Refrakt handles facial scans, biometric measurements, and personal information. We take that seriously. This policy explains what we collect, why, and the rights you have over it — under the law in your jurisdiction.
This notice is issued by Refrakt ("we", "us", "our") in accordance with the General Data Protection Regulation (GDPR). It applies to individuals in the EU and European Economic Area (EEA).
Refrakt UG (haftungsbeschränkt), Berlin, Germany, is the data controller for all personal data processed through this service. You can reach us at lirikkazh@gmail.com.
Biometric scan data is deleted within 90 days of your last interaction with Refrakt, unless you request earlier deletion. Account data is retained for 24 months following last login, then automatically purged.
To exercise any right, email lirikkazh@gmail.com. We respond within 30 days. If unsatisfied, you may lodge a complaint with your national supervisory authority — e.g. the Berliner Beauftragte für Datenschutz und Informationsfreiheit for users in Germany.
Your data is processed on servers in the EU (Frankfurt). Any transfer outside the EEA is governed by Standard Contractual Clauses (Art. 46(2)(c) GDPR).
Strictly necessary cookies are always on. Analytics and marketing cookies are off by default and only set with your explicit consent via our cookie banner.
Material changes will be posted here with an updated date. Where required by law, we will seek renewed consent.
Bu aydınlatma metni, 6698 sayılı Kişisel Verilerin Korunması Kanunu (KVKK) kapsamında Türkiye'deki kullanıcılara yönelik olarak Refrakt tarafından hazırlanmıştır.
This notice is issued by Refrakt in accordance with Turkish Law No. 6698 on the Protection of Personal Data (KVKK), for individuals located in Turkey.
Refrakt UG (haftungsbeschränkt), Berlin, Germany, is the data controller (veri sorumlusu) under KVKK. Contact: lirikkazh@gmail.com.
Biometric scan data is deleted within 90 days of your last interaction, unless you request earlier deletion. Account data is retained for 24 months after last login.
Send requests to lirikkazh@gmail.com. We respond within 30 days. You may also apply to the Kişisel Verileri Koruma Kurumu (KVKK Kurumu) if your request is not resolved.
Your data is stored on EU-based servers. Cross-border transfers are carried out in accordance with KVKK Art. 9, subject to your explicit consent and appropriate contractual safeguards.
Strictly necessary cookies are always on. Analytics and marketing cookies are off by default and require your explicit consent.
Material changes will be posted here with an updated date.
This notice is issued by Refrakt ("we", "us", "our") in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore. It explains how we collect, use, disclose, and protect personal data for individuals in Singapore.
We collect, use and disclose your personal data only for purposes you would reasonably consider appropriate:
We obtain your consent before collecting biometric data such as your 3D facial scan. Where the PDPA permits, we may rely on deemed consent or relevant exceptions (e.g. legitimate interest, business improvement) — and we will be transparent with you about this in each case.
You may withdraw consent at any time by emailing lirikkazh@gmail.com. We will action your request within a reasonable period and explain any consequences of withdrawal (for example, certain features may become unavailable).
You have the right to request access to the personal data we hold about you, and to ask us to correct it if inaccurate. We will respond within 30 days, or notify you if more time is required. A reasonable fee may apply for access requests, in line with the PDPA's permitted recovery of costs.
We take reasonable steps to ensure personal data is accurate and complete, and we apply administrative, physical and technical safeguards to protect it. See our security page for technical details.
We retain personal data only for as long as needed for the purposes set out above, or as required by law. Facial scans and derived biometric data are deleted within 90 days of your last interaction with Refrakt, unless you ask us to retain them longer for continuity of care.
To deliver the service, your personal data may be transferred to and processed in jurisdictions outside Singapore (including the European Union, where our processing infrastructure is hosted). We ensure any such transfers are subject to a standard of protection that is comparable to the PDPA, via contractual safeguards and binding processor obligations.
We use a small number of strictly necessary cookies to make this site work. Analytics and marketing cookies are off by default and only enabled with your explicit consent via our cookie banner. You can change your preferences anytime from the footer.
Our Data Protection Officer can be reached at lirikkazh@gmail.com for any privacy-related queries, access or correction requests, complaints, or to withdraw consent.
If you are not satisfied with our handling of your personal data, you may raise a complaint with the Personal Data Protection Commission (PDPC) of Singapore at www.pdpc.gov.sg.
We will post any material changes to this notice on this page and update the "Last updated" date. Where required, we will obtain renewed consent.
This notice applies to users located in the United States, Canada, and Latin America. It explains the categories of data we collect, why, the rights you have, and how to exercise them.
We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
If you are a California resident, you have the right to:
To exercise these rights, email lirikkazh@gmail.com with the subject line "Privacy request — California." We will verify your identity and respond within 45 days.
If you are in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) applies. We respect the ten fair information principles, including:
Complaints may be referred to the Office of the Privacy Commissioner of Canada at www.priv.gc.ca. If you're in Québec, additional rights apply under Law 25, including the right to data portability and the right to be informed of automated decision-making.
If you are in Latin America, your local data protection law applies in addition to the protections we offer globally. Notably:
Your 3D facial scan and derived measurements are biometric data. We treat this category with extra care:
Refrakt's infrastructure is hosted primarily in the European Union. By using Refrakt, you understand and agree that your data may be transferred to and processed there. We rely on appropriate safeguards (including Standard Contractual Clauses) for such transfers.
We use strictly necessary cookies to make this site work. Analytics and marketing cookies are off by default and only enabled with your consent. You can change your preferences anytime from the footer.
For privacy questions, requests, or complaints: lirikkazh@gmail.com. We aim to respond within 10 business days and resolve verified requests within the timelines required by your local law.
If we make material changes, we'll post them here and update the "Last updated" date above. Where local law requires it, we'll seek your renewed consent.