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Privacy Policy

Last updated: August 11, 2025

This Privacy Policy describes Our policies on the collection, use, and disclosure of Your information when You use the Service and tells You about Your privacy rights. We use Your Personal data to provide and improve the Service, particularly to offer personalized insights and recommendations. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Accountmeans a unique account created for You to access our Service or parts of our Service.
  • Affiliatemeans an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Applicationrefers to Vera Beauty, the software program provided by the Company.
  • Company(referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Vera Beauty Inc., 2300 Maple Ave, Torrance, CA 90503.
  • Countryrefers to: California, United States
  • Devicemeans any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Facial Analysis DataInformation and scores generated by our AI from your facial photos, such as skin tone classification, perceived age, and scores for lines, breakouts, sagging, etc.
  • Personal Datais any information that relates to an identified or identifiable individual. For the purpose of the CCPA, Personal Data corresponds to Personal Information. This includes Sensitive Personal Data.
  • Sensitive Personal DataA subset of Personal Data that may include government identifiers, precise geolocation, race, ethnicity, religion, genetic data, biometric data, health information, or sexual orientation.
  • Servicerefers to the Application.
  • Service Providermeans any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Datarefers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • User-Generated ContentInformation you provide in your Diary or post in Talk Groups, such as treatment history, opinions, and photos.
  • Youmeans the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data You Provide Directly

While using Our Service, particularly the AI Aesthetician, We may ask You to provide Us with certain personally identifiable information, including Sensitive Personal Data. This includes:

  • Contact Information: Phone number.
  • Profile & Demographic Information: Birth year, gender identity, ethnicity.
  • Aesthetic & Health Information: Your treatment history and primary aesthetic concerns.
  • Sensory & Biometric Data: The three (3) facial photos (front, left profile, right profile) you upload for Facial Analysis.
  • User-Generated Content: Information and photos you add to your Diary or post in Talk Groups.

Data We Generate and Infer About You

When you use certain features of our Service, particularly the AI Aesthetician, our systems analyze the data you provide to generate new information and inferences, which are linked to your account. This includes:

  • Facial Analysis Data: Based on the facial photos you upload, our AI generates a comprehensive analysis which may include:
    • Skin Tone Classification: An evaluation of your skin tone based on the Monk Skin Tone Scale.
    • Perceived Age: An estimation of your skin's age based on visible characteristics.
    • Detailed Skin Scores: Individual scores estimating the presence and severity of various skin characteristics, including Lines, Breakouts, Sagging, Pigmentation, Pores, Redness, Dark Circles, and Eye Bags.
  • AI-Generated Summaries and Recommendations: This includes any treatment recommendations or summaries of clinics and treatments that our AI Aesthetician generates based on your profile and concerns.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

  • Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

How and Why We Use Your Personal Data, Including Sensitive Data

We use your data for specific purposes, and we only collect sensitive data like ethnicity, gender identity, and facial photos to provide you with the core features of the AI Aesthetician.

  • To Provide and Maintain our Service: Including the core functionality of the Research tool, Diary, and Talk Groups.
  • To Provide Facial Analysis & Personalized Recommendations:
    • Your facial photos are used to generate your Facial Analysis Data.
    • Your birth year helps us tailor recommendations for different life stages.
    • Your ethnicity helps us provide information on how different skin types and facial structures can influence treatment outcomes and potential complications.
    • Your gender identity helps us account for hormonal differences that may require tailored treatments.
  • To manage Your Account: To manage your registration as a user.
  • To Contact You: Regarding updates or informative communications.
  • For Business Transfers: In the event of a merger, sale, or acquisition.
  • For Other Purposes: Such as data analysis and identifying usage trends.

Use of Your Data for Service Improvement and AI Training

To help us improve the accuracy and performance of our AI models and the Facial Analysis feature, we may wish to use certain data, including your facial photos, for research and development purposes.

This is completely optional and requires your explicit consent.

  • Your Control: You can grant or revoke consent for the use of your photos for AI training at any time in your Account settings. Your choice will not affect your access to the core features of the Service.
  • Our Commitment to Privacy: If you do consent, we will take steps to de-identify the data by separating it from your direct personal identifiers (like your phone number) before it is used by our research teams. Our goal is to use the information to improve our models without knowing it's *your* specific data.

How We Share Your Personal Information

We may share Your personal information in the following situations:

  • With Service Providers: To monitor and analyze the use of our Service, provide hosting, and to contact You.
  • With Other Users: When you share personal information in public areas like the Talk Groups or set a Diary entry to "public," this information may be viewed by all users and publicly distributed. Private diary entries are not shared.
  • For Business Transfers: We may share or transfer your personal information during negotiations of any merger, sale of Company assets, or financing.
  • With Affiliates: We may share Your information with Our affiliates.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention and Deletion of Your Personal Data

We will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. You have the right to delete your data. When you delete your account, we will take steps to delete your Personal Data, including your photos and Facial Analysis Data, from our servers in accordance with applicable law. Please note that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Your Privacy Rights under the CCPA (California)

This section supplements our Privacy Policy and applies solely to residents of California. We have collected the following categories of personal information within the last 12 months:

  • Identifiers (e.g., phone number).
  • Personal information categories listed in the California Customer Records statute (e.g., phone number, birth year).
  • Protected classification characteristics under California or federal law (e.g., gender identity, ethnicity, age).
  • Commercial information (e.g., treatment history).
  • Biometric information (e.g., facial photos and derived data).
  • Internet or other electronic network activity information.
  • Sensory data (e.g., your photos).
  • Inferences drawn from other personal information (e.g., Facial Analysis Data).

You have the following rights:

  • The Right to Know and Access: The right to request what personal information we collect, use, disclose, and sell.
  • The Right to Delete: The right to request the deletion of your personal information.
  • The Right to Correct: The right to request correction of inaccurate personal information.
  • The Right to Limit Use and Disclosure of Sensitive Personal Information: We only collect and use Sensitive Personal Information (such as your facial photos, ethnicity, and treatment history) to provide the services you have requested, like generating your Facial Analysis and personalizing your recommendations. Under California law, this is a permitted business purpose. However, you have the right to direct us not to use your Sensitive Personal Information for any other secondary purposes. You can manage your consent for secondary uses, such as for AI model improvement, directly in your account settings.
  • The Right to Opt-Out of Sale/Sharing: We do not "sell" your personal information in the traditional sense. However, you have the right to direct us not to share your information.

To exercise these rights, please contact us.

Children's Privacy

Our Service is not intended for anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under 18. If you are a parent or guardian and you are aware that your child has provided Us with Personal Data, please contact Us.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: