Privacy Policy
Mira Analysis, operated by Cplex Management AG
Lättichstrasse 6, 6340 Baar, Zug, Switzerland
Last updated: June 2026
1. Who We Are
Mira Analysis is an aesthetic consultation service operated by Cplex Management AG, a company registered in Switzerland ("Mira", "we", "us"). We provide personalised facial analysis reports based on photos and questionnaire answers submitted by our customers. For any privacy-related questions, or to exercise your rights, contact us at hello@miraanalysis.com.
2. What Data We Collect
- Account data: your email address and password (stored encrypted) when you create an account.
- Onboarding data: your answers to our questionnaire, including goals, budget, lifestyle habits, and preferences.
- Photos: the photos you upload during onboarding (front-facing, side profile, close-up, full body, and style). Because these are facial and bodily images used to assess appearance, they may constitute sensitive personal data, including biometric data, under the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (nFADP). We treat them accordingly (see Section 3).
- Payment data: payments are processed by Stripe. We do not store your card details. We receive confirmation of payment and your Stripe customer ID only.
- Usage data: basic analytics on how you interact with the platform, such as pages visited and features used.
- Advertising data: if you reach us through an ad, our advertising tools (see Sections 4 and 8) may collect data about how you arrived and whether you subscribed.
3. How We Use Your Data and Our Legal Basis
We use your data only for the purposes below, each with its legal basis under GDPR and the nFADP:
- To produce and deliver your report, populate your dashboard, and track your progress over time. Your photos and questionnaire answers are processed for this purpose only. As these are sensitive data, we process them on the basis of your explicit consent, which you give when you subscribe and submit them. We do not use your photos for any other purpose, we do not use them for any commercial purpose, and we do not use them to train any AI model.
- To run your account and subscription, including transactional emails (submission confirmation, report ready, account notices). Legal basis: performance of our contract with you.
- To process payments and keep required financial records. Legal basis: performance of our contract and compliance with a legal obligation.
- To respond to your support requests. Legal basis: our legitimate interest in helping our customers.
- To maintain and improve the platform using aggregate usage data. This does not involve using your photos. Legal basis: our legitimate interest in improving our service.
- To measure and improve our advertising. Legal basis: your consent, given through our cookie banner (see Section 8).
We do not sell your data.
4. Third Parties We Work With
To deliver our service we share data with the following providers, only to the extent each needs it:
- Anthropic (Claude API): receives your questionnaire answers and photos to generate your analysis. Data sent via the API is not retained by Anthropic to train its models.
- Google (Gemini API): receives your photos and image-generation prompts to produce the renders in your report.
- Stripe: processes all payments. Your payment data is governed by Stripe's privacy policy.
- Lovable Cloud / Supabase: our platform and database infrastructure, where your data is stored.
- Meta (Facebook/Instagram): through the Meta advertising pixel, receives data about visits and subscriptions for advertising measurement, where you have consented (see Section 8).
All providers are bound by contract to protect your data and to use it only to provide services to us.
5. International Data Transfers
Some of our providers are located outside Switzerland and the European Economic Area, including in the United States. Where your data is transferred to such countries, we rely on appropriate safeguards as required by GDPR and the nFADP, such as Standard Contractual Clauses and, where applicable, recognised adequacy frameworks. You can contact us for more detail on the safeguards in place.
6. How Long We Keep Your Data
We retain your account, photos, report data, and historical scores for as long as your subscription is active, so that we can show your progress over time. If you cancel and request deletion, we will delete your account data, photos, and report data within 30 days of your request. You can also request deletion of your photos at any time. Payment records are retained for the period required by Swiss accounting law (currently 10 years).
7. Your Rights
Under GDPR and the nFADP you have the right to: access your data; correct inaccurate data; request deletion; receive your data in a portable format; object to processing; and withdraw consent at any time, including consent to our processing of your photos. Withdrawing consent does not affect processing carried out before withdrawal.
To exercise any of these rights, email hello@miraanalysis.com. We will respond within 30 days.
You also have the right to lodge a complaint with a data protection authority. In Switzerland this is the Federal Data Protection and Information Commissioner (FDPIC). If you are in the EU/EEA, you may complain to the supervisory authority in your country of residence.
8. Cookies and Tracking
We use two kinds of cookies and similar technologies:
- Essential cookies, required for the platform to function, such as authentication session cookies. These do not require consent.
- Advertising and analytics cookies, including the Meta advertising pixel, which we use to measure the performance of our ads. These are only set with your consent, which you give through the cookie banner shown when you first visit. You can change or withdraw your choice at any time through the banner settings.
9. Children
Mira Analysis is only for users aged 18 or over. We do not knowingly collect data from anyone under 18. If we learn that we hold data from a person under 18, we will delete it.
10. Changes to This Policy
We may update this policy from time to time, including when we add or change a service provider. We will notify you of material changes by email. Continued use of the service after changes take effect constitutes acceptance.
11. Contact
Cplex Management AG
Lättichstrasse 6, 6340 Baar, Zug, Switzerland
hello@miraanalysis.com