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Privacy Policy – U.S. Compliant (Smart Beauty App)

Effective Date: [Insert Date]

Company: Bluesense AI Inc.

Application: Smart Beauty

1. Introduction

Bluesense AI Inc. ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, store, and protect your personal and biometric data when you use the Smart Beauty mobile application in the United States.

Since there is no single federal privacy law in the U.S., this policy is designed to comply with applicable federal and state laws, including:

Federal Trade Commission Act (FTC Act)
California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
Illinois Biometric Information Privacy Act (BIPA)
New York SHIELD Act

2. Information We Collect

We may collect the following categories of information from or about you:

Personal Identifiers: Name, email address, IP address, device ID, and usage logs.
Biometric Information: Facial images uploaded by the user for cosmetic skin analysis. These are collected only with your prior written informed consent.
Lifestyle Information: Voluntary inputs such as skin type, age range, water intake, and sleep habits.

The application does not collect any medical data, heart rate, or physiological sensor data.

3. Purpose of Use

We use your data to:

Generate personalized skincare and cosmetic suggestions
Enhance app functionality and user experience
Conduct anonymized product research and development
Meet our legal and operational obligations

All information collected is used solely for informational and cosmetic purposes. The app does not provide medical advice.

4. Medical Disclaimer

Smart Beauty is not intended to diagnose, treat, cure, or prevent any disease or medical condition.

All suggestions provided are non-medical and informational in nature.

If you have any skin conditions or health concerns, please consult a licensed medical professional.

5. Legal Basis for Processing

We follow federal and state laws regarding personal data processing.

Under California law (CCPA/CPRA), you have the right to know what personal data we collect, request access, correction, deletion, and opt out of the sale or sharing of your data. A “Do Not Sell or Share My Personal Information” link is available in the app and on our website.

Under Illinois law (BIPA), biometric data is collected only with your explicit written consent. We disclose our retention policy and delete biometric data within 12 months of your last active use or upon request.

Under the New York SHIELD Act, we apply reasonable technical, administrative, and physical safeguards to protect your data from unauthorized access or misuse.

We do not sell your personal or biometric data. We may share data only with:

Cloud infrastructure and hosting providers
Analytics partners under strict confidentiality agreements
Academic research partners, only with fully anonymized data
Legal authorities, if required by law

7. Cookies and Tracking

We use cookies and similar technologies to understand user behavior, improve performance, and provide a better experience. You may disable tracking through your device settings. We honor “Do Not Track” (DNT) signals where technically feasible.

8. Your Privacy Rights

Under U.S. privacy law, you have the right to:

Know what data we collect and how it’s used
Access and receive a copy of your personal data
Correct inaccurate or outdated personal information
Request permanent deletion of your data
Opt out of the sale or sharing of your data
Withdraw consent for biometric data usage at any time

To exercise these rights, contact us at privacy@bluesense.ai or use the Privacy Center in the app.

9. Data Retention

We retain your data only as long as necessary to fulfill the purposes described in this policy.

Biometric data is deleted within 12 months of your last interaction with the app.
We retain personal identifiers for a maximum of 3 years after your last interaction, unless required longer by applicable law
Deletion requests are honored and completed within 30 days.

10. Security Measures

We use appropriate safeguards to protect your information, including:

End-to-end encryption of sensitive data
Role-based access controls
Continuous security monitoring and breach detection
Regular vulnerability testing
Confidentiality and privacy training for our staff

11. Children’s Privacy

We implement reasonable age-verification measures. If we become aware that a child under 13 has provided personal information, we immediately delete such data within 30 days.

12. Changes to This Policy

We may update this policy from time to time. If significant changes are made, we will notify users via:

In-app notifications
Email (if provided)
Updated effective date displayed in the policy

13. Contact Us

If you have questions or would like to exercise your privacy rights, contact:

Bluesense AI Inc.

Email: privacy@bluesense.ai

Address: 2508-1200 West Georgia Street, Vancouver, BC, Canada V6E 4R2

Phone: +1 (XXX) XXX-XXXX