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Privacy Policy

Effective Date: [dd/mm/yyyy]

Last Updated: [dd/mm/yyyy]

At [Company Name] (“we”, “our”, or “us”), we process your personal data in compliance with the General Data Protection Regulation (GDPR). This Privacy Policy explains how we collect, use, share, and protect your data through our mobile application, which uses artificial intelligence (AI) to analyze facial images and provide personalized skincare recommendations.

1. Introduction

This policy applies to users in the European Union (EU) and European Economic Area (EEA). Our app may collect and process biometric and health-related data, such as facial images and skin condition information, for AI-powered analysis and customized suggestions. We only do so with your explicit consent.

2. Personal Data We Collect

Depending on how you use our app, we may collect:

Name and email address
IP address, device type, operating system
Location data (if permission is granted)
Facial image (selfie)
Skin-related information (e.g., acne, redness)
AI-generated insights (e.g., skin type, age estimate)
Marketing and notification preferences

3. Purpose of Processing

We process your data to:

Analyze facial images and assess skin condition using AI
Offer personalized skincare suggestions
Operate and improve our services
Provide customer support
Meet legal obligations
Send marketing messages (only with your consent)

4. Legal Bases

We rely on the following legal grounds:

Contract performance – to provide the service (Article 6(1)(b))
Explicit consent – for biometric and health data (Articles 6(1)(a), 9(2)(a))
Consent – for location use and marketing (Article 6(1)(a))
Legitimate interest – for app security and functionality (Article 6(1)(f))
Legal obligation – for regulatory compliance (Article 6(1)(c))

The following processing requires your separate, explicit consent:

AI analysis of your facial image
Evaluation of your skin condition
Automated product suggestions
Marketing communications
Use of your location

These consents are collected via separate checkboxes in the app and are not pre-selected.

Our app uses automated decision-making to generate skincare suggestions based on AI analysis. If this has a significant effect on you, you may:

Request human review
Express your viewpoint
Contest the decision

We share your data only with:

Cloud infrastructure providers
AI and analytics service providers
Customer support partners
Public authorities if legally required

All third parties are bound by GDPR-compliant Data Processing Agreements (DPAs).

8. International Transfers

If your data is transferred outside the EU/EEA (e.g., to Canada or the U.S.), we ensure appropriate safeguards are in place, such as:

Adequacy decisions
Standard Contractual Clauses (SCCs)
Technical protections like encryption

9. Data Retention

We retain data only as long as necessary:

While your account is active
As required by law (e.g., financial records)
Facial analysis outputs are anonymized using GDPR-compliant techniques (irreversible data masking and generalization) after 6 months.
Deletion requests are processed within 30 days

10. Your Rights

Under GDPR, you have the right to:

Access your personal data
Correct inaccurate data
Request deletion
Restrict processing
Receive your data in portable format
Object to processing
Object to automated decision-making
Withdraw consent at any time

11. Security

We apply technical and organizational measures to protect your data, including:

SSL/TLS encryption
Access controls
Regular security testing
Anonymization of sensitive outputs

12. Changes

We may update this policy. If changes are significant, we’ll notify you in-app or via email. The “Last Updated” date will always reflect the current version.

13. Contact

Data Controller: [Company Name]

Address: [Full legal address]

Email: privacy@[yourcompany].com

Website: www.yourcompany.com