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SmartSkin Africa Privacy Policy

Effective Date: 1st June 2026

1. Introduction

Welcome to SmartSkin Africa.

SmartSkin Africa ("SmartSkin Africa", "we", "us" or "our") is a digital skincare platform that uses technology, including artificial intelligence and image-analysis technologies, to provide users with personalized skincare insights, information, recommendations and related services.

We are committed to protecting your privacy and handling your Personal Data responsibly, transparently and securely.

This Privacy Policy explains how Personal Data is collected, obtained, used, processed, disclosed, retained and protected when you access or use SmartSkin Africa, including through our web application, platform and related services (collectively, the "Services").

This Privacy Policy forms part of the privacy framework governing the Services and should be read together with the SmartSkin Africa Terms of Use ("Terms").

By using the Services, you acknowledge that you have read and understood this Privacy Policy. Where applicable law requires specific consent for particular processing activities, such consent will be obtained separately.

2. Data Controller

2.1 AccessPlus Communications Limited ("AccessPlus") is the Data Controller responsible for the processing of Personal Data in connection with the Services.

2.2 AccessPlus is duly registered with the Ghana Data Protection Commission and is responsible for determining the purposes for which, and the manner in which, Personal Data processed through the Services is handled.

2.3 SmartSkin Africa is the digital platform through which the Services are made available. Where Personal Data is processed through SmartSkin Africa on behalf of AccessPlus, such processing will be carried out in accordance with applicable law, AccessPlus's instructions and appropriate data-protection safeguards.

2.4 Nothing in this Privacy Policy changes the respective ownership, licensing or other rights relating to the SmartSkin Africa platform or its underlying technology as established under the Terms.

3. What Is Personal Data?

For purposes of this Privacy Policy, "Personal Data" means information relating to an identified or identifiable individual, including information that can reasonably be used to identify an individual, whether directly or indirectly.

"Processing" includes collecting, recording, organizing, storing, accessing, using, analyzing, disclosing, transferring, deleting or otherwise handling Personal Data.

"Data Subject" means the individual to whom Personal Data relates. These terms shall be interpreted consistently with applicable data protection law.

4. Personal Data We Collect

Depending on your use of the Services, we may collect and process the following categories of Personal Data.

4.1 Account and Registration Information

This may include:

4.2 Skincare and Profile Information

Where you choose to provide it, we may collect information relating to your skin, including:

4.3 Facial Images

Certain SmartSkin Africa features may allow you to submit an image of your face or skin for analysis.

A "Facial Image" means an image containing your face or facial skin submitted through the Services for the purpose of the applicable analysis.

Facial Images may be processed using automated image-analysis and artificial intelligence technologies to identify visible characteristics of the skin and generate skincare-related insights and recommendations.

You are not required to submit a Facial Image where the applicable feature can be used without one. However, features that require image analysis may not be available without submission of the relevant image.

4.4 Technical and Usage Information

When you access or use the Services, certain technical and usage information may be collected automatically, including:

4.5 Communications and Support Information

If you contact us or request assistance, we may process information contained in your communication and information reasonably necessary to respond to your request.

4.6 Transaction Information

Where the Services involve payments or transactions, we may process information necessary to facilitate and verify the relevant transaction.

Payment information may be processed by authorized payment service providers in accordance with their own applicable privacy policies and legal obligations.

5. How We Collect Personal Data

We may obtain Personal Data:

We will seek to ensure that Personal Data is collected lawfully, fairly and in a manner that is reasonably necessary and relevant to the purpose for which it is collected.

6. Purposes for Which We Process Personal Data

We may process Personal Data for the following purposes:

We will not use Personal Data for a purpose that is incompatible with the purpose for which it was collected unless permitted by applicable law or otherwise appropriately authorized.

7. Lawful Basis for Processing

We will process Personal Data only where there is a lawful basis for doing so.

Depending on the circumstances, the lawful basis may include:

Where processing is based on consent, you may withdraw your consent at any time, subject to applicable law and any consequences reasonably explained to you.

Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.

8. Facial Images and Image Analysis

8.1 Facial Images submitted through SmartSkin Africa are processed for the specific purpose of providing the applicable image-analysis feature and generating the related skincare insights or recommendations.

8.2 SmartSkin Africa does not retain Facial Images after the applicable analysis process, except as provided in Clause 8.3.

8.3 Notwithstanding Clause 8.2, a Facial Image may be retained temporarily where reasonably necessary for technical processing, security, troubleshooting, prevention of misuse, service integrity or other legitimate operational purposes. Any such temporary retention will be limited to the period reasonably necessary for the applicable purpose.

8.4 Facial Images will not be retained indefinitely merely because you have an account with SmartSkin Africa.

8.5 We do not use Facial Images for unrelated purposes, including advertising, sale to third parties, or the creation of a facial-recognition profile.

8.6 SmartSkin Africa is not intended to identify or authenticate individuals through facial recognition.

8.7 Where information derived from a Facial Image is retained after the image itself is deleted, such information will be handled in accordance with this Privacy Policy and applicable law.

9. Artificial Intelligence and Automated Processing

9.1 SmartSkin Africa may use artificial intelligence, machine-learning models and automated image-analysis technologies in delivering certain Services.

9.2 These technologies may analyze information submitted by you, including relevant Facial Images, to identify visible skin characteristics and generate skincare-related insights or recommendations.

9.3 AI-generated results are based on the information and images available to the system and may not always be accurate, complete or suitable for every individual.

9.4 The Services are intended to provide general skincare information and recommendations and are not a substitute for professional medical advice, diagnosis, examination or treatment.

9.5 You should seek appropriate professional medical or dermatological advice where you have a medical concern, persistent skin condition, adverse reaction or other concern requiring professional assessment.

9.6 We will not use automated processing to make decisions about you that have legal or similarly significant effects where the decision is based solely on automated processing, except where permitted by applicable law and subject to any rights and safeguards required by law.

10. Processing of Special Personal Data

Certain Personal Data may receive enhanced protection under applicable law.

Where information processed through the Services constitutes Special Personal Data or otherwise requires enhanced protection, we will process such information only where permitted by applicable law and will apply appropriate safeguards.

Where consent is required for such processing, the relevant consent will be obtained before processing takes place.

Where consent is required, we will seek consent in a manner that is appropriately informed, specific and voluntary.

You may withdraw consent where the applicable processing is based on consent.

Withdrawal of consent may affect our ability to provide certain features or Services where the relevant processing is necessary for those features or Services.

12. How We Use and Disclose Personal Data

We do not sell your Personal Data.

We may disclose or make Personal Data available to authorized persons or organizations where reasonably necessary to provide, maintain, secure or improve the Services or where otherwise permitted or required by law.

Such recipients may include:

We will take reasonable steps to ensure that third parties handling Personal Data on our behalf are subject to appropriate confidentiality, security and data-protection obligations.

13. Data Processors

13.1 AccessPlus may appoint Data Processors to process Personal Data on its behalf.

13.2 A Data Processor will be permitted to process Personal Data only for authorized purposes and subject to appropriate contractual, technical and organizational safeguards.

13.3 Data Processors may include technology providers, hosting providers, cloud providers, analytics providers, payment providers, security providers and other service providers reasonably necessary for the operation of the Services.

13.4 We will take reasonable steps to ensure that Data Processors comply with applicable data protection requirements.

14. Data Security

14.1 We take reasonable and appropriate technical and organizational measures to protect Personal Data against unauthorized access, loss, misuse, alteration, disclosure, destruction or other unlawful processing.

14.2 Depending on the circumstances, security measures may include:

14.3 No method of electronic transmission, processing or storage can be guaranteed to be completely secure.

14.4 You are responsible for maintaining the confidentiality of your account credentials and for notifying us promptly if you believe your account has been compromised.

15. Data Retention

15.1 We will retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected, including to:

15.2 Retention periods may vary depending on the type of Personal Data, the purpose of processing and applicable legal requirements.

15.3 Facial Images submitted for analysis are not retained after the applicable analysis process, except for limited temporary retention as described in this Privacy Policy.

15.4 When Personal Data is no longer required, it will be securely deleted, anonymized or otherwise disposed of in accordance with applicable law and our data-retention practices.

15.5 Where information is irreversibly anonymized so that it can no longer reasonably be associated with an identifiable individual, it may be retained and used for legitimate statistical, analytical, research or service-improvement purposes.

16. Data Accuracy and Data Minimization

16.1 We will take reasonable steps to ensure that Personal Data processed through the Services is accurate, complete and, where necessary, kept up to date.

16.2 You are responsible for providing accurate and current information and for updating information where appropriate.

16.3 We will seek to collect and process only Personal Data that is reasonably necessary and relevant to the purposes for which it is processed.

17. International Data Transfers

17.1 Some technology, hosting, cloud, software or other service providers used in connection with the Services may operate from locations outside Ghana.

17.2 Where Personal Data is transferred to, stored in or processed from another jurisdiction, we will take reasonable steps to ensure that the transfer and subsequent processing comply with applicable data protection requirements.

17.3 Where required by law, appropriate safeguards or other lawful mechanisms will be used for international transfers.

18. Cookies and Similar Technologies

18.1 The Services may use cookies, device identifiers, pixels, software development kits and similar technologies.

18.2 These technologies may be used to:

18.3 Where applicable law requires consent for particular cookies or similar technologies, the relevant consent will be obtained.

18.4 You may be able to control certain cookies through your browser or device settings. Disabling certain technologies may affect the functionality of the Services.

19. Direct Marketing

19.1 Where permitted by applicable law, we may send communications relating to the Services, including updates, educational information, promotions and other marketing communications.

19.2 Where consent is required for direct marketing, we will obtain the appropriate consent before sending such communications.

19.3 You may withdraw your consent to direct marketing or opt out of promotional communications at any time through the mechanism provided in the communication or by contacting us.

19.4 Opting out of marketing communications will not prevent us from sending necessary service, account, security or administrative communications.

20. Children and Age Requirements

20.1 The Services are subject to the minimum age requirements set out in the Terms of Use.

20.2 We do not knowingly process Personal Data from children in circumstances where such processing is prohibited by applicable law.

20.3 Where applicable law requires parental or guardian consent for the processing of a child's Personal Data, SmartSkin Africa does not currently provide a mechanism for obtaining such consent. Accordingly, the Services must not be used in circumstances where such consent is required. Parents and guardians are encouraged to notify us promptly if they become aware that a child has accessed or used the Services or submitted Personal Data, including a Facial Image, without the required consent.

20.4 If we become aware that Personal Data has been collected from a child in circumstances where it should not have been collected, including following notification by a parent or guardian, we will take reasonable steps to review the circumstances and delete or otherwise appropriately address the Personal Data in accordance with applicable law.

21. Your Data Protection Rights

21.1 Subject to applicable law, you may have certain rights in relation to your Personal Data, including the right to:

21.2 The exercise of any right is subject to applicable law and any conditions, limitations, exemptions or lawful grounds for refusal that may apply. We may decline, limit or defer a request where permitted or required by law, including where responding to the request would adversely affect the rights of another person, interfere with legal or regulatory obligations, compromise the security or integrity of the Services, or require us to retain information that we are legally required or otherwise lawfully permitted to retain.

21.3 We may take reasonable steps to verify your identity before processing a request. We may also request additional information reasonably necessary to understand, authenticate or process your request.

21.4 Exercising a right does not affect the lawfulness of processing carried out before the exercise of that right and does not require us to delete or cease processing Personal Data where continued processing is permitted or required by applicable law.

21.5 Certain requests or choices may affect your ability to access or use particular features of the Services where the relevant Personal Data is necessary to provide those features.

21.6 Where applicable law permits us to charge a reasonable fee for responding to a request, or to refuse a request that is manifestly unfounded, excessive or repetitive, we may do so in accordance with applicable law.

22. Exercising Your Rights

22.1 Requests concerning your Personal Data or the exercise of any applicable data protection right may be submitted using the contact details provided in this Privacy Policy.

22.2 We may request reasonable information necessary to verify your identity before processing a request.

22.3 We will consider and respond to valid requests within the period required by applicable law.

22.4 Where we are unable to comply with a request, we will provide an explanation where required by applicable law.

23. Third-Party Services and Links

23.1 The Services may contain links to or integrations with third-party websites, applications, products or services.

23.2 Third-party services may operate under their own terms and privacy policies. We do not control and are not responsible for the privacy practices, security, content or availability of third-party services.

23.3 You should review the applicable terms and privacy policies of any third-party service before providing Personal Data directly to that third party.

24. Personal Data Breaches and Security Incidents

24.1 We maintain reasonable measures and procedures for identifying, assessing and responding to Personal Data breaches and security incidents.

24.2 Where a Personal Data breach occurs, we will take reasonable steps to contain and investigate the incident, mitigate potential harm and implement appropriate remedial measures.

24.3 Where a Personal Data breach or security compromise is subject to notification under applicable law, we will notify the Ghana Data Protection Commission and/or affected Data Subjects within the applicable timeframe and in the manner required by law.

25. Data Protection Supervision and Accountability

25.1 AccessPlus will maintain appropriate measures, policies and procedures to support compliance with applicable data protection requirements.

25.2 Where required or appropriate under applicable law or regulatory requirements, AccessPlus may designate a qualified person or function to oversee relevant data protection matters.

26. Complaints

26.1 If you have concerns about the processing of your Personal Data or believe that your privacy rights have been infringed, you may contact us using the details provided in this Privacy Policy so that we may review and address the matter.

26.2 You may also lodge a complaint with the Ghana Data Protection Commission or any other competent authority where applicable.

27. Changes to This Privacy Policy

27.1 We may update this Privacy Policy from time to time to reflect changes in the Services, technology, applicable law or our privacy practices.

27.2 Where a change is material, we will provide appropriate notice through the Services or by another reasonable means.

27.3 The revised Privacy Policy will state its updated Effective Date.

27.4 Your continued use of the Services after the effective date of the revised Privacy Policy constitutes acknowledgment of the updated Privacy Policy to the extent permitted by applicable law.

28. Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the Republic of Ghana, including the Data Protection Act, 2012 (Act 843), as amended or replaced from time to time, and any other applicable data protection and privacy laws.

Nothing in this Privacy Policy limits any mandatory rights or protections available to a Data Subject under applicable law.

29. Contact Information

For questions, requests, complaints or other matters concerning this Privacy Policy or the processing of your Personal Data, please contact:

Email: support@smartskin.app

Phone: +233 550 590 714

Address: 28 Djanie Ashie Road, East Legon, Accra, Ghana.

30. Acknowledgement

By accessing or using SmartSkin Africa, you acknowledge that you have read and understood this Privacy Policy.

Where applicable law requires consent to a particular processing activity, such consent will be obtained separately in the manner required by law.

This Privacy Policy, together with the SmartSkin Africa Terms of Use and any applicable privacy notices or consents presented to you when using specific features, governs the processing of Personal Data in connection with the Services.