AI Transparency Notice

Plumped uses artificial intelligence. This notice explains where, how, what it can and cannot do, and what control you have over it.

We publish this because we think you should know, and because the EU Artificial Intelligence Act requires us to tell you when you are interacting with certain kinds of AI system.

1. Where we use AI

1.1 Skin analysis

Provider: Perfect Corp Input: a selfie you choose to take Output: a score for each of the attributes below, plus an estimated age

acne, age spot, dark circle, droopy lower eyelid, droopy upper eyelid, eye bag, firmness, moisture, oiliness, pore, radiance, redness, skin type, tear trough, texture, wrinkle.

This system classifies your skin from a facial image. Under the EU Artificial Intelligence Act this is a form of biometric categorisation, so we are telling you about it directly and asking for your consent before it runs.

The system does not identify you, does not match your face against any database, and does not create a face template capable of recognising you. It does not detect emotion, and it does not infer race, ethnicity, religion, political opinion, sexual orientation or trade union membership. Inferring those attributes from biometric data is prohibited under the EU Artificial Intelligence Act, and we do not do it.

1.2 Routine generation

Provider: OpenAI Input: your skin attribute scores, your stated concerns, your skin type and sensitivity, and the products you have saved Output: a suggested morning and evening routine, usage cadence, and ingredient conflict warnings

Your photograph is never sent to OpenAI. Only the numerical scores and the information you entered yourself are sent.

This is a generative AI system. It produces plausible text, which is not the same as correct text. See section 4.

1.3 Product and ingredient reading

We use optical character recognition to read text from photographs of product labels. This extracts the words printed on packaging so we can match them to ingredient data. It does not analyse you.

2. What we do not use AI for

• We do not use AI to make decisions about your account, your access to the Service, or anything with a legal or similarly significant effect on you.
• We do not use AI to set prices differently for different people.
• We do not use AI for advertising or profiling for marketing.
• We do not use your data, your photographs or your results to train any AI model, ours or a provider's. This is a contractual commitment with our providers, not just a policy statement.

3. Your consent and your control

Skin analysis runs only if you have given explicit consent. You can:

• decline it entirely and build your profile by answering questions instead;
• withdraw consent at any time in Settings, then Privacy, then Skin analysis;
• delete any individual scan and its results;
• override any attribute manually;
• edit or ignore any routine we generate.

Withdrawing consent stops future analysis. It does not make past analysis unlawful, because you consented at the time.

4. What AI gets wrong

We would rather set expectations honestly than oversell this.

Skin analysis. Scores are estimates from a photograph. They are affected by lighting, camera quality, angle, makeup, glare and skin tone. Published research has repeatedly found that image analysis systems perform less consistently on darker skin tones, and we cannot guarantee equal accuracy for every user. Two scans taken minutes apart can produce different numbers.

Estimated age. Approximate. Treat it as entertainment rather than information.

Routine generation. Large language models can produce confident text that is wrong. A generated routine may include a step that does not suit you, omit something that matters, or state an ingredient interaction inaccurately. We apply rules and checks on top of the model output, and errors still get through.

Ingredient data. Comes partly from third-party sources and from reading labels. Formulations change. The label on the product is always more reliable than our database.

Because of all this, Plumped is a starting point for your own judgement, not an authority. Please read the Health Disclaimer.

5. Human oversight

You can ask a person at Plumped to review any automated result you disagree with. Write to operations@plumped.co.uk, tell us what you think is wrong, and a member of our team will look at it and respond.

We monitor the quality of our AI outputs, investigate patterns of complaints, and can disable or change a model where it is not performing acceptably.

6. Legal position on automated decision making

Article 22 of the UK GDPR and the EU GDPR gives you the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you.

We do not consider a skincare suggestion to fall into that category, because it does not affect your legal rights, your access to services, your finances or your employment, and you remain free to ignore it.

We nonetheless give you the safeguards that provision is designed to deliver: you are told when automation is used, you can obtain human intervention, you can express your point of view, and you can contest a result.

7. Providers

Locations and transfer safeguards for these providers are set out in section 7 and section 8 of the Privacy Policy, and in the Sub-processor List.

8. Changes

If we add a new AI system, change provider, or change what a system does with your data, we will update this notice. Where the change affects something you consented to, we will ask again.

9. Contact

Questions about how we use AI, or a request for human review: operations@plumped.co.uk

PLUMPED LTD, 124 City Road, London, England, EC1V 2NX. Company number 16204649.