Privacy Policy — Bloomy: Face Yoga

Last updated: 2 July 2026

Who we are. Bloomy: Face Yoga (“Bloomy”, “the app”, “we”) is operated by Miha Mirt s.p., Naselje pod hribom 31, 4282 Gozd Martuljek, Slovenia. Contact: info@work-out.app. We are the data controller for the personal data described below.

The short version

  • Your before/after photos stay on your device by default. They are only uploaded if you explicitly turn on cloud backup (a Pro feature) and agree to the consent dialog. You can switch back or delete them at any time.
  • We don’t sell your data, we show no ads, and we never use your photos for advertising, facial recognition, identification, or to train AI models.
  • You can delete your account and data from inside the app.

What we collect and why

1. Account data (only if you create an account)

Email address and a password (stored hashed, never in plain text).
Why: sign-in, restoring your data on a new device, password reset (a 6-digit code sent to your email).
Legal basis: performance of a contract (GDPR Art. 6(1)(b)).

2. Practice data

Your plan (goals, focus areas, optional age range, minutes per day), completed sessions, streaks and earned badges. Stored on your device; synced to our server only when you are signed in, so it can be restored on a new device.
Legal basis: performance of a contract.

3. Face photos (sensitive — handled specially)

  • Default: on-device only. Photos you take in the progress journal are saved in the app’s private storage on your phone and never leave it.
  • Optional cloud backup (Pro): if you explicitly enable it and confirm the consent dialog, photos are uploaded over an encrypted connection (TLS) to a private storage zone (Bunny.net) so your journal can be restored on a new device. Storage is server-side — not end-to-end encrypted — which means a password reset never makes your photos unrecoverable. Access keys stay on our server; photos are never publicly reachable.
  • Along with a cloud photo we store small alignment numbers (face position, size and tilt within the frame, produced on your device) used only to line up your before/after pairs visually. Face detection runs on your device (Google ML Kit); no photo is sent anywhere for analysis, and we do not use photos or these numbers to identify you or anyone else.
  • You can switch back to on-device storage or delete any photo (or all of them, via account deletion) at any time — deletion removes the server copy too.

Legal basis: your explicit consent (GDPR Art. 9(2)(a)), withdrawable at any time in Settings.

4. Purchases

Subscriptions are processed by Google Play / the App Store and managed through RevenueCat (our subscription processor). We receive subscription status (active / trial / expired) and a pseudonymous purchase identifier — never your card number.
Legal basis: performance of a contract.

5. Analytics and crash reports (Firebase — Google)

Anonymous usage events (e.g. “session completed”, which onboarding variant you saw), crash reports and performance metrics. Used to fix bugs and improve the flow of the app, including A/B testing of copy and screen order. We do not send your photos, your email or your notes to analytics.
Legal basis: legitimate interest (GDPR Art. 6(1)(f)) in keeping the app working and improving it.

6. Video streaming

Exercise videos are streamed from the Bunny.net CDN; like any web request, the CDN sees your IP address in order to deliver the video.

Our processors

Processor What for Where
Neoserv (hosting) our API server (api.work-out.app) and database Slovenia / EU
Bunny.net video streaming; optional photo cloud backup EU (global CDN for video)
RevenueCat subscription management US — EU Standard Contractual Clauses
Google Firebase analytics, crash reports, performance, remote config US/EU — EU Standard Contractual Clauses
Google Play / Apple billing per their own policies

We have data-processing agreements with these providers. Where data leaves the EU, transfers rely on Standard Contractual Clauses.

Retention

  • Account, practice data and cloud photos: until you delete them or delete your account. Account deletion (in the app, under Profile) removes your server-side data, including cloud photos.
  • On-device data: under your control; removed when you clear the app’s data or uninstall.
  • Crash and analytics data: per Firebase’s standard retention (up to 14 months).

Your rights (GDPR)

You can ask us for access, correction, deletion, restriction or portability of your data, or object to processing — write to info@work-out.app. You can withdraw photo consent at any time in Settings (switch storage to “On this device”). You may also complain to your supervisory authority — in Slovenia: Informacijski pooblaščenec, www.ip-rs.si.

Children

Bloomy is not directed at children under 16. We do not knowingly collect data from children under 16; if you believe a child has provided us data, contact us and we will delete it.

Changes

We’ll post any changes on this page and update the date above. For material changes we’ll notify you in the app.

Contact: info@work-out.app · Miha Mirt s.p., Naselje pod hribom 31, 4282 Gozd Martuljek, Slovenia