Terms of Service — Trace

Effective date: 2026-05-04 Last updated: 2026-07-06

1. About these Terms

These Terms of Service (the "Terms") form a legally binding agreement between you ("you", "your") and SIA Celetum, a Latvian company (Reģ.Nr. 43603084537) registered at Riņķa iela 52, Ventspils, LV-3601, Latvia ("Celetum", "we", "us", "our").

These Terms govern your use of the Trace mobile application for iOS (the "App"), including any AI-powered features it offers.

The App is distributed on Apple's App Store under the developer account of LD TRADING (Apple Developer Team ID W5DX3JG884), which acts solely as the App Store distribution channel under a separate agreement with Celetum. LD TRADING is not a party to these Terms.

By downloading, installing, or using the App, you confirm that you have read, understood, and agreed to these Terms, together with our Privacy Policy. If you do not agree, do not use the App.

2. Eligibility

The App is not intended for users under 13.

You may use the App only if:

• you are at least 13 years old; and
• if you are between 13 and 16 and reside in the European Economic Area, you have obtained verifiable consent from a parent or legal guardian; and
• you have the legal capacity to enter into a binding contract under the laws of your country of residence.

We may, in our reasonable judgment, suspend or terminate access for any user we believe does not meet the eligibility criteria.

3. What Trace is — and what it isn't

Trace lets you take consistent face photographs over time and observe how your skin and appearance change. Its core features are:

• Guided photo capture with face-landmark alignment to a canonical frame.
• Photo comparison via a side-by-side slider.
• Challenges, events, and notes for tracking lifestyle interventions and personal context.
• AI chat assistant ("Trace assistant") that helps you navigate the app, log events and notes, and answer general questions about your timeline and progress.

3.1 IMPORTANT — Trace is not a medical product

Trace is a personal tracking and lifestyle tool, not a medical device. Trace does not:

• diagnose any medical condition;
• measure any clinically validated biomarker;
• replace or substitute for the advice, diagnosis, or treatment of a qualified healthcare professional;
• establish a doctor-patient or any other professional healthcare relationship.

The AI chat assistant may provide general information about skin, ingredients, lifestyle, or skincare practices. This is general educational information, not medical advice, not personalized recommendations, and not a substitute for consultation with a dermatologist or other qualified healthcare professional.

If you have a skin or health concern, consult a qualified healthcare professional. Do not delay seeking medical advice or disregard medical advice you have received because of anything you read, see, or compute in the App.

Do not use the App for emergencies. If you believe you have a medical emergency, contact your local emergency services immediately.

4. The license we grant you

Subject to your compliance with these Terms, Celetum grants you a limited, personal, non-exclusive, non-transferable, non-sublicensable, revocable license to download, install, and use the App on iOS devices that you own or control, solely for your own personal, non-commercial use.

Your use of the App on Apple devices is also subject to Apple's Licensed Application End User License Agreement, available at https://www.apple.com/legal/internet-services/itunes/dev/stdeula/. To the extent of any conflict, those Apple terms apply between you and Apple regarding your use of the App on Apple devices.

You may not:

• sell, rent, lease, sublicense, distribute, or otherwise transfer the App;
• copy or modify the App, except as permitted by applicable law;
• reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code, except to the limited extent that applicable law (including Latvian and EU law) expressly permits;
• remove or alter any copyright, trademark, or other proprietary notice in the App;
• use the App in any way that violates these Terms, applicable law, or the rights of third parties.

5. No accounts; your data lives on your device

Trace does not require you to create an account. There is no sign-up, no email, no password.

Your photos, notes, events, challenges, and chat messages are stored on your device and (if you have iCloud Backup enabled) included in your standard Apple device backup. We do not run our own servers that store this content. Detailed information about data flow is in our Privacy Policy.

You are responsible for the security of your iOS device and for the contents of your iCloud Backup (which is governed by Apple's terms).

6. AI features and third-party services

The App includes an optional AI chat assistant ("Trace assistant"). When you use it, your typed messages, certain on-device metadata, and any photos you explicitly attach are transmitted to:

1. our Cloudflare Worker (a relay we operate);
2. OpenRouter, an AI routing service;
3. Anthropic (Claude models) and/or OpenAI (GPT models).

By using the AI chat feature, you acknowledge and agree that:

• your message content (including any attached photos) leaves your device and is processed by the third-party services listed above;
• those third parties operate under their own privacy policies and data-use terms (linked in the Privacy Policy, §4), over which we have no control;
• the AI assistant produces responses using statistical language models and may produce inaccurate, incomplete, outdated, biased, or otherwise unreliable outputs. You are solely responsible for evaluating the accuracy and applicability of any AI output before acting on it.
• the AI assistant has no medical training, no professional credentials, and no continuity of awareness between unrelated conversations beyond a brief on-device summary;
• daily usage limits apply: a per-device cap on chat messages and a hard cap of 10 photo shares per device per day, both enforced by our proxy;
• we may, at our discretion and without notice, suspend, throttle, modify, or discontinue the AI features for operational, cost, safety, abuse-prevention, or compliance reasons.

If you do not agree with any of the above, do not use the AI chat feature. The remainder of the App works entirely on-device and does not require contact with any third-party service.

7. Acceptable use

You agree to use the App in good faith and in accordance with applicable law. You agree not to:

• attempt to attack, overload, probe, or otherwise interfere with the App, our Cloudflare Worker, or any third-party service in the AI chat path;
• attempt to bypass, disable, or circumvent our rate limits, photo-share quota, authentication tokens, or any other technical controls;
• use the App to upload, generate, request, or distribute content that is illegal, abusive, harassing, defamatory, infringing, or otherwise harmful;
• use the App to depict any person other than yourself in a way that violates their privacy, dignity, or rights — for example, by uploading photos of other identifiable individuals to the AI chat without their consent;
• use the App in any commercial product, professional clinical setting, or research context without our prior written agreement;
• use the App to attempt to extract, reproduce, fine-tune, or compete with any underlying AI model or service.

We may suspend or terminate your access to the App or to specific features (especially the AI chat) if we reasonably believe you have violated this section.

8. Your content

You retain all rights, title, and interest in:

• the photographs you take with the App;
• the notes, events, challenge selections, and chat messages you create.

We do not claim any ownership over your content. We do not use your content to train any AI model owned by us. The on-device storage and AI-relay processing of your content are governed by the Privacy Policy.

You are solely responsible for the content you create or upload, including for ensuring you have the right to do so. By using the AI chat feature, you grant us a limited, non-exclusive license to transmit your message content (and any photos you explicitly attach) to the third-party AI providers described in §6, solely for the purpose of generating an AI response back to you in the App.

9. Our intellectual property

Except for the user content described in §8, the App, including its source code, design, branding, name "Trace", logo, screenshots, marketing copy, on-device machine-learning models we have integrated (MediaPipe Face Landmarker), and all related materials, is owned by Celetum or its licensors and is protected by copyright, trademark, and other intellectual property laws.

These Terms grant you no rights in our intellectual property other than the limited license in §4.

Third-party components used in the App (including SwiftTasksVision, MediaPipe, and others) are subject to their respective licenses; details are listed in the App's open-source attribution screen (Settings → Legal → Open-source attribution).

10. Disclaimer of warranties

To the maximum extent permitted by applicable law:

• the App is provided "as is" and "as available", without warranties of any kind, whether express, implied, statutory, or otherwise;
• we do not warrant that the App will be uninterrupted, error-free, secure, accurate, fit for any particular purpose, or compatible with any specific device or iOS version;
• we do not warrant that the AI features will produce accurate, complete, or reliable output, nor that the third-party AI services will remain available.

Nothing in these Terms excludes or limits any rights you have under mandatory consumer protection law in your country of residence, including under Latvian Patērētāju tiesību aizsardzības likums, EU Directive 2019/770 on contracts for the supply of digital content and services, and EU Directive 2019/771 on the sale of goods. Where mandatory law gives you statutory rights, those rights remain unaffected.

11. Limitation of liability

To the maximum extent permitted by applicable law:

• in no event will Celetum, its directors, employees, agents, or affiliates be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages, including loss of data, loss of profits, loss of goodwill, or business interruption, arising out of or related to your use of the App;
• our total aggregate liability arising out of or related to these Terms or the App will not exceed fifty euros (€50.00) or the total amount you have paid us for the App in the twelve months preceding the claim, whichever is greater (currently zero, since the App is free);
• nothing in this section limits our liability for: (i) death or personal injury caused by our negligence; (ii) fraud or fraudulent misrepresentation; (iii) any liability that cannot be limited or excluded under applicable Latvian or EU law.

12. Indemnification

You agree to indemnify and hold harmless Celetum, its directors, employees, agents, and affiliates from and against any third-party claims, damages, losses, liabilities, and reasonable expenses (including legal fees) arising out of or related to:

• your use of the App in violation of these Terms or applicable law;
• content you upload to the AI chat that infringes the rights of any third party.

This obligation does not apply to the extent the claim is caused by our gross negligence, willful misconduct, or breach of these Terms.

13. Termination

You may stop using the App at any time by uninstalling it from your device. Uninstalling removes all on-device data; data already transmitted to third-party AI providers (where applicable) is governed by their respective policies and cannot be retroactively withdrawn.

We may suspend or terminate your access to the App or to specific features (especially the AI chat) at any time, with or without notice, if we reasonably believe you have violated these Terms, abused the AI proxy, or engaged in conduct that risks harm to us or to third parties. We may also discontinue the App or any feature at our discretion.

Sections that by their nature should survive termination (including §3.1 medical disclaimer, §8 your content rights, §9 our IP rights, §10 disclaimer of warranties, §11 limitation of liability, §12 indemnification, §15 governing law, and §16 general provisions) will survive termination of these Terms.

14. Changes to the App and these Terms

We may update the App at any time, including to add, change, or remove features. We will use reasonable efforts to give you notice of material changes through the App or the App Store listing.

We may also update these Terms from time to time. Material changes will be communicated through the App and reflected in the "Last updated" date at the top of this document. Continued use of the App after the effective date of a material update constitutes acceptance of the revised Terms. If you do not agree, you must stop using the App.

15. Governing law and disputes

These Terms are governed by the laws of the Republic of Latvia, without regard to its conflict-of-laws provisions, and (where applicable) by EU law. The application of the United Nations Convention on Contracts for the International Sale of Goods is excluded.

The competent courts of the Republic of Latvia have exclusive jurisdiction over any dispute arising out of or related to these Terms or the App, except where mandatory consumer-protection law in your country of residence gives you the right to bring an action in your local courts, in which case those mandatory rights prevail.

16. General provisions

Entire agreement. These Terms, together with the Privacy Policy and Apple's End User License Agreement (where applicable), constitute the entire agreement between you and us regarding the App and supersede any prior agreements.

No waiver. Our failure to enforce any provision is not a waiver of that provision.

Severability. If any provision of these Terms is held invalid or unenforceable, the remaining provisions remain in full force.

Assignment. You may not assign these Terms without our written consent. We may assign these Terms to a successor in connection with a merger, acquisition, or sale of substantially all of our assets.

Notices. Notices to us must be sent to the postal or email address in §17. Notices to you may be made through the App or to any contact information you have provided.

Apple-specific terms. You and we acknowledge that Apple has no obligation to provide maintenance or support for the App. To the maximum extent permitted by applicable law, Apple is a third-party beneficiary of these Terms and has the right (and is deemed to have accepted the right) to enforce these Terms against you. The remaining Apple-related terms required by Apple's Schedule 1 to the Paid Applications Agreement (where applicable) are deemed incorporated into these Terms.

17. Contact

For questions or notices about these Terms:

Email: in@digicomm.lv

Postal address: SIA Celetum Riņķa iela 52 Ventspils, LV-3601 Latvia

End of Terms.