Privacy Policy

Last updated October 14, 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. Most of the concerns you can pick are cosmetic. A few count as health information, such as TMJ or headaches. We only use those if you tick the box at the end of the quiz, only to build your routine, and we never send them to our email or AI providers. To withdraw, email help@fingertipfacelift.com.
• If you take the routine quiz before joining: the email address you give us, your answers, and the routine we build from them, so we can send you your plan and have that routine ready for you if you join
• 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.

To open an account and buy a membership you have to give us a name, an email address and a payment method, because we cannot create your account, take the payment, or give you access without them. Everything else on this page is optional, and not giving it only means you do not get the feature it is for.

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. Two things are different, and both are your own choice: a photo you deliberately share with us, and 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. 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. You choose whether to share any of them: you can 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

Marketing emails, meaning practice tips, new levels as they open, and the occasional offer, go only to people who ask for them. Every one has an unsubscribe link, and you can turn them on or off any time on your account page. Saying no changes nothing about your access to anything you bought.

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.

Text Messages (SMS)

We ran a text message program in September 2026. It has ended, and we no longer send texts. If you signed up, you can ask us to delete your number by emailing help@fingertipfacelift.com.

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
• Resend: sends the service emails about your purchase or your membership, such as the instructions for getting into what you bought. These are not marketing, so they are sent whatever you have chosen about marketing email
• 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)

We also use 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: our course checkout. It holds your name, email address, and what you bought
• Stan Store: a checkout we used previously, which still holds the records of anything bought through it
• ManyChat: our Instagram and Facebook messages. It holds a copy of the conversation itself, including anything you send us in a message, along with your social media profile name and any contact details you give us there
• 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

"Disclosed to" means the service providers listed above who handle that data for us, never a sale.

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 have deliberately shared with us, and any photo 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
• Restrict what we do with your data while a question about it is open
• 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. 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 fulfillment, 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.

Our Representative in the EU, the UK and Switzerland

We are based in the United States. If you are in the European Union, the European Economic Area, the United Kingdom or Switzerland, you can reach us through our appointed Data Protection Representative instead of contacting us in the US.

A Wise Approach LLC, trading as Fingertip Facelift, has appointed DataRep (Data Protection Representative Limited, trading as DataRep, registered in Ireland, company number 616588) as its Data Protection Representative under Article 27 of the EU GDPR, the UK GDPR and the Data Protection Act 2018, and under the FADP in Switzerland.

You can contact DataRep about your personal data in any of these ways:

• email datarequest@datarep.com, putting Fingertip Facelift in the subject line
• use their form at www.datarep.com/data-request
• write to DataRep at whichever address below is easiest for you

If you write by post, address your letter to "DataRep" and not to Fingertip Facelift. Letters addressed to us rather than to DataRep are likely not to reach them. Please say clearly inside the letter that it is for Fingertip Facelift.

For anything that is not about your personal data, such as a question about your account, an order or a class, please email us directly at help@fingertipfacelift.com. DataRep cannot help with those and it will be slower.

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 "Keep me signed in on this device" is checked when you sign in, one of them keeps you signed in on that device until you sign out or go about 30 days without a visit, whichever comes first. 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), advertising measurement where enabled (the Meta pixel), and a cookie that remembers how you first found us, for example from an email, a social post or another website, so we can tell which of our own channels bring people here. A second cookie remembers the most recent of those links you followed, so we can tell which one you bought from. Both follow the same rules as the other non-essential cookies described next: if you appear to be in the EEA or UK they are never set before you accept, and elsewhere they are set by default until you opt out. Either way they are only set if the page you arrived on actually told us where you came from. If it did not, nothing is recorded; we never guess. If you opt out afterwards they are removed.

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 traveling 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.

Contact

help@fingertipfacelift.com