Draft — pending legal review

Privacy Policy

Last updated: 24 September 2026

Applies to: the Visage iOS application ("Visage", "the App")

Data controller: Bias Labs FZ, Meydan, Dubai, United Arab Emirates

1. Who we are

Visage is developed and operated by Bias Labs FZ, a company located in Meydan, Dubai, United Arab Emirates.

Trade licence number[to be completed]
Registered address (full)[to be completed]
Contact email (privacy)[to be completed]
Data Protection Officer[to be completed]

We refer to Bias Labs FZ as "we", "us", or "our" in this policy, and to a person using Visage as "you".

2. What Visage does

Visage lets you upload photos of your own face and generates simulated "after" images that illustrate what certain aesthetic or cosmetic procedures might look like on you. The images are produced by artificial intelligence models and are illustrative simulations only — see Section 9 and our Terms of Use for the full disclaimer.

3. Information we collect

CategoryWhat it includesSource
Account & identity Email address; name (from your sign-in provider, or entered by you); date of birth (email sign-up only — see Section 6); gender (optional, if you choose to provide it) You, or Apple / Google when you sign in with them
Face photos Up to five photos of your face (front, left, right, left-oblique, right-oblique angles), captured through the in-app guided camera You, via the App's camera
Generated images AI-simulated "after" images produced from your uploaded photos, and associated metadata (procedure selected, model used, status) Generated by our service on your request
Consent records Whether and when you accepted this Privacy Policy and our Terms of Use Recorded automatically when you tap accept
Purchase data In-app purchases of credits, processed through Apple and RevenueCat. This feature is not yet live at the time of this policy's last update Apple / RevenueCat, when purchases are enabled
Device & technical data Basic technical information needed to operate the service (e.g. request logs, device type, app version). We do not currently use third-party advertising SDKs Generated automatically by use of the App

4. How we use your information

5. Legal basis for processing

We process your personal data on the basis of your consent, which you give on the in-app consent screen before your first photo upload, generation, or analysis request. Where relevant (for example, users in the European Economic Area), we may also rely on the performance of a contract with you (to provide the service you requested) or our legitimate interests in operating and improving Visage, balanced against your rights.

6. Age requirements

Visage is not directed at children and you must be at least 13 years old to use it.

If you sign up with email, we ask for your date of birth and check that you are at least 13. If you sign in with Apple or Google, those providers do not share a verified date of birth with us, so no automated age check runs for that sign-in method. We state this plainly rather than implying a check we cannot perform: an App Store age rating describes content suitability, it does not verify an individual user's age.

7. Where your data is stored

Your photos and generated images are stored in private cloud storage (provided by Supabase) and are never publicly listed. The App accesses them only through short-lived, cryptographically signed links that expire after a limited time. Our application programming interface runs on servers hosted by Hetzner in Ashburn, Virginia, USA. Our database and authentication provider (Supabase) may store data in the region configured for our project: [to be completed — Supabase project region].

8. Who we share data with

We use the following categories of processors to operate Visage. We do not sell your personal data.

ProcessorPurpose
SupabaseAuthentication, database, and private file storage
fal.aiRuns the AI image-generation models used to create your simulated "after" images
OpenRouter (routing to model providers including OpenAI and Google) Provides access to the AI image models used for certain procedures (for example, OpenAI's image model and Google's image model)
Apple / RevenueCatProcesses in-app purchases of credits, once this feature is enabled
HetznerHosts our backend servers (Ashburn, Virginia, USA)

Each of these processors only receives the data necessary for the function it performs. Your face photos are sent to the AI image-generation processors above solely to produce the simulation you requested.

9. AI-generated content and accuracy

The images Visage produces are computer-generated simulations for illustrative purposes. They are not medical advice, not a diagnosis, and not a guarantee of any real-world surgical or cosmetic outcome. See our Terms of Use for the full medical disclaimer.

10. International data transfers

Bias Labs FZ is based in the United Arab Emirates. Our backend servers are hosted by Hetzner in Ashburn, Virginia, USA, and other processors we use may be located in the United States or elsewhere. This means your data is transferred from the UAE to the United States, and potentially to other countries, in the course of providing the App. Where we transfer personal data across borders, we rely on the safeguards required by applicable law, including the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and, for users in the European Economic Area, mechanisms such as standard contractual clauses. Additional detail on specific transfer mechanisms: [to be completed].

11. Data retention

12. Your rights

Depending on where you live, you may have the right to access, correct, delete, restrict, or object to our processing of your personal data, and the right to data portability. UAE PDPL and, for EEA users, the General Data Protection Regulation (GDPR) both give you these rights.

13. Children

Visage is not intended for children under 13. If we learn that we have collected personal data from a child under 13 without appropriate consent, we will delete it.

14. Contact us

If you have questions about this Privacy Policy or want to exercise your rights, contact us at:

[to be completed — privacy contact email]

Bias Labs FZ
Meydan, Dubai, United Arab Emirates
[to be completed — full registered address line]

15. Changes to this policy

We may update this Privacy Policy from time to time. We will update the "Last updated" date above when we do. Material changes will be highlighted in the App.

16. Governing law

This Privacy Policy is governed by the laws of the United Arab Emirates. Any dispute arising from it is subject to the exclusive jurisdiction of the courts of Dubai [to be completed — DIFC Courts opt-in, if elected].