Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy applies to consumers in Nevada — anyone who is a Nevada resident or whose consumer health data is collected in Nevada — and supplements our Privacy Policy. It is provided under the Nevada Consumer Health Data Privacy Law (SB 370). Skin Intelligence is not available to Washington residents: we restrict access from Washington IP addresses and do not offer the service to Washington residents (see the Service Availability section of our Privacy Policy), so the Washington My Health My Data Act does not currently apply. Should that change, before offering the service in Washington we will update this policy to give effect to the Washington My Health My Data Act, at which point the references to Washington below would apply.

Skin Intelligence is a cosmetic skincare guidance app. It is not a medical device and does not diagnose, treat, cure, monitor, or prevent any skin disease or condition. Where these laws apply, your facial images and skin-appearance scores may be treated as "consumer health data," and this policy describes how we handle that data. Your facial images are also addressed by our separate Biometric Data Policy, which sets out our biometric retention schedule, deletion practices, and data-security-incident response.

Providing this notice does not make Skin Intelligence a health or medical service; it remains a cosmetic skincare app. We publish it because some state privacy laws may treat certain data we handle as "consumer health data," so you know how it is handled if they do.

We handle two categories of data that these laws may treat as consumer health data:

Facial Images — the photos you voluntarily capture through the in-app camera for cosmetic skin appearance analysis. Skin-Appearance Scores — the numerical results derived from your photos: scores across eight cosmetic categories (Hydration, Redness, Breakouts, Pigmentation, Pores, Wrinkles, Firmness, and Eye Area), an overall skin score, your skin type, and your skin tone.

We use this data solely to generate the cosmetic skin-appearance results you request and to show you how your scores change over time. We do not use it to identify or recognise you, we do not create or store a facial-recognition template or face embedding, and we do not use it for advertising, profiling, or to train AI models.

Routine preferences you choose in the app — including any pregnancy- or nursing-related cosmetic filter (such as Maternity & Nursing) — are handled entirely on your device. They are not collected, shared, or sold as consumer health data and are never transmitted to Skin Intelligence servers; when you generate a routine, the only signal these preference selections produce that leaves your device is the resulting list of excluded ingredient identifiers — it does not name any preference or reason, is held in memory for that request only, and is never stored; we do not attempt to infer why an ingredient was excluded. Other data used to build your routine is described in our Privacy Policy (Section 3).

We collect this data directly from you: facial images are captured by you through the in-app camera, and the skin-appearance scores are derived from those images by our AI processing providers at the moment you request a scan.

To generate your scores, we share your facial images with the following AI processing providers, solely to perform the analysis you request:

OpenAI, L.L.C. (United States) Google LLC, via Google Cloud Vertex AI (United States)

Your photos are transmitted to Skin Intelligence servers for transient processing only — held in server memory during analysis and immediately discarded — and are never stored, logged, or retained by Skin Intelligence. Under our agreements with these providers, your facial images are never used for model training and, under the zero-retention terms we have enabled, are not logged or retained for abuse monitoring — an image is kept only where a child-safety system flags it — in which case, as United States federal law (18 U.S.C. § 2258A) requires, the provider may retain and report it to the National Center for Missing and Exploited Children (NCMEC) — or where a longer period is required by law, as described in our Privacy Policy. To improve accuracy, your age range and gender are included in the request. These providers return only the analysis output — your numerical scores, your detected skin tone and skin type, and the brief written skin-appearance observations used to produce them, which are discarded once your scores are generated — to Skin Intelligence; your image is never returned with these results.

Category of third parties with whom we share consumer health data: AI processing providers (OpenAI and Google), as named above.

Affiliates: we have no affiliates that receive your consumer health data.

We do not sell your consumer health data, and we do not share it for any purpose other than performing the cosmetic analysis you request, except for the automated child-safety reporting described in our Privacy Policy.

No third party collects your consumer health data over time and across different websites or online services when you use Skin Intelligence. We do not use advertising networks, cross-site trackers, or third-party analytics that identify you.

Your facial images and skin-appearance scores are stored on your device only, unless you enable optional cloud backup to your own personal iCloud (iOS) or Google Drive (Android). They are not stored on Skin Intelligence servers. You can delete individual scans or all scan data at any time from within the app.

We collect and share your consumer health data only with your consent. At sign-up, before your first scan, consent to capture and process your facial images and consent to share them with our AI providers are presented as separate, unbundled checkboxes that you must each select before you can continue. You may withdraw your consent at any time in the app (Profile → Privacy & Data), which turns off scanning, so no new photos are taken or analyzed. Withdrawing does not delete your existing scans or deactivate your account — your scans stay on your device (and in your cloud backup, if you enable it) until you choose to delete them (Delete Scan or Delete Account).

If you are a Nevada resident, or your consumer health data is collected in Nevada — or a Washington resident, should the service become available in Washington — you have the right to:

Confirm whether we collect, share, or sell your consumer health data, and access that data. Obtain a list of the third parties with whom we have shared your consumer health data. Withdraw your consent to our collection and sharing of your consumer health data. Have your consumer health data deleted. Appeal a denial of any of these requests.

Review and correct: because your facial images and skin-appearance scores are stored on your device, you can review them in the app at any time, correct them (by re-scanning, or by editing your skin type and skin tone), or delete them yourself. For anything you cannot complete in the app, email privacy@skinintelligence.ai.

You can exercise these rights directly in the app, or by emailing privacy@skinintelligence.ai. We will respond within the time the law requires — currently 45 days for a request (extendable once by a further 45 days, with notice). As our own voluntary commitment, we aim to complete deletion requests within 30 days. If we deny your request, you may appeal by emailing privacy@skinintelligence.ai with the subject "Health Data Appeal." Within 45 days of receiving your appeal, we will tell you in writing what we decided and the reasons. If we deny your appeal, we will give you the contact information for the Office of the Attorney General so you can complain. Nevada residents: file a complaint with the Office of the Nevada Attorney General, Bureau of Consumer Protection — online at ag.nv.gov/Complaints/File_Complaint/, or by phone at (702) 486-3132. Should the service become available in Washington, Washington residents may contact the Washington State Attorney General.

If we make a material change to this policy or to how we handle your consumer health data, we will notify you in the app and, where required, ask you to re-accept before you continue using the scan feature.

Skin Intelligence Inc. 329 Howe St #2031, Vancouver, BC V6C 3N2, Canada Email: privacy@skinintelligence.ai