DM

Privacy Policy

Last updated: July 3 2025

1. Introduction

DS Maker LTD ("DS Maker", "we", "our" or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose and safeguard your information—including face data—when you use the ByeByeAcne mobile application, our website and related services (collectively, the "Services"). By accessing or using the Services, you agree to the practices described below.

2. Definitions

3. Information We Collect

Category Examples Source
Account & Contact Data Name, email, password (hashed), support inquiries Provided by you
Device & Usage Data Device model, OS version, app interactions, crash logs Collected automatically
Face Data • On-boarding selfie
• Weekly progress photos (front & profiles)
• Acne assessment responses (severity, history, lifestyle)
Provided by you
Analytics Events Anonymous in-app events, feature usage Collected automatically

We do not knowingly collect Personal Data from children under 13 (or equivalent minimum age). If you are a parent or guardian and believe we have collected a child's data, please contact us to request deletion.

4. How We Use Your Information

Purpose Legal Basis* Details
Provide & improve Services Performance of contract Account creation, selfie storage, progress display
Acne severity analysis Legitimate interest / Consent On-device & cloud AI grading of face images
Personalised care plans Performance of contract Tailored skincare, nutrition & habit recommendations
Optional AI cosmetic preview Consent Temporary upload to AI Skin Beauty API via RapidAPI
Analytics & product development Legitimate interest Aggregate metrics via Mixpanel to enhance the app
Legal & security Legal obligation Fraud detection, terms enforcement, legal compliance

*If you reside in the EEA/UK, the above GDPR legal bases apply. Consent can be withdrawn at any time via the app.

5. Sharing & Third-Party Processing

Recipient Data Shared Purpose Safeguards
Google Firebase (EU region) Photos, questionnaire answers, auth data Secure storage, database, hosting TLS in transit; AES-256 at rest
AI Skin Beauty API (AILab Tools) via RapidAPI Temporary copy of selfies (Beautify feature) Real-time enhanced image preview Original deleted immediately; enhanced file purged ≤ 24 h
Mixpanel Pseudonymised usage events (no images) Analytics TLS; encrypted at rest; EU Standard Contractual Clauses

We do not sell, rent or share Face Data with advertisers.

6. Data Retention

6.1 Face Data

6.2 Other Data

7. Cookies & Similar Technologies

We use cookies, local storage and SDK trackers (e.g. Firebase Crashlytics, Mixpanel) to:

You may disable non-essential cookies via your browser or device settings, but core functionality may degrade.

8. Security Measures & Data Breach Notification

In the unlikely event of a data breach, we will notify affected users within 72 hours (or as required by law) and inform relevant supervisory authorities.

9. International Transfers

When transferring Personal Data outside the EEA/UK, we rely on EU Standard Contractual Clauses or equivalent safeguards to ensure adequate protection.

10. Your Rights & Choices

You may exercise the following in-app (Settings → Privacy) or by emailing [email protected]:

  1. Access – Receive a copy of your data.
  2. Correction – Update or amend your data.
  3. Deletion – Erase Personal Data ("Delete My Data"). Fulfilled within 30 days.
  4. Portability – Obtain data in machine-readable format.
  5. Objection / Restriction – Limit certain processing activities.
  6. Withdraw Consent – Revoke any consents (e.g. cosmetic preview).

10.1 Additional Rights

11. Children's Privacy

We do not target or knowingly collect data from children under 13. Parents may request deletion of a minor's data via [email protected].

12. Changes to This Policy

We may update this Policy. Material changes will be communicated via in-app notice or email. Continued use after updates constitutes acceptance.

13. Contact Us

For questions or requests regarding this Policy or your data, email [email protected] or write to:

DS Maker LTD
9 Efesou, 5280, Paralimni, Famagusta, Cyprus
Attn: Privacy Officer

End of Policy