Privacy Policy

Effective Date: December 4, 2025

Kello Solutions ("we," "our," or "us") is committed to protecting the privacy of the users ("user" or "you") of the Pure Skin | DERMA AI mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

By using the App, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

The App collects information to perform its core functions—skin analysis and providing personalized skincare suggestions. We collect two main types of information:

A. Information You Directly Provide

This information is necessary for the App's primary functions, which include skin analysis, routine tracking, and personalized recommendations.

• Skin and Health Data (Sensitive Personal Data):

  • Images/Photos: You may upload images or photos of your skin for the AI analysis feature.

  • Self-Reported Data: Information you manually enter, such as skin type, age, gender, skincare goals, and details about your current routine.

  • AI-Derived Data: Data generated by the App’s AI model based on your images, which constitutes information about your physical health or status (e.g., condition scores, analysis of blemishes, hydration levels, etc.).

• Contact/Account Information (Optional):

  • If we implement account creation, we may collect your email address or unique user ID linked to your device.

B. Information We Collect Automatically

When you access and use the App, we automatically collect certain device and usage data.

• Device Information: Device type, operating system version (iOS), unique device identifiers, IP address, and network information.

• Usage Data: Details of how you use the App, such as features accessed, time spent on the App, crashes, and performance data.

• Analytics Data: Data collected via third-party analytics services (e.g., Google Firebase) to track and analyze App usage patterns for improvement. This data is generally non-personally identifying or aggregated.

2. How We Use Your Information

We use the information we collect for the following purposes:

1. To Provide Core Services: To perform the skin analysis function, track your skincare routine, generate personalized AI-driven suggestions, and display progress over time.

2. Service Improvement and AI Training: To understand usage trends, debug errors, and continuously improve the accuracy and quality of our AI skin analysis models. We use de-identified or aggregated health and skin data for this purpose.

3. Personalization: To customize the App experience, including recommendations and routine reminders, based on your specific skin data and goals.

4. Security and Support: To ensure the security of the App and to respond to your inquiries, support requests, and troubleshoot issues.

5. Legal Compliance: To comply with applicable laws, regulations, and legal processes.

3. How We Share Your Information

We may share your information only in the following limited circumstances:

• With Service Providers: We may share data with third-party vendors, consultants, and other service providers who perform services for us or on our behalf, such as cloud hosting providers (for data storage) and analytics providers. These providers are contractually obligated to protect your data.

• For Legal Reasons: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) prevent fraud, or (iv) protect the safety of users of the App or the public.

• Business Transfers: If Kello Solutions is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you via a prominent notice on the App if such an event occurs and of any change in ownership or use of your personal data.

• With Your Consent: We may disclose your personal information for any other purpose with your explicit consent.

We do not sell your personal data, including your sensitive skin and health data.

4. Retention of Your Information

We retain your personal data and sensitive health data only for as long as necessary to provide you with the App’s services, for our legitimate business purposes (such as maintaining and improving our AI models), and as required by law.

If you delete your account, or request deletion of your data, we will take steps to delete your personal data from our systems. However, some data may persist in backups or archives for a limited period, and anonymized/aggregated data derived from your health data may be retained indefinitely for the purpose of improving our AI model.

5. Security of Your Information

We use administrative, technical, and physical security measures designed to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

6. Children’s Privacy (COPPA Compliance)

The Pure Skin | DERMA AI App is not intended for use by anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If we become aware that we have collected Personal Information from a child under age 13 without verification of parental consent, we will take steps to remove that information from our servers.

7. Your Data Protection Rights (GDPR and CCPA)

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right to Access: The right to request copies of your personal data.

• Right to Rectification: The right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

• Right to Erasure (Right to be Forgotten): The right to request that we erase your personal data, under certain conditions.

• Right to Restrict Processing: The right to request that we restrict the processing of your personal data, under certain conditions.

• Right to Object to Processing: The right to object to our processing of your personal data, under certain conditions.

• Right to Data Portability: The right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

To exercise any of these rights, please contact us using the contact information provided below.

8. Changes to This Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time. We will alert you about any changes by updating the “Effective Date” of this Privacy Policy and may notify you by email or through a prominent notice on the App. Your continued use of the App after such modifications will constitute your acknowledgment of the modified Privacy Policy.

9. Contact Us

If you have questions or comments about this Privacy Policy, please contact us at:

Kello Solutions Email: info@kellosolutions.com