Skincentric Inc.

Privacy Policy

Date: August 22, 2025

1. Introduction

Welcome to Skincentric! We offer a platform to explore and learn about skincare. Please note that while we provide educational and informational resources (including but not limited to Skin Plans, Routines, Images, Media, Skin Coach, or any future products and services), we are not medical professionals and do not provide medical advice. All information and content you encounter through Skincentric is for educational purposes only. Always consult a qualified healthcare provider for questions or concerns regarding a medical condition.

We offer free and paid features. We do not show third-party behavioral ads in the app at this time. This Privacy Policy explains the information we collect, how we use it, and the steps we take to protect it. By using our website, mobile app, or any of our online products and services (collectively, our “Services”), you agree to the practices described in this policy.

2. Information We Collect About You

  1. Account Information. When you open an account, you provide us with information such as your name, address, age, email, phone number, and skin care topics that interest you.

  2. Payment & Billing Information. If you purchase a subscription or other paid feature, payment processing is provided by our third-party processor, Stripe. We do not store full credit or debit card numbers or CVV on Skincentric servers. Stripe collects and processes your payment details pursuant to its own terms and privacy policy. We may receive and store limited billing information from Stripe—such as your name, email, billing address, card brand and last four digits, expiration month/year, Stripe customer/subscription/invoice IDs, transaction and refund IDs, payment status, and tax determinations and amounts via Stripe Tax—so we can operate the Services, prevent fraud, calculate and collect taxes, provide receipts/support, manage your subscription or prepaid access, and process refunds.

  3. Usage Information. When you use Skincentric (even without an account), we collect information about how you interact with our Services, such as the pages or features you use, and any transactions you undertake with us.

  4. Community Content. If you participate in our community features (“Communities”), you may create posts, comments, or send messages (collectively, “Content”).

  5. Definition of “Content.” “Content” refers only to the public or private posts and related data that you share within the Communities (e.g., forums, group chats, direct messages in the Communities). This does not include your personal routine information, progress photos, or other data you do not intentionally publish to the Communities.

  6. Web Browser and Geolocation. We may collect information about your web browser and approximate geolocation (based on IP address), including for security, fraud prevention, and tax calculation (via Stripe Tax).

  7. Chat Prompts & Responses (Skin Coach Lite). When you use Skin Coach Lite, we collect your messages/prompts, tool calls (e.g., requests to analyze a routine), and the assistant’s responses. We also log basic metadata (timestamps, language, feature flags) to operate, secure, and improve the feature.

  8. SkinID & Routine Metadata. If you enable personalization, we store minimal fields needed to tailor guidance (e.g., SkinID typing/flags and routine step names, actives/ingredients, frequency, and notes) in your user account.

  9. Inferences. Based on the data we collect, we may make inferences about you for purposes of recommending content, advertising, or analytics.

  10. Media and Biometric Data. You may choose to provide photos, videos, audio, or similar information (“Media Data”) to enable features such as SkinID analysis and routine personalization. Where Media Data reveals or is used to infer health-related information (e.g., skin conditions) or biometric identifiers, we treat it as sensitive and obtain your consent where required. You can delete Media Data you uploaded from within the app.

3. How We Use Information About You

  1. Providing and Improving Our Services. We use information about you to operate, maintain, and enhance the Skincentric platform. This may include using your Media Data (photos, videos, audio, biometric data) to generate personalized routines, educational resources, or other product features.

  2. AI Processing (Skin Coach Lite). To generate answers, we may transmit your prompts and relevant personalization fields to AI service providers acting as our processors. We configure providers to not use your data to train their public models and to apply limited retention consistent with security and abuse prevention. We use your chats to operate, secure, and improve Skin Coach Lite, including quality review, unless you request deletion.

  3. Payments, Subscriptions, Taxes, and Refunds. We use your information to process payments, manage auto-renewing subscriptions and prepaid access, calculate and collect taxes (via Stripe Tax), send invoices and receipts, prevent, detect, and remediate fraud and chargebacks, and process refunds to your original payment method through Stripe.

  4. Personalization. We may use your information to personalize services and content to your interests and skin care needs.

  5. Customer Service. We use your information to provide support, respond to inquiries, and communicate with you about your account or use of Skincentric. For billing/refund support you can contact support@skincentric.us.

  6. Advertising and Analytics. We may serve you advertisements based on your activity and preferences and analyze aggregated usage to improve our Services. We will not email or text you advertisements if you have asked us not to.

  7. Educational Purposes Only. Nothing in our Services (Skin Plans, Routines, Images, Media, Skin Coach, etc.) is intended to be medical advice. Always consult a licensed professional for medical questions.

4. We Are a Public Platform (for Community Content)

Skincentric allows you to post “Content” in publicly (or privately) viewable Communities. Any information you publish within the Communities is not protected by HIPAA or other medical privacy laws, as we are not a medical provider. While you may have seen a doctor about your skin concerns, sharing your experiences in the Communities means that information is publicly or privately visible to other users within that Community space.

  • Profile Page: If you have an account, you may have a public profile page. Your profile is visible to other users, but the rest of your account details are not publicly displayed.

  • Routine & Progress Data: Your personal routine information or progress photos remain private unless you explicitly choose to post or share them in the Communities.

5. How We Protect Your Information

We use reputable third-party storage providers and security tools to help protect against unauthorized access, alteration, disclosure, or destruction of your personal information. However, no online platform can guarantee absolute security.

Payments Security. We use Stripe to process payments. Stripe is a PCI-DSS Level 1 certified service provider. Skincentric does not store full credit or debit card numbers or CVV on our servers; those are transmitted directly to and stored by Stripe. We implement technical and organizational measures appropriate to the risk, and we review our safeguards periodically.

6. Our Content Policy

Under our content policy, we may remove offensive or off-topic posts without the consent of the person posting. If content violates our guidelines or is unrelated to skincare and related topics, it may be removed or modified in accordance with our policy.

6A. How We Share Information

We share personal information as follows:

  • Service Providers/Processors. With vendors who help us operate the Services (e.g., cloud hosting and databases such as Google Cloud/Firebase, authentication, analytics and crash reporting, customer support and email delivery, AI processing for Skin Coach Lite, and Stripe for payments, subscriptions, refunds, and Stripe Tax). These providers process your information on our behalf under contracts that limit their use to the Services.

  • Payment Networks and Banks. With card networks, banks, and payment gateways as needed to process transactions, refunds, prevent fraud, and handle chargebacks.

  • App Stores (if used). If you purchase through Apple’s App Store or Google Play, those stores collect and process your payment information under their terms and may share limited purchase details with us so we can provide access.

  • Legal and Safety. To comply with law, regulation, legal process, or governmental request; to protect the rights, property, and safety of Skincentric, our users, or the public; or to detect and prevent fraud or security issues.

  • Business Transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets.

We do not sell your personal information.

6B. AI/ML Service Providers (Skin Coach Lite)

Skin Coach Lite
We use third-party AI infrastructure to process prompts and generate responses. These providers act under contract as processors and may receive: your prompt, limited personalization fields (e.g., SkinID/routine metadata), and system instructions necessary to complete your request. We require confidentiality, restrict use to our instructions, and configure settings to opt out of model training where available.

7. Your Rights and Choices

  1. Advertising Preferences. You may opt out of receiving marketing emails or text messages by updating your account settings or emailing us at privacy@skincentric.us.

  2. Tracking & Cookies. Your web browser may provide a Global Privacy Control (GPC) or other cookie-limiting features. We will honor GPC unless it conflicts with settings you have explicitly configured in your account.

  3. Selling/Sharing Information. We do not sell or share your personal information for cross-context behavioral advertising. If this changes, we will update this Policy and provide any required “Do Not Sell or Share” links and notices.

  4. Privacy Requests. You can email us at privacy@skincentric.us to exercise any privacy rights that may apply, such as requesting access, correction, or deletion of your data. You can also do so through the privacy controls in your account.

  5. Billing & Refund Support. For questions about charges, cancellations, or refunds for purchases made directly with Skincentric (processed by Stripe), contact support@skincentric.us.

8. Additional Rights Under Certain Laws

  1. California Residents (CCPA/CPRA). We offer our Services nationwide, including to California residents, and we do business with California consumers. As of the date of this Policy, we do not meet any applicability threshold under Cal. Civ. Code §1798.140(d)(1)—which generally includes: (i) gross annual revenue over $25,000,000 (adjusted to $25.625Mfor the preceding calendar year beginning in 2025), (ii) buying, selling, or sharing the personal information of 100,000 or more California residents or households in a year, or (iii) deriving 50% or more of annual revenue from selling or sharing California residents’ personal information (including cross-context behavioral advertising). Accordingly, the CCPA/CPRA does not currently apply to Skincentric. Regardless of current coverage, we voluntarily honor verified requests from California residents to the extent applicable, including: the right to know/access, delete, and correctpersonal information; the right to opt-out of sale or sharing (including cross-context behavioral advertising); the right to limit the use and disclosure of sensitive personal information where applicable; and the right to non-discrimination for exercising privacy rights. You may submit requests via privacy@skincentric.us or through in-app privacy controls. We also honor Global Privacy Control (GPC) signals as an opt-out preference where required. If the CCPA/CPRA becomes applicable to Skincentric in the future, we will update this Policy and present any required “Your Privacy Choices” link(s) and notices.

  2. EEA, UK, and Switzerland. If you reside in these areas, you may request to exercise local privacy rights (e.g., access, correction, deletion, portability, restriction, objection) by contacting privacy@skincentric.us.

    Automated Decision-Making. Skin Coach Lite provides recommendations only and does not make decisions producing legal or similarly significant effects. You may object to profiling for marketing at any time.
    Minors in the EEA/UK. If you are under the digital age of consent in your country (13–16 depending on the country), a parent/guardian must consent to your use. We do not knowingly allow under-age users to create accounts without such consent.

  3. Legal Bases. Where the GDPR/UK GDPR applies, we process personal data on the following legal bases: performance of a contract (e.g., to provide the Services and process your payments/subscriptions/refunds); legitimate interests (e.g., to secure our Services, prevent fraud/chargebacks, and improve the platform); legal obligation (e.g., tax and accounting record-keeping); and consent where required (e.g., certain marketing or optional analytics).
    International Transfers. Your information may be transferred to and processed in the United States and other countries where we and our service providers (including Stripe) operate. When required, we use appropriate safeguards for such transfers (for example, Standard Contractual Clauses).
    We plan to adhere to any applicable Data Protection Framework(s) once we have established a threshold of accounts in these regions.

8A. Consumer Health Data (Washington & Nevada Notice)

If you are a resident of Washington or Nevada, some information we process (e.g., skin photos, skin concerns, routine data, and inferences drawn from them) may be “consumer health data.”

  1. Categories & Purposes. We collect identifiers, photos/media you upload, routine metadata, and inferences to provide Skin Coach Lite and personalization, secure the Services, prevent fraud/abuse, and support customer requests.

  2. Disclosures. We disclose such data to processors (hosting, AI processing, analytics, support, payments) under contracts limiting use to our instructions. We do not sell consumer health data.

  3. Your Choices. Where required, we obtain consent to collect or share consumer health data and allow you to withdraw consent and delete your data.

  4. Geofencing. We do not use geofencing around health care facilities for targeted marketing.
    To exercise rights, contact privacy@skincentric.us or use in-app controls.

9. Children

Children under 13 may not create an account or post on our platform. By creating an account or using our platforms, you affirm that you meet the minimum age in your region (e.g., 13 in the U.S.; 13–16 in the EEA/UK depending on country law) or have verifiable parental consent.

10. Data Retention

We keep personal information for as long as necessary to provide the Services and for the purposes described in this Policy, including to comply with our legal, accounting, and reporting obligations, resolve disputes, and enforce our agreements. For payment records, tax records, invoices, refunds, and subscription history, we generally retain associated data for the period required by applicable law (for example, tax and audit requirements). When we no longer need personal information, we take steps to delete, de-identify, or aggregate it.

11. Changes to This Privacy Policy

We may amend or change this Privacy Policy from time to time. Any revisions will be noted by updating the “Date” at the top. In the event of material changes, we may also send an email to the address associated with your Skincentric account.