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.
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.
The table below summarises all categories of personal data we collect. Rows marked Sensitive require your explicit consent before we process them.
| Category | What We Collect | Why We Collect It |
|---|---|---|
| Identity and Account | Name, email address, password (hashed and salted) | Account creation and authentication |
| User and Session Identifiers | An internal identifier tied to your account or app session | Associating AI requests and analytics events with your account or session so responses and features work correctly |
| Skin Profile Data | SPEC profile (OD, SR, PN, WT axes), skin quiz responses, skin type, concerns, product sensitivities | Personalised 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 calibration | HR axis calibration only. Entirely voluntary. Skipping this has no impact on other features. |
| Coarse Location | A 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 Data | Free-form chat messages and the context categories shown in Settings > Data & Privacy, only when you have given explicit consent to AI sharing | Personalised 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 Photos | Photographs of skincare or cosmetic products and ingredient labels that you submit, whether captured with the camera or chosen from your photo library | Reading the brand, product name, and ingredient list from the photo you submit, so we can identify the product and provide analysis |
| Usage and Product Data | Products scanned, ingredients checked, dupes searched, routines built, saved product shelf, scan history | Product recommendations, anonymised B2B cohort analytics, affiliate revenue attribution |
| Device and Technical Data | Device type, OS version, app version, crash logs, session duration | App stability, fraud prevention, and performance improvement |
| Subscription Status | Active 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:
| Processing Activity | Legal Basis | Notes |
|---|---|---|
| Account creation and authentication | Contract performance | Necessary to provide the service |
| SPEC profile and recommendations | Contract performance | Core product functionality |
| Derived face scan results | Explicit consent | Separate consent screen before first scan. Withdrawable at any time. |
| Heritage Response (HR) data | Explicit consent | Voluntary. May be skipped entirely. |
| LLM AI chatbot processing | Explicit consent | Off 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 analytics | Legitimate interest | Aggregated data only. Minimum cohort of 50 users enforced. No individual is identifiable. |
| Push notifications | Consent | Requested at account creation. Opt-out available in device settings at any time. |
4.1 To Provide the App
4.2 To Improve the Platform
4.3 Affiliate Commerce
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.
5.1 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:
What leaves your device:
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.
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:
You may also request deletion by emailing hello@skinagent.net with the subject line "Account Deletion Request".
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.
We retain your personal data for as long as your account is active. When you delete your account:
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.
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:
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.
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.
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.
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.
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