Data Protection Notice

Last updated: September 2026

This text is a draft. It is not final until the company name and address, the retention periods and the basis for transfers abroad are filled in and a lawyer has approved it.

This notice explains what data this page collects and why. It is the transparency notice required of us as data controller. Where we need your consent, we ask for it separately, with the tick box next to the email field.

Who is the data controller?

Onerify is the data controller. You may be seeing this page under a creator's name, but Onerify is the party that processes and stores your data; the creator only manages their own catalogue and questions and sees aggregate statistics. The company name, registration number and address will be added here before launch.

What we collect

Three groups of data:

  • Your analysis answers, and anything you write in the free-text box.
  • Only if you tick the box: your email address.
  • Usage events: the analysis being started, the result being viewed, a product being clicked. Product clicks also record your browser type (user agent).

Anonymity, and where it ends

We want to be plain about this. Your answers are stored without being tied to your identity, and your IP address is never recorded. But if you give us your email address, that session is no longer anonymous: your answers, your free text and that session's clicks all become linkable to your email. Giving an email is entirely optional and is not needed to see your routine.

Why we process it, and on what basis

Purpose by purpose:

  • Your answers: to build your routine. The basis is performance of the service you asked for and our legitimate interest in providing it; once you give an email, and the data is tied to you, we also rely on your explicit consent.
  • Your email: only to send your routine and share care content. The basis is your consent, which you can withdraw at any time.
  • Usage events: to check the service works, to see errors, and to give the creator aggregate statistics that carry no identity.

Are hair and skin answers health data?

Because your answers can touch on things like hair loss, dandruff or sensitivity, they may count as health-related data once they are tied to your identity. That is exactly why we do not link answers to a person unless you give us an email. What this page produces is cosmetic care guidance, not a diagnosis or a treatment.

Who we share it with

We do not sell your data and we do not share it with third parties for advertising. To run the service we use:

  • A hosting and database provider (Supabase, Frankfurt, Germany).
  • An email delivery provider — only if you gave us your email address.
  • What you write in the free-text box is sent to an AI provider (Google Gemini) to group it into themes. Your email address is never sent with it.
  • Public authorities, where the law requires it.

Transfers abroad

Your data is stored on servers in Frankfurt, Germany, and free text is sent to an AI provider based in the United States. For a Turkish data controller both count as transfers abroad. The mechanism we rely on under Article 9 of the Turkish data protection law will be stated here before launch.

How long we keep it

At present, analysis records and usage events are kept for as long as the service runs. Exact retention periods for each kind of data are being set and will be written here before launch. Regardless of that, if you write to us we will delete your data.

Automated processing

Your routine is worked out by an automatic matching engine that reads your answers and the creator's product tags. No person makes that decision. The result is a care suggestion and has no legal effect on you. You can still object to the outcome.

Your rights

You have the right to:

  • Learn whether your personal data is being processed,
  • Request information about it if it is,
  • Learn its purpose and whether it is used in line with that purpose,
  • Know the third parties it is transferred to, at home or abroad,
  • Have it corrected if it is incomplete or wrong,
  • Ask for it to be erased or destroyed,
  • Ask that correction, erasure and destruction be notified to anyone it was transferred to,
  • Object to an outcome that works against you and came solely from automated analysis,
  • Claim compensation if unlawful processing caused you harm.

How to make a request

Write to info@onerify.com. We answer within thirty days at the latest. We may need to ask for enough information to confirm who you are. Our postal address will be added here before launch.

Cookies

This page uses no third-party advertising or analytics cookies. There is only a cookie that remembers your language and a small preference stored in your browser. If that ever changes, this notice will be updated and, where it is needed, we will ask for your consent separately.

Data Protection Notice