This Privacy Policy explains how Sentienta QualityAI Advanced Technology Research Private Limited. (“Sentienta QualityAI,” “we,” “us,” or “our”) collects, stores, uses, and protects your Personal Data in connection with usage of our website trueskinapp.in and our application TrueSkin (together referred to as “TrueSkin” or the “Services”). This policy also explains your personal data protection rights, and we are happy to help you exercise them. We value your privacy and do our best to ensure its security and comply with Information Technology Act 2010 , and DPDP act 2023. This Policy applies to all of our Services (as defined in our Terms of Service).

Data collection

We collect the following data

1. Your name and email

2. Your age and gender

3. Skin goals, skin issues, habits, behaviors, physical characteristics, including Face Data (defined below)

4. Photos of your cosmetic products

5. AI chatbot data

6. Name, age, sex, skin characteristics, pregnancy/breastfeeding information, ingredient preferences, inferences about your skin.

Please note that photos of your face (further will be referenced as “Face Data”) made with TrueSkin are stored on your device. We delete them from all our systems upon completion of the visual analysis.

2. Face Data:

2.1. Collection and Use of Face Data. We collect photos of your face to personalize your skincare programs based on the visual analysis of your facial skin conditions, such as pimples, wrinkles, pigmentation, and others. Photos may be collected through the in-app camera when you upload a photo during your interaction with our services. Each time a photo is required, the application will explicitly request your consent. We do not capture any photos without your active involvement through the in-app camera.

2.2. Disclosure and Sharing of Face Data. We do not disclose or share your Face Data with any third parties. Our automation only has access to your Face Data during the analysis. Once the analysis is complete, we can’t access your Face Data with any automation. It is technically impossible to access your Face Data for our developers at any moment.

2.3. As a general rule, the Face Data is only stored on your device. The Face Data is deleted from your device upon uninstalling Lovi. We only store your Face Data on the server side during the analysis stage. Therefore, your data will no longer be present on our servers after the analysis is complete. If you, however, provide your consent for TrueSkin to use your photos for TrueSkin improvement, the special retention terms of Section 2.4 below apply.

We only store your Face Data at the server side during the analysis stage. Therefore, your data is no longer present on our servers after the analysis is complete.

2.4. Using Face Data for TrueSkin Improvement. If you provide your prior consent, we will use your Face Data for TrueSkin improvement. In such a case, we will store your Face Data for three years. Consent can be withdrawn anytime by contacting us at support@qualityai.in, and we will promptly delete your Face Data. We do not share your Face Data with any third parties, all the processing is performed on TrueSkin’s side.

3. How Long we retain your personal data

We retain your Personal Data for no longer than is necessary for the purposes of its collection and processing but no longer than is necessary for the purposes of its collection, unless we are required to retain your Personal Data for a longer period due to applicable legislation requirements, any ongoing dispute resolution or in order to enforce our agreements. 

4. What are your data protection rights?

We want to make sure that you are fully aware of all your data protection rights and the ways you can exercise them. You are entitled to the following:

• The right to access. You can ask us for confirmation that we process your Personal Data with the information related to its processing.
  
  
  

• The right to data portability. You can request that we provide you with your Personal Data in a structured and portable format. Apart from that, you can ask us to transmit those data to another controller directly, where technically feasible.
  
  
  

• The right to correction. You can ask us to correct your Personal Data if you believe that it might be inaccurate.
  
  
  

• The right to erasure. You may ask us to erase your Personal Data upon your withdrawal of the consent to processing if you believe that such processing is unlawful. You may also ask us to erase your Personal Data in some other cases. Please note that the erasure of your Personal Data may affect your use of our Services.
  
  
  

• The right to restrict processing. You can request a restriction of your Personal Data processing if you contest the accuracy of your Personal Data
  
  
  

• The right to object to processing. You can object to the processing of your Personal Data that is processed under certain legal bases — for example, the data that we process under the legitimate interest basis.
  
  
  

• The right to lodge a complaint with your local data protection supervisor. You can do so in case you believe that our activities are not compliant with the applicable data protection regulations. However, if you have such concerns about our data protection activities, we would kindly ask you to first contact us at support@qualityai.in and we will do our best to ensure proper handling of your Personal Data.

If you wish to exercise any of the rights above, please contact us at support@qualityai.in  and describe your request in plain language. If you make a request, we have one month to make respective actions in connection with your request. If we need any more time to help you exercise any of your rights, we will let you know, but we will extend the response time by no longer than two more months.

In case your request is vague or unclear, we may engage in a conversation with you in order to better understand your request. We may also refuse manifestly unfounded and excessive requests.

We might ask you to prove your identity while exercising your data protection rights. This is made to ensure that you are indeed entitled to receive certain information and that no rights of third parties are violated by your request. For this reason, we encourage you to contact us using the email that you utilize for login with TrueSkin.

5. Security Measures

We take the protection of your Personal Data very seriously and take all reasonable and appropriate measures to protect them from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction. 

Please understand that the security system is perfect and, as such, we cannot guarantee the absolute security Services, or that your information won’t be intercepted while being transmitted to us. In case your Personal Data got compromised due to a security breach, we will act promptly to identify the cause and take all reasonable steps to remedy the breach. We will inform you of the incident, if necessary, in connection with the applicable legislation. 

If you want to report security incident related to Services, please contact us at support@qualityai.in 

6. Children’s privacy 

We are committed to protecting the privacy of children in India. We do not knowingly collect Personal Data from anyone under the age of 18, as per Indian regulations. If you become aware of any individual under the age of 18 using our Services, please contact us at support@qualityai.in. We will take the necessary steps to remove such information and/or delete the account immediately.

7. Sharing of your Personal Data

We may use external service providers to process your Personal Data on our behalf. When we do so, we have appropriate agreements in place to protect such data. In the case of international transfers, we always make sure the additional safeguards mechanisms are in place. 

Currently, we share your Personal Data with the following Service Providers:

• Google Firebase - Database management and Scalability of our services. You can check the data processing and security terms here. 

• Google Gemini - Google Gemini is used as the AI engine to interpret a user's skincare goals and current condition, it is used to recommend the best skincare products and personalised routines in the app. Here you can check the Gemini API additional Terms of Service. 

8. Change in our privacy policy 

We review our policies regularly to reflect any changes in our collection, processing, sharing, or retention procedures as well as any regulatory changes. You can always find the up-to-date version of our Privacy Policy on our website with the indication of the last update date. 

Contact us

You can contact us using the following email: support@qualityai.in