Legal
Privacy Policy
Effective date: [Effective date — to be set at launch]
This is template language provided for completeness and should be reviewed and adapted by qualified legal counsel before launch. Bracketed values are placeholders to be completed for your jurisdiction and entity.
Your face is personal. This Privacy Policy explains what [Company legal entity] (“Skinda,” “we,” “us”) collects when you use Skinda, why we collect it, how we store and delete it, and the choices and rights you have. It applies to our website and mobile apps.
In short: your photos
Your face photos are used only to analyze your skin. We never sell them, never use them to train third-party advertising models, and never use them for advertising. You can delete your photos and your account at any time.
Depending on your settings, a scan can be processed and then discarded, or saved to your account so you can track progress over time. You control which.
1. Information we collect
- Photos you upload (face scans)
- The selfie images you submit for analysis. These may be considered sensitive personal data / biometric-adjacent data in some jurisdictions, so we treat them with heightened care and process them only with your consent (see Section 3).
- Skin Profile and quiz answers
- The structured attributes derived from your scan (for example skin type, oiliness, texture, concerns) and the answers you give in the onboarding quiz (age range, goals, sensitivities, products you use).
- Account information
- Your email address and authentication identifiers (handled by our auth provider, Supabase), and your subscription tier.
- Payment information
- Processed by Stripe (web) or the Apple App Store / Google Play via RevenueCat (mobile). We do not store your full card number. We receive limited billing metadata such as plan, status, and the last four digits.
- Usage and device data
- Standard analytics (pages viewed, feature usage, approximate region, device and browser type) collected via Google Analytics to improve the Service. See our Cookie Notice.
2. How we use your information
- to run the AI skin analysis and generate your Skin Profile;
- to recommend products matched to your skin and budget;
- to save your scans and show progress over time, if you choose to keep them;
- to operate your account, process subscriptions, and provide support;
- to maintain security, prevent abuse, and comply with legal obligations;
- to understand aggregate usage and improve the Service (analytics).
We do not sell your personal information, and we do not use your face photos for advertising or to train advertising models.
3. How face photos are stored, used, and deleted
The face scan is the most sensitive thing you share with us, so it gets special handling:
- Consent. We process your photos only after you give explicit consent at the point of upload. You can withdraw consent at any time by deleting your scans or account.
- Processing.Your image is sent over an encrypted connection to our analysis provider (Anthropic’s Claude vision model) to estimate cosmetic attributes. It is used only to produce your Skin Profile for that request.
- Storage. If you do not save a scan, the image is processed transiently and not retained in your account. If you choose to save a scan (for progress tracking), the image and its derived profile are stored in your account in our infrastructure (Supabase), encrypted in transit and at rest, until you delete it.
- Deletion. You can delete an individual scan, or your entire account and all associated photos, at any time. On account deletion we remove your photos and Skin Profiles within 30 days, except where we must retain limited records to meet legal obligations.
- No advertising or model-training resale. Your photos are never sold and never used to train third-party advertising models.
To request deletion, use the controls in the app or email privacy@skinda.app.
4. Legal bases for processing (GDPR / UK GDPR)
If you are in the EEA or UK, we rely on these legal bases:
- Consent — for processing your face photos and other special-category data, and for non-essential cookies. You may withdraw consent at any time.
- Contract — to provide the Service and your subscription.
- Legitimate interests — to secure, maintain, and improve the Service, balanced against your rights.
- Legal obligation — to comply with law (for example, tax and accounting records).
6. International transfers
Your information may be processed in countries other than your own, including the United States. Where we transfer personal data out of the EEA or UK, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses.
7. Data retention
We keep personal data only as long as needed for the purposes above: account and profile data for as long as your account is active; saved scans until you delete them; and limited billing records for as long as required by law. Unsaved scans are not retained after processing.
8. Your rights (GDPR & CCPA/CPRA)
Depending on where you live, you may have the right to:
- access the personal data we hold about you;
- correct inaccurate data;
- delete your data (“right to be forgotten”);
- export your data (portability);
- object to or restrict certain processing;
- withdraw consent at any time;
- opt out of any “sale” or “sharing” of personal information — note Skinda does not sell your data;
- not receive discriminatory treatment for exercising your rights.
To exercise any right, email privacy@skinda.app. We will respond within the timeframe required by applicable law. You may also lodge a complaint with your local data-protection authority.
9. Security
We use encryption in transit and at rest, access controls, and reputable infrastructure providers to protect your data. No system is perfectly secure, but we work to safeguard your information and will notify you and the authorities of a qualifying breach as required by law.
10. Children
Skinda is not intended for children under 16, and we do not knowingly collect their personal data. If you believe a child has provided us information, contact us and we will delete it.
11. Changes to this policy
We may update this Privacy Policy from time to time. We will post the new effective date and, for material changes, provide additional notice. Continued use of the Service after changes means you accept the updated policy.
12. Contact us
For any privacy question or request, email privacy@skinda.app or support@skinda.app. Postal: [Company legal entity], [Registered business address — to be set at launch].