PRIVACY POLICY

Last updated December 05, 2025
 
 
 
This Privacy Notice for P.N.G. Stidio Ltd (doing business as Skinlav) (‘we‘, ‘us‘, or ‘our‘), describes how and why we might access, collect, store, use, and/or share (‘process‘) your personal information when you use our services (‘Services‘), including when you:
  • Visit our website at https://skinlav.com or any website of ours that links to this Privacy Notice
 
  • Download and use our mobile application (Skinlav), or any other application of ours that links to this Privacy Notice
 
  • Use Cosmetics designed for your skin.
 
  • Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@skinlav.com.
 
 

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
 
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
 
Do we process any sensitive personal information? Some of the information may be considered ‘special’ or ‘sensitive’ in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.
 
How do we process facial images? All facial image processing occurs entirely on your device using local machine learning models. Your facial images are never uploaded to our servers, stored permanently, or shared with any third parties. Learn more about facial image data processing.
 
Do we collect any information from third parties? We do not collect any information from third parties.
 
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
 
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
 
How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
 
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
 
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
 
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
 
 

TABLE OF CONTENTS

   

 
 
 
 

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

 
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
 
 
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
  • names
 
  • phone numbers
 
  • email addresses
 
  • mailing addresses
 
  • contact preferences
 
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
  • health data
 
Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/en-cy/privacy.
 
 
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
 
  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
 
 
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

 
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
 
 
The information we collect includes:
  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
 
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

 
 

Facial Image Data

In Short: We process facial images entirely on your device using local machine learning models. Your facial images are never uploaded to our servers or shared with third parties.

 
How We Collect Facial Images
The Skinlav mobile application allows you to capture facial images for skin analysis through:
  • Your device’s front-facing camera (primary method)
  • Photo selection from your device gallery (secondary method)
 
What We Do With Facial Images
Facial images are used exclusively for on-device machine learning analysis to:
  • Classify your skin type into one of three categories: Dry, Normal, or Oily
  • Detect skin concerns including acne, dark circles, puffy eyes, skin pigmentation, skin redness, skin texture issues, and wrinkles
  • Generate personalized skincare recommendations based on the analysis results
 
On-Device Machine Learning Models
All image processing occurs entirely on your device using the following machine learning models stored within the application:
  • Skin Type Classification Model (ONNX format, 83MB) – Uses Vision Transformer architecture to analyze facial images and determine skin type with confidence scores
  • Face Characteristics Model (ONNX format, 83MB) – Multi-label classifier that detects up to 7 different skin concerns simultaneously
  • Sebum Predictor Model (TFLite format) – Analyzes oil production patterns from diagnostic test films and outputs non-dimensional reference values used internally by Skinlav’s cosmetic manufacturing process (not medical measurements)
  • Desquamation Predictor Model (TFLite format) – Analyzes skin cell turnover patterns from diagnostic test films and outputs non-dimensional reference values used internally by Skinlav’s cosmetic manufacturing process (not medical measurements)
  • Real-Time Face Detection (Google ML Kit) – Provides on-device face contour detection for camera guidance only; face landmarks are not stored
Processing typically takes 2-5 seconds per image. Models are immediately freed from memory after analysis to optimize device performance. All analysis results are non-dimensional reference values for cosmetic formulation purposes, not medical measurements or diagnoses.
 
Storage and Retention
Selfie Images:
  • Stored in temporary memory (RAM) only during analysis
  • Automatically deleted after 2-5 seconds when ML processing completes
  • Never written to persistent storage on your device
Analysis Results (No Images):
  • Only text-based results are stored (e.g., “Oily skin”, confidence: 85%)
  • Stored locally on your device until you clear app data or uninstall
  • You can delete analysis results at any time through the app
 
No Cloud Upload or Third-Party Sharing
Your facial images are NEVER:
  • Uploaded to our servers or any cloud storage service
  • Transmitted over the internet
  • Shared with third-party services (including Firebase, Google Analytics, or Stripe)
  • Accessible to our staff or any external parties
  • Used for any purpose other than the immediate on-device analysis
 
The application does not include any cloud storage SDKs (such as Firebase Storage or AWS S3) and contains no code for uploading images to external servers.
 
Optional Sharing of Test Results
While facial images are never shared, you may optionally choose to share your analysis results in the following ways:
  • PDF Reports: You can generate and share PDF reports containing your non-dimensional test results (sebum and desquamation reference values, skin type assessment) via email or messaging apps. This is entirely user-initiated and optional.
  • Individual Cream Orders: When you press the “Buy Now” button on Individual Cream products after completing a test-kit analysis, the app encodes your test results (non-dimensional reference values for forehead sebum, cheek sebum, forehead desquamation, cheek desquamation, and determined skin type) and includes them as URL parameters when opening our e-commerce website. This allows our cosmetic laboratory to receive your personalized data for custom formulation.
Laboratory Data Usage (Cyprus):
When you choose to order an Individual Cream product, your encoded test-kit data is received by Skinlav’s licensed cosmetic manufacturing laboratory located in Cyprus. The laboratory uses this data as reference information combined with:
  • Manual review by cosmetic formulation experts
  • Pattern analysis across product formulations
  • Professional cosmetic formulation expertise and safety assessments
The AI-generated results assist the laboratory in choosing the correct formulation direction but are not solely relied upon. Custom creams are not manufactured based exclusively on AI analysis. All cosmetic formulas are inherently safe and have undergone safety assessments, ensuring they cannot cause harm even if analysis values vary. Skinlav operates under a valid cosmetic manufacturing license issued by the Ministry of Health of Cyprus.
 
Important: Cosmetic Purpose Only – Not Medical Advice
This application provides skin analysis for cosmetic and skincare product recommendation purposes only. The app does NOT provide medical data, medical diagnoses, medical measurements, or medical treatment advice. The analysis outputs are non-dimensional reference values used internally for cosmetic formulation and are not medical diagnostic information.
 
You should always consult with a qualified healthcare professional or dermatologist regarding any medical concerns about your skin health. This app is not a substitute for professional medical advice, diagnosis, or treatment. Never disregard professional medical advice or delay seeking it because of information provided by this application.
 
 

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

 
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
 
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
 
  • To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
 
  • To save or protect an individual’s vital interest.
    We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
 
 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a
valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

 
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a
    specific purpose. You can withdraw your consent at any time. Learn more about     withdrawing your consent.
 
  • Performance of a
    Contract.
    We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a
    contract with you.
 
  • Legal Obligations.
    We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a
    law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
 
  • Vital Interests.
    We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
 
 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

 
 
Vendors, Consultants, and Other Third-Party Service Providers.
We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties‘) who perform services for us or on our behalf and require access to such information to do that work.
 
The third parties we may share personal information with are as follows:
  • Cloud Computing Services
Google Cloud Platform
  • Functionality and Infrastructure Optimisation
Firebase Hosting
and Termly.io
  • Invoice and Billing
Stripe
  • Web and Mobile Analytics
Google Analytics for Firebase
and Google Analytics
 
We also may need to share your personal information in the following situations:
  • Business Transfers.
    We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
 
 

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

 
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
 
We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.
 
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice:

Google Analytics


We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

 

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

 
As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, ‘AI Products’). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.
 
Our AI Products
 
Our AI Products are designed for the following functions:
  • Image analysis
 
How We Process Your Data Using AI
 
All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data’s safety.
 

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

 
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a
longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
 
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
 

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a
system of organisational and technical security measures.

 
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a
secure environment.
 

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

 
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a
minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@skinlav.com.
 

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

 
In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a
copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a
request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below.
 
We will consider and act upon any request in accordance with applicable data protection laws.
 
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority
or UK data protection authority.
 
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
 
Withdrawing your consent:
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below.
 
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.
 
  • Contact us using the contact information provided.
 
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
 
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
 
If you have questions or comments about your privacy rights, you may email us at info@skinlav.com.
 

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a
revised version of this Privacy Notice.

 
 

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

 
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated ‘Revised’ date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a
notice of such changes or by directly sending you a
notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
 

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at info@skinlav.com
or contact us by post at:

 
P.N.G. Stidio Ltd
Georgiou Anagnostopoulou 12a
Strovolos, Lefkosia 2047
Cyprus
 

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.