1. Who is responsible?
Roselle is operated by Efe Boran Berber, based in Kadıköy, İstanbul, Türkiye. For privacy requests, email info@rosellemakeup.com.
Phone: +90 553 303 88 87.
2. Information we process and store
Information comes from your app choices and submitted content, Apple sign-in and purchase verification, technical service-request records and support messages. App and provider processing is electronic; authorized people may read and respond to support correspondence.
Preferences and library
Onboarding status, skin and makeup preferences, favorites, completed tutorials and the free allowance ledger are stored on your device. You can manage notification permission in iOS Settings. A reminder stores the selected look title and step so it can open that tutorial.
After you sign in with Apple, identifiers of catalog tutorials completed on this device are sent to Supabase, including completions waiting to be sent from before sign-in. The server stores your Roselle user identifier, the tutorial identifier and the time the record is added to the server. We use these records to count each account once per tutorial and rank the most completed looks. The catalog shares only aggregate completion counts; your individual completion records are not exposed to other users. This does not synchronize your local history across devices.
Support correspondence
Messages sent to info@rosellemakeup.com are read through Gmail within Google Workspace. We process your email address, message and attachments to respond to your support request. The publisher reads this correspondence to provide support. If a business partner is given access to provide support, that partner also processes the correspondence only for that purpose. Support correspondence is kept for 6 months after the request is closed and then deleted. The email provider’s trash and backup processes are separate, so we do not claim that every copy is removed at the same moment. Do not include your Apple password, verification codes or payment card details in your message.
For Google Workspace support email, deletion from the provider’s systems follows a separate process. The accepted Cloud Data Processing Addendum allows up to 180 days for that process after deletion that cannot be recovered by the customer, subject to legal retention exceptions. This does not extend our six-month deadline for deleting closed support requests from our mailbox.
Offline looks
The full catalog is not persistently downloaded. A look that you explicitly download contains its tutorial, product relationships, palette and two verified images. Adding a favorite does not download a look.
Apple sign-in
We process your Roselle user identifier, Apple account identifier, and the email or private relay address Apple shares with us. Session credentials are stored in iOS Keychain. For new authorizations, an Apple refresh token is stored encrypted on the server so we can revoke sign-in permission during account deletion. Its encryption key is stored separately from the database. The app cannot read this server-side token.
App verification and security
On supported versions, Apple App Attest checks that requests come from a verified Roselle app. We process an app key identifier, public key, Apple attestation receipt, app version and security counters linked to your account. One-time verification records include account and session identifiers, a request identifier, a one-way digest of the request and timestamps. These records help prevent acceptance of a request under another session or through replay; the security tables do not store the reference photos or note themselves.
Technical access records
Standard provider access logs contain the IP address, country/city-level approximate location derived from IP, browser or device information, request status and response duration. These records support security and service operation and can be associated with an account on authenticated requests. The app does not request GPS or precise-location permission.
AI Studio
- One to four selected reference photos and an optional note of up to 500 characters.
- Your account and installation identifiers, monthly allowance, request status and technical security records.
- Apple transaction identifiers or signed transaction information to verify Premium.
- The generated guide, your note and an optional cover image.
Reference photos are not saved in the local AI archive. The guide and note are stored locally; an optional cover is a separate image on your device. The Turkish and English generated response is also cached on the server for safe retries. Translation processes the completed guide text without resending reference photos. This cache does not synchronize your local archive across devices.
3. Why we use this information
- Deliver catalog tutorials and your selected experience.
- Verify Premium, the monthly allowance of 10 AI looks, and ownership of purchase information.
- Generate requested guides, handle retries without duplicate generation and limit abuse.
- Manage local favorites, history, reminders, offline packages and generated looks.
- Count account-linked catalog completions once per tutorial and use aggregate counts to rank the most completed looks.
Roselle does not sell data for advertising or track you across apps. Optional website analytics operates separately from the native app.
Legal bases for processing
The basis depends on the purpose. Reading this policy or accepting the terms does not give consent to optional AI photo processing or analytics.
| Processing | Türkiye’s KVKK | Where GDPR applies |
|---|---|---|
| Requested service, account, Premium and quota management; service-related support | Necessary for a contract — Art. 5/2(c) | Contract performance — Art. 6(1)(b) |
| Optional AI photo and note processing; optional website analytics | Separate explicit consent — Art. 5/1 | Consent — Art. 6(1)(a) |
| Service security, abuse prevention and counting each account’s tutorial completion once | Legitimate interests that do not harm fundamental rights and freedoms — Art. 5/2(f) | Legitimate interests balanced against your rights — Art. 6(1)(f) |
| Data-rights requests we are legally required to handle | Legal obligation — Art. 5/2(ç) | Applicable legal obligation — Art. 6(1)(c) |
Our interests are running a secure service and preventing duplicate counts so aggregate tutorial rankings remain accurate. These purposes do not include advertising profiles. Your rights and objection channel are explained below. A processing basis and the conditions for international transfers are assessed separately.
4. AI photo processing
- Your selected photos are resized and prepared as JPEGs on your device.
- You read the disclosure and enable the consent switch before starting generation.
- Photos and notes travel over an encrypted connection to Roselle’s Supabase service and then to the OpenAI API.
- The service creates a makeup tutorial from visible makeup details. General web search may help research techniques; the system is not designed to identify a person or infer sensitive traits.
Requests use the OpenAI API with response storage disabled. API data is not used for model training by default. Abuse-monitoring records may be retained for up to 30 days, or longer for legal or safety reasons. See OpenAI’s data controls.
Disabling response storage does not disable every form of technical retention. Supported models may retain encrypted representations of inputs in a cache for up to 24 hours. Images undergo safety screening, and flagged content may be retained for review. We do not promise Zero Data Retention or processing exclusively in one country.
Before a new generation, turn off the AI processing consent switch in Studio to stop photo submission. An already submitted request cannot be unsent. To withdraw consent for previously submitted content or request its deletion, email info@rosellemakeup.com. This does not automatically remove records a provider is legally required to retain; we explain the scope in our response.
5. Optional website analytics
Google Analytics loads only after you choose “İzin ver” (Allow) on the website. Before consent or if you decline, the site sends no Google Analytics measurement requests. You can read all pages without agreeing.
With consent, visited pages, tutorial and Studio link clicks, App Store link clicks, approximate city-level location and browser/device details may be measured. These details can include device model, operating system, browser version and screen resolution. Photos, notes and form contents are not included in analytics events. URL query parameters are excluded; advertising personalization and Google Signals are disabled in code.
Analytics may use cookies beginning with _ga; the configured cookie lifetime is 180 days. Your choice is stored in this browser. Use “Çerez tercihleri” (Cookie preferences) in the footer to withdraw consent. Withdrawal clears analytics cookies and stops future measurement; it does not delete data already received by Google.
Our Google Analytics property is set to retain event data for 2 months and user data for 14 months. New activity can restart the 14-month period for that user’s data. Expired data covered by these settings is deleted during monthly cleanup; standard aggregated reports are unaffected. These periods are separate from browser cookie lifetime. See Google Analytics data retention.
Search Console reports search visibility without adding a visitor-tracking cookie to the site. See Google’s Privacy Policy.
6. Service providers and sharing
- Apple: sign-in, subscription billing, restoration, purchase verification and app verification. Payment details are managed by Apple.
- Supabase: catalog and media delivery, authentication, account-linked tutorial completion records and aggregate counts, AI request handling, generated response cache, quota and security records.
- OpenAI: reference photos, notes and guide text for requested generation and translation.
- Cloudflare: website hosting and standard web access/security records.
- Squarespace: domain management and redirection from the address without www to the www address. Redirect requests include the IP address, requested web address and standard technical access information.
- Google: support email through Gmail within Google Workspace, website analytics only with consent, and Search Console reports.
Providers process information to deliver the service, verify purchases, protect security, meet legal obligations or carry out your request. Photos and free-form notes may identify you, so AI inputs are treated as linked to you. Provider policies: Supabase, OpenAI and Cloudflare, Squarespace.
7. Retention
- Local preferences, favorites, history and downloads remain until deleted or removed with app data. Keychain entries may survive uninstalling the app.
- The local AI archive is limited to 50 records and 64 MB and can be deleted separately.
- Account-linked tutorial completion records on the server have no automatic time-based expiry. They are removed when your account or the associated catalog tutorial is deleted, and the aggregate count is updated. Clearing only your local history does not delete server-side completion records.
- AI responses, retry records and security counters older than 30 days since their last update are removed when subsequent AI requests trigger cleanup. Without new requests, they may remain longer. There is no guaranteed daily cleanup.
- The app verification key and Apple attestation receipt remain linked to your account on the server without automatic time-based deletion. One-time verifications are valid for at most 2 minutes. When a new verification is issued for the same account, verification and rate-limit records older than 10 minutes are removed; without a new request, physical retention may be longer. Account deletion removes that account’s security records; session deletion removes its associated one-time verifications.
- The local app verification key identifier and registration state are stored in iOS Keychain for this device only. Ordinary sign-out retains this record; completing account deletion in the app removes the corresponding account’s local record.
- Account quota and purchase-ownership records remain until account deletion. The encrypted Apple credential is also removed when the account is deleted.
- A one-way digest used to confirm a completed account deletion is valid for 24 hours. It contains no raw session token or deleted account identifier. Expired digests are removed on a later account deletion or receipt request, so physical retention may be longer.
- Shared IP-based and global security counters are not owned by one account and follow operational cleanup. Providers’ technical-log and backup retention processes depend on the services we use and the provider’s terms. We do not promise one deletion period for every provider copy; account deletion does not imply immediate removal from every backup.
- Data-location and transfer details: Roselle’s Supabase database is located in the eu-west-1 region in Ireland. This does not mean that all processing takes place in that region. Providers for authentication, media delivery, AI, website hosting and optional web analytics may also process data in other countries. We do not promise processing exclusively in Türkiye or the European Union.
8. Deletion and data requests
Profile → My Looks lets you delete the local AI archive and covers without deleting your account. Profile → Delete Account removes your Roselle account, linked usage, tutorial completion and retry records, and personal preferences, favorites, history, AI archive, offline packages and reminders on this device.
You may need to authorize with Apple again to revoke sign-in permission. If the earlier Apple authorization is no longer available, you can still delete Roselle data and separately revoke permission in Settings → Apple Account → Sign in with Apple → Roselle. Deleting Roselle does not cancel an App Store subscription; manage that separately in Apple settings.
For access, correction or other deletion requests, email info@rosellemakeup.com. Requester verification: You can request account deletion while signed in to the app. For other requests, use the email or Apple private relay address registered to your account and describe your request. Before disclosing personal data or acting on an account, we verify your connection to it and, when necessary, request only appropriate additional verification information. We never ask for your Apple password, verification code or payment card details. Other legally valid request channels remain available.
Your rights and response times
Under Türkiye’s KVKK, you may learn whether, why and with whom your data is processed; request correction, deletion or destruction where conditions apply, and notification of these actions to recipients; object to adverse outcomes from solely automated analysis; and seek compensation for unlawful processing.
We handle KVKK requests promptly and within 30 days. A rejected, inadequate or unanswered request can be brought to the Personal Data Protection Board within the statutory deadlines. See the official request and complaint deadlines.
Where GDPR applies, rights may include access, correction, erasure, restriction, portability and objection, subject to their conditions. You may complain to the competent supervisory authority. Requests normally receive a response within one month; if a legally permitted extension is needed, we explain why within that first month. You may withdraw consent for consent-based processing without affecting lawful processing before withdrawal.
9. Security
We use HTTPS, iOS Keychain for local credentials, local file protection and server authorization checks. No storage or transmission method is completely risk-free.
10. Children
Roselle is intended for users aged 13 and above. Contact us if you believe information about a child has been processed. Applicable local age and parental-consent rules still apply.
11. International users
Roselle is intended for worldwide distribution, including the European Union. Providers may process data in other countries. Data locations and the providers we use are described above. Providers’ data processing agreements do not automatically replace the additional legal mechanism required for transfers from Türkiye. Completion of that additional mechanism has not yet been verified. For information about the countries receiving your data and the protections applicable to transfers, contact info@rosellemakeup.com.
12. Updates and contact
We may update this policy as the product or legal requirements change and communicate material changes through an appropriate app or website notice. Visit Support or contact info@rosellemakeup.com.