Privacy policy — draft

Draft updated: 11 November 2026

Draft — pending qualified legal review

This wording is provisional, not a finalized legal document or a statement of compliance. Legal approval and data-residency arrangements remain unresolved.

Support contact: [support email] (placeholder; not a working contact).

Legal seller: [full legal name], [business status], [ИНН / registration details], [registered address]. Missing details must be verified before merchant submission or sales. Payments remain disabled.

Unresolved decisions for qualified counsel

Identify the legal operator, its jurisdiction, contact details, target countries and applicable laws.
Determine whether selfie analysis, facial metrics and generated looks constitute biometric or other specially protected data, including under Russian 152-ФЗ; determine the lawful basis and any separate consent requirements.
Verify actual countries and regions for account records, photos, AI processing, logs, backups and subprocessors. Decide whether Russian data-localization requirements apply and what hosting or launch restrictions are needed.
Assess cross-border transfers, required notices or authorizations, processor agreements and safeguards. A checkbox alone does not resolve these obligations.
Confirm AI providers' retention, training-use and onward-transfer terms; decide whether the proposed purposes and disclosures can be supported.
Set retention and deletion periods for photos, generated looks, consent, usage, reports, logs and backups; define withdrawal, data-request and incident-response procedures and their limits.
Review the 18+ restriction, age assurance, third-party-photo permission, image rights, prohibited content, liability and dispute terms.
Before enabling purchases, approve RUB prices, pack expiry, consumer disclosures, renewal consent, cancellation timing, refund eligibility and deadlines, paid-access delivery, store requirements and the seller-specific 54-ФЗ or НПД receipt process.
Review whether making Russian payment methods conditional on biometric-processing consent is appropriate and freely given; withdrawal must not erase existing billing, refund or fiscal-record obligations.

What we collect

Your email address and display name, when you create an account.
The selfie you choose, while it is being used to create a look.
The looks you save: the generated image, the styles it was made from, and the date.
A count of how many looks and stylist reads you used each day.
A record that you agreed to this processing, with the date and the version of this notice.
Separate draft biometric-processing consent, recorded before accepting a photo, with server time and any withdrawal time.
Payment records, subscription status, receipt status and purchased-allowance records if payments are enabled in the future. Payments are currently disabled.

Why we collect it

To generate the looks and recommendations you request, keep saved looks private to you, and stop anyone using the app faster than its daily allowance allows. We do not sell your data and we do not use your photo to identify you.

Visitor analytics

Page visits, clicks on buttons and links, and app events are recorded for every visitor. No analytics-choice banner is currently connected. App events record browser assistant tool names, success or failure and duration.

Lovable’s visitor analytics uses no cookies, stores nothing on your device, does not keep IP addresses and does not identify visitors. It records pages visited, where visitors came from, country, browser, operating system, device type, time on page, page-load speed and errors. Detailed data is kept for 90 days and daily summaries for a year.

Lovable collects this data for us. Lovable’s privacy policy explains how it handles it. The app also sends error reports to Lovable.

Sign-in and browser storage

Lovable Cloud handles account authentication, email and display name, consent and usage records, saved-look files and app records. Sign in with Lovable also involves Lovable’s sign-in service. Sign-in session credentials are persisted in browser storage on the published app. Temporary saved-look images and style selections, and the intended return page after sign-in, may be held in session storage; a random sharing/referral identifier is stored in local storage. Sharing sends the image and link to the destination you choose. These app storage uses are separate from cookieless visitor analytics.

External resources and processors

Google Fonts receives requests for the site’s fonts. The on-device hair preview downloads software from jsDelivr and a model from Google-hosted storage; the preview does not upload the selfie to those resource hosts. These external requests reveal connection information such as your IP address to the receiving host; their retention practices need review. AI generation, stylist advice and Ideal Look send your photo and requested styles to services through Lovable’s AI gateway. [Actual AI processor names, processing countries, retention and training-use terms] must be verified. No additional advertising pixels or embedded third-party media were found in the current app.

YooKassa is not active and the app does not currently send it checkout data. Before activation, [payment and receipt data fields], [provider recipients], [retention] and [transfer arrangements] must be confirmed and this notice updated.

Who sees your photo

Your selfie is sent to an AI image service that runs outside this app, and the finished picture comes back through us. The hair-colour preview before you tap Generate is calculated on your own device and is not uploaded. Saved looks and their files are stored in your private area of our hosting; only your own account can read them.

Where your data lives

The actual hosting and AI-processing countries, including subprocessors, logs and backups, have not been verified in this draft. Processing may occur outside your country. Russian data localization and cross-border transfer requirements must be assessed by qualified counsel before launch in affected markets; agreeing to photo processing does not establish compliance.

How long we keep it

Saved looks stay until you delete them. Daily usage counts are not deleted automatically but hold a date and a count linked to your account. Your consent record stays while your account exists. Retention periods, backup deletion and the legal sufficiency of the consent record remain subject to review.

Your controls

Delete any single look from My looks.
Download the account data available through Export my data in My looks. Provider records, logs and backups are not covered by this export.
Remove your account and its app-held saved looks and records with Delete account in My looks. Provider retention, backups and a legally sufficient withdrawal procedure remain to be confirmed.
Withdraw separate photo-processing consent before adding a selfie or in Payment account. New photo processing and Russian payment methods stop; existing payment obligations remain. Accounts with payment history require billing and retention review before deletion.
Stop using the app at any time. The app does not offer purchases or take payment.

Children

Mirror AI is for adults. We do not knowingly accept anyone under 18.

Contact

Support contact: [support email] (placeholder; a working contact and legal operator details must be supplied before launch).