Face Doctor Privacy Policy

Complete, transparent disclosure regarding camera imagery, on-device skin lesion evaluation, biological anamnesis intake, and our zero-selling guarantee.

Effective Date: November 8, 2026
Last Updated: November 8, 2026
Application Version: 1.4.0 (Native Android & Web)
Governing Entity: Face Doctor Technologies
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Local-First Storage

Your face photos and computer vision scan outputs stay inside your device's private sandbox storage. No automatic background cloud photo sync.

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Zero Ad Trackers

We do not use AdMob, Facebook Ads, or third-party marketing brokers. Your health data is never sold, brokered, or used for ad targeting.

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Biological Honesty

We analyze real medical etiology—genetics, dietary IGF-1, hormones, and barrier integrity—to tell you the biological truth without sales gimmicks.

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One-Tap Deletion

You own your data completely. Tap Delete all data anytime in the app to immediately wipe all photos, scans, and records from your device.

1. Radical Honesty & Privacy Philosophy

At Face Doctor, our fundamental thesis is that people facing persistent skin concerns deserve complete biological truth, not aggressive cosmetic marketing or deceptive advertising. Skincare is personal health; it is governed by genetics, hormones, diet, and barrier biology.

Because we operate on radical honesty, we apply that identical standard to your privacy. We believe that your face and health data belong exclusively to you. We do not monetize your insecurities, we do not package your health records for insurance or data brokers, and we do not display targeted third-party advertising.

Key Privacy Principle: Face Doctor operates primarily as an on-device, client-side utility. Your facial photographs are captured locally, evaluated locally, and stored locally in your phone's encrypted sandboxed storage unless you explicitly choose to invoke optional cloud AI assistance.

2. Categories of Information We Access & Collect

Depending on how you interact with Face Doctor, we process the following categories of data:

Data Category Examples & Data Points Primary Purpose Storage Location
Facial Imagery (Camera) Frontal, left cheek, and right cheek camera photos taken inside the viewfinder or imported from your gallery. Computer vision detection of erythema, comedones, papules, pustules, nodules, and ITA skin tone angle. Local sandboxed device storage (filesDir/scans/).
Biological Anamnesis Age group, biological sex, family acne history (genetics), whey protein intake, high-GI carb frequency, dairy/chai consumption, menstrual cycle status, active skin stinging, and acid count. Deterministic clinical etiology mapping (linking observable symptoms to androgenic, dietary, or barrier causes). Local SharedPreferences / Room DB on device.
Cosmetic & Barcode Queries Barcode numbers (EAN/UPC) or product brand names entered by the user. Querying Open Beauty Facts for INCI ingredient lists and cross-referencing openFDA safety/recall records. Processed ephemerally in RAM; not tied to your user identity.
Device & Diagnostic Telemetry Device manufacturer, model, Android OS version, screen density, and unexpected crash call-stacks. Ensuring viewfinder rendering stability, camera preview aspect ratio correctness, and bug fixing. Ephemeral system diagnostics; zero advertising ID tracking.
Payment & Subscription Records Subscription tier (Free, Monthly ₹299, Yearly ₹1,799), order ID, and transaction state. Managing access to premium features, unlocking custom ingredient audits, and billing fulfillment. Secure Cashfree API / Google Play Billing. Face Doctor never receives or stores raw payment cards.

3. Camera Access & Facial Image Privacy

Face Doctor requires runtime access to your device camera (android.permission.CAMERA) solely for the live viewfinder and skin inspection workflow.

On-Device Sandboxing

When you capture a photograph through Face Doctor:

  • Sandbox Isolation: The full-resolution image is saved strictly to your application's private, internal storage directory (Context.getFilesDir()). Other applications installed on your device cannot view or access these images.
  • No Passive Background Scanning: The camera is active only while the viewfinder screen is open in the foreground. Face Doctor never captures background images, records audio, or runs passive background camera monitoring.
  • Zero Face-Recognition or Identity Tracking: We do not compute facial embeddings, biometric identification vectors, or surveillance features designed to identify who you are. Our computer vision algorithms exclusively calculate localized dermatological metrics: erythema dispersion, comedone density, inflammatory papule/pustule counts, and skin tone luminance (ITA angle).

4. Biological Anamnesis & Health Intake Privacy

In accordance with first-principles clinical dermatology, visual inspection alone cannot pinpoint the root cause of skin changes without understanding internal biology. Face Doctor incorporates an evidence-based anamnesis intake that examines four biological pillars:

  1. Genetics & Familial History: SREBP-1 transcription and sebaceous gland androgen hyper-responsiveness.
  2. Dietary & Metabolic Factors: Whey protein (bovine IGF-1 leucine spikes), dairy/milk frequency, and high-glycemic glycemic carbohydrates (hyperinsulinemia-driven sebum lipogenesis).
  3. Hormonal Fluctuations: Luteal-phase progesterone surges, androgen spikes, and menstrual cyclicity.
  4. Moisture Barrier Integrity: Over-exfoliation from chemical acids (AHAs/BHAs), transepidermal water loss (TEWL), and neurosensory stinging.
Protected Health Information Standard: All biological anamnesis responses are treated with the highest tier of confidentiality. They are evaluated deterministically using on-device clinical rules and are never disclosed, shared with employers, or sold to health insurers.

5. How We Use & Process Your Data

We process your data strictly to provide the Face Doctor services you request:

  • To Compute Observable Dermatological Metrics: Determining erythema levels, lesion counts, and Individual Typology Angle (ITA) skin tone classification.
  • To Synthesize Biological Root Causes: Formulating honest, clinical etiology reports showing the direct mathematical probability of dietary, hormonal, genetic, or barrier drivers.
  • To Check Pharmacological Conflicts & Contraindications: Cross-referencing your skincare products to prevent adverse chemical interactions (e.g. retinoids paired with strong glycolic acid or peeling solutions).
  • To Maintain Your Skin Timeline: Enabling you to track changes over 7, 14, and 30 days locally on your smartphone.
  • To Send Local Routine Notifications: Optional morning (8:00 AM) and evening (10:00 PM) reminder notifications scheduled strictly via your phone's native AlarmManager/WorkManager.

6. Third-Party Subprocessors & AI Services

To deliver specific features, Face Doctor coordinates with selected, industry-standard service providers under strict data-protection agreements:

Service Provider Location / Jurisdiction Role & Data Processed Safeguards & Terms
Google Generative Language API (Gemini Vision) United States / Global Cloud Optional multimodal skin image feature extraction (when user provides a Gemini API key or selects cloud-enhanced assessment). Encrypted via TLS 1.3 in-transit. Data sent via the Gemini API is processed ephemerally and is not used to train Google's foundation AI models under Google Cloud enterprise terms.
Open Beauty Facts France / European Union Anonymous barcode (EAN/UPC) lookups to fetch INCI ingredient lists and comedogenic ratings. Non-profit open database. Zero personal data or user identifiers are transmitted.
openFDA (U.S. Food & Drug Administration) United States (Public API) Cross-checking cosmetic brand names against adverse event logs and recall enforcement records. Public government regulatory database. Zero user health or identification data is sent.
Cashfree Payments India (RBI-Authorized Payment Aggregator) Processing in-app subscription payments (₹299/mo or ₹1,799/yr) via UPI, cards, and net banking. PCI-DSS Level 1 compliant gateway. Sensitive card details are tokenized and never stored on Face Doctor infrastructure.

7. Zero Data Selling & Zero Advertising Tracking

Affirmative Declaration: Face Doctor does NOT sell, rent, monetize, or lease your personal information, facial photos, or health data to any data brokers, advertising networks, or third parties.

Unlike conventional consumer apps:

  • We do not embed the Google AdMob SDK, Meta Audience Network, Unity Ads, or any other mobile advertisement SDK.
  • We do not track you across other applications or websites using Apple's Identifier for Advertisers (IDFA) or Google's Advertising ID (GAID).
  • We do not participate in programmatic real-time bidding (RTB) auctions.

8. Data Security, Storage & Retention

We employ defense-in-depth security measures to protect your health and biometric information:

  • At-Rest Protection: Images, scan logs, and intake responses are stored locally within the Android app sandbox, encrypted by default by Android's hardware-backed full-disk or file-based encryption (FBE).
  • In-Transit Protection: All communications between the app and backend services (such as barcode lookups or API requests) use modern Transport Layer Security (TLS 1.3 / HTTPS) with strict certificate validation.
  • Retention Period: Because data is stored on-device, your photos and history remain on your smartphone as long as you choose to keep the app installed. We do not retain persistent cloud copies of your face photos.

9. User Controls & Self-Service Data Deletion

You have absolute control over your information at all times. Face Doctor provides immediate, self-service mechanisms to export or delete your data:

How to Delete All Data Immediately:
  1. Open the Face Doctor app.
  2. Navigate to Profile → Data & privacy.
  3. Tap Delete all data and confirm your choice.

This permanently and irrecoverably deletes all saved skin photos, scan results, biological intake responses, routine history, and API keys from your device storage.

If you have created a cloud account or made a subscription purchase and wish to have all associated server records completely purged from our databases, simply email us at privacy@genpharma.in with your account email. We will process and confirm your full deletion within 30 days without cost.

10. International Privacy Rights & Regulatory Compliance

Face Doctor respects data protection frameworks worldwide:

A. European Union & UK General Data Protection Regulation (GDPR)

If you are located in the EEA or UK, you hold the following statutory rights under Articles 15–22 of the GDPR:

  • Right of Access (Art. 15): Right to obtain confirmation and copy of your personal data processed.
  • Right to Rectification (Art. 16): Right to correct inaccurate personal data.
  • Right to Erasure / "To Be Forgotten" (Art. 17): Right to demand deletion of your data.
  • Right to Restriction of Processing (Art. 18): Right to restrict how we process your records.
  • Right to Data Portability (Art. 20): Right to receive your personal data in a structured, machine-readable format.
  • Right to Withdraw Consent (Art. 7(3)): You may withdraw your consent at any time without affecting the lawfulness of processing based on consent prior to withdrawal.

B. California Consumer Privacy Act & CPRA (California, USA)

For California residents:

  • Notice at Collection: We collect facial imagery and health intake for direct application functionality as disclosed herein.
  • Do Not Sell My Info: We do NOT sell or share your personal information with third parties for commercial cross-context behavioral advertising.
  • Non-Discrimination: We will never discriminate against you for exercising any of your CCPA/CPRA rights.

C. Digital Personal Data Protection Act, 2023 (DPDP, India)

For individuals residing in India:

  • Face Doctor complies with the principles of consent, purpose limitation, and data minimization under the DPDP Act 2023.
  • You have the right to access an itemized summary of personal data being processed, right to correction and erasure, and the right to nominate an individual in the event of death or incapacity.
  • You may reach our designated Grievance Officer as detailed below for any concerns or disputes.

11. Children's Privacy

Face Doctor is designed for individuals who are at least 13 years of age (or 16 years of age in the European Economic Area).

We do not knowingly solicit or collect personal or health information from children under these age thresholds. If you are a parent or legal guardian and discover that your minor child has provided us with personal information without required parental consent, please contact us immediately at privacy@genpharma.in. We will promptly delete such information from our records and storage.

12. Medical & Dermatological Disclaimer

Important Clinical Notice: Face Doctor is an informational, educational, and computer vision intake software application. It is not a certified medical device (such as an FDA Class II or EU MDR device) and is not intended to provide definitive medical diagnosis, triage acute dermatological infections, prescribe controlled pharmaceuticals, or replace clinical judgment.

While our biological intake algorithms and pharmacology engines are grounded in peer-reviewed scientific literature (including studies published in JAAD, British Journal of Dermatology, and the Journal of Clinical and Aesthetic Dermatology), you should always consult a licensed dermatologist or qualified healthcare provider for:

  • Suspicious, irregular, evolving, or pigmented moles (potential melanoma/skin cancer risk).
  • Severe cystic nodular acne causing scarring or systemic symptoms.
  • Severe allergic reactions, sudden contact dermatitis, or widespread blistering eruptions.
  • Prescription-only therapies requiring physician monitoring (e.g., oral isotretinoin, oral spironolactone, systemic antibiotics).

13. Grievance Officer & Contact Information

If you have questions, comments, or requests regarding this Privacy Policy, or wish to exercise any of your statutory rights, please reach out to our dedicated Privacy Office:

Face Doctor Privacy Office

Email: privacy@genpharma.in

Grievance Officer: Ayush (Designated Data Protection & Grievance Officer)

Organization: Face Doctor Technologies / GenPharma

Jurisdiction: Bangalore, Karnataka, India

Official Website: https://genpharma.in

We respond to all verified privacy and data deletion inquiries within 30 days of receipt.