Our Privacy Policy

Skinly Privacy Policy

Last Updated on April 17, 2025

Introduction

This Privacy Policy explains how Echelon Digital Inc. ("we", "us", or "our") collects, uses, and protects your personal information when you use our Skinly application ("Skinly" or the "App"), a skincare app designed to help users evaluate their skin quality, find suitable products, follow skincare routines, and track their progress over time.

Information We Collect

We may collect personal information from you when you download our App, register for an account, or interact with our services. This information may include:

- Your name, email address, and contact details

- Profile information and account preferences

- Facial images that you voluntarily provide for skin analysis

- Device information and usage data

- Any other information you voluntarily provide to us

Special Note on Facial Images

Our App collects facial images that you voluntarily submit for the sole purpose of evaluating your skin condition and tracking your skincare progress over time. These images are an essential part of our service that allows us to provide personalized skincare recommendations and progress tracking.

How We Use Your Information

We may use the information we collect from you for various purposes, including:

1. Providing and improving our products and services

2. Personalizing your experience within our App

3. Analyzing your skin condition and tracking changes over time

4. Recommending appropriate skincare products and routines

5. Communicating with you about your account and any updates or promotions

6. Analyzing App usage and user behavior to enhance our offerings

Special Use Limitations for Facial Images

Facial images you provide through the App are used SOLELY for the purpose of evaluating your skin condition and tracking your progress. These images are NEVER used for:

- Facial recognition technology

- Identity verification or linking

- Any purpose beyond skin condition analysis and progress tracking

Data Security

We take data security seriously and employ industry-standard measures to protect your personal information, including facial images, from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

### Special Security for Facial Images

We maintain a strict access control policy for facial images:

- Only you, the user, can access your own facial images through your account

- Internally, only designated employees with a specific need to access the image database for service maintenance and improvement can do so

- All employees with such access are bound by strict confidentiality obligations

Data Retention and Deletion

We retain your personal information, including facial images, for as long as your account is active or as needed to provide you with our services.

### Special Retention Policy for Facial Images

- Facial images are stored for the duration of your active account to enable progress tracking

- If you become inactive (do not use the subscription service) for a period of three (3) years, all facial images associated with your account will be automatically deleted from our systems

- You can request deletion of specific images at any time through the App

Account Deletion

If you choose to permanently delete your account:

- All your personal information, including ALL facial images, will be permanently deleted from our database

- This deletion process may take up to 30 days to complete across all our systems and backups

- To delete your account, go to the "Settings" page in the app, scroll to the bottom, and tap "Delete Account."
Important: Deleting your account does not cancel your subscription. You must cancel it separately through the App Store's Subscriptions tab.

Third-Party Disclosure

We do not sell, trade, or otherwise transfer your personal information, including facial images, to third parties without your consent, except as required by law or as necessary to provide our services. We may share certain non-image information with trusted third-party service providers who assist us in operating our App, conducting our business, or servicing you, provided that they agree to keep your information confidential.