Privacy Policy

Effective Date: March 8, 2026 · Last updated: November 3, 2026

1. Introduction

kissinskin ("we", "our", "us") operates the website https://kissinskin.net. This Privacy Policy explains how we collect, use, protect, and disclose your information when you use our AI makeup analysis service ("Service").

We are committed to protecting your privacy and complying with applicable data protection laws worldwide, including the EU General Data Protection Regulation (GDPR), UK GDPR, California Consumer Privacy Act (CCPA/CPRA), Brazil's Lei Geral de Proteção de Dados (LGPD), South Korea's Personal Information Protection Act (PIPA), Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Japan's Act on the Protection of Personal Information (APPI), and the Australian Privacy Act 1988.

2. Data Controller

kissinskin is the data controller responsible for your personal data processed through the Service. For payment-related data, Polar acts as an independent data controller.

• Data Controller: kissinskin
• Contact: [email protected]
• Website: https://kissinskin.net

3. Information We Collect

3.1 Photos You Upload (Biometric/Facial Data)

• When you use our Service, you upload a facial photo for AI analysis.
• Your photo is sent to OpenAI's API (makeup image generation) and Google's Gemini API (tone and product analysis report) for processing, and is not stored on our servers.
• Photos are processed in real-time memory and discarded immediately after your analysis results are generated.
• We do not keep, archive, or back up your photos in any form.
• Biometric data notice: Your facial photo may constitute biometric data under certain laws (e.g., Illinois BIPA, Texas CUBI, Washington state law). We do not extract, store, or create biometric identifiers or templates from your photos. The photo is used solely for the purpose of generating AI makeup simulations and is not retained.

3.1.1 Records Saved to Your Account (signed-in members)

• When a signed-in member saves them, we keep your free quiz results (My Beauty Record), saved AI makeup looks and saved makeup how-tos (/looks/) linked to your account (Supabase) so you can reopen them on My Page.
• Your uploaded photos are never stored. We keep result values such as quiz types and look names; a saved AI makeup look also keeps a link to its generated result image. These records are deleted together with your account. To delete a generated result image itself, email its link to [email protected].

3.1.2 Face Shape Selfie Measurement (processed on your device only)

• The face shape tool's "measure from a selfie" option never sends your photo to a server. It runs in your browser, locates the face outline and computes only the ratios of forehead, cheekbone and jaw widths and face length.
• A small copy of the photo with measurement lines and the resulting ratios are kept only in that browser tab's session storage (up to 6 hours, cleared when the tab closes) so the result page can show them. We cannot collect or see them.
• We do not create or store biometric identifiers or face templates.

3.1.2-2 Face Reading & Five Elements Makeup (processed on your device only)

• Face reading runs in your browser only, like the face shape tool — your photo is not sent to a server. It computes only ratios such as eye shape and feature proportions.
• Your birth date (and optional birth hour) is used only to compute your five elements and is not sent to a server. Your result, birth date and Face Dex stay in this device's browser storage (localStorage) so they can be shown again, and disappear when you clear your browser data. We cannot collect or see them.
• "Send to friends" links contain only your animal face, fortune scores and element summary — never your photo or birth date.
• Only if you choose to try the prescribed makeup on your face is your selfie used for AI makeup generation, handled exactly as in Section 3.1 (AI makeup).
• If you request a full reading, we send only your already-computed results (pillar characters, element counts, animal-face percentages, face ratios and fortune scores) — never your raw birth date or photo — through our server to OpenAI to write the reading. Our server does not store them, and the reading is saved only on this device.

3.1.3 Email Subscription & Result Emails

• When you subscribe to our newsletter or ask for your quiz result by email, we keep your email address, the page you signed up from, and your language. A subscription only starts after you click the button in the confirmation email (double opt-in), and you can unsubscribe at any time via the link at the bottom of every email.
• Creating an account does not sign you up for the weekly (promotional) email. Members are asked separately, on the site, whether they want it (optional); we record your choice and when you made it, and you can change it any time on My Page. Saying no does not limit the service. Service emails such as password resets and delivery of something you bought are sent regardless.
• Emails are sent through Resend, which measures whether an email was opened (a 1×1 transparent image in the email) and which links were clicked (redirected via links.kissinskin.net). We use this only to improve delivery and content, and measurement stops once you unsubscribe.

3.1.9 Images You Post to the Customer Gallery (Optional)

• Only if you choose Post to the gallery on a result, or pick a saved result with Upload from my photos on the gallery page, and agree to show it publicly, we store the one image you selected (resized to 1024px on the long side), its look or feature name, your account ID and a record of your consent (Supabase). Posting from a result never sends your original selfie, and photos uploaded from your device that are not kissinskin results are rejected and deleted.
• The image stays private until we review and approve it. Once approved, it appears in the gallery and on the home page without your name or email. Anyone can view public images, and others may save them.
• Only people aged 18 or older may post, and only photos of themselves.
• Retention: until you delete the image or your account. You can delete it and withdraw consent at any time under "My photos" in the gallery. Rejected images are deleted right away.
• Heart and report records are stored with your account ID. Only the number of hearts is shown publicly.

3.2 Payment Information

• All payment processing is handled by Polar (polar.sh), acting as our Merchant of Record.
• We never receive, see, or store your credit card number, CVV, or full billing details.
• Polar collects the necessary payment information (card details, billing address, email) to process your transaction. This data is subject to Polar's Privacy Policy.
• We may receive from Polar: transaction confirmation, order amount, and a reference ID for customer support purposes.

3.3 Automatically Collected Data and Cookies

This site currently shows no third-party display (banner) ads. We use the following third-party services with cookies and similar technologies (localStorage, pixels) to operate the site and measure anonymous usage. EU/EEA and UK visitors are protected by Google Consent Mode v2: analytics cookies remain disabled until you click "Accept all" on the cookie banner.

Display advertising: This site currently serves no third-party display ads, including Google AdSense, and uses no advertising cookies. If we introduce advertising in the future, we will update this policy and collect separate consent through the cookie banner.

Changing your consent: Clearing your browser storage or site data will re-show the cookie banner.

Coupang Partners affiliate links: Some product recommendation cards and the "Find on Coupang" buttons on makeup how-to (/looks/) pages contain Coupang affiliate links, marked with rel="sponsored". Tracking cookies (e.g. OVERSEAS_GUEST_COUNTRY, X-CP-PG-NID) are set by the Coupang domain (link.coupang.com, coupang.com) only when you click such a link. These cookies are not set by kissinskin.net and we have no access to the data they collect. Affiliate revenue does not influence which products we recommend. See Coupang Partners for their policies.

LinkPrice (CLIO) affiliate links: Some product recommendation cards and perfume diagnostic result pages contain CLIO official store (clubclio.co.kr) affiliate links served through LinkPrice, marked with rel="sponsored". Tracking cookies are set by the LinkPrice domain (newtip.net) and the CLIO domain only when you click such a link. These cookies are not set by kissinskin.net and we have no access to the data they collect. Affiliate revenue does not influence which products we recommend. See LinkPrice for their policies.

4. Legal Basis for Processing (GDPR Article 6)

For users in the EU/EEA and UK, we process your data based on the following legal grounds:

5. How We Use Your Information

6. Automated Decision-Making & Profiling

In accordance with GDPR Article 22:

• The Service uses automated processing (AI models by OpenAI and Google Gemini) to generate makeup simulations and analysis reports.
• This automated processing produces results that are artistic/cosmetic in nature and do not produce legal effects or similarly significantly affect you.
• We do not use your data for profiling, targeted advertising, credit scoring, or any automated decision-making that produces legal or similarly significant effects.
• The legal basis for this automated processing is your explicit consent provided when you upload your photo and initiate the analysis.

7. Third-Party Services & Data Processors

We use the following third-party services. Each has their own privacy policy:

Important: Your tone & product analysis report is processed by either Google Gemini or OpenAI. Which one is used is decided automatically at request time based on service availability; the protections below apply either way. OpenAI's API data usage policy states that data sent through the API is not used to train their models. We use the Google Gemini API on a paid tier only; under the Gemini API Terms, Google does not use prompts, uploaded files, or responses from paid services to improve its products. We never use your photos to train any model of our own.

8. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence, including the United States and Singapore. We ensure appropriate safeguards are in place:

• EU/EEA to US & Singapore: Transfers to OpenAI, Google, Polar, Resend and Supabase are protected by Standard Contractual Clauses (SCCs) as adopted by the European Commission, and/or the EU-U.S. Data Privacy Framework where applicable.
• UK: Transfers are protected by the UK International Data Transfer Agreement (IDTA) or UK Addendum to EU SCCs.
• South Korea: Cross-border transfers comply with PIPA Article 17 requirements. Your consent to use the Service constitutes consent to cross-border data transfer for the stated purposes.
• Brazil: Transfers comply with LGPD Article 33, based on your consent and adequate safeguards.
• Japan: Transfers comply with APPI requirements, with appropriate safeguards in place.
• We do not store your uploaded photos, so their transfer is transient and limited to the duration of AI processing. Member accounts, records saved to your account and subscription emails are kept in Supabase (Singapore) and deleted as described in Section 15.

9. Data We Do NOT Collect

• We do not directly collect your name, phone number, or address (except information you provide to Polar during payment, or the email you enter to receive your analysis report).
• We do not force you to create user accounts or profiles.
• We do not use your uploaded photos to train any model of our own — OpenAI's API no-training policy and Google's paid-tier no-improvement policy apply to the photos we send there.
• We do not create or store biometric identifiers (face embeddings, hashes, or templates).
• We do not sell or rent your personal information. Because this site serves no display advertising, there is no ad-related third-party data sharing.

10. Data Security

• All data transmission is encrypted using HTTPS/TLS (TLS 1.2 or higher).
• Photos are transmitted directly from your browser to the OpenAI and Google Gemini APIs via our secure serverless function — no intermediate storage.
• Our infrastructure runs on Cloudflare Workers (serverless), meaning there is no persistent server where data could be stored or accessed.
• We implement appropriate technical and organizational measures to protect against unauthorized access, alteration, disclosure, or destruction of data.

11. Data Breach Notification

In the unlikely event of a data breach involving personal data:

• EU/EEA (GDPR): We will notify the relevant supervisory authority within 72 hours of becoming aware of the breach (Article 33). If the breach poses a high risk to your rights and freedoms, we will also notify affected individuals without undue delay (Article 34).
• UK: We will notify the Information Commissioner's Office (ICO) within 72 hours.
• South Korea (PIPA): We will notify affected individuals and the Personal Information Protection Commission (PIPC) without delay.
• Brazil (LGPD): We will notify the National Data Protection Authority (ANPD) and affected individuals.
• California (CCPA): We will notify affected California residents as required by Cal. Civ. Code § 1798.82.
• Canada (PIPEDA): We will notify the Privacy Commissioner of Canada and affected individuals for breaches posing a real risk of significant harm.
• Australia: We will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals for eligible data breaches under the Notifiable Data Breaches scheme.

12. Your Rights

12.1 Rights for All Users

Regardless of your location, you have the right to:

• Access: Know what data we hold about you (effectively none, as described above).
• Deletion: Request deletion of any data. Since we don't store photos or personal data, this primarily applies to payment records held by Polar.
• Portability: Request your data in a portable format.
• Objection: Object to any data processing.
• Withdraw consent: You may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing performed before withdrawal.

12.2 EU/EEA Users (GDPR)

In addition to the above, you have the right to:

• Rectification: Correct inaccurate personal data (Art. 16).
• Restriction: Request restriction of processing in certain circumstances (Art. 18).
• Object to legitimate interest processing: You may object to processing based on legitimate interests (Art. 21).
• Not be subject to automated decision-making: You have rights regarding automated processing (Art. 22). See Section 6 above.
• Lodge a complaint: You have the right to lodge a complaint with your local Data Protection Authority (DPA). A list of EU DPAs is available at edpb.europa.eu.

12.3 UK Users (UK GDPR)

• You have equivalent rights to EU users under the UK GDPR and Data Protection Act 2018.
• You may lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

12.4 California Users (CCPA/CPRA)

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months.
• Right to Delete: You may request deletion of your personal information.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information as defined by the CCPA/CPRA. No opt-out is necessary.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
• Authorized Agent: You may designate an authorized agent to make requests on your behalf.
• Categories of PI collected: Internet activity (anonymous analytics via Cloudflare), financial information (via Polar, not by us directly). We do not collect sensitive personal information as defined under the CPRA.
• We will respond to verifiable consumer requests within 45 days.

12.5 South Korean Users (PIPA)

• You have the right to access, correct, delete, and suspend processing of your personal information under PIPA.
• We comply with the duty to destroy personal information when its purpose has been achieved — photos are destroyed immediately after processing.
• You may lodge a complaint with the Personal Information Protection Commission (PIPC) at pipc.go.kr.
• You may also seek dispute resolution through the Korea Internet & Security Agency (KISA) Privacy Center (privacy.kisa.or.kr).

12.6 Brazilian Users (LGPD)

• You have the right to confirmation, access, correction, anonymization, portability, deletion, information about sharing, and revocation of consent under the LGPD.
• You may lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).

12.7 Canadian Users (PIPEDA)

• You have the right to access your personal information, challenge its accuracy, and withdraw consent.
• You may lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca.

12.8 Japanese Users (APPI)

• You have the right to request disclosure, correction, cessation of use, and deletion of your personal information under the APPI.
• You may lodge a complaint with the Personal Information Protection Commission (PPC) of Japan.

12.9 Australian Users (Privacy Act 1988)

• You have the right to access and correct your personal information under the Australian Privacy Principles (APPs).
• You may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

To exercise any of these rights, contact [email protected]. We will respond within the timeframe required by applicable law (generally 30 days, or 45 days for CCPA).

13. Children's Privacy

• The Service is not intended for children under 16 (or the applicable minimum age in your jurisdiction).
• We do not knowingly collect data from children under 16 (or 13 under COPPA in the United States).
• If you believe a child has used our Service, contact us and we will take appropriate action, including deleting any data that may have been inadvertently collected.
• In the EU/EEA, the minimum age varies by member state (13–16) per GDPR Article 8.
• In South Korea, the minimum age is 14 under PIPA.

14. Do Not Track (DNT) Signals

Our Service does not track users across third-party websites and therefore does not respond to Do Not Track (DNT) signals. We do not engage in any cross-site tracking.

15. Data Retention & Destruction

• Photos: Not retained. Destroyed immediately after AI processing is complete.
• Analysis results: By default they exist only in your browser. They are kept on your account only if a signed-in member saves them (Section 3.1.1), and are deleted together with your account.
• Member account: Kept until you delete your account, then deleted immediately. Any remaining credits and credit history are deleted with it and cannot be restored.
• Free sign-up pass records: To stop the free passes from being claimed again by deleting and re-creating an account, if you used a free pass we keep only a one-way converted value (hash) of your email address and sign-in account ID plus the number of passes used. Your email address cannot be recovered from it. To have it removed, email [email protected].
• Friend invite records: If you joined through an invite link, we keep who invited whom and whether the reward was paid. When you delete your account, the link to your account is removed and only the hash described above is kept, to stop invite rewards being claimed again by re-registering. Your own invite code is deleted with your account.
• Subscription email: Kept while you are subscribed. When you unsubscribe, only your email address stays on a suppression list so we never email you again. To have that address removed too, email [email protected]. Sign-ups that were never confirmed are not emailed.
• Transaction references: Retained for up to 12 months for customer support and legal/tax compliance, then deleted.
• Payment data: Retained by Polar according to their data retention policy and applicable financial regulations.
• We comply with the data destruction requirements under PIPA (South Korea), LGPD (Brazil), and other applicable laws.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected with an updated effective date at the top of this page. Where required by law (e.g., GDPR, PIPA), we will provide notice of material changes before they take effect. Continued use of the Service after changes constitutes acceptance.

17. Contact Us

For privacy-related questions, data requests, or to exercise any of your rights:

• Email: [email protected]
• Website: https://kissinskin.net

We aim to respond to all privacy-related inquiries within 30 days (or within the timeframe required by your applicable local law).