Who we are
CEVO (cevolab.com and app.cevolab.com) is run by Fideo LLC, a Wyoming limited liability company. It decides how your data is used, which makes it the controller under the GDPR and UK GDPR, and the business under US state privacy laws.
- Controller
- Fideo LLC, a Wyoming limited liability company, 1309 Coffeen Avenue STE 1200, Sheridan, WY 82801, USA
- Privacy contact
- Privacy Team · privacy@cevolab.com (general questions: info@cevolab.com)
- EU and UK
- CEVO is operated from the United States by Fideo LLC and has not appointed a representative in the EU or the UK. You can contact us directly at privacy@cevolab.com.
What we collect
Everything below comes from you, from Apple or Google when you choose to sign in with them (your verified email address, an Apple sign-in ID if you use Apple and, from Google, your name if present), or is worked out by CEVO from what you give us. We buy no data about you from anyone.
| Category | What it is | Required? |
|---|---|---|
| Questionnaire answers | Your main goal, age band, reference baseline (Male or Female reference norms), skin, hair and grooming routine, hair type, hair length, morning styling time, eyewear, facial hair and style preferences, how much change you want, and your ancestry and body-fat answers only if you tick their boxes. Each answer is saved on CEVO's server when you give it, also if you stop before the end | Yes, to tailor your results |
| Ancestry | One self-reported answer, used only to choose reference norms | No. "Prefer not to say" gives a general baseline |
| Body fat | Your own estimate on a slider from 8% to 30%, used only to estimate the soft tissue over your facial bones for your analysis. The result is shown as an estimate in millimetres | No. Leave it out and a general baseline is used |
| Photos | One front photo, taken in your browser for the free scan, with any retakes; a private copy of each is kept for up to 90 days to fix problems and improve quality, and the photo is used for your report if you buy one. If you choose Continue on your phone, the photo you take there is sent to your computer end-to-end encrypted through CEVO's server, which cannot see it, holds it in memory only and deletes it once delivered or after 30 minutes. Once it arrives, your computer keeps a private copy of it, like every photo in the scan. For a $59 or $119 report, a 90° side photo, taken and uploaded after you buy. You can take either photo on your phone with the code your computer shows after you buy. The $29 report uses the front photo only | Yes, for the analysis |
| Face geometry | 478 landmark points found on your photos, and the measurements (ratios and angles) calculated from them | Yes, for the analysis |
| Report and renders | Your written report, its measurements and the facial balance breakdown (in every tier); the simulations and hairstyle renders you ordered; in the $119 tier or with the $39 Surgical Simulation add-on, the Vector Shift Map; in the $119 tier, a surgeon PDF you can download | Created for you |
| Free-readout unlock | Your email (as typed, or as Google verified it), your name if Google gives it, whether you ticked the product-email box, your main goal and tier if you picked them, and your consent receipt. Never your photos, landmarks, measurements, ancestry, body fat, sex, age or IP address | Yes, to see the free readout |
| Account | Email address, and an ID from Apple if you sign in with Apple. With Google: the email Google has verified and, if present, your first and last name. Never your Google account ID or Google sign-in tokens | Yes |
| Payment | Name, billing address, card brand, last 4 digits and orders. Stripe holds the full card number; we never see it. Each order also notes how many of the 10 free front measurements the price page showed for your photo (as a band) | Yes, to buy |
| Device and log data | IP address, browser type, pages requested, error logs | Collected automatically |
| Anonymous visit counts | Which step of the site was reached (for example a questionnaire step, the scan or checkout) and, at the prices, how many of the 10 free front measurements the photo got (as a band) and which report tier was picked, the day, phone or computer and, only if Google Ads measurement or visit records are on for you and you send no Global Privacy Control signal, whether you came from a Google ad (yes or no). No ID, answers, page address, browser details or IP address. See visit measurement | No. On by default; switch it off in Cookie settings |
| Visit records | In the United States, and elsewhere after you accept the cookie banner: a random visitor ID and session ID (the cookies __Host-cevo_vid and __Host-cevo_sid) and, with them, each step with its time; the address of the first page of each visit, without anything after a "?"; where you came from: the site and page that linked to you, the campaign tags and ad click IDs in the link (such as utm_source, gclid or fbclid) and a partner code; phone, tablet or computer, and your browser and operating system family (never the full browser string); and your country. Once you unlock your free readout or sign in, your visits are linked to that unlock or account, including its email address, and your orders from then on (tier, amount, payment) are added to them. Your questionnaire answers are kept separately (see Questionnaire answers above) and, if visit records are on when you answer, linked to your visitor ID. Never your photo, face data, free text you type or your IP address. See visit measurement | No. In the United States on by default, switch it off in Cookie settings; elsewhere only if you accept the cookie banner |
| Consent records | Which boxes you ticked, the exact wording shown, its version, the time, and the account or free-readout unlock it belongs to | Kept as proof |
| Messages | Emails you send us | Only if you write |
| Partner code | The partner name in a link you followed (?via=), stored on your order and, where visit records are on, with your visit record | Only if you came from a partner |
| Google ad click ID | If you arrive from a Google ad, the click ID in the link (gclid, gbraid or wbraid), saved in this tab's session storage and sent to CEVO's server and Google Ads in the United States unless you switch Google Ads measurement off in Cookie settings or your browser sends a Global Privacy Control signal. Where visit records are on, they also keep it, even with Google Ads measurement off (see visit records). Elsewhere, or when we cannot tell your country, it is held only in the page and in the link from our homepage to the questionnaire until you choose in the cookie banner, and it is saved, and sent to Google Ads, only if you accept advertising cookies; until then our server receives it with the visit counts and discards it | Only if you came from a Google ad |
| Country | The country of your IP address, looked up on CEVO's own server (IP geolocation by DB-IP), used only to decide whether to show the cookie banner. The IP address is not stored for this | Collected automatically |
Sensitive data
Several of these are special or sensitive under the law: your face geometry (biometric data), your ancestry (racial or ethnic origin) and your body fat (health data). We collect each only with your explicit consent and use it only to provide the analysis you asked for. For how face geometry is handled, see the biometric notice. For Washington and Nevada residents, see the consumer health data policies for Washington and Nevada.
Why we use it
Each use has a legal basis. For people in the EU and UK, these are the bases under GDPR Article 6, and for sensitive data also Article 9.
| Purpose | Data used | Legal basis (EU/UK) |
|---|---|---|
| Measure your proportions and write your report | Photos, face geometry, questionnaire answers | Explicit consent (Art. 9(2)(a)) and contract (Art. 6(1)(b)) |
| Personalise your results and improve CEVO's questions, reports and products | Questionnaire answers (ancestry and body fat only for the use their own boxes name) | Contract (Art. 6(1)(b)) and legitimate interests (Art. 6(1)(f)): learning from the answers people give, to make CEVO's results better |
| Choose ancestry-specific reference norms | Ancestry answer | Explicit consent (Art. 9(2)(a)), optional |
| Estimate the soft tissue over your facial bones for your analysis | Body-fat answer | Explicit consent (Art. 9(2)(a)), optional |
| Generate the renders in your $59 or $119 report | Front photo, and side photo if a render needs it; a short description of each style | Explicit consent (Art. 9(2)(a)): the photos and face-geometry consent, which covers the report and renders you order |
| Show your free readout, run your account, sign-in and re-scans | Unlock record, account data | Contract (Art. 6(1)(b)) |
| Move your answers and photo between your computer and your phone, if you choose Continue on your phone | End-to-end encrypted copies of your answers, which optional consent boxes you ticked, report tier, progress, email once you unlock, and the photo you take on your phone | Contract (Art. 6(1)(b)), and your explicit consent for the photo and any ancestry or body-fat answer (Art. 9(2)(a)) |
| Take payment and send receipts | Payment and order data, email | Contract (Art. 6(1)(b)) |
| Keep invoices and tax records | Order data | Legal obligation (Art. 6(1)(c)) |
| Keep proof of your consents | Consent records | Legal obligation (Art. 6(1)(c), Art. 7(1)) |
| Keep the service secure and stop fraud | Device and log data | Legitimate interests (Art. 6(1)(f)): protecting you and CEVO |
| Count how many visitors reach each step of the site, to see where people stop and improve it | Anonymous visit counts | Legitimate interests (Art. 6(1)(f)): anonymous statistics about CEVO's own site. You can object at any time by switching the counter off in Cookie settings or sending a Global Privacy Control signal |
| See how visitors find and move through the site, which ads, links and partners bring them and which visits lead to a sign-up or an order, to improve the site and our marketing | Visit records | In the United States, legitimate interests (Art. 6(1)(f)): understanding how CEVO's own site is used; everywhere else, consent (Art. 6(1)(a)) through the cookie banner. You can object or withdraw at any time by switching visit measurement off in Cookie settings or sending a Global Privacy Control signal |
| Pay partners their commission | Partner code on your order and, where visit records are on, the partner codes in your visit records from the 60 days before you pay | Legitimate interests (Art. 6(1)(f)): paying partners correctly. Partners see totals only, never who you are |
| Send product news and offers | Email, and your name if Google provided it | Consent (Art. 6(1)(a)), optional, off by default. Sent only to an address Google has verified or that you have confirmed |
| Record your product-email choice and keep unsubscribed addresses from being emailed | Free-readout email address, your name if Google provided it, and whether you are subscribed, held in our email service | Legitimate interests (Art. 6(1)(f)): respecting your choice and unsubscribes. Deleted with the unlock record |
| Test and train CEVO's own measurement models | Photos and face geometry | Explicit consent (Art. 9(2)(a)), optional, off by default |
| Measure our Google ads | If you came from a Google ad: one conversion when you unlock your free readout, with the click ID, the time your sign-up was stored, a fixed value of 5.00 USD, a random transaction ID and a signal that ad measurement is allowed; if you pay for a report, one more with the click ID, the amount paid in USD, the payment time and a transaction ID; never your email, name, photos, face geometry, answers, goal, tier or report contents | Consent (Art. 6(1)(a)) through the cookie banner where it is shown; in the United States, on until you switch it off in Cookie settings or send a Global Privacy Control signal |
| Decide whether to show the cookie banner | Country of your IP address | Legitimate interests (Art. 6(1)(f)): showing each visitor the right cookie choice, without storing the IP address for it |
Your photos are used only to make your report and the renders you bought, and, if you opted in, to improve CEVO's measurements. We will not use them for anything else without asking you again.
If you do not give the photo and face-geometry consent, we cannot make a report. Every other optional item can be left out, and the report still works.
Your separate consents
We ask for each consent on its own, with its own unticked box, so you can say yes to one and no to another. We show the exact wording next to each box when you give it and keep a copy with your consent record; ask privacy@cevolab.com for a copy at any time.
- Photos and face geometry (required for the analysis): measuring your proportions from your photos and, for a $59 or $119 report, sending your photos to fal.ai to make your renders. A CEVO team member checks your report and renders before you see them.
- Report writing (required for the analysis): sending your measurements and the questionnaire answers you allow, never your photos, to Anthropic, the service that writes the report text.
- Ancestry (optional): using your answer to choose reference norms.
- Body fat (optional): using your estimate only to estimate the soft tissue over your facial bones for your analysis.
- Improving CEVO (optional, off by default): using the photos you upload for a paid report, and their measurements, to test and train CEVO's own measurement models. CEVO never sees free-scan photos, so they are never used.
- Emails (optional, off by default): product news and offers, sent only to an address Google has verified or that you have confirmed.
- Advertising cookies (optional; outside the United States, asked in the cookie banner; in the United States, on until you switch it off in Cookie settings): letting Google Ads measure our ads, as set out under cookies and ads. Accepting also turns on visit records (see visit measurement).
You can withdraw any consent at any time by emailing privacy@cevolab.com from the address you signed in with. It stops that use from then on and does not undo what was done before. Withdrawing the photo and face-geometry consent deletes your photos, landmarks, measurements, report and renders within 30 days, so download your report first if you want to keep it.
What we never do
- We never use your photos or face geometry to identify you, recognise you or match you against other people. We compare faces only to check that your renders still show you, using a similarity score computed in memory; that score is never stored and never used to identify you.
- We never infer your ancestry, race, sex or emotions from your face. Those answers come only from you.
- We never sell, rent or trade your personal data, and never take payment for it.
- We never share photos, face geometry, measurements, answers, ancestry, body fat or report links with advertising platforms. No ad pixel or ad tag runs on any CEVO page.
- We never use your photos or measurements to train AI models, ours or anyone else's, unless you tick the separate "Improving CEVO" box. Our providers are not allowed to train on them either.
- We never pass your data to clinics, surgeons or telehealth services. The surgeon PDF in the $119 tier is a file you download; only you decide whether to share it.
- We never review your photos or renders in chat apps. Review happens only inside CEVO's own tool.
- The scan itself (your photo, the landmark points and the measurements) sends nothing to any third party. The face-landmark library's built-in usage reporting is switched off and blocked by the page's security policy, so nothing from your scan reaches Google.
How the analysis works
The scanner finds 478 landmark points on your face, such as the corners of the eyes and the edge of the jaw. CEVO calculates distances, ratios and angles between those points, then places each one against published reference ranges for the baseline you chose, and shows, feature by feature, how they balance against those ranges (the facial balance breakdown, in every tier), never as one overall score. The report text is written from those numbers.
The free scan uses one front photo and shows three measurements, calculated in your browser: facial width-to-height ratio (FWHR), canthal tilt (an estimate, about ±1.5°), and the middle-to-lower face ratio. If you take the photo on your phone with Continue on your phone, your computer measures it again itself once it arrives; no measurement is sent between your devices. The gonial angle and the other side-profile measurements come from a 90° side photo, taken after you buy a $59 or $119 report. The $29 report uses the front photo only.
In the $59 and $119 reports, CEVO's software also estimates the age your face appears in the photo, shown as the Biological Facial Age Index (EU AI Act Art. 50(3)).
Every $59 and $119 report includes generated images made from your photo: a Layer 1 grooming simulation, with your bone structure kept as it is, and 3 ($59, or 10 with the $19 hairstyle pack) or 10 ($119) hairstyle renders. Layer 2, in the $119 tier or with the $39 add-on, is a structural illustration made by moving the pixels of your own photo, with nothing redrawn, and a Vector Shift Map that gives, in millimetres, how far each point moves in the simulation. Each image is labelled "Generated simulation, not a photo or a prediction" and carries IPTC metadata marking it as generated. A CEVO team member approves each set in CEVO's own tool before you see it, and the images follow your report in a second email.
Optical Lens Normalization (24mm to 85mm) estimates the camera distance from the size of your iris and the photo's lens data. It does not change your photo. If the photo was taken too close, we warn you or ask you to retake it.
Automated decisions
The report is produced by automated measurement. Working out your measurements, facial balance breakdown and, in the $59 and $119 reports, the Biological Facial Age Index evaluates aspects of your appearance, which can count as profiling under the GDPR. It does not make any decision about you with legal or similarly significant effects: nobody is refused a service, priced differently or assessed for anything because of it (GDPR Art. 22 and UK GDPR Arts 22A–22D). We do not use it for profiling for advertising.
CEVO is an appearance and grooming analysis. It is not a medical device and does not diagnose, treat or plan any medical or surgical procedure.
Human review of reports and renders
Every paid report is checked by a CEVO team member before it opens. Before you see a generated render, the team member checks it for errors, such as a distorted face or the wrong hairstyle, and approves or remakes it.
- Who
- A trained CEVO team member bound by a confidentiality agreement
- What they see
- Your report, your photos and the renders. Renders are checked with no name or email attached
- Where
- Only inside CEVO's own signed-in admin tool, on our servers. No downloads. Every view is logged. Chat tools get only a count of renders waiting, never images or details
- Why
- So your report is complete and correct, and you receive only renders that match the style described
Who receives your data
The table lists everyone who receives data through CEVO, including our own reviewer. The companies in it process data for us under contract, only on our instructions, and each receives only what it needs. Google Ads and the Google and Apple sign-ins are the exceptions: they act for themselves, as explained below the table.
| Company | What for | What it receives | Where |
|---|---|---|---|
| Hetzner Online GmbH | Hosting: the server that runs CEVO and encrypts photos and backups before they are stored, the database, the review tool and the relay for Continue on your phone | Everything CEVO stores, and the keys that encrypt what is kept in Cloudflare R2. For Continue on your phone, only end-to-end encrypted messages that neither CEVO nor Hetzner can read, held in memory | Helsinki, Finland |
| Cloudflare, Inc. | DNS, content delivery, blocking automated traffic, and storage in Cloudflare R2 of paid photos and their landmark records, renders and daily database backups | IP address and requests. In R2, only files encrypted on CEVO's server before upload; the keys stay on CEVO's server, so Cloudflare cannot read them | US and global; R2 storage in Western Europe |
| Stripe | Payments, saved card and membership billing | Name, email, card, billing address, amounts | US and Ireland |
| Resend | Sign-in, receipt and report-ready emails, the emails of your 90-day plan (a reminder to save your photos before they are deleted, and one at the start of each new phase and in its last week), and the list of free-readout email addresses | Email address and email content. For the list: your address, your name if Google provided it, and whether you are subscribed. You stay unsubscribed unless you ticked the product-email box and the address is verified by Google or confirmed by you | US |
| Google LLC (sign-in) | Continue with Google | Only the sign-in request. You sign in on Google's own page, and Google sends CEVO your verified email and, if present, your name. CEVO loads no Google script on its pages | US |
| Apple Inc. | Sign in with Apple | Sign-in identity and email or relay address | US |
| Features & Labels, Inc. (fal.ai) | Generates the Layer 1 simulation and hairstyle renders in your $59 or $119 report | Your front photo (and side photo if needed) and a short description of each style. Never your name, email, landmarks or answers. It uses the photos only to make the images, may not train on them, and deletes the photos and renders under its data processing terms | US |
| Anthropic, PBC | Writes the report text | Your measurements and the questionnaire answers you allow. Your ancestry answer is never sent: CEVO's servers use it to choose the reference norms, and Anthropic receives only the comparison results, not the answer or which norms were used. Anthropic never receives your photos, name or email. It deletes what it receives within 30 days, except content its safety systems flag, which it may keep for up to 2 years, and may not train on it | US |
| CEVO team reviewer | Checks reports and renders before delivery | Reports, photos and renders (renders without name or email), inside CEVO's tool | Data stays on our servers and, encrypted, in Cloudflare R2 |
| Google LLC (Google Ads) | Measuring our Google ads: in the United States unless you switch it off, elsewhere, or when we cannot tell your country, after you accept advertising cookies | Only if you came from a Google ad: one conversion when you unlock your free readout, with the click ID, the time your sign-up was stored, a fixed value of 5.00 USD, a random transaction ID and a signal that ad measurement is allowed; if you pay for a report, one more with the click ID, the amount paid in USD, the payment time and a transaction ID. Enhanced conversions are off, so no email address or phone number, hashed or not. Nothing about your face, answers, goal, tier or report | US |
Google acts as a separate company for its own ad purposes, not as our processor, so its use counts as "sharing" under California law. Google uses the conversions it receives as an independent controller under the Google Ads Controller-Controller Data Protection Terms. You can turn it off: see cookies and ads. Meta advertising tools (the Meta pixel and Conversions API) are not in use yet. Before we turn them on, we will update this policy. We use no third-party analytics service. CEVO's own visit measurement runs on our server in Helsinki, and its counts and visit records go to no other company (see visit measurement).
Apple and Google run their sign-in services under their own privacy policies. You sign in on their pages, so they learn that you signed in to CEVO, and they send CEVO only what the Account row above lists.
We may also disclose data when the law requires it, for example a valid court order, and to a buyer of the business, who would be bound by this policy. We tell you first where the law allows.
International transfers
Several providers are in the US. When your data leaves the EU or UK, it is protected as follows.
| Provider | EU safeguard | UK safeguard |
|---|---|---|
| Stripe, Cloudflare, Resend, Google (sign-in and Google Ads) | EU-U.S. Data Privacy Framework | UK Extension to the Framework |
| Apple | Standard Contractual Clauses, which Apple uses for transfers out of the EU | UK Addendum to those clauses |
| fal.ai | Standard Contractual Clauses (2021/914) | UK Addendum to those clauses |
| Anthropic | Standard Contractual Clauses (2021/914) | UK Addendum to those clauses |
| Hetzner | No transfer: servers in Helsinki, Finland | UK adequacy regulations for the EEA |
Cloudflare R2 keeps CEVO's encrypted copies of paid photos and their landmark records, renders and database backups in Western Europe, encrypted with keys that stay on CEVO's server in Helsinki. Cloudflare is a US company, so the Framework above also covers that storage.
Ask us at privacy@cevolab.com for a copy of the safeguards.
How long we keep it
We keep each kind of data only as long as it is needed, then delete it. One schedule applies everywhere, built to meet the strictest law that applies to you.
| Data | Kept for |
|---|---|
| Free-scan photo and landmarks | The landmarks stay on your devices and are discarded when you close the tab; the photo's private copy is kept as a photo check record (below). While you sign in to unlock the free readout, an encrypted copy of the photo, its landmarks and your answers is kept in this browser for up to 30 minutes, so your scan is still there when you come back from Google or your email; it is deleted when the readout opens, when you discard the photo, exit or start over, when you come back to the scan after leaving it, and otherwise the next time you open the CEVO questions or scan once 30 minutes have passed, and only that tab, and the Google sign-in tab it opened, hold the key. If you choose Continue on your phone, your answers are sent to your phone and the photo you take there is sent back to your computer through CEVO's server, end-to-end encrypted so CEVO cannot see them, held in memory only and deleted once delivered or after 30 minutes; once the photo arrives, your computer keeps a private copy of it as a photo check record (below) |
| Paid photos (front, and side for $59 and $119) | 30 days after CEVO releases your report to you, from CEVO's server and from Cloudflare R2, where they are stored encrypted; photos of a report not yet released are kept until then. For $59 and $119 reports, CEVO's own server also makes a cut-out of your front photo (you without the background) and close-ups of each feature carrying the report's measurement marks. They are made only on CEVO's server and never sent to any other service, are stored encrypted with your front photo, and are kept and deleted together with it, including when you keep your photos in your CEVO account or delete them sooner. fal.ai deletes its copies under its data processing terms. When you press Pay, an encrypted copy of your front photo and its landmarks is kept in this browser so it reaches your order even if you close or reload the scan tab; only the tab you paid from and the payment tab it opened hold the key, and the copy is deleted as soon as CEVO has the photo, when you discard the photo or start over, when you exit the scan with no payment open, when the payment is cancelled or expires, and otherwise the next time you open the CEVO questions, scan or order page once 2 hours have passed |
| Photos you choose to keep in your CEVO account (your scan photos, their landmark records, your renders and maps, and your report measurements) | Only if you turn on "Keep my photos in my CEVO account". Kept with no fixed end date, so you can compare a later scan with the first, until you turn it off (then the usual periods above apply, counted from when CEVO released your report to you, and anything already past them is deleted within the hour), delete them in My CEVO, or delete your account. A reversed payment or a lost payment dispute still deletes them at once |
| Landmark records (face geometry) | Deleted with the photos, 30 days after your report is released to you |
| Photo check records (every photo taken or uploaded in the free scan, a paid report or a re-scan, including ones our checks did not accept, with their quality readings such as lighting, sharpness, face size and head angle, the message you saw, and your device type, browser, screen size and the country of your connection) | 90 days after the photo was taken, from CEVO's server, where they are stored encrypted. Used only to fix problems and improve quality; CEVO staff may view them. Deleted earlier if you ask us to delete your data, and the records of a paid report (with the free-scan photos taken before it) are deleted together with that report's photos |
| Re-scan photos and their landmark records | 30 days after that re-scan's report is delivered |
| Measurements, report text, renders, and the answers saved with your order | 12 months after the latest of: your report being made, your last re-scan, the end of your membership. We email you 30 days before, so you can download your report |
| Jaw point statistics (anonymous measurement statistics about how the pre-placed jaw points were adjusted on side photos: no photo, name, email or order number) | 25 months from when the side photo was taken |
| The record of your questionnaire answers, saved as you answer, including ancestry and body fat if you ticked their boxes | 25 months from when you gave each answer, whether or not you finished or bought; deleted with your account, at once if you tell us you are under 18, and an ancestry or body-fat answer at once if its box is left unticked |
| Account or free-readout unlock with no purchase | 12 months after your last sign-in or unlock, with a reminder email 30 days before. Your address leaves the Resend list at the same time |
| Google ad click ID | In the United States, unless you switch Google Ads measurement off: in this tab's session storage, until you close the tab. Elsewhere, or when we cannot tell your country, before you choose: only in the page, never saved; after you accept: in this tab's session storage, until you close the tab. Once it reaches CEVO's server, the server keeps it with your free-readout unlock, and with your order if you pay, until the conversion upload to Google Ads has finished or failed, then deletes it from the unlock record and the order and keeps only a keyed hash (a one-way code). Where visit records are on, they keep the click ID from the link you arrived with for 25 months (see Visit records below). If you unlocked with an email address and do not later continue with Google from a browser that came from a Google ad with Google Ads measurement on, the conversion is dropped after 7 days |
| Consent records | 5 years after the consent ends |
| Orders and invoices | 7 years, as US tax law requires |
| Saved card (held by Stripe) | Removed 24 hours after your order |
| Email and server logs | 30 days; security incidents until closed |
| Anonymous visit counts | 400 days (about 13 months), then deleted |
| Visit records | Each step and arrival (with the campaign tags, ad click IDs and partner code of the link you arrived with) is deleted 25 months after it is recorded. Your visitor ID, with its device, country and email link, is deleted 25 months after your last visit or order (checked daily). The __Host-cevo_vid cookie lasts 400 days from your last visit, __Host-cevo_sid 30 minutes from your last step |
| Records of privacy requests | 24 months |
| Database backups | Made once a day, encrypted on CEVO's server and stored in Cloudflare R2 (Western Europe). Each backup is deleted 30 days after it is made, so data you delete or correct can remain in an encrypted backup for up to 30 days. Backups are used only to recover from a failure. Photos and landmark records are not in them |
You can have any render, your report or your whole account deleted sooner at any time: email privacy@cevolab.com. The face-geometry schedule and how it is destroyed are set out in the biometric notice.
Security
- Data is encrypted in transit and at rest.
- Paid photos and their landmark records, renders and database backups are encrypted on CEVO's server before they are stored in Cloudflare R2. The keys stay on CEVO's server, so Cloudflare cannot read them.
- Photos are served only through short-lived signed links, and only to you and the reviewer.
- Only named team members can reach personal data, through the signed-in admin tool, and access is logged.
- We protect face geometry at least as carefully as any other confidential data we hold.
- Continue on your phone is end-to-end encrypted (AES-256-GCM). Through it pass your answers, which optional consent boxes you ticked, chosen report tier, which screen each device is on and, once you unlock your readout, your email address, plus the photo and its camera lens details, and, once you buy, that your report is paid, its order number and, for a $59 or $119 report bought on your computer, a link for your side photo. The key is made on your computer and travels only in the QR code's link, in the part of the address that browsers never send to a server, so CEVO's relay holds only data it cannot read. It keeps that data in memory, never on disk, deletes it once delivered or after 30 minutes, and logs no content. Once the photo reaches your computer, your computer keeps a private copy of it with CEVO for up to 90 days, like every scan photo. Its logs record IP addresses only as keyed hashes, kept 30 days like our other server logs. The code works once and expires after 30 minutes, so show it only to your own phone.
- After you buy, your computer can show a code to take a photo for your order on your phone, with no sign-in there. The code holds a one-time link for that one photo of that one order. Your phone must open it within 15 minutes; once opened, it works for 30 minutes. The photo is uploaded to CEVO's servers like any photo for your report. While the link lives, CEVO keeps with it your cookie choice, your consent record and your age range from your computer, so your phone does not ask again; they are deleted when the link is used or your photo arrives another way, and at the latest 10 minutes after it expires. The link's one-way code is deleted a day after it expires.
If a breach puts your data at risk, we tell the supervisory authority within 72 hours where required and tell you without undue delay, and in any case within 30 days of discovering it.
Your rights
Everyone
Wherever you live, you can ask us to show you your data, give you a copy, correct it, delete it, or stop any optional use. We do not treat you differently or charge you more for using these rights.
EU and UK
Under the GDPR and UK GDPR you have the right to:
- access your data and get a copy (Art. 15);
- correct it (Art. 16);
- have it deleted (Art. 17);
- restrict how we use it (Art. 18);
- receive the data you gave us in a machine-readable file, or have it sent to another service (Art. 20);
- object to uses based on our legitimate interests (Art. 21); for visit measurement, switch it off (see visit measurement);
- withdraw any consent at any time, without affecting what was done before;
- complain to a supervisory authority (see complaints).
UK users can also complain to us first by emailing privacy@cevolab.com. We acknowledge it within 30 days and tell you the outcome without undue delay.
California
Under the CCPA you have the right to know what we collect and why, to delete it, to correct it, and to opt out of the sale or sharing of your personal information. We do not sell personal information. The conversions we send Google Ads count as "sharing". For visitors in the United States they are on until you opt out: switch off "Measure Google ads" in Cookie settings, in the footer of the homepage and the scan page and at the top of the questionnaire. We treat a Global Privacy Control signal from your browser as the same request.
We use sensitive personal information (face geometry, ancestry and body fat) only to provide the analysis you asked for and, if you opt in, to improve CEVO's own measurements (CCPA Regs §7027(m)), so no "limit" request is needed. You can use an authorised agent; we will ask them for proof of your permission.
In the 12 months before this policy's date, we collected personal information only in the categories listed under what we collect, only from you and, when you sign in with them, from Apple or Google, only for the purposes under why we use it, and disclosed it only to the recipients under who receives your data. We have not sold personal information. We share it for cross-context behavioral advertising only with Google Ads, and only if you came from a Google ad and did not opt out, as described under cookies and ads. Anonymous visit counts are deidentified: we keep them in that form and never try to re-identify anyone from them.
Other US states
Residents of Texas, Colorado, Virginia, Connecticut, Oregon, Delaware, New Jersey, Minnesota, Maryland and other states with privacy laws can access, correct, delete and get a copy of their data, and opt out of targeted advertising, sale and profiling. We ask for opt-in consent before collecting any sensitive data. In Maryland we collect sensitive data only where strictly necessary to make the report you asked for, so the optional ancestry, body-fat and improvement uses are not offered there; we tell where you are from your IP address or billing state. If we turn down a request, you can appeal by replying to our answer; we decide within 45 days and, if we still refuse, tell you how to contact your state attorney general.
Biometric rules in Illinois, Texas, Washington and Colorado are covered in the biometric notice. Consumer health data rights are in the policies for Washington and Nevada.
Making a request
- Email privacy@cevolab.com to get a copy of your data or to have single renders, a report or your whole account deleted, visit records linked to your email included. We do it within 30 days. My CEVO (cevolab.com/account) shows your orders and their status in the meantime.
- Write from the address on your account, so we can match the request to it.
We confirm it is you through your sign-in or a code sent to your email, and ask for nothing more than that. We answer within 30 days. If a request is complex we may take up to two more months (EU and UK) or 45 more days (US), and we will tell you why. When you ask us to delete your data, we delete it from live systems and from our providers, including fal.ai, within 30 days. Copies in our encrypted database backups are gone within 30 days, when those backups expire; until then they are used only to recover from a failure.
Adults only
CEVO is for adults aged 18 and over. We do not knowingly collect data from anyone younger. If we learn that someone under 18 has used CEVO, we stop, process no photo for them, and delete their data at once. If you think this has happened, email privacy@cevolab.com.
Cookies and ads
Sign-in and security cookies are always on, because the service needs them. Our own visit measurement runs until you switch it off; in the United States, and elsewhere after you accept the cookie banner, it sets two CEVO cookies, __Host-cevo_vid and __Host-cevo_sid (see visit measurement). CEVO runs no ad pixel or ad tag on its pages. Meta advertising tools (the Meta pixel and Conversions API) are not in use yet. Before we turn them on, we will update this policy. If you came from a Google ad, we keep its click ID in your browser for that visit, and our server tells Google Ads, once, that you unlocked your free readout, with that click ID, the time and a fixed value, and once when you pay for a report, with that click ID, the time and the amount paid. In the United States there is no cookie banner: this is on until you switch it off in Cookie settings. Everywhere else, and whenever we cannot tell your country, the cookie banner asks you first and this happens only if you accept. We tell your country from your IP address on our own server (IP geolocation by DB-IP) and do not store the IP address for this. If you switch it off, refuse, have not chosen in the banner, or send a Global Privacy Control signal, Google gets nothing about you, and switching off cancels a conversion not yet sent. In Washington and Nevada, sending this to Google counts as sharing consumer health data. Continue with Google opens Google's own sign-in window; CEVO loads no Google script on its pages. Partner codes are stored on your order, not in a cookie. Details and your choices are on the cookies page.
Visit measurement
To see how visitors find cevolab.com, how they move through it and where people stop, our own server measures visits. Each time a page reaches a step, your browser tells our server. The steps are: a page opened (for example the homepage, the questionnaire, the scan page or the page after payment); each questionnaire step reached (about you, goal, routine, hair type, hair length, style, body fat, consent); a scan started (camera, upload or phone), a photo taken (and whether it passed the photo checks) or accepted, the free readout shown; an unlock or sign-in, with Google or by email; the prices seen, a report tier picked (and which one), checkout opened. Choosing to take a new photo from the price page instead of buying is a step too. The prices seen, the tier picked and that choice also say how many of the 10 free front measurements the photo got, as a band (1 to 4, 5 to 9, all 10, or not certain).
Visit records
In the United States, and everywhere else only after you accept the cookie banner, our server keeps a record of your visits:
- It sets two first-party cookies:
__Host-cevo_vid, a random visitor ID kept for 400 days and renewed when you come back, and__Host-cevo_sid, a random session ID that ends after 30 minutes without activity. Scripts on the page cannot read them, and no other company receives them. - With them it records each step with its time; the address of the first page of each visit, without anything after a "?"; where you came from: the site and page that linked to you, the campaign tags and ad click IDs in the link (such as utm_source, gclid or fbclid) and a partner code; phone, tablet or computer, and your browser and operating system family (never the full browser string); and your country.
- When you unlock your free readout or sign in, your visits are linked to that unlock or account, including its email address, and your orders from then on (tier, amount, payment) are added to them, so we can see which visits led to a sign-up or an order.
- Each step and arrival is deleted 25 months after it is recorded. Your visitor ID, with its device, country and email link, is deleted 25 months after your last visit or order (checked daily).
Anonymous counts
- Every step is also added to an anonymous daily count, for every visitor who has not switched it off. A count holds only the step, the day (never the time), and whether the device is a phone or a computer. For those three price-page steps it also holds that band. Only if Google Ads measurement or visit records are on for you, and your browser sends no Global Privacy Control signal, does it also say whether you came from a Google ad: yes or no, never the click ID.
- Where visit records are not on (outside the United States or when we cannot tell your country, until you accept or if you refuse), only these counts are made: no cookie, nothing stored on your device and no ID.
- Counts are deleted after 400 days (about 13 months).
What neither ever holds
- Your answers themselves (they are kept in their own record, see Questionnaire answers, and linked to your visitor ID if visit records are on when you answer), your photo, face data or measurements, or free text you typed.
- Your IP address: our server uses it only in memory, to stop floods of fake counts and to tell your country. It is never written to a log or database, not even as a hash.
- Counts and visit records are never sent to another company. They are made only on cevolab.com and stay in CEVO's own database on our server in Helsinki, Finland, hosted by Hetzner. They are never sold, never shared for advertising and never used to make any decision about you.
In the United States, visit records rest on our legitimate interest in understanding how our own site is used and which ads, links and partners bring visitors (GDPR Art. 6(1)(f)); everywhere else, and when we cannot tell your country, on your consent in the cookie banner (Art. 6(1)(a)). The anonymous counts rest on our legitimate interest in anonymous statistics about our own site (Art. 6(1)(f)). You can object or withdraw at any time: open "Cookie settings" in the footer of the cevolab.com homepage or scan page, or at the top of the questionnaire ("Cookies" on phones), and switch off "Measure my visits". That stops both the visit records and the counts in that browser, and our server expires the two ID cookies. The choice is kept in the cevo_consent cookie for 182 days. A Global Privacy Control signal does the same automatically. If your visits are linked to your email, you can ask privacy@cevolab.com for a copy or to delete them. Because a count carries no ID, we cannot find or delete the counts made before you switched it off, and we will never try to link them to a person.
Complaints
Please tell us first at privacy@cevolab.com, so we can put it right. You can also complain to a regulator at any time:
- EU
- The data protection authority in the country where you live or work. CEVO has no establishment in the EU, so there is no lead authority
- UK
- The Information Commissioner's Office, ico.org.uk
- US
- Your state attorney general, or in California the California Privacy Protection Agency, cppa.ca.gov
Changes to this policy
If we change this policy in a way that matters, we email you 30 days before it applies. If we want to use your data for a new purpose, we ask for your consent first. Each version is dated. We keep every version published from 25 October 2026 onwards and send any of them on request.