Privacy Policy

Effective Date: Jan 2026

FozDoc operates beauty AR and AI skin analysis services and related platform features available through mobile devices, in-store consultations, tablets, computers, and other consumer electronic devices (the "Service(s)"). As used in this policy, "FozDoc" refers to FozDoc and its subsidiaries and affiliates. This policy applies to all FozDoc‑authorized operations of the Service available through https://FozDoc.com and any related applications or in-store interfaces.

By using our Services, creating an account, or continuing to use the app after this policy is presented to you, you acknowledge that you have read this policy and you give your explicit consent to the collection, use, storage, and disclosure of your personal data, including facial images and biometric-related data, as described below and in accordance with applicable Egyptian law, including Egypt’s Personal Data Protection Law No. 151 of 2020 and its Executive Regulations where applicable.

This app and service provide cosmetic and wellness‑oriented information only and are not intended to provide medical advice, diagnosis, or treatment. Always seek the advice of a qualified physician or other healthcare provider with any questions you may have regarding a medical condition before making any medical decision. Do not disregard professional medical advice or delay seeking it because of any information or output you obtain through the service.

Personal data we collect

We may collect and process the following categories of personal data, for the purposes set out in this policy:

Information you provide

• Name, email address, mobile number and other contact details you submit when registering or contacting us.
• Demographic information and skin or beauty preferences you choose to provide (for example, skin type, concerns, product preferences).

Skin analysis images and biometric-related information

• Photos or video frames of your face and skin that you capture or upload to receive skin analysis, virtual try‑on, or simulation results.
• Facial geometry and other technical measurements derived from those images enable our algorithms to perform virtual try‑on, skin analysis, and similar functions.
• These data may constitute sensitive personal data under Egyptian law and are therefore processed based on your explicit consent and subject to enhanced protection.
• For real-time analysis, your face images and facial geometry are captured and processed to generate your skin analysis and recommendations. In addition, FozDoc keeps a copy of your analysis images and derived facial measurements so that the app can compare your current results with future analyses and show your cosmetic progress over time, and so that we can train and improve our AI models.

Technical and device information

• IP address, device type, operating system version, browser type, mobile network information, app version, language settings, and other technical identifiers (such as device identifiers and MAC address).
• Log information such as access dates and times, app or website features used, and diagnostic information.

Location information

• Approximate location based on IP address and, if you grant permission in your device settings, more precise location information.

Membership account and transaction data

• Account credentials (email, password) and profile details.
• Billing and payment information for paid features is processed via authorized payment service providers.
• History of your use of the Service, including analysis sessions and recommendations viewed.

Customer support and communications data

• Information you provide when you contact us (e.g., support tickets, email messages, call recordings where permitted by law).
• Preferences regarding marketing communications where you opt in.

We may also receive limited information about you from third parties (such as business partners that embed our technology, or service providers), and from public or governmental sources where permitted by law.

Cookies and similar technologies

We use cookies, SDKs, and similar technologies to:

• Keep you signed in;
• Remember your preferences;
• Measure and analyze the performance and use of our Services; and
• Support security and fraud prevention.

You can manage cookies through your browser or device settings, but some features may not function properly if certain cookies are disabled.

How we use your data (including model training)

We use personal data only for specified, clear, and legitimate purposes, and we do not further process it in a way that is incompatible with those purposes.

We use your data to:

• Provide and operate the Services: Perform skin analysis, virtual try‑on, and simulations. Display product recommendations and personalized experiences. Maintain and secure your account and enable core features.
• Improve, train, and develop models and Services: When we store face images and facial geometry beyond a single analysis, we do so only for specific purposes, including:
  • enabling progress‑tracking features by comparing your current analysis with later analyses; and
  • training, testing, and validating our AI and AR models to improve accuracy, robustness, and fairness for cosmetic skin assessments.
  We do not store face data indefinitely and apply data‑minimization and de‑identification techniques where possible.
• Analytics and statistics: Analyze usage trends and performance to understand how the Services are used and to improve user experience. Produce aggregated statistics for internal reporting and for our business customers, without identifying individual users.
• Communications and support: Respond to your requests and inquiries. Send you important notices about changes to our Services or this policy. Send you marketing communications (such as new features or offers) only where you have given prior consent, and allow you to opt out at any time.
• Legal compliance and protection: Comply with legal obligations under Egyptian law, including responding to lawful requests by regulators, courts, or law enforcement. Protect the rights, property, or safety of FozDoc, our users, or others, and detect, prevent, or address fraud, abuse, or security issues.

We do not sell your personal data and do not share it with third parties for their own independent direct marketing purposes.

Legal basis and consent (Egypt PDPL focus)

Under Egyptian Personal Data Protection Law No. 151 of 2020, processing of personal data is generally prohibited unless the data subject has consented or another legal basis applies.

For most processing, including account data, skin analysis images, and biometric‑related data, our primary legal basis is your explicit consent.

You may withdraw your consent at any time, but this will not affect the lawfulness of processing carried out before withdrawal; it may also limit or disable some or all functionalities of the Service.

In limited cases, we may process personal data without consent where this is required by applicable law or necessary to establish, exercise, or defend legal claims, or to comply with court orders or binding decisions from competent authorities.

How we share personal data

We may share your personal data with:

• Service providers (processors): Face images and facial geometry are processed only on FozDoc’s backend systems and are not shared with external providers for their own use.
• Business clients and partners: We only share aggregated, anonymized, or pseudonymized statistics with our business partners (such as retailers, pharmacies, or beauty brands), so that they cannot identify you from this information. We do not share your identifiable face images or facial geometry with business partners.
• Affiliates and group companies: Our group entities may access personal data where necessary for the purposes described in this policy, subject to appropriate safeguards.
• Legal and regulatory recipients: Competent authorities, courts, or regulators when we believe disclosure is required by applicable law or necessary to protect our legal rights or those of others.

We may also share de‑identified, anonymized, or aggregated information that does not identify you, for research, analytics, or business purposes.

Retention (including images and biometric‑related data)

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including providing the Service, training and improving our models, complying with our legal obligations, and resolving disputes, and then securely delete or anonymize it.

• Account and transactional data: kept for the duration of your account plus a reasonable period to comply with recordkeeping obligations and limitation periods.
• Support and communication records: retained for as long as necessary to address your request and for a limited subsequent period.
• Facial images and biometric‑related data used for the Service and for model training: When you perform a skin analysis, your face images and derived facial measurements are processed to produce your cosmetic assessment and recommendations and to enable progress tracking over time. From the moment they are stored, these images and measurements are handled in a way that removes direct identifiers and are stored under technical identifiers rather than your plain name or contact details. We retain these anonymized or pseudonymized analysis images and derived facial measurements for at least two years and until you have completed at least two additional analysis scans, so that we can: start showing you your cosmetic progress over time; and train, test, and improve our AI and AR models for cosmetic skin assessment.

After the applicable retention period in our internal schedule has passed, we delete the underlying data or irreversibly anonymize it so that it can no longer be linked back to you, except where a longer retention period is required by law or needed to establish, exercise, or defend legal claims. We do not store raw face images or identifiable facial geometry for model‑training purposes indefinitely.

Data subject rights (Egypt)

Subject to conditions and exceptions under Egyptian law, you have the following rights in relation to your personal data:

• Right to be informed about the processing of your personal data;
• Right to access your personal data and obtain information about how it is processed;
• Right to request rectification, updating, or completion of inaccurate or incomplete data;
• Right to request erasure of your personal data where the legal conditions are met;
• Right to restrict or object to certain forms of processing, including direct marketing;
• Right to withdraw consent at any time where processing is based on consent;
• Right to lodge a complaint before the competent Egyptian data protection authority or Personal Data Protection Center, once fully established and operational.

You can exercise your rights by contacting us at info@artrixx.com. We may need to verify your identity before responding, and we may not always be able to fully comply with your request where a legal obligation or overriding legitimate interest applies; in such cases, we will explain our reasons as required by law.

Data security

We apply appropriate technical and organizational security measures designed to protect personal data against unauthorized access, accidental loss, alteration, or destruction. These measures may include:

• Encryption in transit (e.g., TLS/SSL) and at rest where appropriate;
• Access controls and authentication;
• Segregation of duties and least‑privilege access;
• Regular security assessments and monitoring.

However, no system can be completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential and immediately notifying us of any suspected unauthorized use of your account.

International data transfers

Where data is transferred outside the Arab Republic of Egypt to countries that may have different data protection rules, such transfers will take place in compliance with applicable Egyptian law and any requirements or approvals set by the competent Egyptian authority.

Children’s data

The Services are not directed at children under 18 years of age, and we do not knowingly collect personal data from children without appropriate consent from a parent or legal guardian where required by law. If you believe that a child has provided us with personal data without such consent, please contact us so that we can take appropriate steps.

Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be notified through the app, our website, email, or other appropriate means before they take effect. Your continued use of the Services after the effective date of an updated policy constitutes your acceptance of the changes.