Privacy Policy

This Privacy Notice for Peak Lock ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (Peak Lock), or any other application of ours that links to this Privacy Notice
• Use Peak Lock. Peak Lock is an iOS app that blocks distracting apps until you complete a daily looksmaxing routine, verified by a selfie video.
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• selfie images and short verification videos used to perform face-scan analysis and to verify completion of your daily routine
• onboarding profile information you choose to provide, including sex, date of birth, height, weight, ethnicity, country, skin type and concerns, hair status, dietary habits, sleep patterns, and looksmaxing goals
• your selection of which apps to block (stored on-device only)

Sensitive Information.

Some of the information you provide may be considered sensitive in certain jurisdictions — for example facial images used for face-scan analysis. Where required by applicable law, we obtain your explicit consent before collecting or processing this information. You can withdraw this consent at any time by deleting your account or by contacting us at [email protected].

Face Data.

Peak Lock's core features rely on images of your face, so we want to be specific about exactly what this involves:

• What we collect. A single frontal selfie photo when you choose to run a face scan, and a short (up to roughly 10-second) front-facing selfie video — or, for certain routine steps, a single photo — when you verify that you completed your daily routine. You capture these yourself using the in-app camera, and only when you choose to start a scan or a verification.
• How we use it. The image or video is used solely to generate your "looks score" and personalized routine, or to confirm that you performed a routine step so the app can unlock your blocked apps. We do not use your face data for advertising, we do not sell it, and we do not use it to train AI models.
• No facial recognition or biometric identification. We do not create a faceprint, face template, or any other biometric identifier from your images, and we do not use them to recognize or identify you. This feature does not use Apple's Face ID. On-device face detection is used only to help you frame the camera while recording, and that framing data never leaves your device.
• Who we share it with. Only Google's Gemini API receives your selfie photos and verification videos, and only the visual content itself — never your name, email, or other account details (see Section 3).
• How long we keep it. Your selfie photos and verification videos are permanently deleted from our servers immediately after the analysis completes; we retain only the resulting non-image results, such as your numeric scores (see Section 7).

Payment Data.

We may collect data necessary to process your subscription if you choose to purchase Peak Lock Premium, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by the App Store. You may find their privacy notice link(s) here: https://www.apple.com/legal/privacy/data/en/app-store/.

Social Media Login Data.

We may provide you with the option to register with us using Sign in with Apple. If you choose to register in this way, we will collect certain profile information about you from Apple, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data.

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your camera (for selfie capture), Screen Time and Family Controls (for app blocking), notifications, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
• Push Notifications. We may request to send you push notifications regarding your account, your daily routine, or certain features of the application. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

The information we collect includes:

• Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.
• Device Data. Information about your device used to access the Services, including IP address, device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of services to the user, including performing face-scan analysis on your selfies and verifying that you have completed your daily looksmaxing routine.
• To evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends so we can better understand how our Services are being used and improve them.
• To comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Third-Party AI Services. To provide our face-scan and routine-verification features, we share your selfie images and short verification videos with Google (Gemini API) for vision analysis. Only the visual content of your selfies and verification videos is transmitted to Google — no other personal account information such as your name or email address is sent with these requests. Your explicit consent is obtained in the app before any data is sent to these services. Google is contractually required to handle your data in accordance with its respective privacy policies and applicable data protection laws.
• Subscription Management. We use RevenueCat to manage subscriptions and entitlements. RevenueCat receives a pseudonymous user identifier and your subscription status. It does not receive your name, email, or any selfie content.
• Authentication. We use Apple (Sign in with Apple) to authenticate you. Apple may share with us a private relay email address and your name if you authorize it. We never receive your Apple ID password.
• Infrastructure. Our backend services run on Cloudflare (Workers, D1, R2, Queues). Cloudflare processes data on our behalf as a data processor and is contractually bound to handle your data in accordance with applicable data protection laws.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) on our website to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: Yes — Peak Lock relies on AI vision models to score your face scan and verify your daily routine.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Our AI Products

Our AI Products are designed for the following functions:

• Face-scan analysis. A vision model rates features such as symmetry, jawline definition, and skin clarity from your frontal selfie in order to produce a "looks score" and a personalized routine.
• Routine verification. A vision model reviews a short selfie video to confirm that you have completed the daily routine steps shown in the app.

How We Process Your Data Using AI

When you submit a face scan or complete a daily routine, the following data is processed by third-party AI services:

• Selfie images: Your frontal selfie is sent to Google (Gemini API) for face-scan analysis.
• Verification videos: Short videos of you completing your daily routine are sent to Google (Gemini API) for routine verification.

No personal account information (such as your name, email, or payment details) is shared with these AI service providers. Only the visual content needed to perform the analysis is transmitted.

Your explicit consent is obtained within the app before any image or video data is shared with these third-party services. All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with these providers, which require them to provide equivalent data protection safeguards.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using Sign in with Apple, we may have access to certain information about you.

Our Services offer you the ability to register and log in using Sign in with Apple. Where you choose to do this, we will receive certain profile information from Apple. The profile information we receive may include your name and a private relay email address. We do not receive your Apple ID password.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by Apple. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

Your selfie images and verification videos are processed transiently only. When you submit a face scan or a routine verification, the image or video is sent to our analysis provider and is then permanently deleted from our servers immediately after the analysis completes — whether the analysis succeeds or fails. We do not store your selfie photos or verification videos at rest on our servers. We retain only the resulting non-image analysis results (for example, your numeric scores) so that we can show you your score history. Any scan photos shown in your in-app progress timeline are stored only on your device and never leave your phone except for this transient analysis.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent:

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications:

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using the contact information provided.
• Open the Peak Lock app and use the "Delete account" option in Settings.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies:

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at [email protected].

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at [email protected].