Privacy policy.

SmartLED® is a trademark operated by SmartLed Mask L.L.C-FZ, a Limited Liability Company registered in the Meydan Free Zone, Dubai, United Arab Emirates.

This Privacy Policy is maintained by SmartLed Mask L.L.C-FZ and explains how we handle personal data when you visit our website, use our app, use our connected products and skin-analysis features, communicate with us, or purchase our products.

For any privacy-related question, you can contact us at privacy@smartled.ai or through our contact page.

SmartLed Mask L.L.C-FZ is the data controller responsible for the processing described in this Privacy Policy, unless otherwise stated.

• Legal name: SmartLed Mask L.L.C-FZ
• License number: 2647542.01 — Meydan Free Zone Authority
• Formation number: 2647542
• Registered address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.
• Manager: Yoan Alexandre Abelanski
• Activities: Beauty & Personal Care Requisites Trading · E-Commerce

We only collect information that is reasonably necessary to provide, personalize, secure, and improve our services. Depending on how you interact with SmartLED®, this may include:

• Account information: your name, email address, account identifier, password, language, country, and account preferences when you create or manage an account in the SmartLED app.
• Order information: your shipping and billing address, contact details, order history, delivery information, and payment-related information. Complete payment card details are processed by our secure payment providers and are not stored directly by SmartLED® unless expressly stated.
• Skin profile data: optional information you choose to provide, such as your skin type, skin concerns, sensitivities, skincare goals, preferred routines, and other information used to personalize your SmartLED experience.
• Facial images: photographs or images of your face that you choose to capture or upload when using a skin-analysis feature. The app will request permission before accessing your camera or photo library.
• Skin-analysis results: cosmetic skin indicators and observations generated from your skin profile or facial images, which may include information relating to the appearance of wrinkles, fine lines, pores, redness, pigmentation, blemishes, hydration, texture, elasticity, or other visible skin characteristics.
• Recommendations and progress data: personalized LED routines, skincare recommendations, suggested products, previous skin analyses, routine history, and information used to help you monitor changes over time.
• Usage data: information about how you interact with the website, app, and connected device, such as session duration, features used, screens viewed, routine activity, button interactions, and crash or diagnostic reports.
• Device and technical information: app version, operating system, device type, language, IP address, device or app identifiers, connection information, and technical information used to operate, secure, and optimize our services.
• Marketing preferences: your choices regarding emails, push notifications, personalized recommendations, promotional offers, cookies, advertising, and other marketing communications.
• Communications: emails, contact requests, support messages, reviews, survey responses, feedback, and other information you choose to send us.
• Fraud-prevention and security information: information reasonably necessary to verify transactions, protect accounts, detect misuse, prevent fraud, and maintain the security of our services.

You are not required to provide optional skin-profile information or use the facial-analysis feature. However, certain personalized functions may not be available without this information.

If you choose to use a SmartLED® facial or skin-analysis feature, we may process facial images and generate cosmetic skin-analysis results to:

• assess visible skin characteristics;
• personalize your LED routines;
• recommend relevant skincare routines and SmartLED® products;
• allow you to monitor cosmetic changes over time;
• improve the accuracy, reliability, and usability of our services, where permitted by law;
• provide personalized content, recommendations, and offers where you have provided consent when required.

Facial images and skin-analysis results are processed for cosmetic skincare and wellness purposes only. They are not intended to provide medical advice, diagnose a medical condition, or replace advice from a qualified healthcare professional. SmartLED® does not use facial images for facial recognition, identity verification, surveillance, or biometric identification. We do not sell facial images or raw skin-analysis results. We do not provide facial images or raw skin-analysis results to advertising networks for their own advertising purposes. Where technically possible, facial images may be processed on the user's device. Where server-side processing is required, images may be transmitted securely to our systems or to service providers acting solely on our instructions. The exact processing method may depend on the version of the app, the feature used, and the user's device.

SmartLED® may use artificial intelligence, machine-learning models, image-processing technologies, or automated systems to analyze visible skin characteristics and generate cosmetic skincare recommendations.

These systems may process information such as facial images, skin-profile information, previous analyses, and usage preferences.

The resulting analysis is intended to assist with cosmetic personalization only. It does not constitute a medical diagnosis or professional medical advice.

SmartLED® does not use skin-analysis results to make decisions that produce legal effects or similarly significant effects concerning a user.

We may use personal data for the following purposes:

• To create, authenticate, maintain, and secure your account.
• To process payments, fulfill and deliver orders, manage returns, and provide customer support.
• To operate the SmartLED app and connected device.
• To perform cosmetic skin analyses requested by you.
• To personalize LED routines based on your skin profile, skin-analysis results, preferences, and previous use.
• To recommend SmartLED® products, skincare routines, content, and features that may be relevant to your skin profile or cosmetic goals.
• To retain previous skin assessments, when the relevant feature is enabled, so that you can monitor changes over time.
• To improve our products, artificial-intelligence systems, skin-analysis features, app experience, website, and customer service, where permitted by law.
• To send important transactional or service-related information concerning your account, orders, device, safety, security, or changes to our services.
• To send newsletters, promotional messages, product recommendations, special offers, or other marketing communications where you have agreed to receive them or where otherwise permitted by applicable law.
• To personalize marketing communications and promotional offers based on your purchases, preferences, skin profile, or skin-analysis results, with your consent where required by applicable law.
• To measure the effectiveness of our communications and marketing campaigns.
• To display or measure advertising, where permitted and subject to any consent required by law or by the operating-system platform.
• To detect, investigate, and prevent fraud, misuse, security incidents, or violations of our terms.
• To comply with legal, regulatory, tax, accounting, and contractual obligations.
• To establish, exercise, or defend legal claims.

SmartLED® may use information such as your skin profile, skin-analysis results, purchase history, routines, preferences, and interactions with our services to recommend products, routines, content, and promotional offers that may be relevant to you.

Personalization may take place within the SmartLED app, on the SmartLED website, through email, through push notifications, through customer-support communications, or through other channels for which you have provided the necessary permission.

Where required by applicable law, we will ask for your consent before using skin-profile or skin-analysis information for personalized marketing.

You can withdraw your marketing consent or change your preferences at any time through the settings made available in the app, by using the unsubscribe link included in marketing emails, by disabling push notifications in your device settings, or by contacting privacy@smartled.ai.

Withdrawing consent will not affect service-related communications that are necessary to operate your account, fulfill an order, provide requested services, or communicate important safety and security information.

SmartLED® may use advertising, analytics, and measurement partners to promote its products, understand the performance of its campaigns, and reach people who may be interested in its services.

Where permitted by applicable law and only after obtaining the required permissions, we may share limited information with advertising platforms, such as:

• an email address or telephone number in a hashed or otherwise protected form;
• an advertising or device identifier;
• information indicating that an account holder visited our services, used a feature, or made a purchase;
• marketing campaign and conversion information.

We do not share facial images or raw skin-analysis results with advertising platforms for their own advertising purposes. Where information from the SmartLED app is linked with information collected by other companies for targeted advertising or advertising measurement, we will request the permissions required by the applicable operating-system platform. On Apple devices, this may include requesting authorization through Apple's AppTrackingTransparency framework before engaging in activity that Apple defines as tracking. Refusing tracking permission will not prevent you from using the principal functions of the SmartLED app. You may also manage certain advertising choices through the app, your device settings, our cookie-preference tools, or the relevant advertising platform.

Depending on your location and the particular processing activity, we process personal data on one or more of the following legal grounds:

• Performance of a contract: where processing is necessary to provide the app, connected product, order, skin-analysis feature, customer support, or another service requested by you.
• Consent: where you voluntarily provide optional skin-profile or facial-analysis information, agree to receive marketing communications, authorize personalized marketing, permit non-essential cookies, or authorize tracking where required.
• Legitimate interests: where processing is reasonably necessary to operate, secure, analyze, and improve our business and services, provided that these interests are not overridden by your rights and freedoms.
• Legal obligation: where processing is necessary to comply with applicable legal, regulatory, tax, accounting, or law-enforcement obligations.
• Establishment, exercise, or defence of legal claims: where necessary to protect our rights or respond to legal proceedings.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

We do not sell your personal data for money.

We may share personal data only where reasonably necessary with trusted service providers and partners that help us operate our business, such as:

• Payment processors that handle transactions securely.
• Shipping, fulfillment, and logistics partners that deliver your orders.
• Cloud-hosting, database, storage, and infrastructure providers that operate our website and app.
• Artificial-intelligence, image-processing, or technical service providers that assist us in providing the skin-analysis features, where applicable.
• Analytics and crash-reporting providers that help us understand and improve our services.
• Email, push-notification, customer-relationship-management, and customer-support platforms.
• Advertising and campaign-measurement providers, subject to the applicable permissions and restrictions described in this Privacy Policy.
• Professional advisers such as accountants, auditors, insurers, lawyers, and consultants.
• Government authorities, courts, regulators, or law-enforcement bodies where disclosure is required by law or necessary to protect our rights or the safety of users.
• A purchaser, investor, successor, or other relevant party in connection with a potential or completed merger, financing, restructuring, acquisition, or transfer of all or part of our business, subject to appropriate confidentiality protections.

Our service providers are contractually required to process personal data only for the services they provide to us, to follow our documented instructions where applicable, and to apply appropriate security and confidentiality measures. Any third-party SDK or service integrated into the app must provide the same or an equivalent level of protection required by this Privacy Policy and applicable platform rules.

SmartLED® is based in Dubai, United Arab Emirates. Some of our service providers may process personal data in other countries, including countries that may have data-protection laws different from those in your country.

Where required, we use appropriate safeguards for international transfers, such as contractual protections, standard contractual clauses, adequacy mechanisms, or equivalent lawful safeguards.

You may contact privacy@smartled.ai for additional information about the safeguards applicable to your data.

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, to provide our services, or to comply with legal, tax, accounting, security, and contractual obligations.

Retention periods depend on the nature of the data and the purpose for which it is processed. In particular:

• Account information is generally retained while your account remains active and for a limited period after account closure where necessary for security, dispute resolution, or legal compliance.
• Order and transaction records may be retained for the period required by applicable tax, accounting, consumer-protection, and commercial laws.
• Marketing preferences and consent records may be retained for as long as necessary to demonstrate and respect your choices.
• Skin-profile information, saved skin-analysis results, routines, and progress history may be retained while your account remains active or until you delete them, disable the relevant feature, withdraw your consent where applicable, or request account deletion.
• Facial images are retained only for as long as necessary to perform the requested analysis, provide an expressly requested history feature, or fulfill another purpose clearly disclosed to you. Images that are not needed after analysis will be deleted or anonymized in accordance with our technical and operational retention procedures.
• Security, diagnostic, and fraud-prevention records may be retained for a reasonable period necessary to protect our services.

When personal data is no longer required, we delete it, anonymize it, or isolate it securely unless continued retention is required by law.

You may request deletion of your account and associated personal data through the account-deletion feature available in the SmartLED app or by contacting privacy@smartled.ai.

When an account-deletion request is completed, we will delete or anonymize the personal data associated with the account unless we are legally required or otherwise lawfully permitted to retain certain information.

Certain records may be retained where necessary to comply with tax, accounting, fraud-prevention, product-safety, regulatory, or legal obligations, or to establish, exercise, or defend legal claims.

Deleting the app from your device does not automatically delete your SmartLED account or personal data stored on our systems.

Apple requires applications that support account creation to allow users to initiate account deletion from within the application.

Depending on your location, you may have the right to:

• Access the personal data we hold about you.
• Obtain information about how your personal data is used.
• Correct inaccurate or incomplete personal data.
• Request deletion of your account and personal data in certain circumstances.
• Object to or restrict certain types of processing.
• Withdraw your consent at any time.
• Opt out of marketing communications.
• Receive a copy of certain personal data in a portable format.
• Lodge a complaint with a competent data-protection or supervisory authority.
• Request information regarding international transfers and applicable safeguards.

To exercise your rights, contact privacy@smartled.ai. We may need to verify your identity before responding to a request. We will respond within the timeframe required by applicable law.

Our website and, where applicable, our app use cookies, pixels, local storage, SDKs, and similar technologies to:

• provide essential website and app functions;
• remember your preferences;
• secure accounts and prevent fraud;
• analyze traffic and usage;
• measure the performance of our services and communications;
• personalize content and offers;
• support advertising and campaign measurement where permitted.

Essential technologies required for the website or app to operate cannot always be disabled. Where required by law, analytics, personalization, or advertising technologies will be activated only after you have provided the necessary consent. You may manage your choices through our cookie-preference tools, where available, through your browser settings, through your device settings, or by withdrawing a previously provided consent. Blocking certain technologies may affect the availability or performance of some functions.

We take the security of personal data seriously. We use reasonable technical and organizational measures designed to protect personal information, including, where appropriate:

• encryption during transmission and storage;
• secure servers and cloud environments;
• access controls and authentication measures;
• restricted employee and contractor access;
• logging, monitoring, and security reviews;
• procedures for responding to suspected security incidents.

However, no method of storage or transmission over the internet is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and for notifying us promptly if you suspect unauthorized access to your account.

Our website and app are not intended for children under 16.

We do not knowingly collect personal data, facial images, or skin-analysis information from children under 16.

If you believe that a child has provided personal data to us, please contact privacy@smartled.ai. We will investigate and delete the information where required.

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, services, legal requirements, or relationships with service providers.

The updated version will be published on this page with a revised effective date.

Where changes materially affect how we use personal data, we will provide additional notice or request new consent where required by applicable law.

We encourage you to review this Privacy Policy periodically.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal data, please contact us:

• Data controller: SmartLed Mask L.L.C-FZ
• Privacy email: privacy@smartled.ai
• Support email: support@smartled.ai
• Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.