Privacy Policy

Effective Date: 20 April 2026 | Last Updated: 10 September 2026 | Version 2.4

This Privacy Policy describes how The Skin Agent Pte. Ltd. ("The Skin Agent", "we", "us", or "our"), incorporated in Singapore (UEN: 202609661M), collects, uses, stores, and shares your personal data when you use the Skin Agent mobile application (the "App").

We are committed to handling your personal data responsibly and in compliance with applicable privacy laws across all markets in which we operate, including Singapore, Japan, South Korea, Thailand, Indonesia, Vietnam, the Philippines, and Malaysia.

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

IMPORTANT: Skin Agent processes sensitive personal data including derived face scan results and heritage data. We obtain separate, explicit consent before processing either category. You may use the App without providing either type of sensitive data.

1. Who We Are

Data Controller:

The Skin Agent Pte. Ltd.

Registered in Singapore

UEN: 202609661M

Address: 2 VENTURE DRIVE #19-21 VISION EXCHANGE SINGAPORE 608526

Privacy contact: hello@skinagent.net

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing our compliance with applicable data protection laws, including Singapore's PDPA. The DPO can be contacted at hello@skinagent.net.

Japan:We process your personal data in accordance with Japan's Act on the Protection of Personal Information (APPI). Contact us at hello@skinagent.net for APPI-related requests.

South Korea:We designate a local representative for PIPA compliance. Details are available in the Korean-language supplement accessible in Settings > Legal within the App.

2. What Data We Collect and Why

The table below summarises all categories of personal data we collect. Rows marked Sensitive require your explicit consent before we process them.

CategoryWhat We CollectWhy We Collect It
Identity and AccountName, email address, password (hashed and salted)Account creation and authentication
User and Session IdentifiersAn internal identifier tied to your account or app sessionAssociating AI requests and analytics events with your account or session so responses and features work correctly
Skin Profile DataSPEC profile (OD, SR, PN, WT axes), skin quiz responses, skin type, concerns, product sensitivitiesPersonalised skincare intelligence and product recommendations
Derived Face Scan Results (Sensitive)SPEC skin zone scores, skin health metrics, and zone analysis outputs derived on-device. Raw face images and facial landmark coordinates are NEVER transmitted.SPEC scan feature and longitudinal skin tracking. Explicit consent required before first scan.
Heritage Response Data (Sensitive)Self-reported ethnic heritage and genetic skin characteristics for Heritage Response (HR) axis calibrationHR axis calibration only. Entirely voluntary. Skipping this has no impact on other features.
Coarse LocationA city you enter manually, or a city derived on your device after you choose Use Current Location. The precise coordinates used for that one-time lookup are not sent to Skin Agent's server or stored in your profile.Climate Response (CR) axis recalculation using local weather conditions
Chat and Conversation DataFree-form chat messages and the context categories shown in Settings > Data & Privacy, only when you have given explicit consent to AI sharingPersonalised AI responses. See Section 5.5 for exactly who receives this data, what they do with it, and how to withdraw consent.
Submitted Product and Ingredient PhotosPhotographs of skincare or cosmetic products and ingredient labels that you submit, whether captured with the camera or chosen from your photo libraryReading the brand, product name, and ingredient list from the photo you submit, so we can identify the product and provide analysis
Usage and Product DataProducts scanned, ingredients checked, dupes searched, routines built, saved product shelf, scan historyProduct recommendations, anonymised B2B cohort analytics, affiliate revenue attribution
Device and Technical DataDevice type, OS version, app version, crash logs, session durationApp stability, fraud prevention, and performance improvement
Subscription StatusActive or inactive Pro subscription status and tier only. No card numbers or payment details.Pro entitlement verification. Payment processing handled entirely by Apple App Store or Google Play.

Data we do NOT collect:

  • Precise GPS coordinates in Skin Agent's server or profile. If you choose Use Current Location, the App uses your coordinate transiently on your device to derive a city, then sends and stores only the city, country, and preference source.
  • Raw face images or facial landmark coordinates. All face processing is on-device only.
  • Credit card or bank account numbers. These are handled entirely by Apple and Google.
  • Medical diagnoses or clinical health records.

3. Legal Basis for Processing

Processing ActivityLegal BasisNotes
Account creation and authenticationContract performanceNecessary to provide the service
SPEC profile and recommendationsContract performanceCore product functionality
Derived face scan resultsExplicit consentSeparate consent screen before first scan. Withdrawable at any time.
Heritage Response (HR) dataExplicit consentVoluntary. May be skipped entirely.
LLM AI chatbot processingExplicit consentOff by default. The same disclosure names every recipient and data category before you agree — shown during setup and again any time in Settings > Data & Privacy; consent is checked server-side before each request and is withdrawable in Settings > Data & Privacy at any time. See Section 5.5.
Anonymised B2B cohort analyticsLegitimate interestAggregated data only. Minimum cohort of 50 users enforced. No individual is identifiable.
Push notificationsConsentRequested at account creation. Opt-out available in device settings at any time.

4. How We Use Your Data

4.1 To Provide the App

  • Generate and maintain your SPEC skin profile (OD, SR, PN, WT, CR, HR axes)
  • When separately disclosed and explicitly enabled, power the Derma AI chatbot with personalised, context-aware responses. This sharing is unavailable in the current release candidate.
  • Run the on-device SPEC face scan and produce skin zone analysis results
  • Build and analyse your AM/PM skincare routine
  • Match products to your SPEC profile via the Dupe Finder
  • Provide Travel Lens: real-time product scanning with SPEC-calibrated verdicts on J-beauty, K-beauty, and duty-free products

4.2 To Improve the Platform

  • Analyse aggregated, anonymised usage patterns to improve AI accuracy
  • Create anonymised B2B cohort reports for beauty brand clients. Minimum cohort of 50 users enforced.
  • Train and refine our proprietary SPEC classification models using anonymised skin outcome data

4.3 Affiliate Commerce

  • When you tap an outbound product link in the App, we record the click event for commission tracking only
  • No personal identifying information is transmitted to affiliate retailers

Skin Agent is not a medical service provider and does not give medical advice. SPEC scores, skin zone analysis, and AI guidance are informational only and are not a diagnosis or a substitute for consultation with a licensed dermatologist or physician.

5. Face Scan Technology and Sensitive Data

5.1 How the Face Scan Works

The SPEC face scan is built on a fully on-device processing pipeline. No raw face data of any kind is ever transmitted to our servers or to any third party.

Step 1: Face Detection and Mesh Generation via MediaPipe Face Mesh. The App uses MediaPipe Face Mesh to detect the face and generate a 3D mesh of 468 facial landmark coordinates entirely on your device. The landmark coordinates and the camera image never leave your device.

Step 2: Skin Region Extraction. From the MediaPipe mesh, the App identifies skin zones corresponding to the six SPEC axes. These zones are cropped from the camera frame in memory on your device.

Step 3: On-Device Skin Classification via EfficientNet and ONNX Runtime. The cropped skin zone images are passed to a lightweight EfficientNet model, which runs on-device via ONNX Runtime without any server calls.

Step 4: SPEC Score Transmission. Only the final SPEC axis scores (six numerical values) leave your device. These are transmitted over TLS 1.2 or higher encryption.

What stays on your device:

  • Camera frames and face images
  • MediaPipe Face Mesh landmark coordinates
  • Cropped skin zone image regions
  • EfficientNet intermediate outputs

What leaves your device:

  • Final SPEC axis scores only (six numerical values)
  • Scan timestamp and app version number

5.5 Non-Face Third-Party AI and Analytics Sharing

Several App features — the Derma AI chatbot, profile and routine analysis, and ingredient or product identification — send data to third-party providers so they can generate a response. This sharing is off by default. Before it is ever turned on for your account, this disclosure — shown during setup when you are first asked, and available again at any time in Settings > Data & Privacy — shows you every recipient below, what each one receives, and why, and asks for your explicit consent. That consent is checked on our servers immediately before every request to a third-party AI provider, so no request can go out without a current, valid consent record, and you can withdraw consent at any time in Settings > Data & Privacy, which stops all future sharing.

Depending on which feature you use, the data sent may include the text you type or say, your chat history, your SPEC skin profile and skin quiz notes, your product and routine data, product or ingredient photos you submit, your city-level location and local weather context, an account or session identifier, and AI-generated output from earlier steps. The four recipients are:

Google Asia Pacific Pte. Ltd. (Singapore) is the Google entity that contracts for our Gemini API paid usage; that contract and billing account, billed from Vietnam, is held by CYBERK CO., LTD, the development partner that runs this infrastructure on our behalf. Google may store what you send for a limited time to check for abuse of its policies; Google does not publish an exact number of days for this, and we have not turned on Google's optional extra data-logging feature. Because our development partner uses Google's paid tier on our behalf, Google does not use what you send it to train or improve its AI models. Google commits to encrypting your data both in transit and in storage and maintains an independent ISO 27001 security certification for the systems that process it. Google may store or process this data in any country where it or its service providers operate; there is no fixed region.

Cloudflare, Inc. (San Francisco, USA), with the account held by CYBERK CO., LTD, our development partner, receives short text extracted from your request — such as your message or a product or skin-condition label — which it converts into a numeric search embedding used to look up relevant items in our internal knowledge base. Cloudflare processes this data at an unspecified data center; it does not publish which one, and there is no regional guarantee, though our requests to it originate from Singapore. Cloudflare does not keep what you send it after it answers, unless our app specifically asks it to save that data, which it doesn't for this feature. Cloudflare does not use what you send it to train its AI models or to improve its other products, and won't start doing so without asking your permission first. Cloudflare holds independent security certifications (including ISO 27001 and SOC 2 Type II) and commits to measures like encryption to protect your data, while noting no security system can be guaranteed error-free.

A self-hosted Langfuse observability instance, operated for us by CYBERK CO., LTD, our development partner, on a server located in Vietnam — not an unrelated third party we send your data to. It records the inputs and outputs of the AI calls above, for our own debugging and quality checks, and does not train any AI model. This tool has no automatic deletion feature turned on: what you send stays stored until we manually remove it, and it is not automatically deleted when you delete your account. Data sent to it is encrypted in transit, and access to the server is limited to staff at CYBERK CO., LTD; we have not yet separately verified disk encryption, backups, or access logging for this server.

A self-hosted PostHog analytics instance, operated for us by CYBERK CO., LTD, our development partner, on a server located in Vietnam — not an unrelated third party we send your data to. It records product-usage events, such as which screens you use, when your subscription changes, and an account or session identifier, tied to your account, for our own product analytics, and does not train any AI model. We have not yet confirmed how long this tool keeps your data, so it should be assumed to be kept indefinitely until we check. Data sent to it is encrypted in transit, and access to the server is limited to staff at CYBERK CO., LTD; we have not yet separately verified disk encryption, backups, or access logging for this server.

6. Account Deletion

You may initiate deletion of your account and all associated personal data directly within the App. No external steps or emails are required.

To delete your account:

  • Open the App and go to Settings > Data and Privacy > Delete My Account
  • Confirm deletion. Your account is deactivated immediately.
  • All personal data is permanently deleted within 30 days.
  • Backup copies are purged within 90 days, subject to technical backup rotation cycles.

You may also request deletion by emailing hello@skinagent.net with the subject line "Account Deletion Request".

7. Data Sharing and Third Parties

We do not sell your personal data to any third party. We do not use your data for advertising.

We share data only with service providers necessary for app functionality: Apple App Store/Google Play for subscription processing, RevenueCat for in-app purchase management, cloud infrastructure providers (AWS or GCP), and weather API providers for CR axis recalculation.

AI and analytics processors: Only when you have given explicit consent as described in Section 5.5, we share data with Google Asia Pacific Pte. Ltd. (Singapore) for AI processing, Cloudflare, Inc. (San Francisco, USA) for search embeddings, and a self-hosted Langfuse observability instance and a self-hosted PostHog analytics instance, both operated for us by CYBERK CO., LTD, our development partner, on servers in Vietnam. Section 5.5 identifies exactly what each of these recipients receives, where it is processed or stored, how long it is kept, and whether it is used to train AI models.

B2B data sharing: Beauty brand clients receive anonymised, aggregated cohort reports only. These reports contain no names, email addresses, device identifiers, or any other data capable of identifying an individual user. A minimum cohort threshold of 50 users is enforced.

Equal protection confirmation:We require every third party named in this Section and in Section 5.5 to protect your personal data with encryption in transit and controls that limit access to authorised personnel, consistent with this Policy. Google and Cloudflare additionally hold independent security certifications (ISO 27001 for both, plus SOC 2 Type II for Cloudflare) and contractually do not train their AI models on what you send them. Our self-hosted Langfuse and PostHog instances are operated under our own infrastructure and access controls, but as disclosed in Section 5.5 we have not yet independently verified disk encryption, backups, or access logging for those servers, and Langfuse's retention does not currently match the account-deletion timelines described in Section 8 — it is not automatically purged when you delete your account.

8. Data Retention

We retain your personal data for as long as your account is active. When you delete your account:

  • Account data (name, email): deleted within 30 days
  • SPEC profile and skin quiz responses: deleted within 30 days
  • Derived face scan results and skin health scores: deleted within 30 days
  • Chat history: deleted within 30 days
  • Anonymised, aggregated B2B cohort data: not deleted, as it contains no personal data
  • Backup copies: purged within 90 days of account deletion

9. Data Security

  • On-device face processing: The full face scan pipeline runs entirely on your device. No raw face data is ever transmitted.
  • Encryption in transit: TLS 1.2 or higher for all data transmitted between the App and our servers
  • Encryption at rest: AES-256 encryption for all stored personal data
  • Access controls: Role-based access control. Only authorised personnel may access personal data.
  • K-anonymity: Minimum cohort of 50 users enforced before any dataset is used in B2B reports
  • No advertising SDKs embedded in the App

10. International Data Transfers

The Skin Agent is headquartered in Singapore. Your data may be processed in Singapore and in other countries where our cloud infrastructure providers operate, primarily in Asia Pacific regions.

Where we transfer personal data outside your country of residence, we ensure appropriate safeguards are in place including standard contractual clauses and data processing agreements with all sub-processors.

11. Your Rights

You have rights over your personal data under applicable law, including: access, correction, deletion, withdrawal of consent, and data portability where required by law.

How to Exercise Your Rights:

  • Use in-app controls in Settings > Data and Privacy for common requests: download your data, delete face scan results, clear chat history, delete account
  • Email hello@skinagent.net. We will respond within 30 days.

12. Cookies and Tracking

The App does not use advertising tracking identifiers (IDFA on iOS, GAID on Android). We do not track users for advertising purposes. No third-party advertising SDKs are embedded in the App.

13. Children's Privacy

Skin Agent is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13 years of age.

Users between the ages of 13 and 17 should use the App with the involvement and permission of a parent or guardian.

If you believe we have inadvertently collected data from a child under 13, please contact us immediately athello@skinagent.net.

14. Apple App Store Privacy Details

Our App Store privacy nutrition labels accurately reflect the data practices described in this policy. Health and Fitness data, Sensitive Info (derived face scan results, Heritage Response data), User Content (chat messages), and Usage Data are linked to your identity for App Functionality purposes.

15. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, technology, or applicable law. When we make material changes, we will update the Effective Date and notify you via in-app notification. For changes involving sensitive data processing or new third-party AI providers, we will request fresh explicit consent.

16. Contact Us

For any questions, to exercise your rights, or to make a complaint:

Email: hello@skinagent.net

Address: 2 VENTURE DRIVE #19-21 VISION EXCHANGE SINGAPORE 608526

Response time: Within 30 calendar days of receipt

If you are not satisfied with our response, you may lodge a complaint with your local data protection authority (PDPC in Singapore, PPC in Japan, PIPC in South Korea, or the relevant authority in your market).

The Skin Agent Pte. Ltd. | Singapore | Version 2.4 | 10 September 2026