Biometric Data Policy
Last updated: August 2025
This Biometric Data Policy supplements our Privacy Policy and Terms and Conditions. It describes in detail how See Stella Pty Ltd (ACN 669 216 924) collects, processes, retains, and deletes biometric information obtained when you use the Stella facial scanning feature.
1. What Counts as "Biometric Data" at Stella?
At Stella, Biometric Data refers to:
- High-resolution facial photographs captured via the in-app camera.
- Derived facial-skin metrics — for example, wrinkle depth, redness index, pore visibility, and pigmentation maps — computed from those photographs.
2. Why We Collect Biometric Data
We collect and process Biometric Data only for the following purposes:
To Generate Skin Insights
Analyse facial metrics to provide you with personalised cosmetic and wellness observations, tracked over time.
User Experience
Display your scan history and progress so you can see how your skin metrics change in response to your routine, lifestyle, and environment.
Product Improvement
Train and validate our AI skin-analysis models using aggregated or de-identified data where feasible, to improve measurement accuracy for all users.
Security & Fraud Prevention
Detect spoofed, reused, or fraudulently submitted images to maintain the integrity of your personal skin data.
3. Consent
We obtain explicit, informed opt-in consent before your first facial scan. The consent screen explains:
- What Biometric Data we capture and how it is processed.
- Why we collect it and how it benefits you.
- Our retention schedule and how to request deletion.
- How to withdraw consent at any time.
You must tap "I Consent" to proceed. Consent can be withdrawn at any time by deleting your account or emailing privacy@seestella.co.
Without consent, scanning features will be unavailable, but you can still browse content and use other non-biometric features of the app.
4. Retention Schedule
We retain Biometric Data for the minimum time necessary to deliver our services.
| Data Type | Retention Period | Deletion Method |
|---|---|---|
| Raw facial photographs | 3 years from date of capture | Secure deletion from primary storage; cryptographic erasure applied to backups |
| Derived biometric metrics (skin scores, analysis data) | Up to 3 years from your last account activity, or until you delete your account | Secure deletion; anonymised aggregates may be retained for model improvement |
If you withdraw consent or request early deletion, we will complete the process within 45 days (or within 30 days for users in Illinois, as required under the Illinois Biometric Information Privacy Act).
5. State-Specific Requirements (USA)
Illinois (BIPA)
If you are an Illinois resident, we collect Biometric Data only with your prior written consent. We do not profit from your Biometric Data. You may request deletion within 30 days. Our full BIPA-compliant retention schedule is available on request at privacy@seestella.co.
Texas (CUBI Act)
If you are a Texas resident, we will not sell your Biometric Data and will destroy it within a reasonable time after the purpose for which it was collected has been satisfied, or within 3 years of your last interaction — whichever is first.
Washington (WA MHMD) & Other CHD States
Biometric Data constitutes Consumer Health Data under the Washington My Health My Data Act and equivalent state laws. Your rights and our obligations in those states are detailed in Section 6 of our Terms and Conditions and our Privacy Policy.
6. Security Measures
We apply the following technical and organisational controls to protect Biometric Data:
- Encryption at rest: AES-256 encryption on all stored data.
- Encryption in transit: TLS 1.2+ for all data transmitted between your device and our servers.
- Network isolation: Production systems are network-isolated; access requires multi-factor authentication for all privileged roles.
- Access controls: Only personnel with a documented need-to-know role may access identifiable Biometric Data; all access is logged and periodically reviewed.
- Infrastructure certifications: Our cloud provider (Google Cloud Platform) holds SOC 2 Type II, ISO 27001, and IRAP PROTECTED certifications.
- Incident response: We maintain a documented breach-response plan and will notify affected users and regulators within 72 hours of confirming a breach likely to cause serious harm.
7. Sharing & Disclosure
We share Biometric Data only in the following limited circumstances:
- Service providers who process data strictly on our instructions and under contract, and who are prohibited from further disclosure or independent use.
- Legal requirements — when legally compelled by a valid court order, law enforcement request, or regulatory obligation.
We never sell, rent, or licence Biometric Data to any third party. We never share it with advertisers or data brokers.
8. Your Rights
Request a copy of your Biometric Data in a machine-readable format (JSON or CSV) by contacting privacy@seestella.co.
Delete individual scans or your entire history at any time from within the app, or by emailing us. Deletion is completed within 45 days (30 days for Illinois residents).
Disable future scans at any time in app settings. No further Biometric Data will be collected from that point. Existing data is retained per the schedule in Section 4, unless you also request deletion.
Lodge a complaint with the OAIC (Australia), the relevant US state regulator, or contact us directly at privacy@seestella.co.
Contact Us
For any questions about this Biometric Data Policy or to exercise your rights, please contact our Privacy Officer:
See Stella Pty Ltd
Suite 329 / 98–100 Elizabeth Street, Melbourne VIC 3000, Australia
privacy@seestella.co
We acknowledge complaints within 5 business days and aim to resolve them within 30 days. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or call 1300 363 992.