Privacy Policy
Privacy Policy
TERMS AND CONDITIONS
Last updated: April 13, 2026
TABLE OF CONTENTS
Acceptance of Terms
Definitions
Description of Services
Accounts and Registration
Subscriptions, Payments, and Refunds
Acceptable Use
Health Disclaimer and No Medical Advice
Intellectual Property
User-Generated Content
Third-Party Services
Disclaimers and Limitation of Liability
Indemnification
Termination
Governing Law and Dispute Resolution
Changes to These Terms
Contact Us
1. ACCEPTANCE OF TERMS
By accessing or using the Betterskin website (betterskin.app) or application (collectively, the "Service"), you agree to be bound by these Terms and Conditions ("Terms"). If you do not agree to these Terms, do not use the Service.
These Terms apply alongside our Privacy Policy, which is incorporated by reference.
2. DEFINITIONS
Company / We / Us / Our: Betterskin LLC, registered in Latvia (Ernesta Birznieka-Upisa 29, Riga, LV-1003).
Service: The Betterskin website, mobile application, and all content, features, and services offered therein.
User / You: Any individual who accesses or uses the Service.
Content: Text, images, recommendations, reports, and other materials provided through the Service.
Subscription: A recurring or one-time paid plan granting access to specific Service features.
Skincare Recommendations: Personalized, non-medical suggestions regarding skincare products and routines generated through the Service.
3. DESCRIPTION OF SERVICES
Betterskin provides a personalized skincare companion platform that analyzes user-submitted information — including skin type, concerns, product history, and photos — to generate product recommendations and routine guidance. The Service is offered in three tiers:
Skincare Audit ($5.99, one-time): Analysis of submitted products with a PDF report.
Skincare Pro ($24.99/month): Ongoing routine check-ins, progress tracking, and unlimited product questions.
Skincare Concierge ($59.99/month): Full-service offering including integration with health data and bi-weekly personalized consultations with a Betterskin advisor.
Features and pricing are subject to change with notice as described in Section 15.
4. ACCOUNTS AND REGISTRATION
To access certain features, you must create an account. You agree to:
Provide accurate, complete, and current information.
Maintain the security of your password and accept responsibility for all activity under your account.
Notify us immediately at hi@betterskin.app if you suspect unauthorized account access.
Not share your account credentials with any third party.
We reserve the right to suspend or terminate accounts that violate these Terms.
5. SUBSCRIPTIONS, PAYMENTS, AND REFUNDS
Payment. All payments are processed securely through Stripe. By purchasing a subscription or one-time service, you authorize Betterskin to charge your selected payment method for the applicable fees.
Recurring Subscriptions. Skincare Pro and Skincare Concierge are billed monthly on a recurring basis. Your subscription will automatically renew each billing period unless cancelled before the renewal date.
Cancellation. You may cancel your subscription at any time through your account settings or by contacting hi@betterskin.app. Cancellation takes effect at the end of the current billing period; you will retain access until that date.
Refunds. Due to the digital nature of the Service and the immediate delivery of personalized content:
Skincare Audit (one-time): No refunds once the PDF report has been delivered.
Skincare Pro / Skincare Concierge: No refunds for the current billing period once a billing cycle has started. If you experience a technical failure that prevents service delivery, contact us within 7 days for review.
We reserve the right to offer discretionary refunds on a case-by-case basis.
Price Changes. We will provide at least 30 days' notice before increasing subscription prices. Continued use after the effective date constitutes acceptance.
6. ACCEPTABLE USE
You agree not to:
Use the Service for any unlawful purpose or in violation of applicable laws.
Submit false, misleading, or fraudulent information.
Attempt to gain unauthorized access to the Service, other accounts, or related systems.
Reverse engineer, decompile, or attempt to extract source code from the Service.
Use automated tools (bots, scrapers, crawlers) to access or collect data from the Service.
Reproduce, distribute, or commercially exploit any Service Content without prior written consent.
Upload or transmit viruses or any malicious code.
Harass, abuse, or harm any person through the Service.
We reserve the right to suspend or terminate access for violations of this section without notice.
7. HEALTH DISCLAIMER AND NO MEDICAL ADVICE
The Service does not provide medical advice. All content, recommendations, and consultations delivered through Betterskin — including those provided under the Skincare Concierge tier — are for informational and cosmetic guidance purposes only. They do not constitute medical advice, diagnosis, or treatment, and are not a substitute for consultation with a licensed dermatologist, physician, or other qualified healthcare professional.
Betterskin advisors are not licensed medical practitioners. The "personalized consultations" offered under the Skincare Concierge plan are skincare coaching sessions, not clinical assessments.
If you have a skin condition, allergy, or health concern that may require medical attention, consult a qualified healthcare provider before making changes to your skincare routine based on Service recommendations.
By using the Service, you acknowledge that you are solely responsible for decisions made based on Betterskin's recommendations and that individual results may vary.
8. INTELLECTUAL PROPERTY
All content, software, trademarks, logos, and materials made available through the Service are the property of Betterskin LLC or its licensors and are protected by applicable intellectual property laws.
You are granted a limited, non-exclusive, non-transferable, revocable license to access and use the Service for personal, non-commercial purposes in accordance with these Terms.
You may not copy, modify, distribute, sell, or create derivative works from any part of the Service without our express written permission.
9. USER-GENERATED CONTENT
When you submit content to the Service — including photos, product lists, questionnaire responses, and other information — you grant Betterskin a non-exclusive, worldwide, royalty-free license to use, store, and process that content solely for the purpose of providing and improving the Service.
You represent that you have the right to submit such content and that it does not violate the rights of any third party.
We do not sell or share your personal or health-related content with third parties for their own commercial purposes. See our Privacy Policy for full details.
10. THIRD-PARTY SERVICES
The Service integrates with or links to third-party services including Stripe (payments), Apple App Store, Google Play Store, Mailchimp (email), Supabase (data infrastructure), and Google Analytics. Your use of those services is governed by their respective terms and privacy policies. We are not responsible for the practices of third-party services.
11. DISCLAIMERS AND LIMITATION OF LIABILITY
Disclaimer of Warranties. The Service is provided "as is" and "as available" without warranties of any kind, express or implied, including warranties of merchantability, fitness for a particular purpose, or non-infringement. We do not warrant that the Service will be uninterrupted, error-free, or that results will be accurate or suitable for your individual needs.
Limitation of Liability. To the fullest extent permitted by applicable law, Betterskin LLC, its officers, directors, employees, and affiliates shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising from your use of or inability to use the Service, including but not limited to: adverse skin reactions resulting from following Service recommendations; loss of data; business interruption; or loss of profits.
Our total liability to you for any claim arising out of or relating to these Terms or the Service shall not exceed the amount you paid to us in the twelve (12) months preceding the claim, or €100, whichever is greater.
Note for EU/EEA Users: Nothing in these Terms limits or excludes liability that cannot be excluded under applicable EU consumer protection law, including liability for death or personal injury caused by negligence, fraud, or any other matter where exclusion is prohibited by law.
12. INDEMNIFICATION
You agree to indemnify and hold harmless Betterskin LLC and its affiliates, officers, and employees from any claims, damages, losses, or expenses (including reasonable legal fees) arising from: your use of the Service; your violation of these Terms; or your infringement of any third-party rights.
13. TERMINATION
We may suspend or terminate your access to the Service at any time, with or without cause and with or without notice, including for violation of these Terms. Upon termination, your right to use the Service ceases immediately.
You may delete your account at any time by contacting hi@betterskin.app. Termination does not affect any rights or obligations accrued prior to the termination date.
Sections 7, 8, 11, 12, and 14 survive termination.
14. GOVERNING LAW AND DISPUTE RESOLUTION
These Terms are governed by and construed in accordance with the laws of the Republic of Latvia, without regard to its conflict of law provisions.
EU/EEA Users: Nothing in this section limits your rights as a consumer under applicable EU law, including the right to bring a claim before the courts of your country of residence.
Dispute Resolution. We encourage you to contact us first at hi@betterskin.app to resolve any dispute informally. If a dispute cannot be resolved informally, it shall be submitted to the courts of competent jurisdiction in Riga, Latvia, subject to applicable consumer law rights.
EU residents may also use the European Commission's Online Dispute Resolution platform: https://ec.europa.eu/consumers/odr/
15. CHANGES TO THESE TERMS
We may update these Terms from time to time. We will notify you of material changes by email or by posting a notice in the Service at least 30 days before changes take effect. Continued use of the Service after the effective date constitutes acceptance of the updated Terms.
16. CONTACT US
For questions about these Terms, contact:
- Email: hi@betterskin.app
- Mailing Address: Betterskin LLC, Ernesta Birznieka-Upisa 29, Riga, LV-1003, Latvia
PRIVACY POLICY
Last updated: January 18, 2026
This Privacy Policy describes Our policies and procedures regarding the collection, use, and disclosure of Your information when You use the Service, and explains Your privacy rights under applicable laws, including GDPR, CCPA/CPRA, and CalOPPA. By using Our Service, You consent to the practices described in this Privacy Policy.
We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
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TABLE OF CONTENTS
Interpretation and Definitions
Information We Collect
Legal Basis for Processing Your Data (GDPR) [NEW]
How We Use Your Information
Processing of Special Category/Health Data [NEW]
Sharing Your Information
International Data Transfers [ENHANCED]
Legal Rights and Compliance
Data Protection Officer (DPO) [NEW]
Data Retention
Your Privacy Choices
Security
Children's Privacy
Links to Other Websites
Changes to this Privacy Policy
Contact Us
Cookie Policy Details [NEW]
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INTERPRETATION AND DEFINITIONS
Interpretation
Words with capitalized initial letters have specific meanings defined below. Singular and plural forms share the same meaning.
Definitions
• Account: A unique account created to access our Service.
• Affiliate: An entity that controls, is controlled by, or is under common control with a party.
• Application / Service: Refers to Betterskin, including its website (https://betterskin.app/) and app.
• Company / We / Us / Our: Betterskin.
• Cookies: Small files placed on Your device to store browsing data.
• Personal Data / Personal Information: Any information that identifies or can identify You.
• Special Category Data / Health Data [NEW]: Information about Your health, including skin conditions, treatments, symptoms, or other health-related information processed through the Service.
• Service Provider: Third-party companies or individuals who process data on Our behalf.
• Usage Data: Data collected automatically from Your use of the Service.
• You: The individual or entity accessing or using the Service.
• Data Controller [NEW]: Betterskin, responsible for determining how and why Your Personal Data is processed.
• Data Processor [NEW]: Third parties who process Personal Data on Our behalf under Our instructions.
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INFORMATION WE COLLECT
Personal Data You Provide:
• Name, email address, billing address, and account information
• Pictures and other information from Your device if you allow camera/photo library access
• [NEW] Health and Skin-Related Information: Information about Your skin type, conditions, concerns, symptoms, skincare routines, product usage, treatment history, and photos of Your skin. This constitutes Special Category Data under GDPR Article 9.
Automatic Data Collection (Usage Data):
• Device type, IP address, browser type/version, pages visited, time/date of visit, unique identifiers
• Mobile device information (OS, unique IDs, mobile browser type)
Cookies and Tracking Technologies:
We use cookies, web beacons, and similar technologies for analytics, personalization, and essential functions. Types include:
• Necessary / Essential Cookies – for authentication and core functions
• Functionality Cookies – to remember preferences
• Analytics / Performance Cookies – to track usage trends and improve Service
You may manage or disable cookies through Your device or browser settings. [NEW] When You first visit Our Service, You will be presented with a cookie consent banner allowing You to accept or reject non-essential cookies. You can change Your preferences at any time through Our cookie settings.
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LEGAL BASIS FOR PROCESSING YOUR DATA (GDPR) [NEW]
We process Your Personal Data under the following legal bases:
a) Contract Performance (GDPR Article 6(1)(b))
To provide the Service You have requested, including:
• Creating and managing Your account
• Processing transactions and subscriptions
• Providing customer support
b) Consent (GDPR Article 6(1)(a) and Article 9(2)(a))
When You have given explicit consent for:
• Processing Special Category/Health Data (skin conditions, photos, health information)
• Marketing communications and newsletters
• Non-essential cookies and analytics
• Camera and photo library access
You may withdraw consent at any time by contacting hi.betterskin@gmail.com or using opt-out mechanisms.
c) Legitimate Interests (GDPR Article 6(1)(f))
For purposes such as:
• Improving and personalizing the Service
• Fraud prevention and security
• Analytics and research (using anonymized data where possible)
• Internal business operations
Our legitimate interests are balanced against Your rights and freedoms.
d) Legal Obligation (GDPR Article 6(1)(c))
To comply with legal and regulatory requirements, including tax and financial reporting.
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HOW WE USE YOUR INFORMATION
We use Personal Data for purposes including:
• Providing and maintaining the Service
• Managing Your account and purchases
• Processing transactions through Apple Store, Google Play Store, Stripe, or bank transfer
• Sending emails and newsletters via Mailchimp or our email hi.betterskin@gmail.com
• Communicating updates, offers, or marketing (You may opt out at any time)
• Analyzing usage trends and improving Service performance
• [NEW] Providing personalized skincare recommendations based on Your skin type and concerns (with Your consent)
• Legal compliance and fraud prevention
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PROCESSING OF SPECIAL CATEGORY/HEALTH DATA [NEW]
⚠️ IMPORTANT: Our Service collects and processes health-related information about your skin. This section explains how we handle this sensitive data and your enhanced rights.
What Health Data We Collect:
Our Service may collect and process health-related information, including:
• Skin conditions, sensitivities, and allergies
• Photos of Your skin
• Skincare treatment history and product reactions
• Symptoms and concerns related to skin health
Legal Basis for Health Data Processing:
We process health data only with Your EXPLICIT CONSENT under GDPR Article 9(2)(a). You provide this consent when You:
• Create an account and provide skin-related information
• Upload photos of Your skin
• Complete health questionnaires within the app
How We Use Health Data:
• To provide personalized skincare analysis and recommendations
• To track Your skin progress over time
• To improve Our Service and algorithms
• For anonymized research and product development
Your Rights Regarding Health Data:
You have enhanced rights regarding Your health data, including:
• Withdrawing consent at any time (without affecting prior lawful processing)
• Requesting deletion of all health-related information
• Obtaining a copy in a portable format
• Restricting how We use Your health data
Safeguards for Health Data:
• Encrypted storage and transmission
• Access restricted to authorized personnel only
• Regular security audits
• Anonymization for research purposes where possible
• NO SALE of health data to third parties
To withdraw consent or exercise Your rights regarding health data, contact hi.betterskin@gmail.com.
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SHARING YOUR INFORMATION
We will only share Your Personal Data:
a) With Service Providers (Data Processors)
[NEW] We share Personal Data with the following categories of third-party processors who process data on Our behalf under written agreements:
• Payment Processors: Stripe, Apple App Store, Google Play Store (for payment processing)
• Email Service Providers: Mailchimp (for newsletters and marketing emails)
• Cloud Hosting: [Specify your hosting provider, e.g., AWS, Google Cloud] (for data storage and infrastructure)
• Analytics Services: [Specify, e.g., Google Analytics, Mixpanel] (for usage analytics)
• Customer Support Tools: [Specify if applicable] (for managing support requests)
[NEW] All processors are contractually required to:
• Process data only on Our instructions
• Implement appropriate security measures
• Maintain confidentiality
• Assist with Your data protection rights
• Delete or return data when services end
b) With Affiliates
For Service delivery and business operations, subject to the same privacy standards.
c) During Business Transactions
During mergers, acquisitions, or sales of assets. [NEW] You will be notified of any change in data controller and Your rights under such circumstances.
d) Legal Requirements
With law enforcement or regulators if legally required. [NEW] We will notify You of such requests unless legally prohibited.
e) With Your Consent
For any other purposes with Your explicit permission.
⚠️ OUR COMMITMENT: We do NOT sell Your Personal Data to third parties. We do NOT sell or share Your health data with third parties for their marketing purposes.
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INTERNATIONAL DATA TRANSFERS [ENHANCED]
Your Personal Data may be processed in countries outside the European Economic Area (EEA) where data protection laws may differ.
Transfer Safeguards:
When We transfer Personal Data outside the EEA, We ensure appropriate safeguards, including:
• Standard Contractual Clauses (SCCs): Approved by the European Commission for transfers to countries without adequacy decisions
• Adequacy Decisions: Transfers to countries recognized by the EU Commission as providing adequate protection
• Your Explicit Consent: Where required by law
• Processor Binding Corporate Rules: Where applicable
Current Transfer Destinations:
[NEW] Your data may be transferred to:
• United States (processors using SCCs or certified under EU-US Data Privacy Framework)
• [List other specific countries/regions where your service providers are located]
For more information about transfer mechanisms, contact hi.betterskin@gmail.com.
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LEGAL RIGHTS AND COMPLIANCE
GDPR (EU/EEA Users)
You have the following rights under the General Data Protection Regulation (GDPR):
→ Right of Access (Article 15)
Request a copy of the Personal Data We hold about You.
→ Right to Rectification (Article 16)
Correct inaccurate or incomplete Personal Data.
→ Right to Erasure / "Right to be Forgotten" (Article 17)
Request deletion of Your Personal Data in certain circumstances.
→ Right to Restriction of Processing (Article 18)
Limit how We use Your data while a dispute is resolved.
→ Right to Data Portability (Article 20)
Receive Your data in a structured, machine-readable format and transfer it to another controller.
→ Right to Object (Article 21)
Object to processing based on legitimate interests or for direct marketing.
→ Right to Withdraw Consent (Article 7(3))
Withdraw consent at any time (without affecting prior lawful processing).
→ Right Not to Be Subject to Automated Decision-Making (Article 22) [NEW]
Our Service may use automated processing to provide skincare recommendations. You have the right to:
• Be informed of such processing
• Request human intervention
• Express Your view and contest decisions
• Opt-out of automated decision-making
How to Exercise Your Rights:
To exercise any of these rights, contact us at hi.betterskin@gmail.com. We will respond within ONE MONTH (extendable by two additional months for complex requests).
→ Right to Lodge a Complaint [NEW]
If You believe We have not handled Your Personal Data appropriately, You have the right to lodge a complaint with Your local supervisory authority:
• EU/EEA Residents: Contact Your national Data Protection Authority. Find your authority at: https://edpb.europa.eu/about-edpb/board/members_en
• For example, if You are in Ireland: Data Protection Commission (www.dataprotection.ie)
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CCPA / CPRA (California Users)
If You are a California resident, You have the right to:
• Know what Personal Data is collected, used, shared, or sold
• Request deletion of Your Personal Data
• Opt-out of the sale of Personal Data
• Non-discrimination for exercising these rights
To submit a request, contact us at hi.betterskin@gmail.com.
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CalOPPA (California Online Privacy Protection Act)
Under CalOPPA, we:
• Post a privacy policy on the website
• Inform users of updates and effective dates
• Allow users to request changes to Personal Information
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DATA PROTECTION OFFICER (DPO) [NEW]
We have appointed a Data Protection Officer to oversee GDPR compliance and handle data protection matters.
Contact Our DPO:
• Email: dpo@betterskin.app
• Or via: hi.betterskin@gmail.com (marked "Attention: DPO")
You may contact Our DPO regarding:
• Questions about data processing
• Exercising Your GDPR rights
• Data protection concerns or complaints
• Data breach notifications
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DATA RETENTION
We retain Personal Data only as long as necessary for the purposes outlined, legal obligations, dispute resolution, or enforcement of agreements.
Typical Retention Periods:
• Account Information: Up to 24 months after account closure
• Customer Support Data: Up to 24 months
• Usage Data / Analytics: Up to 24 months
• [NEW] Health/Skin Data: Up to 24 months after account closure or until consent is withdrawn, whichever comes first
• [NEW] Marketing Data: Until You unsubscribe or withdraw consent
• [NEW] Financial Records: Up to 7 years for legal and tax compliance
Data may be anonymized or securely deleted after retention periods.
[NEW] You may request earlier deletion by contacting hi.betterskin@gmail.com. We will delete Your data within 30 days unless legally required to retain it.
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YOUR PRIVACY CHOICES
You may:
• Update or delete Your account information
• Opt out of marketing emails via unsubscribe links
• Manage cookie preferences [NEW] through Our cookie settings panel
• Request deletion of Personal Data by contacting hi.betterskin@gmail.com
• [NEW] Withdraw consent for health data processing at any time
• [NEW] Download Your data in a portable format
• [NEW] Object to automated decision-making
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SECURITY
We implement commercially reasonable technical and organizational measures to protect Your Personal Data. [NEW] These include:
• Encryption: Data encrypted in transit (TLS/SSL) and at rest
• Access Controls: Role-based access and authentication
• Regular Security Audits: Penetration testing and vulnerability assessments
• Employee Training: Data protection training for all personnel
• Incident Response: Procedures for detecting and responding to breaches
[NEW] In the event of a data breach that poses a risk to Your rights and freedoms, We will notify:
• You (within 72 hours where feasible)
• The relevant supervisory authority (within 72 hours as required by GDPR Article 33)
However, no method of internet or electronic storage is 100% secure.
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CHILDREN'S PRIVACY
Our Service is not directed to children under 16. We do not knowingly collect Personal Data from children under 16. [NEW] If We become aware that We have collected data from a child under 16 without parental consent, We will delete that information immediately. Parents may contact us to remove data collected from a child.
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LINKS TO OTHER WEBSITES
Our Service may contain links to third-party sites. We are not responsible for their content, privacy policies, or practices. [NEW] We recommend reviewing the privacy policies of any third-party sites You visit.
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CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy. Updates will be posted on this page, with the "Last Updated" date revised. [NEW] For significant changes that materially affect Your rights, We will:
• Notify You by email (to the address on Your account)
• [NEW] Require Your renewed consent where legally required (e.g., for new uses of health data)
• Provide at least 30 days' notice before changes take effect
[NEW] Your continued use of the Service after changes take effect constitutes acceptance of the updated policy, except where consent is separately required.
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CONTACT US
If you have questions about this Privacy Policy or Your rights, contact us:
• Email: hi.betterskin@gmail.com
• [NEW] Data Protection Officer: dpo@betterskin.app
• [NEW] Mailing Address: [Your company's registered address in the EU - required for GDPR]
[NEW] We will respond to Your inquiry within 30 days.
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COOKIE POLICY DETAILS [NEW]
Essential Cookies
Required for basic Service functionality (login, security, session management). These cannot be disabled.
Functionality Cookies
Remember Your preferences (language, region, theme). You may disable these, but functionality may be affected.
Analytics Cookies
Help Us understand how You use the Service (pages visited, features used, errors encountered). We use [specify tools, e.g., Google Analytics with IP anonymization].
Marketing Cookies
Used to deliver personalized marketing and measure campaign effectiveness. You may opt-out through Our cookie settings.
Managing Cookies:
• In-App Settings: Access cookie preferences in [Settings > Privacy > Cookie Preferences]
• Browser Settings: Configure cookie preferences in Your browser
• Third-Party Opt-Outs:
Google Analytics: https://tools.google.com/dlpage/gaoptout
[List other third-party opt-out mechanisms]
For more information, see Our full Cookie Policy at [link to cookie policy if separate].
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END OF PRIVACY POLICY
All changes from the original policy are marked with [NEW] or [ENHANCED]
For a detailed summary of all GDPR enhancements, please refer to the accompanying "GDPR Changes Summary" document.
PRIVACY POLICY
Last updated: January 18, 2026
This Privacy Policy describes Our policies and procedures regarding the collection, use, and disclosure of Your information when You use the Service, and explains Your privacy rights under applicable laws, including GDPR, CCPA/CPRA, and CalOPPA. By using Our Service, You consent to the practices described in this Privacy Policy.
We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
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TABLE OF CONTENTS
Interpretation and Definitions
Information We Collect
Legal Basis for Processing Your Data (GDPR) [NEW]
How We Use Your Information
Processing of Special Category/Health Data [NEW]
Sharing Your Information
International Data Transfers [ENHANCED]
Legal Rights and Compliance
Data Protection Officer (DPO) [NEW]
Data Retention
Your Privacy Choices
Security
Children's Privacy
Links to Other Websites
Changes to this Privacy Policy
Contact Us
Cookie Policy Details [NEW]
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INTERPRETATION AND DEFINITIONS
Interpretation
Words with capitalized initial letters have specific meanings defined below. Singular and plural forms share the same meaning.
Definitions
• Account: A unique account created to access our Service.
• Affiliate: An entity that controls, is controlled by, or is under common control with a party.
• Application / Service: Refers to Betterskin, including its website (https://betterskin.app/) and app.
• Company / We / Us / Our: Betterskin.
• Cookies: Small files placed on Your device to store browsing data.
• Personal Data / Personal Information: Any information that identifies or can identify You.
• Special Category Data / Health Data [NEW]: Information about Your health, including skin conditions, treatments, symptoms, or other health-related information processed through the Service.
• Service Provider: Third-party companies or individuals who process data on Our behalf.
• Usage Data: Data collected automatically from Your use of the Service.
• You: The individual or entity accessing or using the Service.
• Data Controller [NEW]: Betterskin, responsible for determining how and why Your Personal Data is processed.
• Data Processor [NEW]: Third parties who process Personal Data on Our behalf under Our instructions.
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INFORMATION WE COLLECT
Personal Data You Provide:
• Name, email address, billing address, and account information
• Pictures and other information from Your device if you allow camera/photo library access
• [NEW] Health and Skin-Related Information: Information about Your skin type, conditions, concerns, symptoms, skincare routines, product usage, treatment history, and photos of Your skin. This constitutes Special Category Data under GDPR Article 9.
Automatic Data Collection (Usage Data):
• Device type, IP address, browser type/version, pages visited, time/date of visit, unique identifiers
• Mobile device information (OS, unique IDs, mobile browser type)
Cookies and Tracking Technologies:
We use cookies, web beacons, and similar technologies for analytics, personalization, and essential functions. Types include:
• Necessary / Essential Cookies – for authentication and core functions
• Functionality Cookies – to remember preferences
• Analytics / Performance Cookies – to track usage trends and improve Service
You may manage or disable cookies through Your device or browser settings. [NEW] When You first visit Our Service, You will be presented with a cookie consent banner allowing You to accept or reject non-essential cookies. You can change Your preferences at any time through Our cookie settings.
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LEGAL BASIS FOR PROCESSING YOUR DATA (GDPR) [NEW]
We process Your Personal Data under the following legal bases:
a) Contract Performance (GDPR Article 6(1)(b))
To provide the Service You have requested, including:
• Creating and managing Your account
• Processing transactions and subscriptions
• Providing customer support
b) Consent (GDPR Article 6(1)(a) and Article 9(2)(a))
When You have given explicit consent for:
• Processing Special Category/Health Data (skin conditions, photos, health information)
• Marketing communications and newsletters
• Non-essential cookies and analytics
• Camera and photo library access
You may withdraw consent at any time by contacting hi.betterskin@gmail.com or using opt-out mechanisms.
c) Legitimate Interests (GDPR Article 6(1)(f))
For purposes such as:
• Improving and personalizing the Service
• Fraud prevention and security
• Analytics and research (using anonymized data where possible)
• Internal business operations
Our legitimate interests are balanced against Your rights and freedoms.
d) Legal Obligation (GDPR Article 6(1)(c))
To comply with legal and regulatory requirements, including tax and financial reporting.
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HOW WE USE YOUR INFORMATION
We use Personal Data for purposes including:
• Providing and maintaining the Service
• Managing Your account and purchases
• Processing transactions through Apple Store, Google Play Store, Stripe, or bank transfer
• Sending emails and newsletters via Mailchimp or our email hi.betterskin@gmail.com
• Communicating updates, offers, or marketing (You may opt out at any time)
• Analyzing usage trends and improving Service performance
• [NEW] Providing personalized skincare recommendations based on Your skin type and concerns (with Your consent)
• Legal compliance and fraud prevention
══════════════════════════════════════════
PROCESSING OF SPECIAL CATEGORY/HEALTH DATA [NEW]
⚠️ IMPORTANT: Our Service collects and processes health-related information about your skin. This section explains how we handle this sensitive data and your enhanced rights.
What Health Data We Collect:
Our Service may collect and process health-related information, including:
• Skin conditions, sensitivities, and allergies
• Photos of Your skin
• Skincare treatment history and product reactions
• Symptoms and concerns related to skin health
Legal Basis for Health Data Processing:
We process health data only with Your EXPLICIT CONSENT under GDPR Article 9(2)(a). You provide this consent when You:
• Create an account and provide skin-related information
• Upload photos of Your skin
• Complete health questionnaires within the app
How We Use Health Data:
• To provide personalized skincare analysis and recommendations
• To track Your skin progress over time
• To improve Our Service and algorithms
• For anonymized research and product development
Your Rights Regarding Health Data:
You have enhanced rights regarding Your health data, including:
• Withdrawing consent at any time (without affecting prior lawful processing)
• Requesting deletion of all health-related information
• Obtaining a copy in a portable format
• Restricting how We use Your health data
Safeguards for Health Data:
• Encrypted storage and transmission
• Access restricted to authorized personnel only
• Regular security audits
• Anonymization for research purposes where possible
• NO SALE of health data to third parties
To withdraw consent or exercise Your rights regarding health data, contact hi.betterskin@gmail.com.
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SHARING YOUR INFORMATION
We will only share Your Personal Data:
a) With Service Providers (Data Processors)
[NEW] We share Personal Data with the following categories of third-party processors who process data on Our behalf under written agreements:
• Payment Processors: Stripe, Apple App Store, Google Play Store (for payment processing)
• Email Service Providers: Mailchimp (for newsletters and marketing emails)
• Cloud Hosting: [Specify your hosting provider, e.g., AWS, Google Cloud] (for data storage and infrastructure)
• Analytics Services: [Specify, e.g., Google Analytics, Mixpanel] (for usage analytics)
• Customer Support Tools: [Specify if applicable] (for managing support requests)
[NEW] All processors are contractually required to:
• Process data only on Our instructions
• Implement appropriate security measures
• Maintain confidentiality
• Assist with Your data protection rights
• Delete or return data when services end
b) With Affiliates
For Service delivery and business operations, subject to the same privacy standards.
c) During Business Transactions
During mergers, acquisitions, or sales of assets. [NEW] You will be notified of any change in data controller and Your rights under such circumstances.
d) Legal Requirements
With law enforcement or regulators if legally required. [NEW] We will notify You of such requests unless legally prohibited.
e) With Your Consent
For any other purposes with Your explicit permission.
⚠️ OUR COMMITMENT: We do NOT sell Your Personal Data to third parties. We do NOT sell or share Your health data with third parties for their marketing purposes.
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INTERNATIONAL DATA TRANSFERS [ENHANCED]
Your Personal Data may be processed in countries outside the European Economic Area (EEA) where data protection laws may differ.
Transfer Safeguards:
When We transfer Personal Data outside the EEA, We ensure appropriate safeguards, including:
• Standard Contractual Clauses (SCCs): Approved by the European Commission for transfers to countries without adequacy decisions
• Adequacy Decisions: Transfers to countries recognized by the EU Commission as providing adequate protection
• Your Explicit Consent: Where required by law
• Processor Binding Corporate Rules: Where applicable
Current Transfer Destinations:
[NEW] Your data may be transferred to:
• United States (processors using SCCs or certified under EU-US Data Privacy Framework)
• [List other specific countries/regions where your service providers are located]
For more information about transfer mechanisms, contact hi.betterskin@gmail.com.
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LEGAL RIGHTS AND COMPLIANCE
GDPR (EU/EEA Users)
You have the following rights under the General Data Protection Regulation (GDPR):
→ Right of Access (Article 15)
Request a copy of the Personal Data We hold about You.
→ Right to Rectification (Article 16)
Correct inaccurate or incomplete Personal Data.
→ Right to Erasure / "Right to be Forgotten" (Article 17)
Request deletion of Your Personal Data in certain circumstances.
→ Right to Restriction of Processing (Article 18)
Limit how We use Your data while a dispute is resolved.
→ Right to Data Portability (Article 20)
Receive Your data in a structured, machine-readable format and transfer it to another controller.
→ Right to Object (Article 21)
Object to processing based on legitimate interests or for direct marketing.
→ Right to Withdraw Consent (Article 7(3))
Withdraw consent at any time (without affecting prior lawful processing).
→ Right Not to Be Subject to Automated Decision-Making (Article 22) [NEW]
Our Service may use automated processing to provide skincare recommendations. You have the right to:
• Be informed of such processing
• Request human intervention
• Express Your view and contest decisions
• Opt-out of automated decision-making
How to Exercise Your Rights:
To exercise any of these rights, contact us at hi.betterskin@gmail.com. We will respond within ONE MONTH (extendable by two additional months for complex requests).
→ Right to Lodge a Complaint [NEW]
If You believe We have not handled Your Personal Data appropriately, You have the right to lodge a complaint with Your local supervisory authority:
• EU/EEA Residents: Contact Your national Data Protection Authority. Find your authority at: https://edpb.europa.eu/about-edpb/board/members_en
• For example, if You are in Ireland: Data Protection Commission (www.dataprotection.ie)
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CCPA / CPRA (California Users)
If You are a California resident, You have the right to:
• Know what Personal Data is collected, used, shared, or sold
• Request deletion of Your Personal Data
• Opt-out of the sale of Personal Data
• Non-discrimination for exercising these rights
To submit a request, contact us at hi.betterskin@gmail.com.
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CalOPPA (California Online Privacy Protection Act)
Under CalOPPA, we:
• Post a privacy policy on the website
• Inform users of updates and effective dates
• Allow users to request changes to Personal Information
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DATA PROTECTION OFFICER (DPO) [NEW]
We have appointed a Data Protection Officer to oversee GDPR compliance and handle data protection matters.
Contact Our DPO:
• Email: dpo@betterskin.app
• Or via: hi.betterskin@gmail.com (marked "Attention: DPO")
You may contact Our DPO regarding:
• Questions about data processing
• Exercising Your GDPR rights
• Data protection concerns or complaints
• Data breach notifications
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DATA RETENTION
We retain Personal Data only as long as necessary for the purposes outlined, legal obligations, dispute resolution, or enforcement of agreements.
Typical Retention Periods:
• Account Information: Up to 24 months after account closure
• Customer Support Data: Up to 24 months
• Usage Data / Analytics: Up to 24 months
• [NEW] Health/Skin Data: Up to 24 months after account closure or until consent is withdrawn, whichever comes first
• [NEW] Marketing Data: Until You unsubscribe or withdraw consent
• [NEW] Financial Records: Up to 7 years for legal and tax compliance
Data may be anonymized or securely deleted after retention periods.
[NEW] You may request earlier deletion by contacting hi.betterskin@gmail.com. We will delete Your data within 30 days unless legally required to retain it.
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YOUR PRIVACY CHOICES
You may:
• Update or delete Your account information
• Opt out of marketing emails via unsubscribe links
• Manage cookie preferences [NEW] through Our cookie settings panel
• Request deletion of Personal Data by contacting hi.betterskin@gmail.com
• [NEW] Withdraw consent for health data processing at any time
• [NEW] Download Your data in a portable format
• [NEW] Object to automated decision-making
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SECURITY
We implement commercially reasonable technical and organizational measures to protect Your Personal Data. [NEW] These include:
• Encryption: Data encrypted in transit (TLS/SSL) and at rest
• Access Controls: Role-based access and authentication
• Regular Security Audits: Penetration testing and vulnerability assessments
• Employee Training: Data protection training for all personnel
• Incident Response: Procedures for detecting and responding to breaches
[NEW] In the event of a data breach that poses a risk to Your rights and freedoms, We will notify:
• You (within 72 hours where feasible)
• The relevant supervisory authority (within 72 hours as required by GDPR Article 33)
However, no method of internet or electronic storage is 100% secure.
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CHILDREN'S PRIVACY
Our Service is not directed to children under 16. We do not knowingly collect Personal Data from children under 16. [NEW] If We become aware that We have collected data from a child under 16 without parental consent, We will delete that information immediately. Parents may contact us to remove data collected from a child.
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LINKS TO OTHER WEBSITES
Our Service may contain links to third-party sites. We are not responsible for their content, privacy policies, or practices. [NEW] We recommend reviewing the privacy policies of any third-party sites You visit.
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CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy. Updates will be posted on this page, with the "Last Updated" date revised. [NEW] For significant changes that materially affect Your rights, We will:
• Notify You by email (to the address on Your account)
• [NEW] Require Your renewed consent where legally required (e.g., for new uses of health data)
• Provide at least 30 days' notice before changes take effect
[NEW] Your continued use of the Service after changes take effect constitutes acceptance of the updated policy, except where consent is separately required.
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CONTACT US
If you have questions about this Privacy Policy or Your rights, contact us:
• Email: hi.betterskin@gmail.com
• [NEW] Data Protection Officer: dpo@betterskin.app
• [NEW] Mailing Address: [Your company's registered address in the EU - required for GDPR]
[NEW] We will respond to Your inquiry within 30 days.
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COOKIE POLICY DETAILS [NEW]
Essential Cookies
Required for basic Service functionality (login, security, session management). These cannot be disabled.
Functionality Cookies
Remember Your preferences (language, region, theme). You may disable these, but functionality may be affected.
Analytics Cookies
Help Us understand how You use the Service (pages visited, features used, errors encountered). We use [specify tools, e.g., Google Analytics with IP anonymization].
Marketing Cookies
Used to deliver personalized marketing and measure campaign effectiveness. You may opt-out through Our cookie settings.
Managing Cookies:
• In-App Settings: Access cookie preferences in [Settings > Privacy > Cookie Preferences]
• Browser Settings: Configure cookie preferences in Your browser
• Third-Party Opt-Outs:
Google Analytics: https://tools.google.com/dlpage/gaoptout
[List other third-party opt-out mechanisms]
For more information, see Our full Cookie Policy at [link to cookie policy if separate].
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END OF PRIVACY POLICY
All changes from the original policy are marked with [NEW] or [ENHANCED]
For a detailed summary of all GDPR enhancements, please refer to the accompanying "GDPR Changes Summary" document.