Privacy Policy
Last updated: 2 October 2026
1. Controller
Fabian Bäßler, Jägerstraße 1, 97688 Bad Kissingen, Germany. Email: [email protected].
2. Overview
Cephra measures your face from two photos. Facial geometry is calculated in your browser. Photos leave your device only where described below. We use no advertising, no analytics and no tracking cookies, and we do not sell data.
3. Visiting the website
When you open Cephra, our hosting provider processes technical data (IP address, time, requested page, browser type) to deliver the site and keep it secure (Art. 6 (1) (f) GDPR). Log data is deleted after [retention period, e.g. 14 days]. Hosting provider: [hosting provider, location, data processing agreement].
4. Your photos, scans and measurements
You upload a front and a side photo. Landmarks and measurements are computed in your browser. Your photos, point corrections and results are stored [where scans are stored in the hosted version, e.g. on our servers in the EU / in your browser] so you can reopen your scans. You can delete them at any time in the app (“My data”).
Sensitive data. Face photos can reveal information such as ethnic origin or health, and you may select a gender and ethnicity as reference profile. We process this only with your explicit consent (Art. 9 (2) (a) GDPR), which you give by starting a scan and can withdraw at any time by deleting your scans. We never use your photos to identify you.
5. Automatic appearance assessment
For each new scan, prepared copies of your two photos are sent to the Cephra assessment service, which uses a cloud AI model provider in the United States acting as our processor. The provider returns visual observations, which we store with your scan; it does not use the photos to train models and deletes them according to its data processing terms. Legal basis: your consent (Art. 9 (2) (a) GDPR) and the contract (Art. 6 (1) (b) GDPR). Transfers to the United States rely on the EU–US Data Privacy Framework or standard contractual clauses.
6. AI analyst and AI personas (full access)
When you use the AI analyst, your scan’s measurements, results and plan and the prepared photos are sent to the same assessment service to answer you. When you use AI personas, your questions and the conversation are sent to AI model providers and web search providers to research an answer; the conversation is stored so you can continue it, and you can delete it. Both features are labelled as AI. Legal basis: contract (Art. 6 (1) (b) GDPR); for photos, your consent (Art. 9 (2) (a) GDPR). Third-country transfers as in section 5.
7. Purchases and payment
Purchases are processed by Paddle.com Market Limited, 30 Old Bailey, London EC4M 7AU, United Kingdom, as reseller and Merchant of Record. Paddle collects your payment and billing details and processes them as an independent controller under its privacy notice. We never see your card or PayPal details.
From Paddle we receive and store your subscription and customer identifiers, plan, status and billing period, and we store when your browser last opened full access. We use this to unlock your access and to decide refund requests (Art. 6 (1) (b) and (f) GDPR). We keep it for as long as your subscription runs and afterwards as required by tax and commercial law.
8. Cookies and storage on your device
cephra_access– keeps your paid access in this browser (strictly necessary, up to 400 days).cephra_persona_session– links your AI persona conversations to this browser (strictly necessary).- Local storage – your analysis results, settings and display preferences.
These are required for the features you use (§ 25 (2) TDDDG); we do not set any other cookies.
9. Email contact
If you email us, we use your message and address to answer you (Art. 6 (1) (b) or (f) GDPR) and delete them when no longer needed.
10. Your rights
You have the right to access, rectification, erasure, restriction of processing, data portability and to object to processing based on legitimate interests. You can withdraw consent at any time with effect for the future. Contact us at [email protected]. You can also lodge a complaint with a supervisory authority, for example Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach.
11. Changes
We update this policy when Cephra changes. The date above shows the current version.