Privacy Policy

1. Who we are

Cutr (the app and trycutr.app) is run by SwiftCart Media Limited, Unit B, 3/F., Kai Wan House, 146 Tung Choi Street, Mongkok, Kowloon, Hong Kong ("we", "us"). We are the controller of the personal data described here. Questions about privacy: support@trycutr.app.

2. What we collect

• Account details. An account ID created when you first open the app. If you sign in: your email address, or your name, email and profile picture from Google if you use Google sign-in.
• Setup answers. What you tell the app during setup, such as your first name, age, hair type and the look you want.
• Photos. The selfies you take or pick in the app for analysis, and the pictures our AI makes from them (your "Looks").
• Face measurements. Proportions the app measures on your phone (for example face length to width, jaw and hairline position) and the face shape worked out from them.
• Results. Your analysis, recommended cuts, barber briefs and your saved library.
• Purchases. Which Look packs you bought, when, and your Looks balance. Payment itself is handled by Google Play; we never see your card details.
• Technical data. Our servers log basic request data (such as IP address, time and app version) to keep the service running and secure.
• Messages. What you send us when you email support.

The app contains no advertising and no third-party analytics or tracking SDKs.

3. How we use it

• To run the service you ask for: analyse your photo, recommend cuts, make try-on and colour pictures, and keep your library. (Legal basis: performing our contract with you.)
• To manage your account, sign-in, email confirmation and your Looks balance. (Contract.)
• To keep the service secure, prevent abuse and fix problems. (Our legitimate interests.)
• To answer you when you contact us. (Contract and legitimate interests.)
• To meet legal duties, such as tax records. (Legal obligation.)

We don't sell your data, we don't use it for advertising, and we don't make decisions about you that have legal or similarly serious effects.

4. Your face and photos

The face scan runs on your phone. The app uses Google's on-device ML Kit to find the outline of your face and your hairline. This happens on the device; ML Kit does not send your photo to Google.

The AI work runs on our servers. To make your analysis and pictures, your photo and face measurements go to our server and from there to the AI providers listed below. We use your face only to describe its shape and draw haircuts on it. We don't use it to identify or recognise you, and we don't build a face template to match you against other people.

We don't use your photos to train AI models, and we don't share them with anyone except the providers that do the work for us.

5. Who we share it with

We use these service providers. They process data only to provide their service to us:

We may also disclose data if the law requires it, or to a buyer if the business is sold (with this policy still applying).

International transfers. These providers may process data outside your country, including in the United States and Asia. Where the law requires it, we rely on safeguards such as the European Commission's Standard Contractual Clauses.

6. How long we keep it

• Photos, Looks and results stay in your account until you delete them or delete your account.
• When you delete your account, we delete your profile, photos, Looks and library from our database and storage straight away. Copies in server backups are gone within 30 days.
• AI providers handle each request to return a result. Under their own terms some keep request data for a short time, for example to prevent abuse.
• We may keep purchase records as long as tax law requires. Google keeps its own Google Play records under Google's policy.

7. Your rights

Depending on where you live (for example under the GDPR, the UK GDPR, Hong Kong's PDPO or US state laws), you can ask us to give you a copy of your data, correct it, delete it, limit or object to how we use it, or send it to you in a portable format.

• Delete a Look: in the app, in your library.
• Delete everything: in the app, Settings → Delete account, or see trycutr.app/delete-account.
• Everything else: email support@trycutr.app from the address on your account. We answer within 30 days.

You can also complain to your local data protection authority.

8. Children

Cutr is for people aged 16 and over. We don't knowingly collect data from younger children. If you think a child under 16 is using Cutr, email us and we'll delete the account.

9. Security

Data travels over encrypted connections (HTTPS) and is stored with access controls so each account can only reach its own files. No system is perfectly secure, but we work to protect your data and will tell you and the authorities about a breach when the law requires it.

10. This website

trycutr.app sets no cookies and uses no analytics. It is hosted by Cloudflare, which processes visitors' IP addresses to deliver and protect the site, and it loads fonts from Google Fonts, which sees your IP address when the fonts load.

11. Changes

If we change this policy in a way that matters, we'll tell you in the app before the change takes effect. The date at the top shows the latest version.

12. Contact

SwiftCart Media Limited, Unit B, 3/F., Kai Wan House, 146 Tung Choi Street, Mongkok, Kowloon, Hong Kong. Email support@trycutr.app.