1. What consumer health data we collect
Consumer health data is information that identifies your past, present, or future physical or mental health. In FaceCard, that means:
- Face photos taken during a skin scan, and any inference drawn from them. The photos are sent to an AI service for analysis and are not stored on our servers, except for the optional baseline photos you can choose to save.
- Skin assessments produced by the AI: scores for hydration, texture, tone, radiance, clarity, spots, breakouts, and puffiness, along with written observations, a routine, and product suggestions.
- Skin history you tell us: skin type, recent skin changes, the area you want to improve, and active ingredients you use.
- Allergies and sensitivities you list so the app can flag products you may react to.
- Skin Journal entries: sleep, water intake, stress, diet, exercise, free-text notes, and, if you turn it on, cycle tracking (whether you are on your period and your cycle day).
- Ethnicity, if you choose to provide it. Ethnicity is not health data on its own, but we treat it with the same care because it is used to calibrate your skin assessment.
We do not collect biometric identifiers. We do not identify you from your face, and we do not create face templates. We do not collect precise location, and we do not use geofencing around any facility for any purpose.
2. Where it comes from
- You. You take the photos, answer the profile questions, and fill in the journal.
- Our AI analysis provider. A third-party artificial intelligence service returns the skin assessment generated from your photos and profile.
- Your device. The app keeps your journal and scan results on your device and syncs them to your account.
We do not buy consumer health data and we do not obtain it from data brokers, social networks, or other apps.
3. Why we collect it and how we use it
We collect consumer health data only for the purposes below. Each purpose is one you asked for by using the feature.
| Consumer health data | Purpose |
|---|---|
| Face photos | To generate your skin assessment; if you opt in, to keep a baseline you can look back on |
| Skin assessments | To show you your results, build your routine, and track your progress over time |
| Skin history and active ingredients | To calibrate the assessment and the routine |
| Allergies and sensitivities | To calibrate the assessment and to warn you when a suggested product contains an ingredient you react to |
| Skin Journal, including cycle tracking | To show you patterns between your habits and your skin scores; these patterns are calculated on your device |
| Ethnicity | To calibrate the assessment, because skin presents differently across skin tones |
We do not use consumer health data for advertising, we do not sell it, we do not use it to build profiles of you for anyone else, and we do not use it to train AI models. Journal entries, including cycle tracking, are never sent to our AI analysis provider.
4. Who we share it with
We share consumer health data only with the service providers below, only so they can provide their service to us, and only under written terms that restrict them to that purpose. We do not sell consumer health data, and we would need your separate, signed authorization to do so.
| Category of third party | Consumer health data it receives | Why |
|---|---|---|
| AI analysis provider (a third-party artificial intelligence service) | Face photos from each scan, plus skin type, skin changes, active ingredients, allergies, ethnicity, age, gender, lifestyle, and routine depth | Generates the skin assessment. Does not use the data to train its models. Keeps it for up to 30 days for abuse monitoring, then deletes it |
| Cloud hosting and database provider | Skin assessments, skin history, allergies, journal entries including cycle tracking, ethnicity, and baseline photos if you opt in; relays scan photos to the AI analysis provider without storing them | Hosts our database, file storage, and server functions in the United States |
No other company receives consumer health data. Our subscription, SMS, push notification, and platform providers, including Apple, do not receive health data. Amazon receives nothing from us when you tap a product link. Barcode lookups send only a product barcode to public product databases, never health data. We will provide the names and contact details of the third parties above on request; see section 8.
We may also disclose consumer health data if a valid legal demand requires it, and to a successor operator if the company is sold or merged, as described in the Privacy Policy.
5. Consent, and how to withdraw it
We ask for your consent before collecting consumer health data that is not strictly necessary for a feature you have already requested, and before any use or sharing beyond what this policy describes.
- Face photos and assessments. Before your first scan, the app shows a Face Data notice and asks you to agree. Scans only run when you start them.
- Allergies and skin history. You enter these during onboarding after a short notice. You can edit or clear them in Settings, then My Profile.
- Ethnicity. Optional, in My Profile, with a "Prefer not to say" choice.
- Cycle tracking. Off until you turn it on in the Skin Journal, after a short notice.
- Baseline photos. Saved only if you tap "Save privately" after your first scan. Declining is remembered.
To withdraw consent: stop scanning; clear a field in My Profile; turn cycle tracking off; remove baseline photos in Progress; or delete your account in Settings. Withdrawing consent does not affect processing that already happened, but it does stop further collection and use, and deleting data removes it from our systems.
6. Your rights and how to exercise them
Whatever state you live in, you may:
- Confirm and access. Ask whether we collect, share, or sell your consumer health data, get a copy of it, and get a list of every third party with whom we have shared it and how to contact them. Section 4 lists the categories; we will provide the names and contact details when you ask.
- Withdraw consent as described in section 5.
- Delete. Have your consumer health data deleted from our systems, from our service providers, and from backups on their normal cycle. Delete Account in Settings does this immediately for our live systems.
- Appeal. If we decline a request, we will explain why. Email support@facecard.app with the subject "Health data appeal." We will respond within 45 days. If you disagree with the result, you may contact your state attorney general.
How to ask. Use the controls in the app, or email support@facecard.app with the subject "Health data request." We will verify you by matching your request to the email address or phone number on your account, or by sending a one-time code. An authorized agent may act for you with your written permission. We respond within 45 days and may extend once by 45 days if we tell you why. We will not charge you, deny you the app, or treat you differently for exercising a right.
7. Affiliates
FaceCard Technologies Inc. has no affiliates that receive consumer health data.
8. Contact
- Email: support@facecard.app
- Post: FaceCard Technologies Inc., 25634 Moore Lane, Stevenson Ranch, CA 91381
We will update this policy when our health data practices change, post the new date at the top, and ask for your consent again in the app before any change that expands how we collect or share consumer health data.
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