Legal

Privacy Policy

Effective 11 August 2026 · Folio is operated by SOBR PTY LTD (Australia)

Overview

Folio is an iOS app that generates cosmetic skincare reports from a selfie and a short questionnaire. Because the app works with photos of your face, we hold ourselves to a strict standard: collect the minimum, explain everything, and let you delete it all.

This policy explains what we collect, why, how long we keep it, and the choices you have. It applies to the Folio iOS app and the folioapp.info website, both operated by SOBR PTY LTD, an Australian company ("Folio", "we", "us").

Folio provides cosmetic, educational guidance only. It is not a medical service, and your data is never used to make medical decisions.

What we collect

DataExamplesWhy
Face photosSelfies you take or upload for a report or check-inTo generate your skin report
Questionnaire answersAge range, skin goals, skin feel, sensitivity, routine level, sunscreen habits, ingredients you avoidTo add context a photo can't show
Account detailsEmail address, Apple sign-in identifierTo create your account and sync reports
Purchase dataSubscription status, product identifier, transaction receipts (handled by Apple)To unlock membership features. We never see your card details.
DiagnosticsCrash logs, performance data, basic usage eventsTo keep the app fast and stable

We do not collect your precise location, your contacts, or your browsing history. We do not run third-party advertising trackers in the app.

How we use it

  • To generate your skin reports and routine suggestions
  • To show your report history and progress over time
  • To provide membership features you've purchased
  • To respond when you contact support
  • To fix crashes, improve quality, and prevent abuse

We do not sell your personal information, and we do not use your face photos for advertising.

Face photos

Photos get special treatment:

  • Metadata stripped. EXIF data (including any location information) is removed when a photo is uploaded.
  • Encrypted at rest. Photos are stored encrypted, accessed only through short-lived signed links.
  • Never sold, never traded. Your photos are not sold, rented, or shared with data brokers — ever.
  • No AI training without opt-in. Your photos are used to generate your report. They are not used to train AI models unless you explicitly opt in.
  • Deletable. Deleting a report deletes its photo and generated assets. Deleting your account deletes all of them.

AI processing

To generate a report, your photo and questionnaire answers are sent securely from our backend to a vision-capable AI model operated by an enterprise AI provider under contractual confidentiality and data-protection terms. The model returns structured cosmetic observations (for example, "hydration: moderate"), which we render into your report.

  • API keys and processing happen server-side — never inside the app itself.
  • Our AI providers are contractually restricted from using your data to train their models.
  • Reports describe visible, cosmetic characteristics only, in cautious language. They never diagnose.

When we share

We share personal data only with service providers who help us run Folio, and only as far as needed:

  • Cloud infrastructure — secure hosting, storage, and databases
  • AI processing providers — report generation, as described above
  • Apple — sign-in and subscription billing
  • Analytics & crash reporting — aggregated usage and stability data

We may also disclose information if required by law, or to protect the rights and safety of users. If Folio is ever part of a business sale or merger, your data remains protected by this policy or one at least as protective, and we'll notify you of any change.

Retention & deletion

  • Reports and photos are kept while your account is active so your history works.
  • Delete a report in-app at any time — its photo and files are removed from active systems promptly, and from backups on their rotation cycle (within 35 days).
  • Delete your account from Settings → Delete account. This removes your account record, reports, photos, and questionnaire answers.
  • Transaction records may be retained where required for tax, accounting, or fraud-prevention obligations.

Security

We use industry-standard measures: encryption in transit (TLS) and at rest, signed short-lived storage links, server-side API keys, least-privilege access controls, and audit logging. No system is perfectly secure, but face data is treated as the most sensitive thing we hold, and we design accordingly.

Your rights

Depending on where you live (including under the Australian Privacy Act 1988, the GDPR in the EU/UK, and comparable laws elsewhere), you may have the right to:

  • Access a copy of the personal data we hold about you
  • Correct inaccurate data
  • Delete your data ("right to erasure")
  • Object to or restrict certain processing
  • Receive your data in a portable format
  • Withdraw consent at any time (for example, AI-training opt-in)

The fastest paths are in-app: delete reports, or delete your whole account. For anything else, email hello@folioapp.info and we'll respond within 30 days. If you're not satisfied, you can complain to your local privacy regulator (in Australia, the OAIC).

Children

Folio is not directed at children under 13, and we don't knowingly collect their data. The App Store age rating for Folio reflects its wellness-topic content. If you believe a child has used Folio without appropriate consent, contact us and we'll delete the data.

International transfers

We're an Australian company and our service providers may process data in other countries, including the United States. Wherever data travels, it stays protected by this policy and by contractual safeguards with our providers (including standard contractual clauses where required).

Changes to this policy

If we make material changes, we'll notify you in the app or by email before they take effect, and update the date at the top of this page. Continued use of Folio after changes take effect means you accept the updated policy.

Contact

SOBR PTY LTD
Brisbane, Queensland, Australia
hello@folioapp.info