Smart Mirror LLC
Apple Store: FaceEcho
Play Store: FaceEcho
This application is licensed to You (End-User) by Smart Mirror LLC, located in Houston, Texas (“Licensor”), for use only under the terms of this License Agreement.
By downloading the Licensed Application from Apple’s software distribution platform (“App Store”) or Google’s software distribution platform (“Play Store”), and any updates thereof (as permitted by this License Agreement), You indicate that You agree to be bound by all of the terms and conditions of this License Agreement. The App Store and Play Store are referred to in this License Agreement as “Services.”
The parties of this License Agreement acknowledge that the Services are not a party to this License Agreement and are not bound by any provisions or obligations with regard to the Licensed Application, such as warranty, liability, maintenance, and support thereof. The Licensor, not the Services, is solely responsible for the Licensed Application and the content thereof.
This License Agreement may not provide for usage rules for the Licensed Application that conflict with the latest Apple Media Services Terms and Conditions and Google Play Terms of Service (“Usage Rules”). Users acknowledge that they had the opportunity to review the Usage Rules and confirm this License Agreement does not conflict with them.
THE APPLICATION
Apple Store & Play Store: FaceEcho
The Licensed Application is a piece of software created to analyze facial concerns, provide expert online sessions, and offer solutions and product recommendations.
Customized for iOS and Android mobile devices (“Devices”), it helps users:
Experiment with makeup looks: Virtual makeup sessions and AI-based face scans allow users to explore makeup styles and enhance their appearance. A personalized content library offers makeup tutorials for various occasions.
Learn about skincare: Detailed information on skincare ingredients and home remedies to help users make informed decisions about their skincare routines.
Track skincare progress: Face scans help monitor progress and adjust routines for optimal results.
Receive product recommendations: Skincare and makeup products are suggested based on the user’s skin type and concerns, sourced from third-party brands.
The Licensed Application is not tailored to comply with industry-specific regulations (e.g., HIPAA, FISMA). Users interacting with such regulations must refrain from using the Licensed Application. Additionally, the Licensed Application must not be used in violation of laws such as the Gramm-Leach-Bliley Act (GLBA).
2. SCOPE OF LICENSE
2.1 License Grant
You are granted a non-transferable, non-exclusive, non-sublicensable license to install and use the Licensed Application on any Devices that You own or control, subject to the Usage Rules. Family Sharing or volume purchasing, where applicable, are exceptions.
2.2 Updates
This license governs any updates provided by the Licensor that replace, repair, or supplement the Licensed Application unless a separate license accompanies the update
2.3 Restrictions
You may not:
Share, sell, rent, or lease the Licensed Application.
Reverse engineer, decompile or attempt to derive the source code of the Licensed Application.
Copy or modify the Licensed Application, except as explicitly permitted.
Remove any intellectual property notices.
Violations may result in prosecution and damages.
2.4 Modifications
The Licensor reserves the right to modify the licensing terms. Users must also adhere to applicable third-party terms and conditions when using the Licensed Application
3. TECHNICAL REQUIREMENTS
3.1 Firmware Compatibility
The Licensed Application requires iOS 13 or Android equivalent. Users are encouraged to use the latest firmware.
3.2 Updates
The Licensor attempts to ensure compatibility with updated firmware and hardware but does not guarantee such updates.
3.3 User Responsibility
It is the user’s responsibility to ensure the Licensed Application is compatible with their device specifications.
3. Log Data
Whenever you use our Service, in case of an error in the app, we collect data and information (through third-party products such as BTBP) on your phone called Log Data. This Log Data may include information such as your device’s IP address, device name, operating system version, app configuration, usage time and date, and other statistics.
3.1 Our apps collect the following user data to enhance functionality and provide personalized services:
Facial Data: Photos of users’ faces taken from full-face angles to analyze facial features and detect parameters such as acne, wrinkles, and other skin conditions. For a detailed list, please refer to our comprehensive “facial tags” documentation.
Device Identifiers: Apple versions(IOS iPhone 15.6 or later) & Android ID (Version 14, 15), and Device ID (e.g., Samsung, Apple, OnePlus, etc). Google Analytics and UXCAM collect these identifiers, including IMEI numbers, to monitor app performance and deliver tailored user experiences.
Log Data: User logs are recorded exclusively for personalization and debugging purposes. UXCAM is used to collect bug or crash reports to ensure a seamless app experience.
3.2 We collect data to:
Provide Personalized Recommendations: Offer tailored skincare solutions, makeup tips, and product suggestions based on user’s unique facial features.
Enable Progress Tracking: This allows users to monitor long-term improvements through detailed analyses and visual progress reports.
Analyze Face Anatomy: Detect specific facial parameters to deliver targeted solutions.
Improve App Performance: User’s device identifiers and log data to optimize user experience and maintain app functionality.
3.3 Third-Party Involvement
Third-Party SDKs and Services We employ trusted third-party service providers to process user data:
BrighTex Bio-Photonics (BTBP): Handles facial analysis and temporarily stores data on Google Cloud servers in the USA for processing purposes.
OpenAI API: We share a text identifier—consisting of the user’s optional first name, last name, or a fallback string derived from the prefix of their email address (the portion before the “@” symbol if no name is provided)—along with specific metadata tags derived from the facial analysis (e.g., facial parameters/tags regarding skin conditions like acne) with the OpenAI API. This data is transmitted solely to generate personalized skin insights and tailored positive messages addressed to the user. Full email addresses, email domains, and raw facial images are never sent to OpenAI. OpenAI processes this data securely, does not permanently store or retain the data, and does not use our user data to train its models. We confirm that OpenAI provides an equal level of data protection and privacy compliance as maintained by Smart Mirror LLC.
These third-party services are used exclusively for the purposes outlined in this Privacy Policy and comply with applicable data protection standards.
4. Location Data and Pollution Tag
Our app may request access to your device’s location data to support a feature called the Pollution Tag. This feature uses your location to provide personalized skincare and beauty recommendations based on the pollution levels in your area. By understanding your environmental exposure, we can tailor product suggestions, skincare tips, and routines to better suit your skin’s needs. We do not use your location data for tracking or advertising purposes. Your location is only used in real-time to enhance your personal app experience and is not stored or shared with third parties. Location access is entirely optional and can be controlled via your device settings.
5. Retention Policy
Face data and other collected information are retained only for as long as necessary to deliver the app’s personalized services. The retention periods are as follows:
Progress Tracking Data: Retained for up to 360 days to allow users to monitor and assess improvements over time.
Recommendation Data: Stored temporarily for up to 1 week to ensure relevant suggestions.
Account Data: Deleted automatically within one month after account termination.
Users may request data deletion at any time by contacting us at info@faceecho.ai Upon request, all associated data will be permanently removed within one week.
5.1 User Control
We prioritize user control over personal data. Users can:
Request Data Deletion: The user can submit a request to delete all stored data by contacting us via email. Data will be removed within one week. (FaceEcho)
Monitor Data Usage: We use UXcam to Access information about the types of data collected and how it is used directly through the app.
Control Device Permissions: We provide the user with all instructions to grant permissions to limit data collection.
6. Metadata
Metadata is technical data associated with User Content, such as how, when, and by whom the content was collected and formatted. Users can add Metadata, like hashtags, to their User Content.
7. Cookies
Cookies are files with small amounts of data commonly used as anonymous unique identifiers. These are sent to your browser from websites and stored on your device’s internal memory.
This Service does not explicitly use cookies but may include third-party (BTBP) code and libraries that use cookies to collect information and improve their services. You can choose to accept or refuse these cookies, but some portions of the Service may be inaccessible if you refuse them.
8. Service Providers
We may employ third-party companies and individuals (e.g., BTBP) for the following purposes:
To facilitate our Service.
To provide the Service on our behalf.
To perform Service-related services.
To assist us in analyzing how our Service is used.
These third parties have access to your Personal Information only to perform their tasks and are obligated not to disclose or use the information for other purposes.
9. Security
We value your trust in providing us with your Personal Information and strive to use commercially acceptable means of protecting it. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.
10. Links to Other Sites
This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. These external sites are not operated by us, so we strongly advise reviewing their Privacy Policies. We assume no responsibility for their content, privacy policies, or practices.
11. Brand Partnership
Partner with Us
Get a custom code for your clients to use the app.
Promote your product to our users with minimal commission.
Boost your brand’s visibility in front of our user base.
Customize the app with your logo, colors, and branding to make it uniquely yours.
Tailor the app’s features to meet the skincare and makeup needs of your audience.
Increase your product sales traffic by 3x daily or weekly through our referral system.
Offer expert advice via chat or Zoom, exclusively promoting your brand.
Ensure your products are exclusively featured on our app, omitting any competitor brands.
12. Children’s Privacy
These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If a child under 13 has provided personal information, we immediately delete it from our servers. Parents or guardians aware of such instances should contact us for prompt action.
13. Changes to This Privacy Policy
We may update our Privacy Policy periodically. You are advised to review this page for any changes. Changes are effective immediately upon posting.
14. Contact Us
For questions or suggestions about our Privacy Policy, contact us at info@faceecho.ai
Last updated 4/21/25.