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Smart Beauty Privacy Policy – Final Unified Version (Canada-Compliant)

Introduction

The Smart Beauty app and related services are not intended for or directed to children under the age of 14. We do not knowingly collect personal information from children without verified parental or guardian consent. If we discover that a child under 14 has submitted personal information without appropriate consent, we will promptly delete it.

Data We Collect

Smart Beauty Rewards is a loyalty program that provides users with rewards, discounts, or offers in exchange for account activity or participation. Participation is voluntary and may involve the collection of name, contact details, preferences, or usage patterns. You may withdraw from the program anytime via app settings or by emailing privacy@bluesense.ai.

Privacy Policy – Canada (Final Version with Full Compliance)

Purpose of Data Use

Bluesense AI Inc. (“we”, “our”, “us”) is committed to protecting the personal information of our users in Canada. This Privacy Policy complies with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Information Protection Acts (PIPA) of British Columbia and Alberta, and Law 25 (formerly Bill 64) of Quebec. It outlines how we collect, use, disclose, and protect personal data across our services, including the Smart Beauty app, website, and affiliated platforms.

We may collect the following categories of personal information:

Identity data: Full name, date of birth, gender, email, phone, address
Biometric and health data: Skin imagery, AI-generated diagnostic assessments, user-provided skin concerns, medical history (with separate explicit consent)
Technical data: Device ID, IP address, browser or OS type, usage logs, cookies, analytics
Communication content: Messages, support tickets, in-app feedback
Behavioral data: Preferences, interaction patterns, app activity logs
Location data: General location inferred via IP address

We process personal data to:

Deliver and personalize skincare insights and app features
Improve app functionality, customer support, and user experience
Conduct anonymized analytics for research and development
Send marketing communications only with prior user opt-in consent
Comply with legal obligations and protect against fraud or abuse

Cookies and Tracking Technologies

Our data processing activities are based on:

Explicit informed consent for biometric and health data
Contractual necessity for account creation and service delivery
Legal obligations, including recordkeeping and regulatory compliance
Legitimate interests, such as fraud prevention and security improvement

All processing aligns with the ten fair information principles under PIPEDA and the purpose limitation and safeguard obligations under PIPA.

User Rights

We collect biometric and health-related data only with the user's explicit, informed, and separate consent.

Before any skin imagery is uploaded or analyzed, users are presented with a standalone consent screen that explains:

What data will be collected
The purpose of analysis
Retention periods
User rights, including the right to withdraw consent at any time

Consent is documented with timestamps and stored securely.

Data Retention Period

Some features in the Smart Beauty app involve automated assessments using AI models (e.g., skin type or acne detection).

Users have the right to:

Be informed about the use of such systems
Request additional human review or clarification
Refuse the use of automated analysis (though this may limit app functionality)

International Data Transfers

We share personal data only with:

Authorized service providers (e.g., cloud hosting, analytics, secure storage)
Legal or regulatory authorities, when required
Marketing or research partners only with prior user consent

We do not sell personal data or use it for profiling without explicit permission.

Security Measures

We use cookies, SDKs, and other technologies for session management, performance analytics, and personalization. Users can manage preferences via in-app settings or browser options. All tracking practices adhere to PIPEDA’s reasonableness principle.

Changes and Notifications

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected. Diagnostic imagery and related health data are stored for a minimum of 1 year and securely deleted or anonymized when no longer required. Users may request deletion of their personal data at any time.

Contact Information

Some personal data may be stored or processed outside of Canada (e.g., in the United States). In such cases, we ensure that third-party service providers are contractually obligated to provide an equivalent level of protection, in accordance with PIPEDA, PIPA, and Quebec's Law 25.

Children’s Privacy

We implement robust security measures including:

End-to-end encryption of sensitive data
Access restrictions based on role and need
Employee training on data protection
Regular security audits and vulnerability scans

These measures meet or exceed the standards of PIPEDA, PIPA, and Law 25 for reasonable security safeguards.

Loyalty Program and Incentives

In the event of a data breach posing a real risk of significant harm:

Affected users will be promptly notified via email or in-app alerts
A formal report will be submitted to the Office of the Privacy Commissioner of Canada (OPC)
Mitigation steps will be communicated and executed immediately

13. User Rights

Canadian users have the right to:

Access their personal data
Correct inaccuracies
Withdraw consent at any time
Request deletion, subject to legal limitations
File a complaint with the relevant privacy commissioner

14. Changes to This Policy

We may update this Privacy Policy to reflect changes in technology, regulation, or internal practices. Major updates will be announced via app notification or email. The most current version will always be available within the app and on our website.

15. Governing Law

This Privacy Policy is governed by and interpreted in accordance with the laws of the Province of British Columbia and the federal laws of Canada. Where applicable, Quebec Law 25 will also apply to residents of Quebec.

16. Contact Information

For any privacy-related concerns, requests, or complaints, please contact:

Privacy Officer, Bluesense AI Inc.

Email: privacy@bluesense.ai

Phone: +1 (672) 971-6040