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Privacy Policy

Applicable Regions: Singapore (PDPA), India (DPDP Act), South Korea (PIPA)

Platform: Smart Beauty | Data Controller: Bluesense AI Inc.

1. Introduction

Bluesense AI Inc. (“Bluesense”, “we”) respects the privacy of our users in the APAC region. This Privacy Policy is prepared in accordance with the Singapore Personal Data Protection Act (PDPA), India’s Digital Personal Data Protection Act (DPDP Act, 2023), and South Korea’s Personal Information Protection Act (PIPA). By using our services, you agree to this policy and the related consent forms.

2. Data Collected

Through the app, the following personal data may be collected:

• •Identification and contact information: name, age, email, phone number
• •Skin-related data and lifestyle information
• •Device and usage data: IP address, session duration
• •Facial images and analysis outputs (biometric data)
• •Sensitive data: sleep, stress, health conditions, habits

Note: In India, parental consent is required for users under 18. In South Korea, written consent is required for processing sensitive data. In Singapore, no data may be processed without informed, express consent.

3. Purpose of Data Processing

Your data is processed for the following purposes only:

• •Providing personalized skin analysis and recommendations
• •Enhancing user experience and minimizing system errors
• •Training algorithms and improving models (with anonymized data)
• •Fulfilling legal obligations

4. Legal Basis and Consent

Your data is processed only on the following legal bases:

• •Your explicit, informed, and voluntary consent
• •Contractual necessity or legitimate interests
• •Compliance with local laws and regulations

Under South Korean PIPA, biometric data can only be processed with written consent. Singapore and India require parallel consent mechanisms to be active during data collection.

5. User Rights

As a user, you have the right to:

• •Request access, correction, deletion, or portability of your data
• •Withdraw your consent at any time
• •Object to data processing
• •Lodge a complaint with local data protection authorities

Singapore: Personal Data Protection Commission

India: Data Protection Board

South Korea: Personal Information Protection Commission

6. Data Retention

Data is retained only for as long as needed:

• •Skin analysis data is deleted or anonymized within 30 days unless requested otherwise
• •If you withdraw consent or delete your account, all biometric and sensitive data will be permanently erased

7. International Data Transfers

Data may be transferred outside of Singapore, India, or South Korea.

• •All transfers follow Data Protection Agreements (DPAs) and Standard Contractual Clauses (SCCs) to ensure compliance

India’s law is not yet fully in force but includes a proposed requirement to notify the Data Protection Board of international transfers.

8. Security Measures

Your data is protected using:

• •AES-256 encryption (in transit and at rest)
• •Restricted access – only authorized personnel may access
• •Regular penetration testing and incident response procedures
• •Mandatory DPAs with all third-party processors

9. Age Restrictions

• •Smart Beauty services are for users aged 18 and above
• •For users under 18, parental consent is required under Singapore and Indian law

10. Cookies and SDKs

The app may use cookies and SDKs to improve the user experience.

• •Users are notified and prompted for consent before such tools are activated

Terms of Service

1. Introduction

These Terms of Service govern your use of the Smart Beauty mobile application and website operated by Bluesense AI Inc. (“Bluesense”, “we”). By accessing or using our services, you agree to these terms. If you do not agree, please refrain from using the app.

2. Scope of Services

Smart Beauty offers AI-powered skin analysis, personalized skincare recommendations, and access to skincare-related content.

These services are for informational purposes only and are not a substitute for medical advice or diagnosis.

3. User Responsibilities

By using the app, you agree to:

• •Provide accurate, up-to-date information
• •Use the app lawfully and respectfully
• •Avoid actions that infringe on the rights or safety of others
• •Comply with local digital behavior standards and consumer protection laws

4. Account Creation & Data Accuracy

You are responsible for providing accurate and truthful information when creating an account.

Providing false or misleading data may lead to suspension or termination of your account.

5. Age Restrictions & Parental Consent

• •Smart Beauty is intended for users aged 18 and above
• •Users under 18 may only use the app with parental or legal guardian consent
• •Bluesense does not knowingly collect data from minors without such consent
• •If discovered, the account will be deleted and data permanently erased

In compliance with the PDPA (Singapore), DPDP Act (India), and PIPA (South Korea)

6. Prohibited Uses

You agree not to:

• •Copy or distribute app content
• •Attempt reverse engineering or data scraping
• •Upload obscene, harmful, or culturally inappropriate content
• •Infringe intellectual property rights
• •Impersonate other users or misrepresent identity

7. Service Modifications

Bluesense reserves the right to:

• •Modify, suspend, or discontinue any part of the services
• •Provide notice of changes via in-app alerts or email

8. Intellectual Property

All content, visuals, and branding on the platform are owned by Bluesense or licensed third parties.

Use of content is restricted to non-commercial, personal use only.

9. Disclaimer & Limitation of Liability

• •Smart Beauty provides general analysis and recommendations
• •We do not guarantee uninterrupted service or medical accuracy
• •To the extent permitted by local law, Bluesense is not liable for direct or indirect damages resulting from use of the app

10. Governing Law & Dispute Resolution

This agreement is subject to the laws of your country of residence:

• •Singapore: Governed by the Personal Data Protection Act and applicable consumer laws
• •India: Governed by the DPDP Act (pending full enforcement)
• •South Korea: Governed by the Personal Information Protection Act and the E-Commerce Consumer Protection Act

Disputes will first be addressed through amicable resolution. If unresolved, parties may contact relevant authorities:

• •Singapore: Consumer Association of Singapore (CASE)
• •India: Consumer Disputes Redressal Commission
• •South Korea: Korea Consumer Agency or courts

BIOMETRIC & HEALTH DATA CONSENT FORM

This Consent Form is issued by Bluesense AI Inc. (“Bluesense,” “we,” “us”) in connection with the Smart Beauty application. It is designed to inform you and obtain your explicit consent for the processing of biometric and health-related data under the Personal Data Protection Act (PDPA) of Singapore, the Digital Personal Data Protection Act (DPDP 2023) of India, and the Personal Information Protection Act (PIPA) of South Korea.

1. Types of Data Collected

When using certain features of the app, the following biometric and health-related data may be collected:

• •Facial images and video selfies (biometric data),
• •Skin condition details: acne, sensitivity, wrinkles, UV damage, etc.,
• •Health-related inputs: skin type, water loss, sensitivity history,
• •Lifestyle details (optional): sleep, stress, and nutrition habits,
• •Location data and device identifiers (for technical purposes).

Under Korean law, biometric data processing requires written consent.

Under Indian law, parental consent is mandatory for users under the age of 18.

2. Purpose of Data Processing

Your data is processed solely for the following legitimate purposes:

• •To provide AI-driven skin analysis,
• •To deliver personalized care recommendations,
• •To improve our algorithms using anonymized data,
• •To track your progress and optimize user experience,
• •To support optional virtual consultation services (if offered).

3. Legal Basis & Consent

Your personal data is processed on the following legal grounds:

• •Based on your explicit, informed, and voluntary consent,
• •For the performance of a user agreement,
• •In compliance with applicable data protection laws (PDPA, DPDP, PIPA).

Without this consent, no biometric or health data will be processed.

You may withdraw your consent at any time.

4. Data Retention Period

• •Your data will only be retained for the period required to deliver the service.
• •Biometric and health data will be deleted or anonymized within 30 days unless otherwise requested.
• •Upon withdrawal of consent or deletion of your account, all such data will be permanently erased.

5. Data Sharing with Third Parties

Your data will only be shared in the following situations:

• •With cloud infrastructure providers (bound by confidentiality agreements),
• •With healthcare professionals during optional in-app consultations (with your consent),
• •With public authorities where legally required.

Under Singapore PDPA, any third-party processors must be contractually bound to data protection obligations.

Under Korean PIPA, data transfers abroad require separate, explicit consent.

6. Security Measures

We apply the following technical and organizational measures:

• •AES-256 encryption in transit and at rest,
• •Access control to ensure only authorized personnel may handle data,
• •Routine security audits and penetration testing,
• •Infrastructure compliant with regional data standards.

7. Your Rights

As a user, you have the following rights:

• •To request access to your data,
• •To request correction of any inaccurate data,
• •To withdraw your consent at any time,
• •To request data erasure,
• •To file a complaint with your local Data Protection Authority.

Singapore: Personal Data Protection Commission (PDPC)

India: Data Protection Board (once operational)

South Korea: Personal Information Protection Commission (PIPC)

8. Consent Declaration

By checking the box below or clicking “I Consent” within the app, you acknowledge that:

• •You grant your explicit consent to the processing of your biometric and health data as described,
• •You understand that such data will be used solely for personalized recommendations and analysis,
• •You may withdraw your consent at any time and that this may limit access to some services,
• •You confirm that you are over 18 years of age, and that you have read and understood this consent form voluntarily.

☐ I Consent

Membership & Sales Agreement – APAC Region (Singapore, India, South Korea)

Applicable Laws: Singapore PDPA, India DPDP Act, South Korea PIPA

1. Definitions

• •Bluesense: Bluesense AI Inc., the owner and provider of the Smart Beauty application.
• •User: An individual who registers for an account and accesses the services offered by the application.
• •Membership: A registered user account that provides personalized access to services and content within the Smart Beauty app.
• •Subscription: A premium membership model provided in exchange for payment over a specific time period.
• •Service: All digital services offered through Smart Beauty, including AI-powered skin analysis, skincare suggestions, content, and virtual consultations.

2. Membership Types

• •Basic Membership: Free of charge; includes access to limited features and content.
• •Premium Membership: Paid; includes personalized skincare plans, detailed AI reports, and consultation support.

Bluesense reserves the right to modify membership types and their features. Changes will be announced in advance.

3. Subscription Fees and Payment Terms

• •Subscriptions are available on a monthly or yearly basis.
• •Payments can be made in local currency (SGD, INR, KRW) or in USD.
• •The user affirms that their payment information is accurate and up to date.
• •Prices include applicable local taxes (e.g., GST, VAT).

4. Auto-Renewal and Notification

• •Subscriptions renew automatically unless cancelled by the user.
• •Users will be notified at least 3 days before the renewal date.
• •Cancellations can be made via the “Subscription Settings” section within the application.

5. Cancellation and Refund Policy

• •Users may cancel their subscription at any time. The service remains active until the end of the current billing cycle.
• •Under applicable APAC consumer protection laws, users are entitled to a refund if the service is defective or not delivered as promised.
• •A refund is not required if the user simply changes their mind (“change of mind”).
• •This agreement does not limit any national consumer rights the user may have under applicable law.

6. Termination of Agreement

Bluesense reserves the right to suspend or terminate the user’s account in the following situations:

• •Providing false or misleading information,
• •Misusing the application or services,
• •Failure to make timely payments,
• •Violation of local laws or the terms of this agreement.

The user may also terminate their membership and delete their account at any time.

7. Age Restrictions and Parental Consent

• •Smart Beauty is only intended for individuals aged 18 and over.
• •Under India’s DPDP Act, individuals under 18 may only use the service with verifiable parental consent.
• •If a parent or legal guardian discovers that their child has accessed the service without permission, they may request data deletion by contacting: privacy@bluesense.ai

8. Legal Compliance and Dispute Resolution

• •This agreement is governed by the laws of the user’s country of residence:
• ◦Singapore: Personal Data Protection Act (PDPA)
• ◦India: Digital Personal Data Protection Act, 2023 (DPDP)
• ◦South Korea: Personal Information Protection Act (PIPA)
• •Parties will attempt to resolve disputes amicably.
• •If a resolution cannot be reached, the user may file a complaint with the relevant consumer protection authority or pursue legal action through the appropriate courts in their country.

Contact

For any requests or questions regarding your data and privacy:

privacy@bluesense.ai