Last updated: September 2026

PRIVACY POLICY

INTRODUCTION

BareMatrix is developed, owned, and operated by Candid Design Inc. (“Candid,” “we,” “us,” or “our”).

We respect your privacy and are committed to protecting your Personal Data.

This Privacy Policy explains how we collects, uses, discloses, stores, and protects Personal Data when you use the BareMatrix mobile application, website, or related services (collectively, the “Services”).

This Privacy Policy applies to Users in Canada, the United States, the European Union, and the United Kingdom. Additional rights or protections may apply depending on where you live.

Please read this Privacy Policy carefully. By using the Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

1. Who We Are

BareMatrix is owned and operated by:

Candid Design Inc.
Email: info@candid-design.com

Candid is responsible for the Personal Data collected and processed through the Services.

Where applicable under privacy laws such as the GDPR or UK GDPR, Candid acts as the data controller of Personal Data processed through the Services.

2. Information We Collect

2.1 Information You Provide

Depending on how you use the Services, we may collect:

  • Account information: Email address and authentication information

  • Profile information: Information you choose to provide

  • Product scan information: Images of product packaging, ingredient lists, and product label information

  • Saved information: Products and ingredients you save or bookmark

  • Skincare information: Skincare routines, skincare diary entries, quiz responses, skin preferences, and other information you choose to provide, such as mood, water intake, diet-related notes, or general environmental context

  • Community content: Posts, comments, product feedback, and other content you choose to share publicly

  • Communications: Support requests, feedback, and other communications with us

  • Subscription information: Subscription status and transaction or entitlement information provided by Apple, Google, or our subscription service providers. We do not receive your full payment card details from these platforms.

Some information is optional, but certain features may not function without it.

2.2 Information Collected Automatically

When you use the the App or Website, we may automatically collect:

  • Device information: Device type, operating system, and App version

  • Usage information: Features used, interactions, and in-app activity

  • Approximate location: Country or region, where available. We do not collect precise GPS location.

  • Technical information: Crash reports, diagnostic information, performance data, and error logs

  • Scan information: Images and text extracted from product images submitted through the App to provide ingredient analysis and related functionality.

We use this information to operate, secure, maintain, troubleshoot, and improve the Services.

2.3 Information from Third Parties

We may receive limited information from third parties that support the Services, including:

  • Apple App Store and Google Play: Subscription status, transaction information, and receipt validation

  • Subscription providers: RevenueCat and similar providers that help manage subscriptions and entitlements

  • Service providers: Hosting, analytics, security, and technical infrastructure providers

  • Image-processing providers: Services used to extract or process text from product images for ingredient analysis

These providers process information on our behalf for the purposes described in this Privacy Policy.

We do not purchase Personal Data from data brokers.

3. How We Use Personal Data

We may use Personal Data to:

  • Provide and operate the Website, App and related Services and features

  • Process product scans and provide ingredient analysis

  • Support skincare routines, journaling, personalization, and other features

  • Provide skincare quizzes and use quiz responses to personalize relevant features and content

  • Enable community features and User Content

  • Save and manage User preferences and saved items

  • Verify and expand our product and ingredient database using information obtained from product scans

  • Improve the performance, functionality, accuracy, and user experience of the Services

  • Process subscriptions and manage Premium access

  • Respond to support requests and communicate with Users

  • Maintain security and prevent fraud, abuse, or unauthorized use

  • Comply with legal and regulatory obligations

We do not use Personal Data for targeted advertising or cross-app tracking.

4. Community Content & Public Information

Some features allow Users to share content with other Users through the App, including:

  • Community posts, comments, and product feedback

  • Skincare routines or journal entries that Users choose to share

  • User-submitted product information and reviews

Journal entries, routines, and other Personal Data are private by default unless a User chooses to share them through a community or other sharing feature.

Users should avoid sharing sensitive personal, financial, medical, or other confidential information through public features.

Publicly shared content may be visible to other Users and may be copied, saved, or otherwise used by others. Users are responsible for the content they choose to share.

5. Legal Bases for Processing (European Economic Area and United Kingdom)

For Users in the European Economic Area and United Kingdom, Candid processes Personal Data under applicable legal bases, which may include:

  • Contract: To provide the Services and features requested by the User

  • Consent: Where processing requires consent or is based on the User's choice

  • Legitimate interests: To operate, maintain, secure, improve, and develop the Services, including verifying and expanding the product and ingredient database, where those interests are not overridden by the User's rights and interests

  • Legal obligations: To comply with applicable laws and regulatory requirements

Where processing is based on consent, Users may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

6. Cookies & Similar Technologies

The BareMatrix Website and App may use cookies, SDKs, local storage, and similar technologies to:

  • Enable core functionality and security

  • Remember preferences and session information

  • Understand usage and improve performance

  • Diagnose errors and technical issues

The BareMatrix Website may include links to our social media profiles, including Instagram and TikTok. These links do not by themselves allow those platforms to collect information through BareMatrix.

We do not use cookies, SDKs, or similar technologies for targeted advertising or cross-app tracking.

Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies.

7. Data Sharing & Disclosure

We may disclose Personal Data to the following categories of recipients as reasonably necessary to provide, maintain, secure, and improve the Services:

  • Service providers: Providers of hosting, analytics, security, image processing, technical infrastructure, and other services that support BareMatrix

  • App stores and subscription providers: Apple, Google, RevenueCat, and other providers as necessary to process subscriptions, validate purchases, and manage Premium access

  • Legal and regulatory authorities: Where required by law, legal process, or to protect the rights, safety, or security of Candid, Users, or others

  • Business transactions: In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction

Service providers are authorized to process Personal Data only as necessary to provide services to Candid and in accordance with applicable requirements.

We do not sell or rent Personal Data.

8. International Data Transfers

Personal Data may be processed or stored in Canada, the United States, or other countries where Candid or its service providers operate.

Where required by applicable law, Candid uses appropriate safeguards for international transfers of Personal Data.

9. Data Retention

We retain Personal Data for as long as reasonably necessary to:

  • Provide and maintain the Services

  • Maintain Accounts, preferences, and relevant User history

  • Fulfill the purposes described in this Privacy Policy

  • Meet legal, regulatory, accounting, or security requirements

  • Resolve disputes and enforce agreements

When Personal Data is no longer required, Candid will delete it, anonymize it, or otherwise securely dispose of it, subject to applicable law and legitimate retention requirements.

Users may request deletion of their Account and Personal Data as described in Section 11. Certain information may need to be retained where required or permitted by law.

Information incorporated into BareMatrix's product and ingredient database may be retained separately from a User's Account where it no longer identifies the User.

10. Security

We use reasonable technical, administrative, and organizational measures designed to protect Personal Data against unauthorized access, loss, misuse, alteration, or disclosure.

However, no method of transmission or storage is completely secure, and Candid cannot guarantee absolute security.

11. Your Privacy Rights

Depending on where a User lives and applicable law, Users may have rights to:

  • Access Personal Data held about them

  • Request correction of inaccurate or incomplete Personal Data

  • Request deletion of Personal Data

  • Request restriction of or object to certain processing

  • Request portability of certain Personal Data

  • Withdraw consent where processing is based on consent

  • Lodge a complaint with an applicable privacy or data-protection regulator

To exercise an applicable privacy right or raise a privacy-related concerns, contact us at:

Email: info@candid-design.com

We will handle requests in accordance with applicable privacy laws.

We may need to verify a User's identity before processing certain requests. Some rights are subject to applicable legal exceptions and limitations.

12. Children's Privacy

The BareMatrix App is intended for a general audience and may be accessible to children. The BareMatrix Website is primarily a public-facing marketing website and is not specifically directed to children.

We take children's privacy seriously and apply appropriate privacy and safety measures to Personal Data collected through the Services.

Children should not share sensitive personal, financial, medical, or other confidential information through community features or other publicly accessible areas of the Services.

Where applicable law requires parental consent or authorization for the collection or processing of a child's Personal Data, we will obtain or rely on such consent or authorization as required.

If a parent or guardian believes that a child has provided Personal Data in circumstances where it should not have been collected, they may contact us at info@candid-design.com.

13. Third-Party Links

The Website or App may contain links to third-party websites or services, including social media platforms and external resources.

These third-party sites and services are not controlled by Candid and are governed by their own privacy policies and terms. Candid is not responsible for their privacy practices or handling of Personal Data.

Users should review the privacy policies of third-party websites and services before providing Personal Data.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the Services, our privacy practices, or applicable laws.

When we make material changes, we may provide additional notice through the Services, by email, or by other appropriate means.

The “Last Updated” date at the beginning of this Privacy Policy indicates when the Policy was most recently revised.

15. AI and Automated Processing

BareMatrix uses automated technologies, including AI-powered tools, to support features such as image processing, ingredient analysis, personalization, and other Services.

These tools may process information submitted through the Services to provide or improve the requested functionality.

BareMatrix does not use automated processing to make decisions that produce legal or similarly significant effects on Users.