Privacy Notice
Last updated: 7th October 2026
This Privacy Notice explains how Clicked Technologies Limited (“CLICKED!”, “we”, “us”, “our”) collects, uses and protects your personal data when you use our mobile app (“App”) or visit our website (“Website”). We are committed to keeping your information safe and processing it in line with UK GDPR and the Data Protection Act 2018.
This Notice is available on our Website and inside the App, in Help and Feedback > Privacy Policy. If you have questions, contact us at support@clicked.skin
1. Who We Are
Data Controller: Clicked Technologies Limited. Registered in England & Wales.
Email: support@clicked.skin
Address: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ
2. The Data We Collect
Face Data at a glance
What we collect: front, left and right photographs of your face, which you choose to upload.
How it's used: analysed by AI/ML models to generate your skin analysis, insights and recommendations; a random sample is also reviewed by our skincare team for quality assurance, as this is not currently a fully automated process. Never used for facial recognition, identity verification or advertising, and no facial-recognition template is created.
Shared with: only Amazon Web Services (AWS), our cloud infrastructure and AI-processing provider, and a small number of other service providers under contract — never sold, and never shared with advertisers.
Stored where: AWS's Europe (London) region, i.e. within the UK.
Retained for: as long as your account is active, and deleted once your account deletion request is completed.
Full detail: see Sections 2a, 3, 4, 5, 6, 7 and 9 below.
2a. Data you provide
Account details: name, email address, password.
Profile information: age, gender, skin concerns, lifestyle information you choose to share.
Face Data: photographs of your face that you upload so the App can analyse your skin. This normally includes front, left and right photographs of your face. Before you submit a photo, CLICKED! may use on-device face detection to help you position your face correctly for capture; this runs on your device and is used only to guide capture, not to identify you. Once submitted, your photographs are uploaded securely and analysed by AI/ML models to assess visible skin characteristics. We do not extract facial geometry or create a facial-recognition template, and we do not use your photographs for facial recognition or identity verification. We use Face Data only to generate your skin analysis, routine and recommendations. We do not use it to identify or authenticate you, and we do not use it for advertising, marketing, or any purpose beyond the features you've asked for.
On-device face detection: CLICKED! uses on-device face detection technology to help users correctly position their faces when capturing photographs for skin analysis. This technology processes camera frames locally on your device to detect facial positioning and orientation. The face detection process does not identify individuals or transmit camera frames to external servers.
Photographs captured and submitted for skin analysis are processed separately in accordance with our privacy policy.
Any messages or feedback you send us.
2b. Data collected automatically
Device information (model, OS version)
App usage statistics
IP address
Cookies (on the Website only — see Section 10)
2c. Optional data
Marketing preferences
Survey responses
Product review contributions
We ask for your date of birth when you create an account and will not knowingly create an account for, or collect data from, anyone who tells us they are under 16.
3. How We Use Your Data
Core functions
Analyse your skin, including your Face Data
Provide skincare insights and product recommendations
Personalise your experience in the App
Improve our algorithms and features
Face Data, specifically
We use your Face Data only to analyse your skin and generate your personal insights, routine and recommendations.
We do not use your facial photographs to train general-purpose or third-party AI models. We may use your photographs to fine-tune and improve CLICKED!'s own skin-analysis models, so our analysis gets more accurate over time. You can opt out of this specific use at any time by emailing support@clicked.skin, without affecting your own skin analysis.
We do not use Face Data for advertising, marketing, or to build a profile of you beyond your own skin analysis.
Review by our skin team
Your skin analysis, insights and recommendations are generated by AI/ML models, hosted within our cloud infrastructure, that assess the photographs and information you provide. A random sample of submissions is also reviewed by a qualified member of our skincare team, as part of our quality assurance process. This is not currently a fully automated process. Our skincare team accesses photographs and the related analysis through an internal reporting dashboard, available only to authorised personnel, for this purpose. Neither the AI/ML models nor this review process are used for facial recognition, identity verification or authentication, and neither creates a facial-recognition template or uses facial geometry to identify you.
Operational purposes
Manage your account and customer support requests
Maintain App performance and security
Conduct research and product development
Show anonymised and aggregated insights
Marketing (optional)
Email updates, news, offers
Push notifications
You can opt out of marketing at any time.
4. Legal Bases for Processing
We process your data using the following legal grounds:
Contract — to deliver the service you've signed up and paid for
Consent — when you upload Face Data, provide sensitive lifestyle/skin data, or opt in to marketing
Legitimate Interests — improving the App, preventing fraud
Legal Obligation — keeping required financial records, responding to lawful requests
Face Data, and any other data revealing details about your physical appearance, is “special category data” under UK GDPR. We only process it with your explicit consent, collected through a dedicated consent step before your first photo upload — separate from your general acceptance of our Terms of Service. You can withdraw this consent at any time by emailing support@clicked.skin; doing so stops future photo analysis and lets you delete previously uploaded photos (see Section 9).
5. How We Store and Protect Your Data
We use industry-standard encryption and secure cloud storage providers. Your personal data, including facial photographs, is securely stored and processed within our cloud infrastructure hosted by Amazon Web Services (AWS), in the AWS Europe (London) region.
We retain your data only as long as necessary for the purposes above. For facial photographs specifically: we retain them only for as long as necessary to provide the skin-analysis service and your account, or until your account deletion request is completed, at which point your stored facial photographs are deleted from our systems. We may retain anonymised analysis information that can no longer be linked to you, except for the minimal records described in Section 9.
You can request deletion at any time (see Section 9). We never sell your personal data.
6. Sharing Your Data
We share data only with:
Amazon Web Services (AWS), our cloud infrastructure provider and data processor — which securely stores your data, including facial photographs via Amazon S3, and runs the AI/ML models that analyse it, including via Amazon SageMaker, strictly to provide the CLICKED! service
Other service providers who help us run CLICKED! (for example, customer support tooling), under contracts requiring the same protections as this Notice
Analytics tools (anonymised/aggregated where possible)
Payment processors (if you have a subscription)
Law enforcement, only if required by law
All third parties who process data on our behalf are contractually required to protect it to the same standard as this Notice. Access to your facial photographs, including through our internal reporting dashboard described in Section 3, is restricted to the systems and personnel who need it to provide, review, maintain or support the service. We do not sell your facial photographs, and we do not share them with third parties for their own advertising, marketing, tracking or independent purposes.
If we or our subsidiaries are involved in a merger, acquisition or asset sale, your personal data may be transferred as part of that transaction; we'll tell you if this materially changes how your data is handled.
We do not share your images, Face Data, skin information or profile with advertisers, and we do not use Face Data for advertising or marketing.
7. International Data Transfers
Our production infrastructure, and your facial photographs, are hosted in the AWS Europe (London) region, so this data is stored and processed within the UK. Where any other service provider referenced in this Notice is located outside the UK, we only transfer data to countries the UK government has confirmed offer adequate protection, or under a UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, both of which require the receiving party to protect your data to UK standards.
8. Your Rights
Under UK GDPR, you have the right to:
Access your data
Correct inaccurate data
Delete your data (“right to be forgotten”)
Withdraw consent
Restrict processing
Ask for data portability
Object to certain processing
Make a complaint to the ICO (www.ico.org.uk)
To exercise your rights, email support@clicked.skin
9. Deleting Your Account & Data
You can delete your account from within the App. This deletes your photos (including Face Data), profile and analysis history.
We retain minimal records if legally required (e.g. transaction history).
10. Cookies
Our Website uses cookies. You can manage your cookie preferences at any time via the cookie banner on our Website.
11. Updates to This Notice
We may update this Notice occasionally. If changes are significant, we'll notify you through the App or Website.