Last updated: March 11, 2026
This Privacy Notice for SkinCircle (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at skincircle.help@gmail.com.
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
How We Collect and Handle Skin Images. If you opt in to our data training consent program, your skin images may be used to improve our Services and AI models. If you do NOT opt in, your skin images are encrypted at rest and accessible only through your login-gated encryption key. In either case, skin images are never shared with third-party AI service providers (see Section 6).
Consent for Sensitive Data. We obtain your explicit, informed consent before processing sensitive personal data (including health data and skin images) through an in-app consent flow presented at the time of collection. This consent is recorded and timestamped in our systems. You may withdraw your consent at any time through your account privacy settings or by contacting us at skincircle.help@gmail.com. Withdrawing consent does not affect the lawfulness of processing performed before withdrawal. If you withdraw consent for image training, your images will be removed from training datasets within thirty (30) days.
Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Apple App Store / Apple In-App Purchases. You may find their privacy notice here: https://www.apple.com/legal/privacy/.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in Section 7 below.
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
The information we collect includes:
Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments.
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have data processing agreements (DPAs) in place with our third-party processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
Key Processors and Subprocessors:
If we engage new subprocessors that will have access to your personal information, we will update this list. You may subscribe to subprocessor change notifications by emailing skincircle.help@gmail.com with the subject line “Subprocessor Notifications.”
Aggregated and Anonymized Data for Research and Commercial Insights. We may aggregate and anonymize your skin condition data, product usage data, and demographic information to create statistical insights and research findings. This aggregated data does not identify you personally and may be shared with or licensed to cosmetic brands, market research firms, ingredient suppliers, and other commercial partners for product development, efficacy studies, and market research purposes. For example, we may provide insights such as “Users aged 25–34 with acne concerns showed a 15% average improvement after using retinol products for 6 weeks.” These insights help improve skincare products and advance dermatological research. This aggregated data is only shared or sold when it represents data from at least 50 users to ensure individual privacy. See Section 8 for more details.
The categories of third parties we may share personal information with are as follows:
We also may need to share your personal information in the following situations:
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.
The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies. We do not send any personal data or user images to third-party AI providers.
As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.
We provide certain AI Products through third-party service providers (“AI Service Providers”), including Google Cloud AI.
Our AI Products are designed for the following functions:
All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties. This ensures high security and safeguards your personal information throughout the process. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
In Short: We may aggregate and anonymize your data for research and commercial purposes. You can opt out of having your data included in aggregated datasets sold to third parties.
“Aggregated Data” means data derived from multiple users and presented in a form that does not reasonably identify any individual user. Aggregated Data is always based on groups of at least fifty (50) users to ensure individual privacy.
We will not attempt to re-identify any individual user from Aggregated Data. We contractually require any third parties who receive Aggregated Data to refrain from attempting re-identification. Aggregated Data may not be combined with other datasets in a manner that could reasonably be used to re-identify individual users.
We may use, share, or license Aggregated Data to third parties such as cosmetic brands, market research firms, ingredient suppliers, pharmaceutical companies, and academic researchers for purposes including:
For example, Aggregated Data may include statistical insights such as “Users aged 25–34 with acne showed 15% improvement using retinol products.”
You may opt out of having your data included in Aggregated Data sold or licensed to third parties at any time by:
Opting out will not affect your ability to use the Services. We will process your opt-out request within thirty (30) days.
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
| Data Category | Retention Period |
|---|---|
| Account information (email, username) | Duration of account + 2 years for fraud prevention and legal compliance |
| Skin images (opted-in to training) | Duration of account + 30 days after deletion request or consent withdrawal |
| Skin images (NOT opted-in to training) | Duration of account; deleted within 30 days of account deletion |
| Skin analysis scores and assessments | Duration of account + 1 year for analytics |
| Payment metadata | As required by Apple; we do not store full payment details |
| Device and usage data | 2 years from collection |
| Log data | 1 year from collection |
| Aggregated/anonymized data | Indefinitely (as it does not identify individuals) |
| Customer support communications | 3 years from last interaction |
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. Our security measures include:
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In the event of a data breach that compromises your personal information, we will notify affected users and applicable regulatory authorities as required by applicable law, without undue delay. Where required, such notification will include:
We will provide such notification via email to the address associated with your account, in-app notification, or other means as required by law. For EU/UK users, we will notify the relevant supervisory authority within 72 hours where required by GDPR.
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information.
To exercise any of your privacy rights, you can:
To protect your privacy, we will verify your identity before processing any rights request. Verification may include confirming your email address through a verification link, answering security questions associated with your account, or providing additional identifying information. If you submit a request through an authorized agent, we will require written authorization from you and may contact you directly to confirm the request.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you have the right to lodge a complaint with your local data protection supervisory authority. You can find your supervisory authority at: https://edpb.europa.eu/about-edpb/about-edpb/members_en (for EEA) or contact the UK Information Commissioner’s Office (ICO) at https://ico.org.uk.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent by:
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you would at any time like to review or change the information in your account or terminate your account, you can:
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at skincircle.help@gmail.com.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
Our mobile application does not use browser cookies. We may use the following tracking technologies:
We do not use third-party advertising trackers or sell your personal information for targeted advertising purposes. You can control device-level tracking through your iOS privacy settings (Settings > Privacy & Security).
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.
The table below shows the categories of personal information we have collected in the past twelve (12) months.
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Email address, username, unique device identifier, IP address | YES |
| B. Personal information (CA Customer Records) | Name (if provided), email address, account information | YES |
| C. Protected classification characteristics | Age range, gender (if voluntarily provided) | YES (optional) |
| D. Commercial information | Subscription status, purchase history | YES |
| E. Biometric information | Skin images and photographs | YES (with consent) |
| F. Internet or similar network activity | App usage data, feature interactions, log data | YES |
| G. Geolocation data | Approximate location derived from IP address | YES (approximate only) |
| H. Audio, electronic, sensory, or similar information | Skin images created in connection with our Services | YES |
| I. Professional or employment-related information | N/A | NO |
| J. Education information | N/A | NO |
| K. Inferences drawn from collected personal information | Skin analysis scores, product efficacy metrics, routine recommendations | YES |
| L. Sensitive personal information | Health data (skin assessments), biometric data (skin images), account login information | YES (with consent) |
We only collect sensitive personal information, as defined by applicable privacy laws, for the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
Retention: We will use and retain the collected personal information as needed to provide the Services and in accordance with the retention periods described in Section 9.
Sources of Personal Information: Learn more about the sources of personal information we collect in Section 1.
How We Use and Share Personal Information: Learn more about how we use your personal information in Section 2 and how we share it in Section 4.
Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more in Section 4.
We do not sell or share identifiable personal information. However, we may share aggregated and anonymized data (which does not identify you personally) with commercial partners for research and product development purposes. This aggregated data represents statistical insights from groups of at least 50 users and cannot be traced back to any individual user.
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
We do not sell identifiable personal information. If you wish to opt out of the sale or sharing of aggregated data that may include your de-identified information, you may do so by:
To exercise these rights, email us at skincircle.help@gmail.com with the subject line “US Privacy Rights Request.” Include your account email and the specific right(s) you wish to exercise.
You may designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will verify your identity by sending a confirmation link to the email address associated with your account. If we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at skincircle.help@gmail.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
In Short: We do not knowingly collect personal information from children under the age of 13 without verifiable parental consent. Users between 13 and 18 must have parental permission.
Our Services are intended for users who are at least 13 years of age, consistent with our Terms of Service. All users who are minors in the jurisdiction in which they reside (generally under the age of 18) must have the permission of, and be directly supervised by, their parent or guardian to use the Services.
Children Under 13. In accordance with the U.S. Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect personal information from children under the age of 13 without verifiable parental consent. If we become aware that a child under 13 has provided personal information without verifiable parental consent, we will delete that information as quickly as is reasonably practical.
Users Aged 13–17. Users between the ages of 13 and 17 must have the permission of a parent or guardian to use the Services. We rely on the user’s representation at the time of account registration that they have obtained parental permission. We do not knowingly process sensitive personal data (including skin images) from users under 18 without parental consent.
Parental Rights. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us immediately at skincircle.help@gmail.com. Upon verification, we will promptly delete the child’s personal information and terminate their account.
In Short: We use automated processing to generate skin condition scores and product recommendations. These are informational only and do not produce legal or similarly significant effects.
Our Services use automated processing, including AI and machine learning, to:
The outputs of our automated processing are informational and educational only. They are not medical diagnoses, do not produce legal effects, and do not make decisions that significantly affect your rights or obligations. Skin analysis scores and recommendations are designed to help you track your skincare journey and make informed product choices.
We do not make decisions based solely on automated processing that produce legal effects or similarly significant effects concerning you. If we ever implement such processing in the future, we will provide meaningful information about the logic involved, the significance, and the envisaged consequences, and we will offer a simple way to request human review.
If you have questions about or wish to contest any automated output provided by the Services, you may contact us at skincircle.help@gmail.com. We will provide a meaningful explanation of the factors involved and, where appropriate, have a human review the output.
SkinCircle is not a medical device and does not provide medical advice, diagnosis, or treatment. The information, insights, scores, recommendations, and other content provided through the Services are for informational and educational purposes only and are not intended to replace professional medical advice, diagnosis, or treatment.
Use of the Services does not create a doctor–patient or other healthcare professional relationship between you and SkinCircle or its operators.
Important Note on Lifestyle Factors: Any insights, scores, or recommendations provided through our Services may be influenced by multiple factors beyond the products themselves, including but not limited to: diet, hydration, sleep quality, stress levels, genetics, age, environmental conditions, sun exposure, skincare routines, and overall lifestyle choices. We do not claim that our products are the sole cause of any results or improvements. Individual results may vary significantly based on these and other factors. We encourage you to adopt a comprehensive approach to skin condition that includes professional dermatological advice, healthy lifestyle practices, and appropriate skincare habits.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may email us at skincircle.help@gmail.com or contact us by post at:
SkinCircle
4 Hilldale Lane
Port Washington, NY 11050
United States
Phone: (516) 838-7571
At this time, based on our current scale of operations, we have not appointed a Data Protection Officer (DPO) or EU/UK representative. If our processing activities require the appointment of a DPO under Article 37 GDPR, we will update this notice accordingly. For all privacy-related inquiries, including those from EU/UK residents, please contact us at skincircle.help@gmail.com.
You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.
To submit a request, please email us at skincircle.help@gmail.com with the subject line “Data Request” and include:
We will verify your identity and respond within the timeframes described in Section 11.