nuds skincare co. Privacy Policy

Effective Date: July 7, 2026

This Privacy Policy (this “Policy”) explains how nuds skincare co. ("nuds," "we," "us," or "our") collects, uses, and shares personal information when you use our camera-equipped hardware devices, our skincare coaching platform (the "Platform") available via our website and our mobile app (the “App”), and related services (all of the foregoing collectively, the "Services"). It covers the facial scans you capture with our devices, the AI-powered personalized coaching we provide, and purchases you make through us.

Please read this Policy carefully. By using the Services, you agree to the collection, use, and sharing of your personal information as described below.

1. Personal Information We Collect

1.1 Account Information

When you create an account we collect your name, email address, shipping and billing address, and age.

1.2 Communications

We keep records of your communications with us, including support emails and chat messages.

1.3 Facial Scan and Skin Analysis

The core of our Services is a facial scan you capture using a nuds camera device or, where supported, your phone’s camera. When you consent to a scan, we collect images and video of your face (each, a "Facial Scan"). Along with the Facial Scans, you have the opportunity to provide additional information about your skin and medical history – such as skin concerns, medical history, allergies, and medications. Based on all of this information, our Platform generates a skincare analysis (the “Skin Analysis”) and personalized product and routine recommendations (the “Personalized Recommendations”) for you. Your Facial Scans, medical information, Skin Analysis, and Personalized Recommendations are treated as your “Content”.

1.4 Device and Hardware Information

Each time you connect a nuds device to the internet, we collect information about that device, such as its device identifier, device type, firmware version, language and region settings, and connection timestamps.

1.5 App and Location Information

If you enable location services for the App, we collect location data and may associate it with your Content — for example, to help you find a nearby partner practice or retailer.

1.6 Website Information

We collect data about your visits to our websites and Platform, including IP address, browser and device information, and the pages and content you view, using cookies and similar technologies. We use this data to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible. We do not currently respond to browser "do not track" signals.

1.7 Third-Party Sites

If you choose to link or share your Content to third-party sites (for example, Instagram or TikTok), we collect information that enables that connection, such as your name on that platform. Anything you share to a third-party site is governed by that site's own privacy policy, and not by this Policy.

2. How We Use Your Personal Information

2.1 General Uses

We use your Content and other personal information to:

  • Deliver the Services, including generating your Skin Analysis and Personalized Recommendations

  • Facilitate purchases of nuds products, and, where you choose to connect with one, a partner practice's services or partner skincare products

  • Communicate with you about your account, orders, and support requests

  • Improve our scan technology, AI coaching models, and product line

  • Send you product updates, newsletters, and offers (you can opt out at any time)

  • Comply with legal obligations and manage our general business operations

2.2 Research and Development

If you opt in to "Research Consent" for a piece of Content, we may use that Content in de-identified data sets for internal or external research ("Research Data Sets"). We remove personal information such as name, email address, and precise location from Research Data, but certain Facial Scans may not be capable of being fully de-identified and may remain identifiable. You are responsible for not capturing other identifying information (for example, other people’s faces) in Facial Scans that you consent to include in Research Data Sets. Once Content has been included in Research Data Sets and has been de-identified, it cannot be removed from the Research Data Sets. However, if you revoke your consent, we will refrain from using your Content as a source for future Research Data Sets. In addition, to the extent we are able to identify your Facial Scans in existing Research Data Sets, we will remove those Facial Scans. De-identified data within existing Research Data Sets which cannot be traced back to you will not be impacted by your revocation. Please see Section 3.6 for more information regarding how we may share Research Data Sets.

3. How We Share Your Information

3.1 Service Providers

We share information with vendors who help us operate the Services, such as cloud hosting, payment processing, and customer support providers. We do not store payment card or bank account numbers ourselves — these are handled by our payment processor.

3.2 Partner Practices and Skincare Brands

If your dermatologist or esthetician has partnered with Nuds, and if you provide consent, we will share your Skin Analysis and Personalized Recommendations with that practice or partner brand solely to support the care or recommendations you requested.

3.3 Business Transfers

We may share your information as part of a merger, acquisition, financing, or sale of some or all of nuds skincare co.'s business.

3.4 Analytics

We use Google Analytics to understand how visitors engage with our Services. You can learn more about the information that Google has access to at the following website: https://policies.google.com/technologies/partner-sites. 

3.5 Legally Required Disclosure

We may disclose information if required by law, subpoena, or court order, or to protect the rights, property, or safety of nuds, our users, or others.

3.6 Research Sharing

If you opt in to Research Consent, we may share the resulting Research Data Sets with outside researchers or institutions, potentially without restriction, including in published research or public data sets. 

4. Your Choices

You have the following rights and choices with respect to your personal information:

  • Promotional Emails: You can opt out of promotional emails using the unsubscribe link in any marketing email (we may still send account, transaction, and policy-update emails)

  • Location Services: You can disable location services for the App in your device settings

  • Tracking Technologies: You can manage cookies through your browser settings. 

  • Right to Know: You have the right to request that we disclose to you the personal information we collect, use, disclose, sell, and information about our data practices. 

  • Right to Request Correction: You have the right to request that we correct inaccurate personal information that we maintain about you.

  • Right to Request Deletion: You have the right to request that we delete your personal information that we have collected from or about you. We may reject your request if it is reasonably necessary to maintain your personal information in order to complete the transaction for which we collected the personal information, comply with law, or other applicable reasons that are permitted under the applicable law and that will be communicated to you upon receipt of your request. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.

  • Right to Portability: You have the right to request that we provide you with your personal information in a common file format.

  • Right to Opt Out of Sales and Targeted Advertising: We do not sell or process your personal data for the purpose of targeted advertising. However, if this ever changes, we will notify of you of the update, and you will have the right to opt out of our sale of your personal information and the processing of your personal information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising.

  • Right to Opt Out of Automated Decision Making: The right to opt out of our use of your personal information for automated decisions that produce any legal or similarly significant effect for you. For the avoidance of doubt, we do not conduct any such automated decision making.

  • California “Shine the Light” Law: If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at privacy@nudsskincare.com or write to us at the address listed at the end of this Policy. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

If you wish to exercise any of the rights set out above, please contact us at privacy@nudsskincare.com. If you have authorized an agent to exercise your rights, the agent may contact us on your behalf. Please note that to protect your personal information and the integrity of our Services, we may need to collect additional information to verify your identity (and, if applicable, the authority of your agent) before processing your request. If you are not satisfied with any decision we make with respect to your request, you can let us know the reasons for your concern, and we will review your appeal. 

5. How We Protect Your Information

We use industry-standard safeguards, including encryption in transit (such as TLS/SSL), to protect your information. Account access is protected by a password or other authentication mechanism. You are responsible for safeguarding your own account credentials, including logging out on shared devices.

6. Biometric Information Policy (Facial Scans)

Because your Facial Scan is central to the Services, and is considered biometric data under certain applicable laws, we apply the following specific protections to your Facial Scan:

  • We only capture your Facial Scan after you affirmatively consent, separate from your general acceptance of our Terms.

  • We use your Facial Scan solely to generate your Skincare Analysis and to deliver the Personalized Recommendations and products you request.

We will never sell, lease, trade, or otherwise profit from your Facial Scan.

  • We will not disclose your Facial Scan for any purpose beyond delivering the Services, except as described in this Policy or with your separate consent (such as your optional Research Consent).

  • Your scans are encrypted in transit and at rest and stored on secure servers. Any service provider that stores or processes Facial Scan Information on our behalf is contractually required to use appropriate security safeguards.

  • We retain your Facial Scan Information for up to 1 year from the date of your last interaction with us, or until we no longer need the Facial Scan in order to provide the Services, whichever is earlier, and then permanently destroy it from our servers (including the servers of our service providers).

7. International and U.S. Data Processing

Your information is processed in the United States, where data protection laws may differ from those in your country of residence.

8. Children's Privacy

The Services are not directed to children. You must be at least 13 years old to create an account or use the Services.

9. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you — for example, by email or an in-App notice. Continued use of the Services after an update constitutes acceptance of the revised Policy.

10. Contact Us

If you have questions about this Policy or want to exercise any of your rights, contact us at privacy@nudsskincare.com