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App Review Rejections for Face Photo / AI Cosmetic Analysis App: Need Guidance on Privacy, Metadata, and Business Model Clarifications
Hi Apple Developer Community, I’m preparing an iOS app called Titech for App Review. The app is intended for clinic/business users and provides preliminary AI-generated cosmetic analysis and preview guidance based on user-submitted face photos. The app is not intended to provide medical advice, diagnosis, or treatment decisions, and users are told to consult qualified experts before acting on any recommendation. We have received multiple App Review rejections and I would appreciate guidance on whether our current approach is aligned with Apple’s expectations. Current issues raised by App Review: Guideline 2.1 - Information Needed Apple asked for more information about how the app uses face data, including: What face data is collected How it is used, stored, retained, deleted, and shared Whether it is shared with third parties Where this is explained in the privacy policy Exact privacy policy text about face data We updated the app and privacy policy to explain that: Users voluntarily upload front, left-side, and right-side face photos Photos may be sent to our backend and processed by OpenAI through the OpenAI API Face ID/fingerprint data is not collected Uploaded face photos and generated preview images are deleted after the active session ends The app does not sell face data or share it with advertisers/data brokers Guideline 2.1(b) - Information Needed Apple asked about the business model and whether users access paid content. Our app does not currently include paid digital content, subscriptions, credits, or in-app purchases. Access is controlled by a registration code for clinic/business users and App Review only. Guideline 2.3.3 - Accurate Metadata Apple said the screenshots did not show the current version of the app in use. We replaced the screenshots with updated iPhone and iPad screenshots showing: Clinic access Consent and face-data disclosure Photo capture AI-generated analysis Recommendations Side effects page Generated preview flow My questions: For apps using user-submitted face photos with a third-party AI API, is it enough to clearly disclose OpenAI processing in the consent screen and privacy policy, or should this also be repeated elsewhere in the app flow? For face photos that are deleted after the active session ends, what wording does Apple generally expect around retention and deletion? Since the app is clinic/business access only and does not sell digital content, is a registration code acceptable if we clearly explain that it is not a paid digital unlock? Are there any additional App Review notes or privacy policy sections that developers usually include for apps involving face photos and AI-generated preliminary recommendations? For metadata, should the screenshots avoid login/consent screens entirely, or is it acceptable to include them as long as most screenshots show core app functionality? Any advice from developers who have passed review with apps involving user-uploaded face photos, AI analysis, or cosmetic/health-adjacent recommendations would be very helpful. Thank you.
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App Review Rejections for Face Photo / AI Cosmetic Analysis App: Need Guidance on Privacy, Metadata, and Business Model Clarifications
Hi Apple Developer Community, I’m preparing an iOS app called Titech for App Review. The app is intended for clinic/business users and provides preliminary AI-generated cosmetic analysis and preview guidance based on user-submitted face photos. The app is not intended to provide medical advice, diagnosis, or treatment decisions, and users are told to consult qualified experts before acting on any recommendation. We have received multiple App Review rejections and I would appreciate guidance on whether our current approach is aligned with Apple’s expectations. Current issues raised by App Review: Guideline 2.1 - Information Needed Apple asked for more information about how the app uses face data, including: What face data is collected How it is used, stored, retained, deleted, and shared Whether it is shared with third parties Where this is explained in the privacy policy Exact privacy policy text about face data We updated the app and privacy policy to explain that: Users voluntarily upload front, left-side, and right-side face photos Photos may be sent to our backend and processed by OpenAI through the OpenAI API Face ID/fingerprint data is not collected Uploaded face photos and generated preview images are deleted after the active session ends The app does not sell face data or share it with advertisers/data brokers Guideline 2.1(b) - Information Needed Apple asked about the business model and whether users access paid content. Our app does not currently include paid digital content, subscriptions, credits, or in-app purchases. Access is controlled by a registration code for clinic/business users and App Review only. Guideline 2.3.3 - Accurate Metadata Apple said the screenshots did not show the current version of the app in use. We replaced the screenshots with updated iPhone and iPad screenshots showing: Clinic access Consent and face-data disclosure Photo capture AI-generated analysis Recommendations Side effects page Generated preview flow My questions: For apps using user-submitted face photos with a third-party AI API, is it enough to clearly disclose OpenAI processing in the consent screen and privacy policy, or should this also be repeated elsewhere in the app flow? For face photos that are deleted after the active session ends, what wording does Apple generally expect around retention and deletion? Since the app is clinic/business access only and does not sell digital content, is a registration code acceptable if we clearly explain that it is not a paid digital unlock? Are there any additional App Review notes or privacy policy sections that developers usually include for apps involving face photos and AI-generated preliminary recommendations? For metadata, should the screenshots avoid login/consent screens entirely, or is it acceptable to include them as long as most screenshots show core app functionality? Any advice from developers who have passed review with apps involving user-uploaded face photos, AI analysis, or cosmetic/health-adjacent recommendations would be very helpful. Thank you.
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