature in this app that answers you or looks at what you submit using artificial intelligence says so plainly at the point you use it, not only here.
Photo analysis, when we offer it, sends that photograph to an AI provider, only when you tick the box beside it, and gets back short text descriptions of visible cosmetic concerns. It is not a medical assessment and it does not produce a diagnosis. It never infers, and we never ask it to infer, your race, ethnicity, political opinions, religious beliefs, health conditions, sex life or sexual orientation. The Ask Allison chat, when it launches, answers questions in Allison's voice using an AI model and tells you so in the chat itself.
No feature here generates or alters images of you, and nothing we do makes an automated decision that has a legal or similarly significant effect on you. You can always build your routine without using any AI feature.
US State Privacy Rights
Depending on your state (for example, California, Colorado, Virginia, Connecticut, Texas), you may have rights to know, access, correct, delete, and to opt out of targeted advertising and of the sale or sharing of your personal information, plus the right to appeal described above. Where your state treats health or biometric information as sensitive, including Colorado, Connecticut, Virginia and Texas, we ask for your opt-in consent before we collect it rather than offering you a way to opt out afterwards. That is why the photo boxes are separate, unticked, and never required. We do not sell your personal information for money. To exercise these rights, use the footer control or email help@fingertipfacelift.com. We will not discriminate against you for exercising your rights.
If you live in Washington, Nevada, or Connecticut, please also read our Consumer Health Data Privacy Policy, which gives you additional rights over health data.
Biometric Information
Our photo analysis returns text descriptions of visible concerns. We do not collect, capture, or store a biometric identifier or biometric information such as a scan of face geometry or a faceprint, and we do not use your photos to identify you. We keep your photos and concern results only as described in this policy, and we delete them when you delete them or close your account. Our Biometric Data Retention and Destruction Policy sets out the schedule and the destruction method in full.
International Data Transfers
Your data may be processed in countries outside the EEA/UK, including the United States, where some of our providers operate (including Anthropic for photo analysis). When we use these providers we rely on appropriate safeguards, such as their data-processing agreements and Standard Contractual Clauses, to protect your data. You can ask us for a copy of those safeguards at any time by emailing help@fingertipfacelift.com.
Cookies and Your Choices
We use cookies and similar technologies for two purposes. Essential cookies keep you signed in and remember your preferences, and are always on because the app cannot work without them. If you use the "just use it for this routine" photo option, the concern tags from that photo are also held in an essential cookie on your own device until your routine is built, rather than in our database. Non-essential cookies power product analytics (PostHog) and, where enabled, advertising measurement (the Meta pixel). These non-essential tools require your choice.
When you first visit, a banner lets you accept or decline non-essential cookies. If your browser looks like it is in the EEA or UK, nothing non-essential loads until you accept. We work this out from your browser's time zone rather than your exact location, so if you are travelling or using a VPN it may not match where you actually are. You can always decline using the banner or the footer links, whichever region we think you are in. You can change your decision at any time using the Cookie Preferences link in the footer, or turn off advertising cookies with the Do Not Sell or Share My Personal Information link (also in the footer). We also honor the Global Privacy Control browser signal as an opt-out. You can control cookies through your browser settings as well.
US state privacy rights: we do not sell your personal information for money. Some US state laws treat the use of advertising cookies as "sharing" or "targeted advertising." You can opt out of that at any time using the Do Not Sell or Share My Personal Information link in the footer, with no effect on your access to the app.
Medical Disclaimer
Fingertip Facelift products are for educational and entertainment purposes only. Photo analysis detects the look of visible cosmetic concerns to personalize your routine. It is not a medical assessment, diagnosis, or advice, and it does not detect or diagnose any medical or skin condition. Please consult a professional for any medical or health-related concerns.
Children
This app is for adults 18 and older. We do not knowingly collect personal information, or analyze photos, of anyone under 18.
Policy Updates
We may update this policy from time to time. When we make a significant change, we will tell you by email and in the app, and we will say what changed. By significant we mean things like: collecting a new kind of personal information, using what we already hold for a new purpose, sharing your information with a new kind of company, or a change to your rights or to how long we keep your data.
Smaller changes, like clearer wording or a corrected link, will be posted here with a new "last updated" date and no email.
If a change means we need your permission for something new, we will ask you for it rather than assume it from this notice.