Biometric Data Policy

This policy explains how Skin Intelligence handles your face photos and anything derived from them. It adds to our Privacy Policy and applies wherever biometric-privacy law does — including the Texas Capture or Use of Biometric Identifier Act, the biometric provisions of the Colorado Privacy Act, and any other law that regulates biometric identifiers or biometric data.

Skin Intelligence is a cosmetic skincare app, not a medical device. It is not offered in Illinois, Washington or Quebec (see our Privacy Policy, Section 10).

We collect the face photos you choose to take with the in-app camera, for one purpose: to generate your cosmetic skin-appearance results and show how they change over time.

We do not use your photos to identify or recognize you, to verify your identity, or for advertising or profiling, and we do not create or store a face template or face embedding. To help you frame your face, your phone computes on-screen points as you position it; these are used only for framing, are never stored and never leave your device.

We collect and process your face photos only with your express consent. Before your first scan, we ask for two separate consents — one to capture and process your face photos for cosmetic analysis, and one to send them to our AI providers to generate your results — and we inform you before any photo is captured.

You can withdraw consent at any time in the app, under Privacy & Data. Withdrawing turns off scanning, so no new photos are captured or analyzed. It does not delete your existing scans or your account, which stay on your device (and in your cloud backup, if you turn it on) until you delete them.

They act on our behalf under contracts that prohibit any other use, apart from the automated child-safety checks below. They are barred from training on your photos and do not keep them once your results are made, except where an automated child-safety check flags an image or a law requires a longer period — our Privacy Policy (Section 4) explains both. They return only your results — your scores, skin type and skin tone, and brief written observations that are discarded once your scores are made — never your photo.

We do not sell, lease or trade your photos or any biometric data, we receive nothing of value for them, and no affiliate receives them.

We keep no face photo or biometric identifier on our servers beyond the scan itself. Each photo is processed in memory and discarded as soon as your results are generated; it is never stored, logged or retained, and we cannot retrieve it afterwards. Our providers do not keep it either, subject only to the two exceptions in Section 4.

The photos and scores you choose to keep are stored on your device — and in your own iCloud or Google Drive if you turn on backup — until you delete them or uninstall the app.

Because we store no biometric identifier, no ongoing retention period applies to us. For example, Colorado requires permanent destruction by the earliest of: when the purpose of collection is satisfied; 24 months after your last interaction with us; or 45 days after an at-least-annual review finds continued storage no longer necessary. We meet that limit because nothing is retained in the first place.

On our servers, each photo is deleted automatically when its scan completes; there is nothing you need to request.

On your device, you can delete any scan, or all of them, at any time in the app. Deleting your account deletes the scans on your device immediately, and we try to remove your cloud backup — please confirm it is gone in your own cloud storage settings.

We protect face photos in transit and during processing using at least the reasonable standard of care in our industry, and in a way at least as protective as how we protect other confidential and sensitive information — including encryption in transit, in-memory processing with no server storage, and access controls.

We keep a written protocol for responding to a security incident that may affect biometric data. If one occurs, we act without undue delay to contain and assess it, and notify affected people and the relevant authorities as data-breach law requires — including, for Colorado residents, C.R.S. § 6-1-716; for Canadian users, the Office of the Privacy Commissioner of Canada (and Alberta's Information and Privacy Commissioner for Alberta residents); and, for other US residents, your state's data-breach law. Because we hold no face photo or biometric identifier on our servers, the scope of any such incident is inherently limited.

Depending on where you live, you may have the right to confirm whether we collect, share or sell your biometric data and to access it; to get a list of third parties we have shared it with; to correct it; to withdraw consent; and to have it deleted. We share it only with the AI providers named above, only to perform the analysis you ask for.

You can access, withdraw and delete in the app, or email privacy@skinintelligence.ai. We respond within 45 days, or sooner where your law requires, and may extend once by 45 days where reasonably necessary, with notice. If we decline, you may appeal by emailing privacy@skinintelligence.ai with the subject "Privacy Appeal"; we decide within 45 days (or any shorter period your law sets), after which, where your law provides one, you may complain to your state Attorney General or privacy regulator.

The controller responsible for your biometric data is Skin Intelligence Inc., 329 Howe St #2031, Vancouver, BC V6C 3N2, Canada. Our Privacy Officer answers any question or request under this policy at privacy@skinintelligence.ai.

If we make material changes to this policy, we will tell you in the app and, where required, ask you to accept them before you continue scanning.