Privacy policy

1. Introduction

Welcome to ClearSkin AI ("we," "our," or "us"). We are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "App"). ClearSkin AI is operated by Teddy-Michael Sannan and is based in Ontario, Canada.

By using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use the App.

2. Information We Collect

2.1 Personal Information

When you create an account, we collect:

• Email address
• Password (encrypted)
• Full name (optional, if provided)

If you choose to sign in using Apple Sign-In or Google Sign-In, we receive your name and email address from the respective provider to create and authenticate your account.

2.2 Demographic Information

To provide personalized skin analysis and accurate skin age estimation, we collect:

• Date of birth (used to calculate your age)
• Gender (male, female, other, or prefer not to say)

This information is required for new users during account setup and is used to personalize your AI skin analysis. Once provided, this demographic information cannot be changed to ensure consistent analysis results. We use this data solely to improve the accuracy of your skin age estimation and to provide gender-appropriate skincare recommendations, as male and female skin have different characteristics.

2.3 Face Data and Skin Analysis Data

When you use our skin analysis features, we collect the following face data and related skin analysis data:

• Photographs of your face (front, left side, right side) captured through the App's camera for the purpose of skin analysis
• Analysis results and recommendations derived from those photos
• Skin condition assessments (e.g. breakouts, oiliness, redness, dryness, pores)
• Estimated skin age and skin age comparison to your actual age
• Historical scan data and progress tracking
• Subscription and free-trial status

What face data is collected. The face data we collect is limited to photographs of your face that you choose to capture in the App. We do not generate, store, or transmit a faceprint, face template, face embedding, or any other biometric identifier. We do not perform face recognition and we cannot use our data to identify you from your face.

How face data is used. Your face photos are used solely to generate your personal skin analysis results — skin score, skin conditions, skin age estimate, heatmap, skincare routine, and product recommendations — which are shown to you inside the App and saved to your scan history so you can track changes over time. Face photos are never used for advertising, are never sold, and are never used to train any artificial intelligence or machine-learning models (ours or any third party's).

On-device face detection. Before a photo is uploaded, the App runs Google ML Kit's on-device face detector to confirm a single face is present and well-framed. This detection runs entirely on your device. The face landmarks and contours computed during this check are held only in memory on your device, are used only to position the on-screen heatmap and to gate the capture, and are discarded when you leave the screen. They are never uploaded to our servers, never stored, and are not used to identify you. No biometric template is created or retained.

Sharing of face data with third parties. Your face photos and your demographic context (age and gender) are transmitted to OpenAI's API to perform the AI skin analysis. OpenAI processes this data as our sub-processor under a Data Processing Agreement with Standard Contractual Clauses. Per our agreement with OpenAI and OpenAI's API data policy, your face photos are not used to train OpenAI's models. We do not share your face photos with any other third parties, do not sell them, and do not use them for advertising.

Where face data is stored. After analysis, your face photos and analysis results are stored in a private storage bucket and database operated by Supabase (our hosting and database sub-processor). Both are protected by row-level security so that one user cannot access another user's photos or scan data. Data in transit is encrypted with TLS/HTTPS; data at rest is encrypted by our hosting provider.

How long face data is retained. Your face photos and skin analysis results are retained in your account only for as long as your account exists, so that you can view your scan history and track your progress over time. When you delete your account from within the App, all of your face photos and all of your skin analysis results are permanently deleted from our database and storage. Face photos and skin analysis results are not retained after account deletion (subject only to short-lived backups in the normal course of operating the service, which expire automatically).

2.4 Payment Information

When you subscribe to premium features, payment processing is handled entirely by Apple (App Store) on iOS and Google (Play Store) on Android. We never receive, see, or store your payment card information, billing address, or transaction history. Apple and Google collect and process this information under their own terms and privacy policies.

We use RevenueCat as a service layer to receive subscription status updates from Apple and Google (e.g., active, renewed, cancelled, expired). RevenueCat receives a signed receipt or purchase token that confirms the transaction. Neither RevenueCat nor ClearSkin AI receives your payment card details.

The only purchase-related data we store is: a store-side transaction identifier, the subscription product purchased (monthly or yearly), the current period dates, and the subscription status.

2.5 Contact and Communication Data

When you contact us through the App's contact form, we collect:

• Your contact messages and inquiries
• Subject lines and message content
• Your email address for response purposes
• Timestamp of your communication

The contact form on our website. The same applies if you write to us through the contact form at clearskinai.ca, which you can use without an account. We collect the name you give, your email address, the subject, the message, and the time it was sent. We do not record your IP address or your browser's user agent. These submissions are kept separately from any App account.

Retention of contact data. Messages sent from inside the App are stored with your account and are deleted when you delete your account. Messages sent from the website are deleted 12 months after we have answered or closed them, and in every case no later than 24 months after they were sent. To have a website message erased sooner, email us at the address in Section 14 from the address you wrote from.

2.6 Notification Data

When you enable notifications in the App, we collect:

• Push notification tokens (Expo push tokens) used to deliver notifications to your device
• Notification preferences, including scan reminder day and time, and AM/PM skincare routine reminder times

2.7 Automatically Collected Information

When you use the App, we may automatically collect:

• Device information (device model, operating system version, and the app version and build number). We do not collect advertising identifiers (such as Apple's IDFA or Google's Advertising ID) and we do not collect any hardware serial number, IMEI, or MAC address.
• App usage data (features accessed, time spent in app)
• Camera permissions (only when you actively use the scan feature)
• Error logs and crash reports (via Sentry; see Section 7 for details)
• Authentication session tokens, stored locally on your device using AsyncStorage to maintain your signed-in session. These tokens are not transmitted to third parties and are removed when you sign out.
• IP address, used transiently at the server level for rate limiting and abuse prevention (e.g., preventing abuse of our APIs). Your IP address is held only in short-lived rate-limiting records, which expire within one minute to one hour depending on the operation, and it may appear briefly in our server security logs. It is never stored in your account profile, is not used to build a profile of you, and is not retained for longer than necessary for these security purposes.
• Device locale, language, and device region, used to present content in your language and to apply the correct minimum-age requirement for your region (see Section 11).

2.8 Skin and Lifestyle Questionnaire

During onboarding, and at any time afterwards from the Skin Profile screen, we ask you a short series of optional questions so that your analysis, routine, and product recommendations can be tailored to you rather than generic. If you answer them, we collect and store:

• Your primary skin concern and your skincare goal
• Your self-described skin type
• How often you wash your face
• Skincare products you currently use and products you own
• Whether you believe your breakouts are hormonal
• Typical sugar intake and general diet type (for example, vegetarian or vegan)
• Typical daily water intake
• Typical hours of sleep per night
• Self-reported stress level
• Typical sun exposure
• How you heard about ClearSkin AI, and whether you have used other skincare apps before

These answers are health data. Several of these questions (in particular hormonal breakouts, sleep, stress, diet, and sun exposure) reveal information about your health. We therefore treat your questionnaire answers as special-category health data under GDPR Article 9 and as sensitive personal information under California law, with the same protections we apply to your face photos and skin analysis results.

How they are used. Your answers are included in the profile context sent to our AI sub-processor alongside your photos so that your skin analysis, AM/PM routine, and product recommendations account for your actual circumstances. They are never used for advertising, are never sold, and are never used to train any artificial intelligence or machine-learning models.

They are optional. Every question in this section can be skipped, and you can change your answers at any time from the Skin Profile screen. Skipping them reduces how personalized your results are but does not prevent you from using the App. Two of these answers (how you heard about us and whether you have used other skincare apps) are also sent to our analytics sub-processor as described in Section 5; you can opt out of analytics at any time from Settings.

Retention. Questionnaire answers are stored in your account profile and are permanently deleted when you delete your account, on the same terms as the rest of your account data (see Section 8).

3. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA) and United Kingdom, we process your personal data under the following legal bases:

• Account data (email, name, password, date of birth, gender): Contract performance (Article 6(1)(b)) — necessary to provide the ClearSkinAI service.
• Face photos and skin analysis results (skin scores, conditions, skin age, heatmaps, routines, product recommendations): Explicit consent (Article 6(1)(a) and Article 9(2)(a)) — you provide explicit consent during onboarding before your first scan. You may withdraw this consent at any time from Settings.
• Skin and lifestyle questionnaire answers (Section 2.8), including hormonal, sleep, stress, diet, and sun-exposure answers: Explicit consent (Article 6(1)(a) and Article 9(2)(a)) — these questions are optional, you choose which to answer, and you may change or remove your answers at any time from the Skin Profile screen.
• Payment and subscription data: Contract performance (Article 6(1)(b)) — necessary to process your subscription. Payment data is handled entirely by Apple App Store and Google Play Store and never touches our servers.
• Product analytics (PostHog): Legitimate interest (Article 6(1)(f)) — necessary to understand which features are used, to find where users get stuck, and to prioritize improvements. We have assessed that this processing is limited to the events described in Section 5, does not involve advertising, profiling with legal effects, or any sale of data, and is therefore not overridden by your interests. You may object to this processing at any time by turning off “Share usage analytics” in Settings, which stops analytics events being sent from the App and from our servers.
• Crash reports and error logs (Sentry): Legitimate interest (Article 6(1)(f)) — necessary to maintain app stability and fix technical issues. Sentry is configured with PII collection disabled.
• Push notification tokens and preferences: Consent (Article 6(1)(a)) — collected only when you enable notifications.
• Contact form messages: Contract performance (Article 6(1)(b)) — necessary to respond to your support request.

4. International Data Transfers

ClearSkinAI is operated from Canada. If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, your personal data may be transferred to and processed in countries outside your jurisdiction, including Canada and the United States. We ensure appropriate safeguards are in place for these transfers through the following mechanisms:

• OpenAI (AI skin analysis): We have a Data Processing Agreement (DPA) with OpenAI that includes Standard Contractual Clauses (SCCs) approved by the European Commission for the transfer of personal data to third countries.
• Supabase (database and authentication): We have executed a Data Processing Agreement with Supabase that includes Standard Contractual Clauses and allows selection of data center regions.
• Resend (transactional email): We have a Data Processing Agreement with Resend that includes Standard Contractual Clauses for international data transfers.
• Apple (App Store) and Google (Play Store) (payment processing): Apple and Google each maintain their own GDPR compliance programs and Standard Contractual Clauses for international transfers. RevenueCat (subscription status service) maintains a Data Processing Agreement with Standard Contractual Clauses.
• Sentry (crash reporting): Sentry is configured with PII collection disabled. Crash reports contain only technical data.
• PostHog (product analytics): PostHog processes the usage events described in Section 5. Events sent from our servers are labelled with your account identifier, so they are linked to your account. PostHog maintains a Data Processing Agreement with Standard Contractual Clauses.
• Expo (push notification delivery and app updates): Expo relays push notifications to your device and serves over-the-air app updates. It receives your push notification token and, when checking for updates, your device's IP address and basic device metadata.

Canada has received an adequacy decision from the European Commission under PIPEDA, meaning transfers of personal data from the EEA to Canada are permitted without additional safeguards.

For more information about these safeguards or to obtain a copy of the relevant agreements, please contact us at [email protected].

5. Sub-Processors

We use the following sub-processors to help deliver the ClearSkinAI service:

• OpenAI (San Francisco, USA) — AI-powered skin analysis. Processes face photos, date of birth, gender, age, and user-provided context to generate skin health assessments. Data Processing Agreement with SCCs in place.
• Supabase (San Francisco, USA) — Database, authentication, and file storage. Stores account data, scan results, and photos. Data Processing Agreement with SCCs in place.
• Apple Inc. (Cupertino, USA) — Payment processing for iOS via App Store In-App Purchase. Handles all subscription billing and payment method management for iOS users. No raw payment data touches our servers.
• Google LLC (Mountain View, USA) — Payment processing for Android via Google Play Billing. Handles all subscription billing and payment method management for Android users. No raw payment data touches our servers.
• RevenueCat, Inc. (San Francisco, USA) — Subscription status service. Receives signed receipts/purchase tokens from Apple and Google to confirm subscription state and notifies our backend of subscription events (purchase, renewal, cancellation, expiration). Does not receive payment card information. Data Processing Agreement with SCCs in place.
• Resend (San Francisco, USA) — Transactional email delivery. Sends account verification, password reset, data export, and contact form emails. Data Processing Agreement with SCCs in place.
• Sentry (San Francisco, USA) — Crash reporting and error tracking. Receives anonymized crash reports with PII collection disabled.
• PostHog (San Francisco, USA) — Product analytics and event tracking. Collects only the events we explicitly send (e.g. “scan_completed”, “subscription_started”, “onboarding_completed”), plus basic app lifecycle events such as the app being opened or sent to the background. Automatic screen and tap capture (“autocapture”) is disabled, so we never send the screens you view or the elements you tap. Events sent from within the App carry an anonymous identifier generated by PostHog on your device. Events sent from our servers (for example when a scan completes or a subscription renews) are labelled with your ClearSkin AI account identifier, which means those events are linked to your account. We never send your name, email address, photos, skin analysis results, or payment details to PostHog. Two questionnaire answers — how you heard about us and whether you have used other skincare apps — are sent as properties of the “onboarding_completed” event. You can stop all analytics, on the device and on our servers, by turning off “Share usage analytics” in Settings. Data Processing Agreement with SCCs in place.
• Expo (Expo/650 Industries, Palo Alto, USA) — Push notification delivery and over-the-air app updates. Receives your push notification token in order to deliver notifications to your device, and receives your IP address and basic device metadata when the App checks for updates.
• Discord (San Francisco, USA) — Internal operational alerting. When our servers detect a security or reliability event (for example a rate limit being exceeded or an invalid authentication attempt), an alert is posted to a private channel visible only to the App's operator. These alerts can include your account identifier and the IP address the request came from. They never contain your photos, skin analysis results, questionnaire answers, or payment details. If Discord delivery fails, high-severity alerts are sent instead by email to the operator via Resend.

We will notify users of any changes to this list by updating this Privacy Policy.

6. How We Use Your Information

We use the information we collect to:

• Provide and maintain the App's skin analysis features
• Process your AI-powered skin assessments using OpenAI's API
• Estimate your skin age and compare it to your actual age
• Provide gender-appropriate skincare analysis and recommendations
• Track your skin health progress over time
• Manage your subscription and any introductory free trial
• Process subscription payments and manage your account
• Send you important updates about your account or the App
• Respond to your inquiries and provide customer support through our contact form
• Process and respond to your contact form submissions
• Improve our App's features and user experience
• Detect, prevent, and address technical issues or fraudulent activity
• Comply with legal obligations

7. Third-Party Services

We use the following third-party services that may collect and process your information:

7.1 Supabase (Database & Authentication)

We use Supabase to store your account information, scan data, and manage authentication. Supabase is hosted on secure servers and complies with industry-standard security practices.

7.2 OpenAI (AI Processing)

Your skin photos, along with your date of birth, gender, and age, are sent to OpenAI's API to provide AI-powered analysis and recommendations. This demographic data is included to enable accurate skin age estimation and gender-appropriate analysis. OpenAI processes this data in accordance with their privacy policy and data processing agreements. Images and demographic data are processed for analysis purposes only and are not used to train OpenAI's models.

7.3 Apple App Store, Google Play Store, and RevenueCat (Payment Processing)

All payment transactions are processed by Apple (on iOS) or Google (on Android) through their respective app stores. We do not store your payment card details. Apple's and Google's use of your personal information is governed by their respective privacy policies.

We use RevenueCat as a service layer to receive subscription status events from Apple and Google. RevenueCat receives signed receipts and purchase tokens to verify your subscription state and informs our backend when your subscription is purchased, renewed, cancelled, or expires. RevenueCat's use of your personal information is governed by their privacy policy.

7.4 Resend (Email Services)

We use Resend to send emails, including contact form responses and data export emails. Your email address and message content are processed by Resend in accordance with their privacy policy.

7.5 Sentry (Crash Reporting)

We use Sentry to collect error logs and crash reports to help us identify and fix technical issues in the App. Sentry is configured with personally identifiable information (PII) collection disabled, meaning your IP address and other personal data are not sent to Sentry. Only technical error data and device metadata (such as device model and operating system version) are collected.

7.6 PostHog (Product Analytics)

We use PostHog to understand how the App is used so we can improve it. Automatic screen and tap capture is disabled: the only events PostHog receives are ones we explicitly send, plus basic app lifecycle events. Events sent from our servers are labelled with your account identifier and are therefore linked to your account; events sent from within the App use an anonymous identifier generated on your device. You can turn analytics off entirely at any time under Settings, using the “Share usage analytics” toggle. See Section 5 for the full description.

7.7 Expo (Notifications and App Updates)

We use Expo to deliver push notifications and over-the-air updates to the App. Expo receives your push notification token when you enable notifications, and your IP address and basic device metadata when the App checks for an update.

8. Data Retention

We retain your personal information and skin analysis data until you delete your account. When you delete your account:

• All your personal information is permanently deleted
• All your scan photos and analysis results are permanently deleted
• Your skin and lifestyle questionnaire answers (Section 2.8), routine completion history, and saved product list are permanently deleted
• Your subscription is cancelled (if active)
• Your contact form submissions and communication history are permanently deleted
• Some financial records may be retained as required by law for tax and accounting purposes

One exception: messages sent through the contact form on our website are not tied to an account, so deleting your account does not reach them. They are deleted on their own schedule — 12 months after we have answered or closed them, and no later than 24 months after they were sent — or sooner on request, as described in Section 2.5.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS/HTTPS) and at rest (AES-256, applied by our hosting provider)
• Secure authentication protocols, including token expiry and refresh-token rotation
• Row-level security on our database and a private storage bucket, so one user cannot access another user's photos or data
• Rate limiting, input validation, and security monitoring on our servers
• Regular security assessments
• Access to personal data limited to authorized personnel on a need-to-know basis

9.1 Operator Access to Your Photos and Scan Data

ClearSkin AI is not an end-to-end encrypted service. So that we can provide AI skin analysis, your face photos are processed in readable form on our servers and sent to our AI sub-processor (see Sections 4 and 7). This means that authorized personnel — currently the App's operator — have the technical ability to access stored photos and scan results. We access this data only when necessary to operate, support, secure, or debug the service, to comply with a legal obligation, or with your consent. We do not browse user photos out of curiosity, we do not sell or share them, and we do not use them to train any artificial intelligence models. If our team grows, access will remain restricted to personnel with a legitimate operational need.

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

10. Your Privacy Rights

10.1 General Rights

You have the right to:

• Access your personal information
• Correct inaccurate or incomplete information
• Delete your account and all associated data
• Withdraw consent for data processing
• Export your data in a portable format. Using Export My Data in Settings emails you a machine-readable JSON file containing your profile and questionnaire answers, every scan and its analysis results, your routine completion history, your saved product list, your subscription and scan-credit records, your notification preferences, and your contact-form messages, together with time-limited download links for every photo and heatmap image we hold for you.
• Object to processing based on our legitimate interests, including product analytics, using the “Share usage analytics” toggle in Settings

10.2 Canadian Residents (PIPEDA)

Under Canadian privacy law, you have the right to access your personal information and request corrections. You may also withdraw consent for certain data processing activities.

10.3 European Residents (GDPR)

If you are located in the European Economic Area, you have additional rights under GDPR, including:

• Right to data portability
• Right to restrict processing
• Right to object to processing
• Right to lodge a complaint with a supervisory authority

10.4 California Residents (CCPA/CPRA)

California residents have the right to:

• Know what personal information is collected, used, shared, or sold
• Correct inaccurate personal information we hold about you
• Delete personal information held by businesses
• Opt-out of the sale or sharing of personal information (Note: We do not sell or share personal information, and we have not done so in the preceding 12 months)
• Limit the use and disclosure of sensitive personal information
• Non-discrimination for exercising their privacy rights

Sensitive personal information. Your face photos, skin analysis results, and questionnaire answers are sensitive personal information under the CPRA because they concern your health. We use and disclose this information only to perform the service you requested — generating your skin analysis, routine, and recommendations — and for the security and debugging purposes described in Section 9. We do not use it to infer characteristics about you, and we do not use or disclose it for any purpose that would trigger the right to limit under Civil Code section 1798.121. Because of this, no separate “Limit the Use of My Sensitive Personal Information” mechanism is required; you can nevertheless withdraw consent and delete all of this data at any time from Settings.

We do not sell or share your personal information as those terms are defined by the CPRA, and we do not disclose personal information for cross-context behavioral advertising. We therefore do not offer a “Do Not Sell or Share My Personal Information” link. To exercise any right above, use the Export My Data and Delete Account controls in Settings, or contact us at [email protected]. We will not discriminate against you for exercising these rights.

11. Children's Privacy and Minimum Age

The minimum age to use the App depends on where you are:

• European Economic Area, United Kingdom, and Switzerland: you must be at least 16 years old. This reflects the age of consent for information society services under GDPR Article 8. Because our processing of your face photos, skin analysis results, and questionnaire answers relies on your explicit consent, we apply the higher 16-year threshold across these regions rather than varying it country by country.
• Everywhere else, including Canada and the United States: you must be at least 13 years old.

We determine which threshold applies from your device's region setting, and we check your date of birth against it both in the App and on our servers before any scan is permitted.

We do not knowingly collect personal information from anyone below the applicable minimum age. If you are a parent or guardian and believe your child has provided us with personal information below that age, please contact us at [email protected] and we will delete it from our systems.

For users who are above the minimum age but under 18, we recommend parental guidance when using the App and its skin analysis features.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy within the App and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

Your continued use of the App after any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide by the modified Privacy Policy.

13. Legal Disclaimers and Limitations

13.1 Medical and Health Disclaimers

You acknowledge and agree that:

• All data collection and processing is for informational and educational purposes only
• We do not provide medical advice, diagnosis, or treatment
• We are not responsible for any health outcomes or medical decisions based on our analysis
• You should consult with healthcare professionals for any medical concerns
• We disclaim all liability for any adverse health effects or medical complications

13.2 Product Recommendation Disclaimers

You acknowledge and agree that:

• Any product recommendations are generated by AI and may not be suitable for your specific needs
• We are not responsible for any adverse reactions to recommended products
• You are solely responsible for researching and testing any recommended products
• We disclaim all liability for product-related injuries or damages
• You assume all risks associated with using recommended products

13.3 Data Accuracy and Reliability

You acknowledge and agree that:

• All AI-generated analysis and recommendations may contain errors or inaccuracies
• We do not guarantee the accuracy, reliability, or completeness of any analysis results
• You should not rely solely on our analysis for important health or skincare decisions
• We are not liable for any decisions made based on our analysis or recommendations

13.4 International Data Protection

ClearSkin AI is operated from Ontario, Canada, and complies with Canadian privacy laws (PIPEDA) as its primary legal framework. If you are located in the European Economic Area, United Kingdom, or California, you may have additional rights under applicable data protection laws as described in Section 10 of this Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

We will respond to your inquiry within 30 days of receipt.