Privacy Policy

Last updated: April 2, 2026

1. Introduction

This Privacy Policy explains how Kiwi Skin (referred to as "we" or "us") collects, stores, uses, and protects your personal data when you use our application Kiwi Skin (the "App" or the "Services"). We value your privacy and are committed to protecting it.

By using Kiwi Skin, you agree to the collection and use of information described in this policy.

2. What Data We Collect and Why

When you use our Services, we may collect the following categories of personal data:

Data CategoryHow CollectedPurposeLegal Basis (GDPR)
Device information (hardware model, OS, IP address, unique identifiers)AutomaticallyProvide and improve Services; fix technical issuesArt. 6.1(b) – contract performance; Art. 6.1(f) – legitimate interest
App usage dataAutomaticallyAnalytics and product improvementArt. 6.1(b) – contract performance; Art. 6.1(f) – legitimate interest
Name and email addressProvided by youAccount management and customer supportArt. 6.1(b) – contract performance
Email address (marketing)Provided by youSending updates, offers, and promotions. You may opt-out via 'Unsubscribe' link.Art. 6.1(a) – consent (EU users); Art. 6.1(f) – legitimate interest (non-EU users)
Face photosProvided by youAI-powered skin analysis and personalised recommendationsArt. 6.1(a) – explicit consent
Payment informationProvided by youProcessing in-app purchasesArt. 6.1(b) – contract performance
Location dataAutomatically (if permitted)Personalise recommendations based on climate/regionArt. 6.1(a) – consent
Communications with usProvided by youCustomer support and dispute resolutionArt. 6.1(f) – legitimate interest

You may opt out of AI model improvement at any time by contacting us at [email protected].

3. Face Data

3.1 Collection and Use

We collect photos of your face ("Face Data") solely to personalise your skincare recommendations based on visual analysis of your facial skin (e.g. pimples, wrinkles, pigmentation). Photos are collected through the in-app camera or by uploading an image. We will always request your explicit consent before capturing any photo.

3.2 Storage and Deletion

Face Data is processed on our servers only during the analysis stage and is deleted immediately upon completion. Face Data is not retained on our servers after analysis is complete. The photos are stored locally on your device and are removed when you uninstall the App.

3.3 Sharing

We do not share your Face Data with any third parties. Access is limited to automated systems during analysis only — no human or developer can access your photos.

3.4 Optional Use for App Improvement

If you give your explicit consent, we may retain your Face Data for up to three (3) years to improve Kiwi Skin's AI models. You may withdraw this consent at any time by contacting [email protected], and we will promptly delete your Face Data.

4. How Long We Retain Your Data

We retain your personal data only for as long as necessary to fulfil the purposes described in this policy, or as required by applicable law. When data is no longer needed, we securely delete or anonymise it.

5. Your Data Protection Rights

Depending on your location, you may have the following rights regarding your personal data:

  • Access – Request a copy of the personal data we hold about you.
  • Rectification – Request correction of inaccurate or incomplete data.
  • Erasure – Request deletion of your personal data.
  • Restriction – Request that we restrict processing of your data.
  • Portability – Receive your data in a structured, machine-readable format.
  • Objection – Object to processing based on legitimate interests or for direct marketing.
  • Withdraw Consent – Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please email us at [email protected]. We will respond within one (1) month. We may ask you to verify your identity before processing your request.

6. Sharing Your Data with Third Parties

We use trusted third-party service providers to operate our Services. We share only the minimum data necessary and require all providers to protect your data in accordance with applicable law. Our current service providers include:

  • Amazon Web Services (AWS) – cloud hosting and data storage.
  • OpenAI – AI-powered skin analysis.
  • Firebase / Crashlytics – app performance monitoring and crash reporting.
  • AppsFlyer – marketing attribution and analytics.
  • RevenueCat – subscription management.
  • SendGrid – transactional email delivery.

Where personal data is transferred internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission.

7. Security

We implement reasonable technical and organisational measures to protect your personal data from unauthorised access, loss, or misuse. However, no internet transmission is completely secure. In the event of a data breach that affects your rights, we will notify you as required by applicable law.

To report a security issue, please contact us at [email protected].

8. Children's Privacy

Kiwi Skin is not directed at children under the age of 13 (or 16 in the European Union). We do not knowingly collect personal data from children. If you believe a child has provided us with their data, please contact us at [email protected] and we will promptly delete the information and the account.

9. Cookies

If you access Kiwi Skin through a web browser, we may use cookies to enable core functionality, analyse usage, and support marketing. You can control cookie preferences through your browser settings. Marketing cookies may be used to deliver relevant advertisements.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes through the App or by email. The "Last updated" date at the top of this policy reflects the most recent revision. Continued use of the App after changes are posted constitutes your acceptance of the revised policy.

11. Contact Us

If you have any questions about this Privacy Policy or your personal data, please contact us at:

Kiwi Skin

Email: [email protected]