Smart SKN LLC, doing business as SmartSKN · 100 Cummings Center, Suite 116-E, Beverly, Massachusetts 01915 · privacy@smartskn.com
1. Introduction
Smart SKN LLC, doing business as SmartSKN ("SmartSKN," "we," "us," or "our"), respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit smartskn.com or another website that links to this Policy; use our AI-powered cosmetic skin-analysis tools or personalized-skincare services; make a purchase or subscription; interact with a SmartSKN professional provider; or otherwise use our products and services (the "Services").
SmartSKN provides cosmetic skincare products and technology. Our Services are not intended to diagnose, treat, cure, or prevent disease and are not a substitute for professional medical advice.
This Policy applies to customers and visitors in the United States. SmartSKN currently sells and ships products only within the United States.
2. Notice at Collection
Depending on how you interact with us, we may collect the following categories of personal information:
- Identifiers and contact information, such as your name, email address, telephone number, postal address, account username, and similar identifiers.
- Account and authentication information, such as login credentials, account preferences, and provider-account status.
- Commercial information, such as products viewed or purchased, subscription selections, transaction history, returns, reformulation requests, and provider-attribution information.
- Payment-related information. Payments are processed by Stripe. SmartSKN does not store complete payment-card numbers.
- Professional information, such as professional title, license type, business name, business address, website or professional social profile, and information submitted in a SmartSKN provider application.
- Internet and device information, such as IP address, browser, device type, operating system, cookie identifiers, pages viewed, links clicked, referring pages, and interactions with our Services.
- Communications, such as customer-support messages, survey responses, reviews, webinar registrations, and other correspondence.
- Inferences and preferences, such as product interests, likely skincare preferences, and advertising or engagement audiences created from online activity.
- Sensitive and consumer-health-related information, including age or date of birth, gender where provided, skin images, skin measurements, cosmetic skin-analysis scores, skin concerns, and personalized-formulation information.
- Biometric-related information. Our technology may analyze visible facial or skin characteristics to provide cosmetic assessments. SmartSKN does not use this information to identify you or authenticate your identity and does not intentionally create facial-recognition templates for identification.
When you submit a provider application, we collect the contact and business details you provide along with technical information such as your IP address, which we use to review applications and prevent fraud.
We collect this information to provide the Services, create cosmetic skin analyses and personalized formulations, fulfill orders, administer subscriptions and accounts, provide customer support, operate the provider program, prevent fraud, improve our Services, comply with law, and conduct analytics and advertising as described below.
3. Sources of Personal Information
- Directly from you when you create an account, complete a form, purchase a product, participate in a scan, or contact us.
- From SmartSKN professional providers when they perform a guest scan or assist you with an order.
- Automatically from your browser, device, app, and interactions with the Services.
- From advertising, analytics, payment, security, fulfillment, and technology providers.
- From public or professional sources when we evaluate a SmartSKN provider application or conduct business-to-business outreach.
4. How We Use Personal Information
- Provide AI-supported cosmetic skin analysis and generate personalized skincare formulations.
- Operate accounts, scan-result pages, guest-scan links, and SmartSKN provider workflows.
- Process transactions through Stripe, fulfill orders, and administer subscriptions.
- Deliver customer service, respond to inquiries, and review reformulation requests.
- Verify or review professional-provider applications and manage the provider relationship.
- Send transactional communications about accounts, orders, subscriptions, safety, warranties, and policy changes.
- Send marketing communications where permitted and honor communication preferences.
- Measure website and advertising performance, create advertising audiences, and provide more relevant advertising, subject to your privacy choices.
- Operate, secure, troubleshoot, analyze, and improve our websites, apps, devices, formulas, and other Services.
- Detect fraud, misuse, security events, and violations of our Terms.
- Comply with legal obligations, establish or defend legal claims, and enforce our agreements.
- Create aggregated or de-identified information that is not reasonably capable of being associated with an individual.
5. AI Skin Analysis and Overseas Processing
SmartSKN uses contracted skin-analysis and formulation technology providers to process skin images, measurements, and related information for cosmetic analysis and personalized formulation. Because certain of these providers are located in South Korea, this information may be processed or stored outside your state and outside the United States.
SmartSKN directs service providers to process personal information for authorized purposes and subject to contractual restrictions. SmartSKN is working to document its providers' specific retention periods, backup practices, subprocessor arrangements, and model-improvement practices, and will update this Policy if those practices materially affect how your information is handled.
We do not authorize service providers to use identifiable skin-analysis information for unrelated advertising. Any use for independent AI-model training or unrelated product development must be separately authorized by SmartSKN and disclosed or consented to where required.
6. SmartSKN Professional Providers and Guest Scans
A SmartSKN professional provider may collect or enter information to perform a scan, review results, recommend a cosmetic formula, or help place an order. The provider may access information associated with the scan and related client activity as needed to provide the requested service and manage the professional relationship.
Professional providers are independent businesses and may have their own privacy practices for information they collect separately. SmartSKN is responsible for information processed through SmartSKN-controlled systems, while the provider is responsible for information collected or maintained independently in the provider's own systems.
Guest scan results may be available through a unique private-access link. Anyone who possesses that link may be able to view the associated results. Keep the link confidential and do not forward it to unauthorized persons. SmartSKN takes steps to prevent public search-engine indexing of private scan-result pages.
7. Cookies, Analytics, and Targeted Advertising
We and our partners use cookies, pixels, tags, local storage, software development kits, and similar technologies. These help operate the Services, remember preferences, protect accounts, understand usage, measure advertising performance, and deliver more relevant advertising.
- Essential technologies needed for login, cart, checkout, security, fraud prevention, and core functionality.
- Analytics technologies, such as Google Analytics and Google Tag Manager.
- Advertising technologies, such as the Meta Pixel and TikTok Pixel.
- Security and form-protection technologies, such as Google reCAPTCHA.
Advertising partners may receive identifiers, device information, and internet or network activity and may use that information to measure campaigns or provide targeted advertising. Under certain U.S. state privacy laws, these disclosures may be considered a "sale," "sharing," or processing for targeted advertising even though SmartSKN does not exchange personal information for money.
You may use our cookie banner or Cookie Preferences tool to accept, reject, or manage nonessential technologies. Where legally required, we recognize supported browser-based opt-out preference signals, including Global Privacy Control. See our Cookie Policy for details.
SmartSKN does not intend to send skin images, scan scores, identifiable skin concerns, complete form entries, or payment information to advertising platforms. We use technical and organizational measures intended to prevent advertising trackers from operating on sensitive scan-result and account areas.
8. Marketing Communications
If you opt in or if otherwise permitted by law, we may send promotional emails. You may unsubscribe using the link in any marketing email. We may continue to send non-promotional messages concerning orders, subscriptions, accounts, safety, warranties, or our ongoing business relationship.
We will not send automated marketing text messages unless we obtain the consent required by applicable law. Consent to marketing is not a condition of purchase.
9. How We Disclose Personal Information
- Technology and AI service providers that support skin analysis, formulation, and platform operations.
- Cloud-hosting, database, cybersecurity, customer-support, and software providers.
- Stripe and other providers that support payment processing, fraud prevention, and transaction administration.
- Manufacturing, fulfillment, shipping, and logistics providers.
- SmartSKN professional providers when necessary to provide a scan, formulation, order, follow-up service, or provider-attribution function.
- Analytics, advertising, and social-media partners, subject to your privacy choices.
- Email, webinar, customer-relationship-management, and marketing-communications providers.
- Professional advisers, insurers, auditors, and legal counsel.
- Government authorities, courts, or other parties when required by law or reasonably necessary to protect rights, safety, and security.
- A buyer, investor, lender, or successor in connection with a merger, financing, acquisition, reorganization, bankruptcy, or sale of some or all of our business or assets.
We may also disclose aggregated or de-identified information that is not reasonably capable of being associated with an individual, and we contractually require recipients not to attempt to re-identify it where required by law.
10. Sale, Sharing, and Targeted Advertising
SmartSKN does not sell personal information for money. As described above, our use of advertising and analytics technologies may constitute selling, sharing, or targeted-advertising processing under certain state laws.
Depending on your state, you may opt out through the "Your Privacy Choices" link and through supported Global Privacy Control signals. We do not knowingly sell or share personal information of consumers under 16.
We do not use or disclose sensitive personal information to infer characteristics about you beyond what is reasonably necessary to provide the requested cosmetic analysis, personalized formulation, and related Services, except with consent or as otherwise permitted by law.
11. Consumer Health and Sensitive Data
Skin images, skin measurements, cosmetic analysis results, skin concerns, and formulation information may be treated as sensitive personal information or consumer health data under certain state laws, even though SmartSKN does not provide medical care and is generally not subject to HIPAA.
We collect and process this information to perform the cosmetic skin analysis you request; generate, adjust, and fulfill a personalized skincare formulation; display and preserve scan results for your use and authorized provider follow-up; and support customer service, safety, security, and legally permitted service improvement.
We collect it from you, your device, a SmartSKN provider, and our contracted scan technology. We disclose it only to providers and service providers that need it to perform the requested service, and as otherwise described in this Policy. We do not sell consumer health data, and we do not use skin-analysis information for targeted advertising. Where required, we obtain consent before collecting or sharing consumer health data and permit withdrawal of consent, subject to legal and operational limitations.
12. Data Retention
We retain personal information only as long as reasonably necessary for the purposes described in this Policy. Retention depends on the type of information:
- Account information for the life of the account and a reasonable period afterward.
- Order, payment, and tax records for the period required by financial and legal obligations.
- Scan images and results for as long as needed to provide scan history, personalized formulation, and follow-up, or until an eligible deletion request is completed.
- Provider applications and business records for the duration of the relationship and a reasonable recordkeeping period.
- Cookie and advertising information according to the durations described in our Cookie Policy.
Some information may remain temporarily in secure backups or be retained where required by law, necessary to protect security or rights, or exempt from deletion. SmartSKN is working with its technology providers to document and implement specific retention and deletion procedures for scan information held in provider-controlled systems.
13. Security
We use reasonable administrative, technical, and organizational safeguards designed to protect personal information, including access controls, encryption where appropriate, vendor-management measures, and security monitoring. No system is completely secure, and we cannot guarantee that unauthorized access, loss, or misuse will never occur.
If you believe your account or private scan link has been compromised, contact privacy@smartskn.com promptly.
14. Your Privacy Rights
Depending on your state of residence and subject to applicable exceptions, you may have the right to:
- Know or confirm whether we process your personal information.
- Access personal information we maintain about you.
- Correct inaccurate personal information.
- Delete personal information.
- Obtain a portable copy of certain personal information.
- Opt out of sale, sharing, targeted advertising, or certain profiling.
- Limit certain uses or disclosures of sensitive personal information.
- Withdraw consent to processing sensitive or consumer health data.
- Appeal our denial of a privacy request.
- Receive equal service and not be discriminated against for exercising a privacy right.
To submit a request, email privacy@smartskn.com with the subject line "Privacy Request." We may request information reasonably necessary to verify your identity and authority. If we deny a request, you may appeal by replying with "Appeal Request." You may use an authorized agent where permitted by law; we may require proof of authorization and may verify your identity directly.
For deletion requests involving our overseas technology providers, SmartSKN will direct the provider to delete eligible information and will communicate the outcome. Completion may be subject to lawful exceptions, backup cycles, and verified technical limitations.
15. Children's Privacy
The Services are intended for adults 18 and older. SmartSKN skin analysis is not performed on individuals under 18, and we do not knowingly collect personal information from anyone under 18. If you believe a minor has provided personal information, contact privacy@smartskn.com and we will delete it.
16. Third-Party Services and Links
The Services may link to websites, applications, or services controlled by third parties. Their privacy practices are governed by their own policies. A link does not mean SmartSKN controls or endorses those practices.
17. Changes to This Policy
We may update this Policy to reflect changes in our Services, vendors, practices, or legal requirements. We will post the revised Policy with a new "Last Updated" date. If a change materially affects how we use previously collected sensitive information, we will provide additional notice or obtain consent where required.
18. Contact Us
Smart SKN LLC, doing business as SmartSKN
100 Cummings Center, Suite 116-E, Beverly, Massachusetts 01915
privacy@smartskn.com · https://smartskn.com