Privacy Policy

Wild wire innovations, MB operates Skinreo and is the controller responsible for the personal data described here. Skinreo is operated from Lithuania.

Company code: 306379282.

Contact address: Laisvės pr. 58, LT-05120 Vilnius, Lithuania

Contact: hello@skinreo.com. This notice applies to the iPhone app and website. Skinreo is a tracker and photo journal with estimated skin appearance scores and cosmetic routine guidance.

This policy explains processing; reading or acknowledging it is not blanket consent. Optional permissions are requested separately from agreement to the Terms.

At signup, you separately confirm you are at least 18 and agree to the Terms, and acknowledge this policy. This records your agreement without granting or declining skin-data or OpenAI processing. Before collecting a skin profile or creating your first scan, we ask for separate skin-data and OpenAI permissions. We record your account identifier, submitted choices, server timestamp and notice versions. New social sign-in accounts and accounts without a current agreement complete the agreement step before using the app. Existing saved permissions remain in effect until you change them.

These choices are saved across sessions and devices. We do not ask you to consent before every scan. Facial scans require both permissions. OpenAI explanations require OpenAI permission. Without these optional permissions you can still use manual routines, your product shelf and account controls, subject to the applicable membership.

Use Settings → Privacy & AI permissions to change a choice. Turning off OpenAI stops new AI requests; it does not recall requests already sent. Turning off skin data removes your saved skin profile, scan results, personalised programs, routine entries and product notes, and attempts to clear Skinreo photos and cached data on the current device. If cleanup fails, Settings offers a retry. Your account, subscription and product shelf remain. Remove copies on other devices and exported files separately.

Withdrawal does not affect processing that was lawful before withdrawal. This permission does not authorise research, model training, advertising or future unrelated uses. If a purpose changes in a way requiring new consent, we will ask again.

• Account: email, authentication information, age confirmation, agreement and permission records, membership identifiers and status. Used for sign-in, account operation and demonstrating your choices.
• Optional skin profile: age, sex, self-described skin type, concerns and goals. Used for the personalisation you enable. These answers may reveal health-related information.
• Scan photos: only photos you actively submit are uploaded through Skinreo to OpenAI for appearance estimates. Skinreo prepares an upright, resized JPEG for analysis. The current scan code does not store photo uploads in its database or cloud photo storage. A journal copy is saved locally on your device when storage succeeds. For three-angle scans, only the front photo is kept in the device journal.
• Appearance results: scores, scoring-guide version, capture-quality notes, assessed facial regions and visible observations are saved in your Supabase account. The eight signals describe blemishes, redness, dryness appearance, texture, lines, darker marks, pore prominence and oily-looking shine. They are not clinical measurements.
• Comparisons: the app’s saved-scan comparison reads your existing account results and device-local photos; opening it does not send those photos to OpenAI again. The protected photo-comparison API, if requested, sends both submitted images to OpenAI and returns temporary observations without storing the images in Skinreo’s database.
• Ingredient checks: submitted label photos or ingredient text, with relevant skin type, concerns and goals, are sent to OpenAI. Results are displayed for the current session. A product is saved to your shelf only when you choose to save it.
• Ask Skinreo: your question, recent messages in the current conversation and skin type context are sent to OpenAI. The current assistant does not save new chat conversations in your account.
• Routines, programs and products: chosen programs, routine steps, completion logs and product shelf entries are stored in your account to provide the features you use. Avoid putting medical or other sensitive details in manual product or routine notes when skin data permission is off.
• Technical information: daily feature counters and dates enforce limits. Hosting and authentication providers process technical request information, such as IP addresses and timestamps, for operation and security. We do not run advertising or cross-site tracking analytics in the current app.
• Reminders and photo backups: iPhone reminders are scheduled locally. Photo backups create a password-protected file when you choose to export; copies remain wherever you save or share them.
• Launch updates: an email you separately submit to the website launch list is stored for those updates. Signup to the app does not automatically subscribe you. Confirm the subscription using the email we send. Use the unsubscribe link in any update to leave the launch list; you may also contact us.

Account operation, membership, manual routine and product features use Article 6(1)(b) GDPR (performance of the service contract). Optional skin personalisation and AI processing rely on Article 6(1)(a) (consent), with explicit consent under Article 9(2)(a) for health-related information. Optional launch updates use consent. Necessary service security uses legitimate interests under Article 6(1)(f); required legal records may rely on Article 6(1)(c).

A facial photograph is personal data and may reveal sensitive information. It is not automatically biometric identification data. Skinreo does not identify people, create identity templates or use facial recognition for authentication. The iPhone camera’s face-position guide checks framing on the device.

Skinreo does not make automated decisions with legal or similarly significant effects. Photo estimates and suggestions remain information for you to review.

• Supabase: authentication, account records, profile, results, routines, products, permission records, usage counters and launch-list records. Current scan photos are not uploaded to Supabase storage.
• OpenAI: the content and context described above when you request an AI feature. API content is not used to train OpenAI models by default unless the customer opts in; Skinreo’s permission does not authorise opting your content into training. OpenAI’s default abuse-monitoring retention can be up to 30 days, with longer retention in specified safety or legal circumstances. Setting a request not to be stored is not a promise of zero retention. OpenAI data controls.
• Vercel: hosts the website and API, receives uploaded content while handling the requested analysis, and processes technical request logs.
• Apple: handles iPhone subscription purchases and refunds when the Apple membership is available. A pseudonymous account token links the purchase to your Skinreo account. Skinreo verifies signed transactions with Apple and stores transaction identifiers, product, environment, status and access expiry, not card details. We do not send skin photos or profiles to Apple for billing.
• Stripe: handles existing web subscriptions and payment details. Skinreo stores customer/subscription identifiers and status, not full card numbers.
• Google or Apple sign-in, when available: processes authentication when you choose that provider. Apple’s private relay address can be used instead of sharing your usual email.
• Open Beauty Facts: receives product barcodes or product search queries for catalogue lookups. Skinreo does not send your face photos, skin profile or account identifiers to this catalogue. Remote product images can also expose ordinary network information to their image host.
• Resend: sends launch-list confirmation emails and forwards submitted support messages to Skinreo’s support mailbox. Messages contain the details you enter. These are separate from OpenAI requests.

The account database is deployed in Frankfurt, Germany; the API deployment is configured for a US region. These settings do not establish every provider’s processing, support or subprocessor location.

The exact hosting locations and international transfer safeguards are awaiting confirmation before public launch. Contact hello@skinreo.com for the current status. Agreement to this policy is not a substitute for the required transfer safeguards.

We may disclose data where required by law. We do not sell it or share skin information for advertising.

Account profile, results and feature data remain until you remove them, withdraw the relevant skin data permission or delete the account. Permission history is retained with the account to demonstrate the choices made and is removed by the account-deletion cascade. Device-wide cleanup clears all Skinreo photos on that device, including photos from other Skinreo accounts used there. The launch list is separate from the app account. It records the notice version, source, request time, confirmation time and unsubscribe status. Unsubscribed addresses are suppressed from campaigns; contact us to request erasure of separate launch-list records.

Local journal photos remain until removed from that device. Deleting a scan removes its local photo first, then its account results. If either step fails, the app offers a retry and does not claim deletion finished. Settings also offers removal of all local Skinreo photos. The current iPhone build applies complete file protection to its journal folder and excludes that folder and its files from new operating-system backups. It applies those settings to existing journal files when the folder is prepared. Copies made in earlier backups, exports, screenshots or another device are separate; changing this setting does not erase existing backups. Protection depends on your device security and operating system.

Delete account in Settings clears local Skinreo photos and cached app data on that device, then requests account deletion. If cleanup or deletion fails, the app reports it so you can retry. Successful server deletion removes the authentication account and linked app records. Existing Stripe subscriptions and open checkouts are checked and stopped before server deletion completes; if billing cannot be verified, the account is kept for retry. Deleting the account does not cancel an Apple subscription: manage Apple renewal separately through your Apple Account. Exported files, photos on other devices, payment-provider legal records and OpenAI retention are separate; deleting the account does not instantly erase those copies.

Provider backup and technical-log retention periods are awaiting confirmation before public launch. We do not promise immediate erasure from backups or third-party safety logs.

You can request access, correction, erasure, restriction, portability and, where applicable, object to processing. Withdraw optional permissions in Settings. Settings → Photos & data provides an account-data JSON export and a separate device-photo export. The account export includes stored app records, not provider logs, payment-card information, launch-list records or support mailbox messages. Use the contact form or email hello@skinreo.com for other records, larger exports or rights requests. We may verify your identity and respond within one month for GDPR requests, subject to applicable extension rules. A privacy complaint or appeal can be submitted through the same contact form.

You may complain to the Lithuanian State Data Protection Inspectorate (VDAI) or your local supervisory authority. UK residents can contact the ICO; Canadian residents can contact the OPC or the applicable provincial authority. Australian residents can complain to us first and, if unresolved, the OAIC. We aim to respond to Australian privacy complaints within 30 days.

US consumer-health data rights, including Washington access, withdrawal, deletion and appeals, are described in the Consumer health data privacy notice.

The iPhone app stores sign-in sessions in Keychain, journal photos in local files and preferences in local storage. The website uses necessary storage for the features you request. Camera or notification permission from your device is separate from permission to send content to OpenAI. We do not require access to your whole photo library to submit one chosen photo.

The website downloads Google’s tag library on each page, which involves a connection to Google’s servers. Analytics measurement and analytics cookies remain disabled until you select Accept in the cookie notice. With your permission, Google Analytics measures visits, pages viewed and interactions, including browser and device information. Google processes this information and uses analytics cookies. We save your choice in this browser; you can decline or withdraw permission through Cookie settings in the website footer. Advertising signals and advertising personalisation are disabled. See Google’s Privacy Policy for its processing practices. This website analytics choice is separate from the iPhone app’s skin-data and AI permissions.

Skinreo is for adults aged 18 and over. If you believe a child has provided personal data, choose Report an underage account in the contact form or contact hello@skinreo.com. We investigate credible reports, restrict access where appropriate and remove data when the account is confirmed ineligible. Please do not send a child’s photos or identity documents through the form.

When you contact us, we use the name, email, topic and message you provide to respond. The contact form sends the message through Resend to our support mailbox. The app database stores a reference, email, topic, receipt time, delivery status and response/closure tracking; message text is not copied into that database. Necessary request handling relies on the relevant service contract, legal obligations or legitimate interests, depending on your request.

The form applies abuse limits using keyed hashes of an email and request IP, with rate buckets removed after 24 hours when the form is used again. We do not retain the raw IP in that rate-limit table. Please avoid including photos, medical details, passwords or card data in a support message. Support and launch-list records are separate from the app account and may need a separate erasure request; retention for those records is being finalised before public launch.

We publish the current notice version here. Material changes are brought to your attention in the app. A new permission purpose is not accepted merely by continued use; where fresh consent is needed we request it before the affected processing.