1. Introduction
Eyely ("the App") is committed to protecting your privacy and ensuring you have a positive experience on our App. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, available on the Apple App Store.
Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use the App. By downloading, accessing, or using Eyely, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Effective Date" of this Privacy Policy. Your continued use of the App following the posting of a revised Privacy Policy means that you accept and agree to the changes.

2. Information We Collect

2.1 Camera and TrueDepth Data
Eyely uses your device’s TrueDepth camera system to analyze eye movements, gaze tracking, and facial features for the purpose of providing eye exercise and vision analysis functionality.
This includes:
  • Real-time eye movement data
  • Gaze direction and line of sight information
  • Facial geometry and eye positioning data
  • Pupil tracking information
All TrueDepth camera data is processed locally on your device in real time.

2.2 Data Processing and Storage
Important: Eyely does not record, save, or store any TrueDepth camera data or eye tracking information on your device or our servers. All data is processed in real time for immediate feedback and analysis, then discarded after processing is complete.
We do not upload, transmit, or share this data to cloud servers, third-party services, or external databases.

2.3 Usage Information
We may collect limited non-identifying usage information, such as:
  • App performance metrics and crash reports
  • Feature usage patterns (for improving user experience)
  • Device model and operating system version

3. How We Use Your Information
The information collected through the TrueDepth camera is used exclusively to:
  • Provide real-time eye tracking and vision analysis within the App
  • Deliver personalized eye exercise feedback and recommendations
  • Monitor App performance and improve functionality
  • Comply with applicable laws and regulations

We do not use your information for:
  • Targeted advertising or marketing purposes
  • Building user profiles or behavioral tracking
  • Selling or sharing data with third parties
  • Training artificial intelligence or machine learning models

4. Camera Permissions and User Control
To function, Eyely requires access to your device’s camera. Your device’s operating system manages these permissions, and you retain full control over camera access.
You can:
  • Grant or deny camera access when first launching the App
  • Revoke camera permissions at any time through your device’s Settings application
  • Use the App’s in-app controls to pause or disable TrueDepth processing
If you revoke camera permissions, Eyely will not function, but this will not affect any other App or system functionality.

5. Data Sharing and Disclosure

5.1 Third-Party Sharing
Eyely does not share, sell, or disclose your personal information or camera data to third parties, advertisers, data brokers, or marketing partners under normal circumstances.

5.2 Legal Compliance
We may disclose information when required by law or when we believe in good faith that such disclosure is necessary to:
  • Comply with applicable laws, regulations, or legal processes
  • Respond to lawful requests from government or law enforcement authorities
  • Protect the security, rights, or safety of our users, the App, or the public
  • Prevent or investigate possible fraud, security violations, or violations of our Terms of Use

5.3 No Third-Party AI Processing
As of the Effective Date, we do not use third-party artificial intelligence services or external AI providers to process your camera data or personal information. Any future use of third-party AI services will require explicit, prior, informed consent from you.

6. Data Security
We implement industry-standard technical and organizational security measures designed to protect your information from unauthorized access, alteration, disclosure, or destruction. These measures include:
  • Local data processing on your device (no cloud transmission)
  • Encrypted transmission of any non-personal diagnostic data
  • Regular security updates and vulnerability assessments
  • Limited employee access to sensitive systems

However, no security system is completely impenetrable. While we strive to protect your information, we cannot guarantee absolute security of any data transmitted or stored.

7. User Rights and Data Control

7.1 Access and Deletion
Since Eyely does not store persistent user data or personal profiles, there is no stored personal information to access, modify, or delete. Your TrueDepth data is processed and discarded in real time.

7.2 Opt-Out Options
You can disable Eyely’s data collection by:
  • Revoking camera permissions through device Settings
  • Discontinuing use of the App
  • Deleting the App from your device

8. Children’s Privacy
Eyely is not intended for children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will take steps to delete such information promptly.
Parents or guardians who believe their child has provided information to Eyely should contact us immediately using the contact information provided below.

9. International Data Transfers
The App may operate from servers or infrastructure located in different countries. By using Eyely, you consent to the transfer of your information (to the extent any is collected and transmitted) across international borders in accordance with applicable privacy laws.
If you are located in the European Union, United Kingdom, or other jurisdictions with data protection laws, your information will be processed in compliance with applicable regulations, including the General Data Protection Regulation (GDPR).

10. California Resident Rights
If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) may provide you with the following rights:
  • Right to Know: Request what personal information is collected and used
  • Right to Delete: Request deletion of personal information
  • Right to Opt-Out: Opt out of the sale or sharing of personal information
  • Right to Correction: Request correction of inaccurate personal information
  • Right to Non-Discrimination: Freedom from discrimination for exercising your CCPA/CPRA rights

Since Eyely does not store personal data or engage in data sales, most CCPA/CPRA rights may not practically apply. However, you can still submit requests using the contact information below.

11. European Union Resident Rights
If you are located in the European Union, United Kingdom, or other GDPR-applicable jurisdictions, you have the following rights:
  • Right of Access: Access personal data held about you
  • Right to Rectification: Correct inaccurate personal data
  • Right to Erasure: Request deletion of your data ("Right to be Forgotten")
  • Right to Restrict Processing: Limit how your data is processed
  • Right to Object: Object to specific processing activities
  • Right to Data Portability: Receive your data in a portable format
  • Right to Lodge a Complaint: File a complaint with your supervisory authority

To exercise these rights, contact us using the information provided below.

12. TrueDepth API Data Collection and Processing

12.1 Information Collected via TrueDepth API
Eyely collects information about users’ eye movements through the TrueDepth API in order to accurately validate the performance of exercises inside the application. The data includes real-time eye movement patterns, gaze direction, and facial geometry needed to determine whether each exercise is being performed correctly in line with the intended instructions.

12.2 Purpose of This Data Collection
The information collected via the TrueDepth API is used solely to verify correct execution of exercises within Eyely and to improve the quality of the in-app training experience. Specifically, this data is used to:
  • Monitor eye movements while an exercise is being performed
  • Check that the user follows the required eye movement trajectory and timing for each exercise
  • Provide immediate feedback on whether the exercise has been completed correctly or needs to be repeated
  • Mark exercises as completed and support in-app progress tracking and statistics
  • Help ensure that users perform exercises safely and effectively according to the recommended patterns
All such analysis is done in real time on the device and is only used to support the exercise validation and feedback features of the App.

12.3 Data Sharing and Storage
The eye movement data collected through the TrueDepth API is not shared with any third parties, including advertisers, analytics providers, data brokers, or external service vendors.
This information is also not stored in any persistent way. The data is processed locally on your device in real time while an exercise is running and is discarded immediately after the validation and feedback processes are completed. No TrueDepth eye movement data is saved on the device, uploaded to servers, backed up to the cloud, or retained in logs.
This design ensures that your eye movement information remains private, ephemeral, and fully under your control.

13. Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. When we make material changes, we will:
  • Update the "Effective Date" at the top of this policy
  • Provide notice through the App or via other appropriate means
  • Obtain your consent if required by law

Your continued use of Eyely following notification of changes constitutes your acceptance of the updated Privacy Policy. You are encouraged to review this policy periodically for any updates.

14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy, our privacy practices, or wish to exercise your privacy rights, please contact us:
Email: algo.web.develop@gmail.com
We will respond to your inquiries within thirty (30) days or as required by applicable law.

15. Intellectual Property Rights
All intellectual property rights, including trademarks, logos, and branding associated with Eyely, are the exclusive property of the Company. You agree not to reproduce, modify, or distribute any Eyely intellectual property without our explicit written consent.

16. Governing Law
This Privacy Policy is governed by and construed in accordance with applicable international privacy laws and the laws of the jurisdiction from which Eyely is operated, to the extent permitted by law.

THANK YOU FOR TRUSTING EYELY WITH YOUR PRIVACY
We are committed to protecting your personal information and maintaining the highest standards of data protection in the eye health and wellness industry.