SkinHappy Privacy Policy
Effective: October 14, 2026|Updated: October 14, 2026
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Introduction
SkinHappy, LLC, a Delaware limited liability company qualified to do business in California ("SkinHappy," "we," "us," or "our"), operates the SkinHappy platform, including the website at skinhappy.com and related web applications (collectively, the "Service"). This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use our Service.
SkinHappy provides AI-powered skin wellness insights, personalized skincare recommendations, product suggestions, and progress tracking tools. SkinHappy is a wellness and education platform. We do not provide medical diagnosis, treatment, or medical advice.
This Privacy Policy applies to all users of our Service, including consumers ("Members"), esthetician partners ("Estheticians"), and administrative users. By creating an account or using the Service, you acknowledge that you have read and understand this Privacy Policy. This Privacy Policy should be read together with our Terms of Service, which govern your use of the Service.
Contact Information
SkinHappy, LLC · PO Box 287, Monterey, CA 93942 · privacy@skinhappy.ai
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Information We Collect
2.1·Information You Provide Directly
Account Information
Your name, email address, password, date of birth, and optional demographic information such as gender and referral source.
Skin and Wellness Questionnaire Information
Your responses to our onboarding questionnaire, including skin concerns, skin goals, skin type, lifestyle preferences, and wellness goals. If you use our daily check-in feature, your check-in responses and wellness progress updates.
Facial Photographs
Photos you upload or capture through the Service for AI-powered skin wellness analysis.
Communication Preferences
Whether you opt in to receive wellness tips, product recommendations, and educational content.
Esthetician Partner Information(Esthetician partner accounts only)
The following information is collected from individuals who apply for or hold an Esthetician partner account:
- Professional license information (license number, issuing state, and certifications) and business contact details.
- Payout onboarding information collected by our payout provider, Stripe Connect (operated by Stripe, Inc.), on our behalf during contractor onboarding, including identity-verification data, bank or debit card details, and beneficial-owner information.
- Tax and contractor-reporting information required for federal and state reporting, including IRS Form W-9 (or successor form) and the Social Security Number or Employer Identification Number reported on it; resulting tax records issued for compensation paid (such as IRS Form 1099-NEC); and California Form DE 542 (Report of Independent Contractor(s)) filed with the California Employment Development Department where reporting thresholds are met. SkinHappy receives W-9 information for federal tax-reporting and California EDD-reporting purposes; full bank account numbers are collected and stored by Stripe Connect, not by SkinHappy.
- Agreement acceptance and audit-log records evidencing assent to the Independent Contractor Agreement, Commission Program Exhibit, and Content Standards, including the version accepted, timestamp, account identifiers, IP address, device or browser metadata, and a tamper-evident or signed PDF of the accepted documents.
- Skincare routine descriptions and educational content created on the platform.
Guardian Information(Members ages 13–17)
Guardian consent acknowledgment.
2.2·Information Generated Through Your Use of the Service
AI-Derived Wellness Data
Skin wellness scores and assessments generated by our AI analysis technology, such as indicators related to skin texture, redness, fine lines, and overall skin condition, as well as skin age estimates.
Personalized Recommendations
Product recommendations, skincare routine assignments, and related personalization outputs generated based on your wellness profile.
Progress Data
Wellness progress tracking and trend data generated over time from your use of the Service.
Commerce Data
Purchase history, subscription status, cart contents, order details, and auto-reorder preferences.
2.3·Information Collected Automatically
Device and Usage Information
When you visit our Service, we and our analytics partners may automatically collect information such as browser type, operating system, pages visited, and interaction patterns. This information is collected through analytics tools described in Section 13 and is subject to your consent preferences.
Authentication Data
We use HTTP-only cookies to maintain your authenticated session (access tokens and refresh tokens). These are strictly necessary for the Service to function and do not track your behavior.
2.4·Information Collected from Third Parties
AI Skin Analysis Results
When you upload a photograph for skin wellness analysis, our AI technology partner processes the image and returns wellness assessment results to us, including numerical scores and condition indicators. See Section 4 for details about this processing.
2.5·Payment and Shipping Information
When you make a purchase, you are redirected to a secure checkout page hosted by our third-party payment processor. On that page, you enter your payment method and shipping address. SkinHappy does not operate the checkout form, but we do receive and store certain information from the completed transaction:
Shipping address
After you complete checkout, your shipping address is transmitted to SkinHappy and stored with your order record for fulfillment tracking.
Payment method details (card numbers, billing address)
These are collected and stored by the payment processor. SkinHappy does not receive or store your full card number or billing address.
We do not collect precise geolocation data, Social Security numbers, driver's license numbers, or government-issued identification numbers from Members.
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How We Use Your Information
We use the information we collect for the following purposes:
3.1·Providing and Personalizing the Service
- Creating and managing your account
- Generating your AI-powered skin wellness analysis from your uploaded photographs
- Producing personalized skincare product recommendations based on your wellness profile, skin goals, and quiz responses
- Building and maintaining your skincare routine (AM/PM product sequences)
- Tracking your wellness progress over time
- Processing product purchases, managing subscriptions, and fulfilling orders through our commerce partners
- Facilitating the esthetician referral program and connecting Members with Esthetician partners
3.2·Communications
- Sending transactional messages: account verification, password resets, order confirmations, subscription notifications, and other service-related communications
- With your consent, sending wellness tips, product recommendations, educational content, and platform updates
3.3·Service Improvement and Research
- Improving the accuracy of our AI skin wellness analysis and recommendation engine
- Analyzing aggregate usage patterns to improve the user experience
- Using de-identified and aggregated data for wellness research and scientific analysis (see Section 7 for details)
- Developing and improving algorithms and models that power the Service
3.4·Safety and Security
- Preventing fraud, unauthorized access, and other harmful activities
- Verifying user identity and age eligibility
- Enforcing our Terms of Use and other policies
3.5·Legal Compliance
- Complying with applicable laws, regulations, and legal processes
- Responding to lawful requests from government authorities
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Sensitive Personal Information
Under California law (CCPA/CPRA) and other state privacy laws, certain categories of personal information are considered "sensitive." We collect the following categories of sensitive personal information:
Health and Wellness Data
Your skin concerns, wellness questionnaire responses, longevity selections, daily check-in data, AI-derived wellness assessments, and progress tracking information are considered health-related data under applicable state laws.
Biometric Data
Facial photographs you upload are processed using AI technology to generate skin wellness assessments. Under applicable state laws, facial geometry and photographs used for identification or analysis purposes may constitute biometric data.
How We Use Sensitive Data
We use sensitive personal information only for the purposes described in Section 3 of this Privacy Policy — specifically, to provide and personalize the Service, including generating AI skin wellness analyses and personalized recommendations. We do not use sensitive personal information for purposes beyond what is necessary to provide the Service, unless you provide additional consent.
Your Right to Limit Use
You have the right to limit our use of your sensitive personal information to only what is necessary to provide the Service. See Section 6 for how to exercise this right.
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Your Privacy Rights
Depending on your state of residence, you may have some or all of the following rights regarding your personal information. SkinHappy honors these rights for all users regardless of state of residence, to the extent technically feasible:
6.1·Right to Know
You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share your information.
6.2·Right to Delete
You have the right to request the deletion of your personal information. Upon a verified deletion request, we will delete your personal information from our records and direct our service providers to do the same, except where retention is permitted or required by law (for example, to complete a transaction you requested, for fraud prevention, or to comply with legal obligations).
Upon a verified deletion request, we will take commercially reasonable steps to delete or anonymize your personal information across our systems and direct our service providers to do the same. Certain records (such as anonymized transaction records) may be retained as required by law.
6.3·Right to Correct
You have the right to request correction of inaccurate personal information we maintain about you.
6.4·Right to Opt-Out of Sale or Sharing
We do not sell your personal information. We do not act as a data broker.
We may "share" personal information (as defined under CCPA) with analytics providers (Google Analytics, Microsoft Clarity) for the purpose of measuring platform performance. You may opt out of this sharing by:
We may "share" personal information (as defined under CCPA) with analytics providers (Google Analytics, Microsoft Clarity) for the purpose of measuring platform performance. You may opt out of this sharing by:
- Declining analytics cookies via our cookie consent banner
- Enabling Global Privacy Control (GPC) in your browser
- Contacting us at the address below
6.5·Right to Limit Use of Sensitive Personal Information
You have the right to direct us to limit our use of your sensitive personal information (health data, biometric data) to only what is necessary to provide the Service. To exercise this right, contact us at the address below.
6.6·Automated Decision-Making
Our Service uses AI and automated systems to generate skin wellness assessments and product recommendations. Where applicable law provides you with rights regarding automated decision-making that produces legal or similarly significant effects, you may exercise those rights by contacting us at the address below.
6.7·Right to Non-Discrimination
We will not discriminate against you for exercising any of your privacy rights. We will not deny you the Service, charge you different prices, or provide a different level of quality because you exercised a privacy right.
6.8·Right to Appeal
If we decline to take action on your privacy request, you have the right to appeal our decision. To appeal, contact us at the address below with "Privacy Appeal" in the subject line. We will respond to your appeal within the timeframe required by applicable law.
6.9·Authorized Agents
You may designate an authorized agent to submit privacy requests on your behalf. We may require the authorized agent to provide proof of authorization and may require you to directly verify your identity with us.
How to Exercise Your Rights
To exercise any of the rights described above, contact us at:
- Email: privacy@skinhappy.ai
- Mail: SkinHappy, LLC, PO Box 287, Monterey, CA 93942
We will verify your identity before processing your request. We will respond to verifiable requests within 45 days. If we need additional time (up to 90 days total), we will inform you of the reason and extension period in writing.
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Research and De-identified Data
We use data to improve our Service and to advance understanding of skin wellness. Our current research activities include:
- Refining our AI skin wellness analysis to provide better insights
- Studying relationships between lifestyle factors and skin wellness outcomes
- Analyzing demographic and seasonal patterns in skin wellness trends
- Improving the accuracy and relevance of product and routine recommendations
As the platform evolves, our research activities may expand. We will update this Privacy Policy before introducing materially new research uses and will obtain additional consent where required by applicable law.
7.1·De-identified Data
The primary data we use for research is de-identified data — data that has been processed to remove information that could reasonably be used to identify you. The categories of de-identified data we use are:
| Data Type | What's Included | What's Removed |
|---|---|---|
| Wellness scores | Numerical AI analysis scores (texture, pore appearance, redness, radiance, fine lines, age spots, skin age) | Name, email, account ID, appointment ID, timestamps (generalized to month/year) |
| Questionnaire responses | Skin goals, skin type, lifestyle selections, longevity wellness selections | Name, email, account ID, specific dates |
| Demographics | Age range (e.g., 25–34), gender category, general geographic region | Exact age, exact location, any combination that could identify an individual |
| Product and routine data | Product categories used, routine adherence patterns, purchase categories | Specific product names (if identifiable), order IDs, account details |
| Progress trends | Aggregate wellness score changes over time periods | Individual check-in records, specific dates, account identifiers |
We implement technical safeguards and organizational policies designed to prevent re-identification of de-identified data. Third parties receiving de-identified data are contractually prohibited from attempting re-identification. Our de-identification practices are intended to be consistent with applicable state privacy law standards, including the California Consumer Privacy Act (CCPA).
7.2·Aggregated Data
We also use aggregated data — statistical summaries computed across many users that contain no individual-level records. Examples include:
- Average skin wellness score improvement after 90 days of consistent routine use
- Most commonly selected skin goals by age group
- Seasonal trends in skin redness scores across geographic regions
Because aggregated data contains no individual-level records, we may use it for research, reporting, and public communications without additional consent.
7.3·Facial Photographs — Special Handling
Facial photographs are NOT included in de-identified research datasets by default. A face is a biometric identifier, and we treat it with the highest level of care. Only numerical scores, condition indicators, and metadata derived from photographs are used in research. Identifiable photographs are not shared externally or included in research datasets.
If this practice changes in the future, any use of visual skin data for research would require separate, explicit opt-in consent from participating users, appropriate technical and contractual safeguards, and an update to this Privacy Policy before implementation.
7.4·Commercial Applications
SkinHappy may develop commercial products and services based on insights derived from de-identified research data. These may include:
- Improved algorithms and models that power the SkinHappy platform's recommendations and wellness assessments
- Wellness scoring systems that may be licensed to or integrated with other wellness platforms
- Research publications and white papers based on aggregate findings
- Predictive wellness models that identify trends and patterns in skin wellness data
We do not sell your personal information or identifiable data. We are not a data broker. Commercial applications are built on de-identified and aggregated data, not on individual user records. If an algorithm or model is developed using de-identified data from our user base, that model does not contain or expose any individual's personal information.
7.5·Future Data Types
As the platform evolves, we may collect additional types of wellness data. If we introduce new data categories relevant to research, we will update this Privacy Policy before collection begins, collection of new sensitive data types will require your consent, and new data types will be subject to the same de-identification standards described above.
7.6·Oversight and Accountability
- Research activities are overseen by SkinHappy's wellness and data science team.
- De-identification processes are documented and periodically reviewed.
- Third parties receiving de-identified data are subject to contractual obligations prohibiting re-identification.
- We do not share identifiable data with external research partners without explicit user consent.
7.7·Your Rights Regarding Research
You may request that your data not be included in future research activities (beyond what is necessary to provide the Service) by contacting us. De-identified data that has already been incorporated into aggregate datasets cannot be removed, as it is no longer linked to you. You may request deletion of your personal information at any time (see Section 6). If you have opted in to any photograph-based research program, you may withdraw your consent at any time — withdrawal applies prospectively.
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Children's Privacy
SkinHappy is available to users aged 13 and older. We do not knowingly collect personal information from children under the age of 13. If we discover that we have inadvertently collected personal information from a child under 13, we will promptly delete that information.
Users Ages 13–17
If you are between 13 and 17 years of age, a parent or legal guardian must consent to your use of the Service on your behalf. We collect a guardian consent acknowledgment during the onboarding process for users in this age group.
Under-16 Data
Under the California Consumer Privacy Act (CPRA), we will not sell or share the personal information of consumers we know to be under 16 years of age without affirmative authorization.
If you believe a child under 13 has provided us with personal information, please contact us at the address in Section 17.
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Data Retention
We retain your personal information for as long as your account is active or as needed to provide you the Service. After account deletion or upon a verified deletion request, we will delete or anonymize your personal information in accordance with applicable law, subject to certain exceptions:
Financial records
Anonymized transaction records may be retained as required for tax and financial reporting compliance.
Legal obligations
We may retain information as necessary to comply with legal obligations, resolve disputes, or enforce our agreements.
De-identified data
Data that has been de-identified and incorporated into aggregate research datasets is retained, as it can no longer be linked to you.
Analytics data
Data collected by third-party analytics providers is subject to those providers' respective retention policies.
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Data Security
We implement commercially reasonable technical, administrative, and organizational measures designed to protect your personal information. These measures include encryption of data in transit and at rest, secure password storage, access controls, and use of reputable cloud infrastructure providers that maintain industry-recognized security certifications.
No method of electronic transmission or storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that affects your personal information, we will notify you and applicable authorities in accordance with applicable law.
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AI and Automated Processing
SkinHappy uses artificial intelligence and automated processing in the following ways:
11.1·AI Skin Wellness Analysis
When you upload a facial photograph, it is processed by our AI technology partner to generate a skin wellness assessment. This assessment includes numerical scores for various skin characteristics (texture, pore appearance, redness, radiance, fine lines, age spots, and overall condition), a skin age estimate, and regional breakdowns. These results are wellness insights, not medical diagnoses.
11.2·Personalized Recommendations
Our recommendation engine uses your wellness profile (quiz responses, skin goals, AI analysis results, and selected concerns) to suggest skincare products and routines. Product recommendations are generated algorithmically based on global product-to-concern mappings configured by SkinHappy's wellness team. No individual medical professional reviews or approves recommendations for individual users.
11.3·Your Rights Regarding AI Processing
- You may request information about how AI-generated assessments and recommendations are produced.
- Under applicable state laws, you may have the right to opt out of automated decision-making that produces legal or similarly significant effects. To inquire about this right, contact us at the address in Section 17.
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Global Privacy Control and Do Not Track
Global Privacy Control (GPC)
We honor Global Privacy Control signals as required by applicable law. If your browser transmits a GPC signal, we treat this as a valid opt-out of the "sale" or "sharing" of your personal information under applicable state laws and will limit non-essential data processing accordingly.
Do Not Track
See Section 13.4 for our handling of Do Not Track signals.
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California-Specific Disclosures
Categories of Personal Information Collected (CCPA)
In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA. The matrix below covers all user types; entries marked "Estheticians only" reflect data collected solely from individuals onboarding as Esthetician partners under our Independent Contractor Agreement.| Category | Collected | Examples | |
|---|---|---|---|
| A | Identifiers | Yes | Name, email address, account ID |
| B | Personal information (Cal. Civ. Code 1798.80(e)) | Yes | Name, date of birth; for Estheticians, Social Security Number or Employer Identification Number reported on IRS Form W-9, and bank account information collected by Stripe Connect on our behalf |
| C | Protected classification characteristics | Yes | Age, gender |
| D | Commercial information | Yes | Purchase history, products purchased, subscription records; for Estheticians, commission payout history |
| E | Biometric information | Yes | Facial photographs used for AI analysis |
| F | Internet or other electronic network activity | Yes | Browsing history, interaction with our Service (subject to cookie consent); for Estheticians, IP address and device or browser metadata captured at the time of agreement acceptance |
| G | Geolocation data | No | Not collected |
| H | Sensory data | Yes | Photographs |
| I | Professional or employment-related information | Yes | Estheticians only: professional license number and issuing state, certifications, IRS Form W-9 information, IRS Form 1099-NEC tax records, California Form DE 542 contractor-reporting records, and acceptance audit logs for the Independent Contractor Agreement and related exhibits |
| J | Non-public education information | No | Not collected |
| K | Inferences | Yes | Skin wellness profiles, product preferences, skin condition assessments |
| L | Sensitive personal information | Yes | Health data, biometric data; for Estheticians, Social Security Number reported on IRS Form W-9 (where the Esthetician reports an SSN rather than an EIN) |
Identifiers
Name, email address, account ID
Personal information (Cal. Civ. Code 1798.80(e))
Name, date of birth; for Estheticians, Social Security Number or Employer Identification Number reported on IRS Form W-9, and bank account information collected by Stripe Connect on our behalf
Protected classification characteristics
Age, gender
Commercial information
Purchase history, products purchased, subscription records; for Estheticians, commission payout history
Biometric information
Facial photographs used for AI analysis
Internet or other electronic network activity
Browsing history, interaction with our Service (subject to cookie consent); for Estheticians, IP address and device or browser metadata captured at the time of agreement acceptance
Geolocation data
Sensory data
Photographs
Professional or employment-related information
Estheticians only: professional license number and issuing state, certifications, IRS Form W-9 information, IRS Form 1099-NEC tax records, California Form DE 542 contractor-reporting records, and acceptance audit logs for the Independent Contractor Agreement and related exhibits
Non-public education information
Inferences
Skin wellness profiles, product preferences, skin condition assessments
Sensitive personal information
Health data, biometric data; for Estheticians, Social Security Number reported on IRS Form W-9 (where the Esthetician reports an SSN rather than an EIN)
Sale and Sharing
We have not "sold" personal information in the preceding 12 months. We may "share" personal information (as defined by CCPA) with analytics providers (Google, Microsoft) subject to your cookie consent preferences.
Financial Incentive Programs
We may offer subscription-based discount programs. If we operate a program that qualifies as a "financial incentive" under applicable privacy law, we will provide the required disclosures at the point of enrollment.
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Other State-Specific Rights
Virginia, Colorado, Connecticut, Texas, Oregon, and Other States with Comprehensive Privacy Laws
Residents of states with comprehensive privacy laws have rights that substantially overlap with those described in Section 6, including the right to access, delete, and correct personal information, and to opt out of targeted advertising, profiling, and the sale of personal information. We honor these rights as described in Section 6 for all users.
Washington My Health My Data Act
Washington residents have additional rights with respect to health data, including the right to specific consent before collection, the right to withdraw consent, and the right to delete health data. We collect health data only with your affirmative consent as described in our onboarding consent flow. You may withdraw consent or request deletion at any time by contacting us.
Illinois Biometric Information Privacy Act (BIPA) and Texas CUBI
Residents of Illinois, Texas, and other states with biometric privacy laws have specific rights related to biometric data. We collect facial photographs for AI skin wellness analysis with your informed, affirmative consent. We do not sell, lease, trade, or otherwise profit from your biometric data. Biometric data is retained only for the duration of your active account and is deleted in accordance with our deletion procedures following account deletion or a verified deletion request, subject to reasonable backup purge cycles. Purpose: AI-powered skin wellness analysis for personalized recommendations.
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Changes to This Privacy Policy
We may update this Privacy Policy by posting a revised version with a new effective date. A revised Policy applies only from its effective date. Where applicable law requires prior notice or consent before we use or share information we have already collected in a materially different way, including sensitive or health data, we will give that notice and obtain that consent before doing so.
Your continued use of the Service after the effective date of a revised Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you may delete your account.
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Contact Us
If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:
SkinHappy, LLC
We will respond to all privacy inquiries within 45 days.
- PO Box 287, Monterey, CA 93942
- Email: privacy@skinhappy.ai
This Privacy Policy is effective as of the date listed above and applies to all users of the SkinHappy Service.