Privacy Policy
The Balanx System™ — Kleraty Ltd
Last updated: 21 July 2026
1. Who we are
This app and the associated products are operated by Kleraty Ltd ("Kleraty", "KLERATY", "we", "us", "our"), a company registered in England and Wales (company number 17133319), registered office Office 1, Izabella House, 24-26 Regent Place, Birmingham, West Midlands, B1 3NJ, United Kingdom.
We are the data controller for the personal data described in this policy.
- General contact: contact@kleraty.co.uk
- Data protection contact: dpo@kleraty.co.uk
2. The personal data we collect
Account data — your name, email address, and login credentials (managed via our authentication provider).
Skin scan data — when you use the biometric scan, we process:
- a photograph of your face captured by your device camera;
- the skin analysis results derived from it (our five markers: Texture, Tone, Pigmentation, Hydration, Condition, and related sub-scores and highlighted regions).
Because these results relate to the condition of your skin, they may constitute special category data (data concerning health) under Article 9 UK GDPR, and face imagery processed to analyse physical characteristics may engage the rules on biometric data. We treat this data as sensitive and rely on your explicit consent to process it (see section 4).
Routine and usage data — the KLERATY protocol generated for you, your scan history and progress over time, and in-app interactions.
Concierge chat data — messages you send to the in-app AI concierge and its responses.
Payment data — we use a third-party payment processor (Stripe). We do not store your full card details; Stripe processes them. We retain records of your purchases and subscription status.
Technical data — device type, app version, and basic diagnostic/log data.
3. How your face image is handled
Your face image is sent securely to our third-party skin-analysis provider (AILab Tools) solely to generate your skin markers. Per that provider's terms, uploaded images are used only for processing and deleted immediately after analysis, and are not retained by them.
We do not store your raw face image beyond what is necessary to produce and show your scan result, unless you explicitly choose to save a scan photo for your own before/after comparison.
4. Why we process your data, and our legal basis
| Purpose | Lawful basis (UK GDPR) |
|---|---|
| Create and manage your account | Contract (Art. 6(1)(b)) |
| Perform the skin scan and generate your markers/protocol | Explicit consent (Art. 6(1)(a) + Art. 9(2)(a)) |
| Provide the AI concierge | Contract / legitimate interests |
| Process payments and manage subscriptions | Contract |
| Improve and secure the service | Legitimate interests |
| Send service and (with consent) marketing emails | Consent / legitimate interests |
You can withdraw consent to the skin scan at any time; this won't affect processing done before withdrawal, but some features won't work without it.
5. Who we share data with
We share limited data with service providers acting on our behalf:
- AILab Tools — skin analysis (see section 3)
- Supabase — database, authentication, and storage (hosted in the UK / West Europe – London)
- Stripe — payment processing
- Anthropic (Claude) — powers the AI concierge; chat content is processed to generate responses
- Resend — transactional email delivery
We do not sell your personal data.
6. International transfers
Some of our providers process data outside the UK (for example in the United States). Where your data leaves the UK, we rely on appropriate safeguards such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or an adequacy decision, so your data receives an equivalent level of protection.
7. How long we keep it
We keep account and scan data for as long as your account is active, and delete or anonymise it within 12 months of account closure, except where we must retain records longer for legal or accounting reasons. You can delete your scan data or account at any time from the app's Data & Privacy settings.
8. Your rights
Under UK GDPR you have the right to: access your data; correct it; delete it; restrict or object to processing; data portability; and to withdraw consent. Where our basis is consent, you can withdraw it at any time.
To exercise any right, contact dpo@kleraty.co.uk. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk.
9. Children
The service is not intended for anyone under 18. We do not knowingly collect data from children.
10. Changes
We may update this policy and will post the new version here with a revised date. Material changes affecting the skin scan will be notified in-app.
11. Contact
Kleraty Ltd — contact@kleraty.co.uk — Office 1, Izabella House, 24-26 Regent Place, Birmingham, West Midlands, B1 3NJ, United Kingdom