Privacy Policy

Last updated: February 20, 2026

This Privacy Policy ("Privacy Policy") describes how Gigzy Ltd ("Gigzy", "we", "us" or "our") collects, uses and protects personal data when you access or use the skinPulse mobile application and related services (collectively, the "Services").

Gigzy Ltd is incorporated in Israel.

Privacy contact: support@gigzy.net

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

1. Nature of the Services (Non-Medical Disclaimer)

The Services provide cosmetic, beauty and wellness-related insights based on visual analysis and user-provided information.

The Services:

• do not provide medical advice, diagnosis or treatment;
• are not intended to prevent, treat or cure any disease or medical condition;
• do not replace consultation with licensed medical professionals.

All recommendations provided through the Services are informational and cosmetic in nature only, including skincare routines, ingredient insights and general lifestyle or wellness suggestions.

General wellness suggestions (such as hydration, physical activity or daily habits) are not personalized medical recommendations and should be understood as lifestyle guidance only.

2. Information We Process

2.1 Personal Data

"Personal Data" means any information relating to an identified or identifiable individual.

We may process the following categories of Personal Data:

a. Usage Data

Information about how you use the Services, including:

• IP address;
• device type and operating system;
• interaction events and usage patterns.

Usage Data is processed to operate, secure and improve the Services.

b. Facial Images (Visual Analysis Only)

You may choose to upload a facial image solely for the purpose of cosmetic and beauty-related visual analysis.

Clarifications:

• Facial images are not stored by Gigzy.
• Images are processed transiently and deleted immediately after analysis.
• Images are not used for biometric identification.
• Images are not used to identify diseases, medical conditions or health risks.
• Images are not used for training models.

Facial images are processed exclusively to generate non-medical skincare insights.

c. Email and Communication Data

If you register or communicate with us, we may process:

• your email address;
• correspondence content and related metadata.

This data is used to:

• operate the Services;
• respond to inquiries;
• send service-related or marketing emails where consent is provided.

3. Legal Basis for Processing

We process Personal Data under the following legal bases:

• Performance of a contract — to provide and operate the Services;
• Consent — for email communications and marketing;
• Legitimate interests — to secure, maintain and improve the Services;
• Legal obligations — where processing is required by law.

4. Automated Processing

The Services use automated processing to generate cosmetic and wellness insights.

The Services do not make automated decisions that produce legal or similarly significant effects on users.

5. Third-Party Processing and AI Services

Gigzy uses third-party service providers strictly as data processors.

Facial image analysis is performed using OpenAI infrastructure, acting as a processor on our behalf. Such processing is conducted solely to provide the requested analysis and in accordance with applicable data processing agreements.

Third-party processors are contractually required to implement appropriate technical and organizational measures to protect Personal Data.

6. International Data Transfers

Personal Data may be processed outside your country of residence.

Israel is recognized by the European Commission as providing an adequate level of data protection.

Where international transfers occur, they are safeguarded through adequacy decisions or other lawful transfer mechanisms.

7. Data Retention

Gigzy applies strict data minimization principles.

• Facial images: not stored.
• Usage and technical data: retained only for the period necessary to operate and improve the Services.
• Email and communication data: retained until you unsubscribe or request deletion, unless longer retention is required by law.

8. Your Rights

Subject to applicable law, you may have the right to:

• access your Personal Data;
• request correction or deletion;
• restrict or object to processing;
• withdraw consent at any time;
• lodge a complaint with a supervisory authority.

Requests may be sent to: support@gigzy.net

9. Marketing Communications

You may receive emails from us if you have provided consent.

You may opt out at any time by:

• using the unsubscribe link included in emails; or
• contacting us at support@gigzy.net.

10. Information Security

We implement industry-standard technical and organizational measures to protect Personal Data against unauthorized access, disclosure or loss.

No method of transmission or storage is completely secure, but we take reasonable steps to protect Personal Data.

11. Children and Age Restrictions

The Services are intended for users 16 years of age or older.

We do not knowingly collect Personal Data from individuals under 16.

12. California Privacy Rights

Where applicable, California residents may have additional rights under California privacy laws, including rights of access and deletion.

Requests may be submitted to support@gigzy.net.

13. Third-Party Links

The Services may contain links to third-party websites or services. We are not responsible for the privacy practices of such third parties.

14. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the State of Israel.

Exclusive jurisdiction is granted to the competent courts of Tel Aviv-Jaffa, Israel.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Material changes will be communicated through the Services or via email.

16. Contact

For privacy-related questions or requests:

Gigzy Ltd
Email: support@gigzy.net
Israel