Privacy Policy

1. Introduction

Radiate ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services (collectively, the "Service").

Radiate is an AI-powered skincare companion that helps you analyze product ingredients, track your skin's progress through selfie analysis, receive personalized skincare reminders, and build effective skincare routines tailored to your skin profile.

2. Information We Collect

Personal Profile Information You Provide

• Name: Your name for personalization.
• Age / Date of Birth: Used to tailor skincare recommendations to your age group.
• Gender: Female, male, or other.
• Ethnicity: Used to provide skin analysis and recommendations relevant to your skin tone and characteristics.
• Skin Type: Oily, dry, normal, or combination.
• Skin Sensitivity: Sensitive or non-sensitive.
• Skin Concerns: Such as acne, dark spots, wrinkles, scarring, dry skin, or enlarged pores.
• Beauty Goals: Such as achieving clear skin, reducing dark spots, evening skin tone, or anti-aging.
• App Usage Intent: How you plan to use the app.
• Language Preference: English or Korean.

Facial Images and Skin Data

• Selfie Photos: Facial images you capture for skin analysis. These are stored locally on your device and uploaded to our cloud storage for AI analysis.
• Skin Metrics: AI-generated scores (0–100) for overall skin health, texture, hydration, acne, dark spots, pore size, elasticity, brightness, and wrinkles.
• AI Commentary: Analysis notes and progress comparisons generated by AI.

Product Data

• Product Scans: Product name, brand, ingredients, and AI analysis results when you scan skincare products.
• Product Photos: Images of products you photograph for ingredient analysis.

Subscription and Purchase Information

• Subscription Plan: Your selected plan (monthly or yearly).
• Referral Code: If provided.

Information Collected Automatically

• Device Information: Device type, operating system, and platform.
• Usage Data: App interactions, features used, product scans, skin analyses completed, and onboarding progress.
• Analytics Identifiers: A persistent anonymous UUID generated locally for analytics purposes.
• Network Status: Device connectivity state.

Information We Do NOT Collect

3. How We Use Your Information

We use the information we collect to:

• Provide AI-powered skin analysis based on your selfies and skin profile
• Analyze product ingredients and provide safety assessments personalized to your skin
• Track your skin's progress over time with metric scores and comparisons
• Generate personalized skincare reminders and routine recommendations
• Customize the app experience based on your skin type, concerns, and goals
• Improve app features and user experience through analytics
• Provide customer support
• Detect, prevent, and address fraud or technical issues
• Comply with legal obligations

4. AI-Powered Features and Data Processing

Radiate uses third-party AI services to power its core features. When you use the app:

Skin Analysis

• Your selfie is uploaded to our cloud storage (Supabase) and a secure URL is sent to AI services for analysis.
• Your skin profile (skin type, concerns, goals, sensitivity, age, ethnicity) is included for personalized analysis.
• The AI returns skin metric scores, commentary, and progress comparisons.

Product Analysis

• Product photos or descriptions are sent to AI services for ingredient analysis.
• Your skin profile is included so the AI can assess ingredient safety for your specific skin.

Smart Reminders

• Your skin profile, product shelf, and latest skin analysis are sent to AI services to generate personalized reminders.

We do not control how third-party AI providers process the data they receive. Each provider operates under its own privacy policy and data handling practices.

5. Third-Party Services

We use the following third-party services to operate the app:

Each third-party service operates under its own privacy policy. We encourage you to review their respective policies.

6. Information Sharing

Service Providers: We share information with the third-party service providers listed above solely to operate and improve the Service.

AI Providers: Your skin profile data and images are shared with AI providers to deliver analysis results. This data is transmitted securely via HTTPS.

We Do Not Sell Your Data: We do not sell, rent, or trade your personal information — including your facial images, skin data, or health information — to third parties for marketing or advertising purposes.

Legal Disclosure: We may disclose your information if required by law, in response to valid legal process, to protect our rights or property, to prevent fraud, or to ensure user safety.

7. Sensitive Data Protections

We recognize that this app collects sensitive categories of data including:

• Biometric-adjacent data: Facial images (selfies) used for skin analysis
• Health-related data: Skin condition metrics and concerns
• Demographic data: Ethnicity, age, and gender

We apply the following protections to this data:

• All data transmission uses HTTPS/TLS encryption
• Facial images are used solely for skin analysis — never for facial recognition or identity verification
• Ethnicity data is used only to provide relevant skincare recommendations
• Health-related skin data is not shared with insurance companies, employers, or data brokers
• You can delete your selfies and skin journal entries at any time

8. Face Data and Selfies

This section describes how Radiate collects, uses, stores, and deletes photographs of your face ("selfies") and any data derived from them ("face data").

What We Collect

When you take or upload a selfie inside the Skin Journal feature, we collect:

• The selfie image itself — the photo you capture or select.
• Derived skin metrics — nine numeric scores (0–100) covering overall condition, texture, hydration, acne, dark spots, pore quality, elasticity, brightness, and wrinkles, produced by our AI model from the image.
• AI commentary and comparison notes — short text summaries describing the image and, where available, changes since your previous entry.
• A timestamp indicating when the entry was created.

We do not create a biometric face template or faceprint, and we do not use your face to identify you across other apps, devices, or services. We do not run facial recognition, emotion inference, or demographic inference on your selfies.

How We Use It

Face data is used solely to:

• Provide personalized cosmetic skincare insights and trend tracking within the app.
• Generate personalized reminders based on your recent skin analysis.
• Allow you to review your own history across time.

We do not sell, rent, or share face data with advertisers or data brokers, and we do not use face data to train third-party foundation models.

How It Is Processed

Selfies are:

• Uploaded securely (HTTPS) to our storage provider (Cloudflare R2), scoped to your anonymous user ID.
• Sent to our AI provider(s) solely to produce the skin metrics, commentary, and comparison notes. The providers process the image under contract and do not retain it for their own training.
• Stored alongside the derived metrics in our database (Supabase) under your anonymous user ID.

Retention and Deletion

• Selfies and derived face data are retained only as long as you keep them in your Skin Journal.
• You can delete any individual entry at any time from the journal detail screen — this removes the image from storage and the row from our database.
• You can delete all your face data at once from Settings → Delete All My Data. This permanently removes every selfie, every derived metric, every commentary string, and every local cached copy, both on your device and on our servers.
• Deleted face data is not recoverable.

Your Rights

You can also request full deletion or export of your data at any time by emailing appstudio@kgen.io. We will respond within 30 days.

Legal Basis

Where GDPR or similar regimes apply, our legal basis for processing face data is your explicit consent, given when you grant the app access to your camera or photo library and when you choose to submit a selfie for analysis. You can withdraw consent at any time by deleting your data and uninstalling the app.

Children

The app is not directed to children under 13 (or the applicable minimum age in your region). We do not knowingly collect face data from children.

9. Data Storage and Security

• User profile data, product analyses, and skin journal entries are stored securely on Supabase cloud infrastructure.
• Facial images and product photos are stored in secure cloud storage (Supabase Storage).
• Local copies of images, product data, and reminders are stored on your device in the app's private directory.
• User preferences (name, skin profile, theme, language) are stored locally using SharedPreferences.
• All network communication uses HTTPS/TLS encryption.

Despite our efforts, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.

10. Data Retention

• Profile Data: Retained while you use the app, stored locally and in cloud storage.
• Skin Journal Entries: Retained until you delete them or request account deletion.
• Facial Images: Retained until you delete them or request account deletion.
• Product Scan History: Retained until you remove products from your shelf or request account deletion.
• Analytics Data: Retained in accordance with our analytics provider's policies.

Upon account deletion request, we will remove your personal data, including facial images, within 30 days. Some information may be retained in anonymized form or as required by law.

11. Your Rights and Choices

Access and Correction: You can view and update your skin profile and preferences through the app settings.

Deletion: You can delete individual skin journal entries, selfies, and scanned products within the app. To request full account and data deletion, contact us at the email below.

Camera and Photo Access: The app only accesses your camera or photo gallery when you explicitly initiate a scan or selfie. You can revoke these permissions through your device settings.

Notifications: You can enable or disable skincare reminders and notifications through the app or your device settings.

CCPA Rights (California Residents): You have the right to know what personal information we collect, request deletion, opt out of sale (we do not sell data), and not be discriminated against for exercising these rights.

GDPR Rights (EEA Residents): You have the right to access, rectify, erase, restrict processing, port your data, object to processing, and withdraw consent at any time. Given that we process sensitive data (health-related and biometric-adjacent), we rely on your explicit consent as the legal basis for processing.

12. Children's Privacy

Radiate is not intended for use by children under the age of 13 (or 16 in the European Economic Area). We do not knowingly collect personal information from children. If we discover that we have inadvertently collected information from a child, we will take steps to delete it promptly, including any facial images. If you believe a child has provided us with personal information, please contact us immediately.

13. International Data Transfers

Your information, including facial images and skin data, may be transferred to and processed in countries other than your country of residence, including the United States. By using the Service, you consent to such transfers. We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy regardless of where it is processed.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the most recent revision. We will notify you of material changes through the app or other appropriate means. Your continued use of the Service after changes take effect constitutes acceptance of the updated policy.

15. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy, your personal data, or your facial images, please contact us:

16. Consent

By using Radiate, you acknowledge that you have read and understood this Privacy Policy — including the collection of facial images, skin health data, and demographic information — and agree to its terms.