Privacy Policy

Last Modified: [04/02/2024]

1. Summary of Key Points

• Trueskin collects and stores user data, including account details, uploaded photos, AI-generated results, and app interactions.
• Data is stored on Supabase and managed securely, with payments processed via RevenueCat (Apple Pay).
• Photos are sent to third-party AI providers for skin analysis, but personal identifiers (e.g., names, emails) are not shared with them.
• Users can have data access, correction, or deletion by contacting trueskin@hybor.co.
• The app is intended for users age 16 and above.
• Trueskin may use images/photos in marketing materials under user opts out.
• We comply with UK GDPR and align with international privacy laws.

2. Who We Are

Trueskin ("we," "our," or "us") is a skincare application operated by an independent sole trader based in the United Kingdom. Trueskin provides AI-powered skin analysis and personalized skin care recommendations.

For any privacy-related concerns, you may contact us at trueskin@hybor.co.

3. Data Collection

Trueskin collects user data to provide its AI-powered skincare analysis, improve user experience, and ensure security.

When users create an account, we collect details such as an email and password, along with additional information like name, gender, age, and skin-related details. Users may also upload or capture photos for AI analysis, which are stored securely and linked to their account. No personally identifiable details, such as names or emails, are shared with AI providers.

As users interact with the app, we track engagement with routines and product recommendations. Third-party analytics tools such as RevenueCat (for subscriptions) and Mixpanel for app usage help us understand how the features are used. Additionally, device information (device type, operating system, crash, and app version) is collected for service delivery.

4. Financial Data

Trueskin processes payments through Apple Pay via RevenueCat and does not store sensitive financial details. However, we retain basic transaction data, including payment amounts, dates, and subscription status.

Users can manage subscriptions at any time.

5. Data Storage & Security

All user data, including personal details, photos, and AI-generated results, is stored securely on Supabase. Subscription and payment information is managed through RevenueCat. AI analysis is conducted using third-party models, with data being sent via API directly from the app.

Supabase follows renowned industry-leading database security practices. Encryption is standard for stored data, but Trueskin does not actively manage encryption methods beyond those provided by providers.

Data is retained until a user requests its deletion. Users can request the removal of specific data, such as photos or AI results, or their entire account by contacting trueskin@hybor.co. Inactive accounts are not automatically deleted, and data remains unless explicitly removed upon request.

6. Data Sharing & Third Parties

Trueskin shares user data only with third-party services necessary to provide core functionality. This includes:

• AI Providers - Used to analyze and via API to third-party AI models for skin analysis.
• Supabase - Used for secure data storage.
• RevenueCat - Manages subscription processing via Apple Pay.
• Analytics Tools - We may integrate third-party analytics services, such as Mixpanel, to track app interactions. These tools typically collect personally identifiable information.

User data may be disclosed if legally required, such as in response to law enforcement requests or fraud prevention measures.

7. Marketing & Communications

Trueskin communicates with users through email, in-app notifications, and push notifications for updates, recommendations, and promotional content.

Users are automatically opted into marketing emails, which may include skincare tips, feature updates, and promotional offers. Notifications may include reminders, product recommendations, and promotions. Users can manage communication preferences through phone settings or, in some cases, within the app. Marketing emails include an unsubscribe option, allowing users to opt out while still receiving account-related emails.

8. User Rights & Control

Users have control over their data and can request access, updates, or deletion.

A copy of stored data, including AI-generated results and account details, can be requested by contacting trueskin@hybor.co. Personal details can be updated directly within the app. Users may request the deletion of specific data, such as photos or AI results, without deleting their entire account. Full account deletion is also available, though some data may be retained as required by legal obligations.

Trueskin is intended for users aged 16 and above. By creating an account, users confirm they meet this age requirement. If we become aware of underage users, we will take steps to delete their accounts.

9. Legal Compliance

Trueskin complies with UK GDPR and aligns with international data protection regulations, including EU GDPR and CCPA where applicable.

Users have the right to request access to their personal data, correct inaccuracies, and request deletion under GDPR's right to be forgotten. Requests can be made via trueskin@hybor.co.

All data is stored on Supabase, which may process information outside the UK. When data is transferred internationally, we rely on appropriate safeguards to ensure compliance with GDPR.

10. Changes

This privacy policy may be updated periodically. Users will be notified of significant changes via email and will also receive updates within the app. Continued use of Trueskin after any updates constitutes acceptance of the revised policy.

11. Face Data Collection & Processing

Trueskin collects and processes face data solely to provide AI-powered skin analysis and, where permitted, for marketing purposes such as user-submitted "before and after" images. When users upload or capture a photo, the image is analyzed to assess various skin concerns, such as acne, redness, and hydration levels. The app does not perform facial recognition, biometric identification, or identity verification.

Uploaded photos are securely stored on Supabase and remain linked to the user's account until they choose to delete them. These images are also sent via API to third-party AI models for processing, but no personally identifiable information, such as names or emails, is shared with these providers. Face data is not used for any purpose beyond delivering AI-powered skin insights unless the user explicitly opts into marketing use.

With user consent, Trueskin may use images for marketing purposes, such as promotional materials, testimonials, or before-and-after comparisons. Users can opt out of this use at any time by contacting trueskin@hybor.co.

Face data is retained for as long as the user's account remains active. Users can delete specific images at any time, and all stored images are permanently removed upon account deletion. Requests for image removal can also be made by contacting trueskin@hybor.co.

The collection, storage, and processing of face data are outlined in this section of our privacy policy, ensuring compliance with relevant data protection regulations.

12. Disclaimer

Trueskin provides AI-generated skin analysis for informational purposes only. The results should not be considered medical advice, diagnosis, or treatment. Users should consult a qualified healthcare professional for any medical concerns related to their skin.

For any privacy-related inquiries, please contact trueskin@hybor.co