Privacy Policy

Last updated: 31 July 2026

This Privacy Policy explains how Kilter Digital (a Norwegian sole proprietorship / enkeltpersonforetak, org. no. 936 936 768, owned by Filip Jolma Helland Kilter) (“we”, “us”, the data controller) collects and uses your information when you download, install and use the Embla mobile application (“the app”).

The photograph of your face is never stored. It exists only inside the single request that reads it: it is sent once to the model that analyses it, and it is gone when the response returns. There is no image storage in our backend, no database column holds image data, and no log line contains the photograph. This is an architectural property of the service, not a policy promise we could quietly change.

1. What we collect

Your capture photograph

When you take a capture, the app measures your face on your device and sends the photograph, together with those measurements, to our backend, which forwards it once to an AI vision model to write the qualitative part of your Face File. As stated above, the photograph is not retained at any point in that path, by us. It is not posted anywhere, it is not shared with other users, and it is never used to train models.

Your measurements and your Face File

The measurements, readings and plan that make up your Face File are kept on your device. If you choose to sign in with Apple, we can associate your entitlement with your account so your access survives a new phone. Signing in is optional and you can skip it.

An anonymous app identifier

Embla works without an account. To deliver analyses and subscription access, the app generates a random, anonymous identifier for your install. It is not your name, email or phone number, and we do not use it to build a profile of you.

Device integrity and usage counters

Our backend stores an Apple App Attest device key and attestation receipt to confirm that requests come from a genuine, unmodified copy of the app, and a count of how many analyses that device has used in the current week so we can apply fair-use limits. It also records that a one-time “potential” drawing was made for your device. That record is the fact that it happened; the drawing itself is returned once and lives only on your device.

Purchases

Subscriptions are processed by Apple and managed through our subscription provider, RevenueCat. We receive your subscription status, for example active or expired, and never your payment-card details, which are handled entirely by Apple.

Technical and diagnostic data

Our servers process the technical information needed to operate the service securely, such as request metadata, rate-limiting counters and error logs. Structured logs carry labels, latency and model identifiers only. This is used to run and protect the service, not to track you across other apps.

Advertising measurement

To understand which marketing campaigns lead to installs, the app reports conversion values to Apple’s privacy-preserving SKAdNetwork and AdAttributionKit. This does not identify you. If we later add a measurement or analytics provider that uses your device’s advertising identifier, it will run only with your consent through the iOS App Tracking Transparency prompt, and we will update this Policy and our App Store privacy labels first.

If you contact us

If you email us, we process the contact details and content you choose to provide, in order to respond.

2. How and why we use it (legal bases)

To produce your analysis and plan from your capture, to perform our contract with you.
To verify subscription entitlements and to apply fair-use limits, for contract performance and our legitimate interests in securing the service.
To confirm requests come from a genuine copy of the app and to prevent abuse, for legitimate interests.
To keep the service secure and reliable and to fix faults, for legitimate interests.
To measure marketing performance in aggregate through Apple’s privacy-preserving frameworks, for legitimate interests. Any identifier-based tracking would require your consent.
To respond to your messages, for legitimate interests.

We do not sell your personal information, and we do not use your photograph or your measurements for advertising.

3. The analysis and AI processing

Your analysis combines deterministic measurements computed on your device with a written reading generated by an AI model, accessed through the OpenRouter API. The photograph and the measurements are sent for that single request and are not retained by us afterwards.

Embla is a cosmetic and informational product. It is not a medical device, it does not diagnose, treat or prevent any condition, and its readings are estimates rather than clinical findings. See our Terms of Use.

4. Service providers

We share the minimum necessary data with providers who process it on our behalf:

Cloudflare: hosting and edge infrastructure for the backend and this site.
OpenRouter, and through it the AI model provider serving the request: to generate the written analysis from the submitted photograph and measurements.
Apple: App Store distribution, in-app purchases, Sign in with Apple, and app integrity through App Attest.
RevenueCat: subscription management and entitlement verification.

These providers may use the data only to deliver their service to us, and process it under their own privacy policies. We do not include third-party advertising networks in the app. If we change the tools we use, we will update this Policy and the App Store privacy labels accordingly.

5. Data retention

Your capture photograph is not retained at all. Your Face File lives on your device and remains until you delete it or remove the app. Server-side records are limited to your entitlement status, your device attestation key, weekly usage counters and the one-time drawing record, kept for as long as necessary to provide and protect the service or as required by law. You can ask us to delete the server-side data associated with your install.

6. Your rights

Because we operate from Norway, which is in the EEA, the GDPR applies. Subject to its conditions, you have the right to:

be informed about how your data is used, which is this Policy;
access the personal data we hold about you;
rectify inaccurate data and complete incomplete data;
erase your data;
restrict or object to certain processing;
receive your data in a portable format;
withdraw consent at any time, without affecting prior processing;
lodge a complaint with a supervisory authority. In Norway this is the Norwegian Data Protection Authority, Datatilsynet.

To exercise any of these, email us at the address below. You can control camera access in iOS Settings, manage tracking permission under Privacy & Security > Tracking, and manage or cancel subscriptions in your Apple ID settings. Removing the app deletes your on-device Face File.

7. Security

We use industry-standard measures including encryption in transit, scoped access, hardware app-integrity checks and rate limiting. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. The strongest protection for your photograph is that it is never written down anywhere.

8. Children

Embla is intended for adults and is not directed to children. We do not knowingly collect personal data from anyone under 16. If we learn that we have, we will delete it promptly.

9. International transfers

Our providers may process data in countries outside the EEA, including the United States. Where this happens we rely on appropriate safeguards, such as the EU Standard Contractual Clauses or an adequacy decision, as required by law.

10. Changes to this Policy

We may update this Policy from time to time. Material changes will be reflected in the “Last updated” date above and, where appropriate, noted in the app.

11. Contact

For any privacy question, or to exercise your rights, contact the data controller:

Kilter Digital (enkeltpersonforetak)
Org. no. 936 936 768
Kong Haralds gate 46A, 4041 Hafrsfjord, Norway
Email: fk.apps.customer@gmail.com