Privacy & consumer health data
Privacy Policy
This policy explains how Acne Risk collects, uses, derives, discloses, retains, and protects personal information and consumer health data.
1. Scope and operator
This policy applies to the Acne Risk website, web application, owner-operated support tools, and related services (collectively, the “Service”). “Acne Risk,” “we,” “us,” and “our” refer to the operator of the Service.
Acne Risk is a direct-to-consumer tracking service. It is not offered by or on behalf of a doctor, hospital, insurer, or other HIPAA-regulated entity. Information entered into the Service therefore may not be protected by HIPAA. Other privacy and consumer-health laws may apply.
2. Information we collect
| Category | Examples | Source |
|---|---|---|
| Account and identity | Name, email address, authentication identifiers, profile photo, account dates, timezone, and login/security events. | You; Google or Apple if you choose federated sign-in; Supabase Auth. |
| Food and nutrition | Foods, meals, portions, dates and meal periods, calories, macronutrients, favorites, templates, barcodes, imported diary text, and saved/custom foods. | You; imported files; USDA FoodData Central; Open Food Facts; deterministic app calculations. |
| Consumer health data | Acne severity, lesion types and approximate counts, face or body locations, oiliness, redness, pain, healing, morning/evening observations, treatment or routine changes, notes, and progress photos. | You and inferences generated from your requested tracking activity. |
| Derived insights | General estimates, daily exposure summaries, observed food-to-skin associations, personalized estimates, confidence, coverage, stability, and model history. | Deterministic calculations using your food and skin logs and non-personal catalog information. |
| Optional AI inputs | Short voice clips, transcripts, meal images, interpreted food candidates, and AI usage/cost metadata. | You when you invoke a paid AI feature; OpenAI returns the transcript or interpretation. |
| Product and support | Notification preferences, plan/entitlement status, privacy requests, feedback, bug reports, and basic browser, screen, and application context attached to reports. | You and your browser. |
| Technical and security | IP-derived request information available to infrastructure providers, device/browser type, timestamps, rate-limit state, access records, security logs, and pseudonymous provider safety identifiers. | Your browser, our infrastructure, and security controls. |
We do not intentionally collect precise geolocation, government identifiers, financial-account numbers, contacts, or advertising identifiers through the Service.
3. Consumer health data
Consumer health data includes the skin observations, acne-related notes, treatment changes, photos, and food-to-skin inferences described above. We collect and use it to provide the log, timeline, evidence, comparison, export, and personalization features you request; maintain data integrity; secure the Service; respond to your requests; and comply with law.
Sources are you, your use of Service features, and deterministic inferences derived from the information you choose to log. We disclose consumer health data only to the processors described in Section 6 as necessary to provide the requested Service, or when legally required. We do not sell consumer health data and do not use it for targeted advertising.
We will not collect, use, or disclose a new category of consumer health data for a materially different purpose without updating this notice and obtaining consent where required. Photo-storage permission is separate from this policy and can be withdrawn for future uploads at any time. Withdrawal does not automatically delete photos already stored; those can be deleted separately.
4. EEA and GDPR information
This section applies when the EU General Data Protection Regulation or equivalent EEA law applies. Acne Risk acts as the controller for the account and tracking purposes described in this policy. Supabase, Netlify, OpenAI, and other infrastructure providers generally act as processors or independent controllers for the limited functions described in Section 7.
| Processing | GDPR legal basis |
|---|---|
| Account creation, authentication, requested food logging, exports, and core service delivery | Performance of the user agreement or steps requested before entering it (Article 6(1)(b)). |
| Acne observations, treatment information, optional skin photos, food-to-skin inferences, and personalized health-related tracking | Your explicit consent (Articles 6(1)(a) and 9(2)(a)). This consent is requested separately from acceptance of the Terms. |
| Optional product notifications and non-essential communications | Consent (Article 6(1)(a)), withdrawable in notification preferences. |
| Rate limits, security monitoring, fraud prevention, service integrity, and limited operational records | Our legitimate interests in securing and operating the Service (Article 6(1)(f)), balanced against your rights. |
| Tax, accounting, valid legal process, regulatory response, and required breach records | Compliance with legal obligations (Article 6(1)(c)) or establishment, exercise, or defence of legal claims where applicable. |
Health-data consent. Providing health-related tracking data is optional, but Acne Risk cannot deliver its acne timeline, photo, or personalized food-to-skin features without processing the data those features require. You may withdraw consent through My Profile → Privacy requests → Withdraw consent. Withdrawal does not make prior consent unlawful. We will stop future consent-based processing after completing the verified request, subject to limited retention required by law or necessary for legal claims. You may request export or deletion at the same time.
Automated analysis. Acne Risk uses deterministic calculations to generate observational associations and personalized estimates. These outputs do not produce legal or similarly significant effects, are not used for eligibility or high-impact decisions, and are not medical diagnoses. Optional AI food-entry tools generate editable candidates and never silently log them.
International transfers. Service providers may process information in the United States or other countries outside the EEA. Where GDPR transfer restrictions apply, transfers must rely on an applicable adequacy decision or safeguards such as the European Commission’s Standard Contractual Clauses, together with supplementary protections where required. You may request information about the safeguard applicable to a transfer.
EEA rights. In addition to the rights in Section 9, you may request restriction of processing, object to legitimate-interest processing, receive portable data you provided in a structured and machine-readable format, withdraw consent, and lodge a complaint with the supervisory authority in the EEA country where you live, work, or believe an infringement occurred. We ordinarily respond without undue delay and within one month, subject to lawful extensions.
5. How we use information
- Authenticate accounts, maintain profiles, and provide account security.
- Store, organize, display, edit, export, and delete the information you submit.
- Search food catalogs, interpret portions, and calculate nutrition or general food estimates.
- Calculate observational food-to-skin relationships and conservative personalized estimates. These are not diagnoses or proof of causation.
- Process optional voice or meal-photo entries only after you invoke those features, and require your review before foods are logged.
- Track feature entitlements and enforce account and platform AI limits.
- Send security or account communications and, when enabled, optional product or tracking notifications.
- Diagnose bugs, prevent abuse, protect users, audit owner actions, and maintain availability.
- Respond to support and privacy requests and satisfy legal obligations.
Acne Risk does not use OpenAI or another generative model to calculate personalized food-to-skin scores. Those models are deterministic and processed on the application backend.
6. AI voice and meal-photo processing
Voice entry and AI meal-photo logging are optional. A short audio clip or prepared meal image is sent through an authenticated Acne Risk Edge Function to OpenAI for transcription or interpretation. Acne Risk does not save the original voice clip or meal image to your account. Foods are not logged until you confirm the review sheet.
Requests use store: false. OpenAI states that API data is not used to train its models unless the API customer opts in. OpenAI may nevertheless process or retain content and related metadata under its then-current API data controls, including safety and abuse-monitoring exceptions. The current OpenAI data controls are linked in Section 6.
Acne Risk stores limited AI accounting records such as the feature, request status, token or audio usage, estimated cost, provider request identifiers, and error codes. These records support allowance enforcement, abuse prevention, billing reconciliation, and troubleshooting.
7. Processors and disclosures
We do not sell personal information or consumer health data. We do not share it for cross-context behavioral advertising. We disclose information only as described below:
| Recipient/category | Purpose and data |
|---|---|
| Supabase | Authentication, database hosting, private file storage, Edge Functions, security controls, and account emails. It processes account, food, skin, photo, usage, and operational data as needed to host the Service. |
| Netlify | Website delivery, hosting, request routing, and infrastructure security. It may receive ordinary web-request and device information. |
| OpenAI · API data controls | Optional voice transcription and meal-image interpretation. It receives only the clip/image and prompt context needed for the feature, plus a pseudonymous safety identifier and request metadata. |
| Google or Apple | Only when you choose that provider for sign-in. The provider returns account authentication information to Supabase. |
| USDA FoodData Central and Open Food Facts | Food, nutrition, and barcode lookup. Search terms or barcodes may be sent; Acne Risk does not intentionally send skin logs or account identifiers to these catalogs. |
| Professional advisers and authorities | Limited information when reasonably necessary for legal advice, audits, insurance, security response, enforcing rights, complying with lawful process, or protecting users and the public. |
| Business successor | Information may transfer as part of a merger, financing, reorganization, bankruptcy, or sale of assets, subject to applicable law and continued protection consistent with this policy. |
Processors may operate in the United States or other jurisdictions. Their handling is also governed by their agreements with Acne Risk and their own legal obligations.
8. Retention
- Account, food, skin, and personalized-model data: retained while your account is active and until deleted through available controls or an approved request, subject to backup, fraud-prevention, dispute, and legal-retention needs.
- Private skin photos: retained until you delete them or your account data is deleted. Withdrawing future photo consent does not delete existing photos.
- AI media: original voice clips and meal images are not stored in your Acne Risk account. Provider-side temporary processing or safety retention is governed by the provider controls described above.
- AI usage, consent, privacy-request, security, and audit records: retained as reasonably necessary to enforce limits, document choices, investigate abuse, respond to disputes, and meet legal obligations.
- Feedback and bug reports: retained until resolved and thereafter as reasonably necessary for product history, security, and dispute prevention.
Retention periods depend on the nature and sensitivity of the data, the feature requested, security and operational needs, and legal requirements. Data may remain temporarily in encrypted or access-controlled backups until those backups cycle out.
9. Your choices and rights
Depending on where you live, you may have rights to access, know, export, correct, delete, or restrict certain processing; withdraw consent; appeal a refusal; and receive equal service without unlawful discrimination. Acne Risk does not require you to waive applicable privacy rights.
- Open My Profile → Privacy requests.
- Select access, export, correction, deletion, or consent withdrawal.
- Submit the request from your authenticated account so we can verify identity.
You can also delete individual food entries, observations, and photos or export acne-log data using in-product controls. We may need additional verification and may retain information where an exception or legal obligation applies. If a request is denied, submit a new privacy request marked as an appeal in the request details or use Feedback & requests.
Because we do not sell personal information, share it for targeted advertising, or use it for targeted advertising, there is no sale/targeted-advertising opt-out required for current practices. If those practices change, this policy and the relevant controls will be updated first.
10. Security and breaches
We use measures designed for the sensitivity of the data, including authenticated access, row-level database policies, private storage, restricted service credentials, upload validation, rate limits, audit records, transport encryption, and bounded server-side processing. No service can guarantee absolute security.
If we discover an incident requiring notice, we will notify affected users and regulators as required by applicable law, which may include the FTC Health Breach Notification Rule.
11. Children
The Service is intended for adults and is not directed to children under 13. We do not knowingly collect personal information from a child under 13 without legally valid parental authorization. If we learn that such information was collected contrary to law, we will take appropriate steps to delete it. Users between 13 and the age of legal majority should use the Service only with permission from a parent or legal guardian where required.
12. Health and medical limitation
Acne Risk is a self-tracking and informational tool, not a medical device or health care provider. Scores, associations, AI interpretations, and research summaries are estimates and may be incomplete or wrong. They are not medical advice, diagnosis, treatment, or proof that a food caused an outcome. See the Terms & Medical Disclaimer.
13. Changes to this policy
We may update this policy as the Service or law changes. We will revise the effective date and provide additional notice when required. We will not use previously collected consumer health data for a materially new purpose without the notice or consent required by applicable law.
14. Contact, controller, and EEA representative
Authenticated users can contact the operator through My Profile → Privacy requests for privacy rights or Feedback & requests for general support. These authenticated channels are used to reduce impersonation and protect account data.
Before Acne Risk is offered to people in the EEA, this section must identify the controller’s legal name, postal address, public privacy email, and—if Article 27 requires one—the appointed EEA representative and contact details. Those details have not yet been supplied for publication, so this local draft is not by itself sufficient for an EEA public launch.