Privacy Policy

Last updated: 26th July 2025

This Privacy Policy outlines how Marketplace Analytics Ltd ("we", "our", or "us") collects, uses, and protects your personal information when you use the Skin AI app or related services ("Service"). By using our Service, you agree to the terms of this Privacy Policy.

1. Definitions

Company refers to Marketplace Analytics Ltd, a company registered in England & Wales.
Country refers to England & Wales.
Device means any device used to access the Service.
Personal Data refers to information relating to an identified or identifiable individual.
Service means the SkinAI app and website.
Usage Data means data collected automatically when using the Service.
You means the user accessing or using the Service.

2. What We Collect

Personal Data
We may collect personal information including your:

  • Name and contact details

  • Selfie images for skin analysis during onboarding and for ongoing skincare tracking

  • Responses to onboarding questions (e.g. skin type, skincare goals)

Face Data for Skin Analysis
During the onboarding process, users are asked to take a selfie. This image is sent to OpenAI's GPT-4o Vision API for analysis of skin characteristics. The image is processed once and is not stored permanently. It is deleted immediately after processing.

Users can also take weekly progress photos within the app to monitor skincare progress. These images are stored securely and used solely to provide cosmetic skincare guidance. No facial recognition, biometric analysis, or identity detection is performed on any face photos.

Usage Data
This includes:

  • IP address

  • Device type and browser

  • App usage patterns and session duration

Tracking Technologies
We use cookies, web beacons, and similar tools to enhance your experience and analyze usage patterns.

3. How We Use Your Data

We use your personal data to:

  • Create and maintain your personalized skincare routine

  • Analyze skin characteristics using GPT-4o Vision API (onboarding selfie only)

  • Provide visual tracking of your skincare journey through weekly progress photos

  • Monitor app engagement and improve functionality

  • Send updates, support messages, and optional promotional content

  • Conduct internal analytics and improve our services

Data Shared with OpenAI
Only the onboarding selfie is sent to OpenAI’s GPT-4o Vision API. This is done to analyze skin characteristics and recommend initial skincare routines. The image is processed once and not retained by OpenAI or by us after processing.

We do not use any face photos for marketing, advertising, or any commercial use beyond core app functionality.

4. Retention of Data

  • The onboarding selfie is deleted immediately after it is processed by OpenAI.

  • Weekly progress photos are stored securely and retained only until account deletion or subscription cancellation.

  • All user data, including face photos and metadata, is permanently deleted upon account deletion.

  • Once deleted, no data is retained in backup systems.

  • Our systems include automated deletion processes to ensure complete and irreversible removal of all user data upon account termination.

  • Users can delete individual progress photos at any time via the app.

Data is stored in Supabase cloud storage, associated database metadata, and may exist temporarily in local device caches.

5. Your Rights

Under UK GDPR and the Data Protection Act 2018, you have the right to:

  • Access the personal data we hold about you

  • Request correction or deletion

  • Object to processing

  • Withdraw consent at any time

You can exercise your rights by contacting us at: hello@365labs.ai

6. Data Transfers

Your data may be stored or processed outside the UK. We ensure appropriate safeguards and contractual protections are in place in accordance with applicable laws.

7. Children’s Privacy

SkinAI is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we discover such data, we will delete it promptly.

8. Security

We implement appropriate technical and organizational measures to safeguard your data. However, no system is completely secure. You are advised to use strong passwords and protect your account credentials.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised "Last updated" date. Your continued use of the Service indicates acceptance of the changes.

10. Contact Us

If you have any questions about this Privacy Policy, please contact us at: hello@365labs.ai