Who we are
HonestFace is made by SwainUK Limited, registered in England and Wales (company number 16224562), Royalty House, 72–74 Dean Street, London W1D 3SG. Contact us at privacy@honestface.app.
Two roles
- Patient records (photos, notes, treatments, consents, documents): your clinic is the controller. When you use a clinic account, SwainUK Limited stores an encrypted copy on your clinic's behalf as a processor, under the Data Processing Agreement.
- Clinic account and billing details (email address, sign-in method, list of iPads): SwainUK Limited is the controller.
What stays on the iPad
HonestFace works without any account. Records, full-size photographs, consents and documents are stored on the iPad, protected by the iPad's own encryption and kept out of iCloud and computer backups. Automatic backups are encrypted and kept on the iPad. Face ID or Touch ID is checked by the iPad itself; HonestFace never receives your face or fingerprint data.
What we store if you use a clinic account
- Your email address, how you sign in (email and password, Sign in with Apple, or a passkey) and when you last signed in.
- Your clinic's iPads: a label such as "iPad", whether each one is approved, and when.
- Who belongs to the clinic and their role (owner, admin or member), and pending invitations.
- Encrypted clinic records and smaller encrypted copies of photographs (at most 1600 pixels, with location and camera details removed). They are encrypted on the iPad with keys only your clinic's iPads hold. We cannot read them.
- A wrapped copy of the clinic key that only your Clinic Recovery Key can open.
- Short-lived security records: one-time email codes (10 minutes), rate limits and server logs, used to keep accounts safe.
Full-size original photographs never leave the iPad that took them, except in backups you make.
Emails
We send sign-in codes, password and email confirmations, invitations and, if you turn it on, a weekly encrypted backup to the clinic owner. The backup attachment is encrypted with your Clinic Recovery Key before it leaves the iPad.
What we don't do
- No advertising, no tracking and no analytics in the app.
- We don't sell or share data for marketing.
- We don't use your clinic's records to train anything.
Lawful bases
- Clinic account: to provide the service you asked for (contract) and to keep it secure (legitimate interests).
- Billing: Apple handles payments; we receive only whether a subscription is active.
- Patient records: your clinic decides the lawful basis (for health data usually UK GDPR Article 9(2)(h), provision of health care). We act only on your clinic's instructions.
Where data is stored
Clinic account data and encrypted copies are stored with Google Cloud in London (europe-west2). Emails are sent through Zoho Mail's EU service. Apple processes payments and Sign in with Apple under its own privacy policy and may process data outside the UK under its own safeguards. See Sub-processors.
How long we keep it
- Account data: until you delete the account in the app (Settings › Privacy & security › Delete clinic account).
- When the owner deletes the account, the clinic's encrypted cloud copy, its iPads list and invitations are deleted straight away. Server logs expire within 30 days.
- Records on each iPad stay until the clinic erases them (Settings › Erase this iPad) or deletes the app.
- Your clinic sets how long it keeps patient records (Settings › Keep records for).
Your rights
You can ask to see, correct, delete or move your data, or object to or restrict how we use it. Email privacy@honestface.app; we reply within one month. Patients should contact their clinic first, because the clinic holds and controls their record. Clinics can export a patient's full record from the patient's page (Subject access export).
Complaints
If you're unhappy with how we handle your data, please tell us first. You can also complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint, or 0303 123 1113.
Children
Clinic accounts are for clinic staff aged 18 or over.
Changes
If we change this policy we will update the date above and, for important changes, tell clinic owners by email or in the app.