Terms of Service

Last Updated: March 21, 2026

These Terms of Service ("Terms") govern your access to and use of the Pearl28™ platform and related services (collectively, the "Service"). The Service is operated by KloudStep LLC, a Wyoming limited liability company ("Company," "we," "us," or "our").

By accessing or using the Service, you agree to be bound by these Terms. If you do not agree to these Terms, you may not access or use the Service.

These Terms apply to all users of the Service, including individuals who visit the website, create accounts, upload images, or access AI-generated skincare analysis results.

Your use of the Service is also subject to our Privacy Policy and Refund Policy, which are incorporated into these Terms by reference.

We may update or modify these Terms from time to time. If we make material changes, we will update the effective date of the Terms or provide notice as required by applicable law. Your continued use of the Service after the updated Terms become effective constitutes your acceptance of the revised Terms.

1. Eligibility

You must be at least 18 years of age and have the legal capacity to enter into a binding agreement to access or use the Service. By accessing or using the Service, you represent and warrant that you meet these eligibility requirements.

The Service is intended only for individuals seeking general cosmetic skincare insights and related informational content. The Service is not intended for use by minors; individuals under 18 may not access or use the Service.

You agree to provide accurate and complete information when using the Service and to update such information if it becomes inaccurate or incomplete.

If you are accessing or using the Service on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that entity to these Terms. In such cases, the terms "you" and "your" will refer to both you and that entity.

We reserve the right to suspend or terminate access to the Service if we reasonably believe that a user does not meet the eligibility requirements described in this Section.

2. Description of the Service

The Service provides an automated digital platform that generates personalized cosmetic skincare insights based on information submitted by users. Through the Service, users may be asked to provide information, such as questionnaire responses on skincare concerns, lifestyle factors, or other relevant inputs, and may also upload facial images for analysis.

Using this information, the Service applies automated technologies, including artificial intelligence and image analysis tools, to evaluate visible skin characteristics and generate individualized skincare insights and recommendations. These insights may include indicators of skin appearance, such as hydration, wrinkles, pore size, and other observable features, as well as estimated skin age or other appearance-based metrics.

The Service may also provide informational content on skincare routines, cosmetic product suggestions, and lifestyle and nutrition considerations to support general skin wellness.

The Service is intended solely to provide informational guidance on cosmetic skincare. The Service does not provide dermatological services, medical advice, diagnosis, or treatment, and the analysis generated through the Service should not be interpreted as a medical or clinical evaluation.

We reserve the right to modify, update, suspend, or discontinue any aspect of the Service at any time, including the features, tools, analysis methods, or content available through the platform.

3. User Accounts

Certain features of the Service may require you to create a user account. When creating an account, you agree to provide accurate and complete information and to keep that information updated if it changes.

You are responsible for maintaining the confidentiality of your login credentials and for all activities that occur under your account. If you believe that your account has been accessed without authorization, you must notify the Company promptly at support@pearl28.com.

The Company is not responsible for losses resulting from unauthorized access to your account where such access results from your failure to safeguard your login credentials.

By creating an account or submitting your email address through the Service, you agree that the Company may send you service-related communications and, where permitted by applicable law, marketing or promotional emails. You may opt out of marketing communications at any time by using the unsubscribe link included in those emails or by contacting support@pearl28.com.

4. AI-Generated Analysis

The analysis, insights, and recommendations provided through the Service are generated using automated technologies, including artificial intelligence and machine learning systems. These systems may include external AI models operated by third parties such as OpenAI, Anthropic (Claude), and other large language model providers. These technologies analyze information submitted by users, including questionnaire responses and uploaded images, to evaluate visible skin characteristics and generate cosmetic skincare insights.

Because the Service relies on automated analysis, the results generated by the Service are estimates and informational outputs only. The accuracy, completeness, or reliability of any analysis or recommendation cannot be guaranteed. AI-generated outputs may be incomplete, inaccurate, or unsuitable for a user's specific circumstances.

The Service does not involve review or evaluation by licensed medical professionals. Certain methodologies, frameworks, or educational content used by the Service may be informed by input from professionals such as dermatologists, cosmetologists, nutritionists, or skincare experts. However, these professionals do not review individual user submissions or analysis results, nor do they provide consultations through the platform. All analysis results and personalization generated by the Service are produced by automated systems. Therefore, results should be interpreted as general informational guidance and should not be relied upon as medical or dermatological advice.

Results produced by the Service may vary depending on factors such as image quality, lighting conditions, user-provided information, and the limitations of automated analysis technologies.

By using the Service, you acknowledge and agree that the insights and recommendations generated by the Service are produced by automated systems and are intended for informational cosmetic skincare purposes only.

5. Medical Disclaimer

The Service is provided for informational and cosmetic skincare purposes only. The Service does not provide medical advice, dermatological care, diagnosis, or treatment of any medical condition. The analysis, insights, and recommendations generated through the Service are not intended to diagnose, treat, cure, or prevent any disease or skin condition.

The Service does not replace consultation with qualified healthcare professionals. If you have concerns about your skin, health, or any medical condition, you should seek advice from a licensed physician, dermatologist, or other qualified healthcare provider.

You should never disregard or delay seeking professional medical advice because of information provided through the Service.

The Company does not represent or warrant that the insights or recommendations generated by the Service are appropriate for your individual health circumstances.

6. No Reliance on Results

The insights, analysis results, and recommendations generated by the Service are intended solely to provide general informational guidance regarding cosmetic skincare. These outputs are based on automated analysis of user-provided inputs and images and may not reflect your individual skin condition or health status.

You acknowledge that any decisions you make regarding skincare products, routines, lifestyle changes, or nutrition based on the results provided by the Service are made at your own discretion and risk.

The Company does not guarantee that following any insights or recommendations generated through the Service will produce any particular outcome, improvement, or result.

You are solely responsible for evaluating whether any products, routines, or lifestyle suggestions are appropriate for you. If you experience irritation, adverse reactions, or other concerns related to skincare products or practices, you should discontinue use and consult a qualified healthcare professional.

7. User Responsibilities

By using the Service, you agree to use the platform responsibly and in a lawful manner.

You agree that:

• Any information you provide through the Service, including questionnaire responses or other inputs, will be accurate and complete to the best of your knowledge.
• You are responsible for how you interpret and use any insights, recommendations, or information generated by the Service.
• You will independently evaluate whether any skincare products, routines, or lifestyle suggestions are appropriate for your personal circumstances.
• You will consult qualified healthcare professionals for any medical or dermatological concerns.
• You are also responsible for ensuring that your use of the Service complies with all applicable laws and regulations.

The Company is not responsible for decisions made by users based on the analysis or recommendations generated by the Service.

8. Photo Uploads and User Content

The Service may allow or require users to upload images, photographs, or other materials to generate analysis results or otherwise use certain features of the platform (collectively, "User Content").

By uploading or submitting User Content through the Service, you represent and warrant that:

• you own the content you upload or have all necessary rights and permissions to submit it through the Service;
• the submission of the content does not violate the rights of any third party, including privacy, publicity, or intellectual property rights; and
• any image you upload depicts yourself or a person who has provided consent for the image to be uploaded and processed through the Service.

When using the Service, you agree not to upload images that:

• contain unlawful, harmful, or abusive content;
• depict another individual without their consent;
• infringe the intellectual property, privacy, or publicity rights of any third party;
• are unrelated to the intended skincare analysis functionality of the Service; or
• are intended to manipulate, test, or disrupt the Service's automated analysis systems.

You retain ownership of your User Content. However, by submitting User Content through the Service, you grant the Company a worldwide, non-exclusive, royalty-free license to use, process, analyze, reproduce, store, and otherwise use the User Content as necessary to operate, maintain, and improve the Service.

This license includes the right to use submitted images and related data to generate analysis results for the user, operate and maintain the platform, and improve and develop the Company's technologies, including artificial intelligence and machine learning systems, as described in the Privacy Policy.

9. Image Processing and Data Use

Images uploaded through the Service are processed using automated technologies to analyze visible skin characteristics and generate cosmetic skincare insights.

By uploading images to the Service, you acknowledge and agree that the Company may process those images using automated systems, including artificial intelligence and image analysis technologies, to provide the Service's analysis features.

To provide the Service's features, the Company may store certain user information, including onboarding responses, skincare routines, uploaded images, analysis results, and historical skin tracking data. This information may be used and processed as necessary to generate results and operate the platform, such as to generate personalized insights, track changes in skin appearance over time, provide progress comparisons, and improve the functionality and performance of the Service. In addition, the Company may use images and related data in aggregated, anonymized, or otherwise de-identified form to improve, develop, and train its artificial intelligence and machine learning technologies.

Certain jurisdictions regulate the collection and use of biometric identifiers or biometric information derived from images. Facial images uploaded through the Service may be analyzed to evaluate visible skin characteristics and generate cosmetic skincare insights.

To the extent that uploaded facial images or related analysis constitute biometric data under applicable law, including laws in certain U.S. states such as Illinois, Texas, or Washington, you acknowledge and provide informed consent for the Company to collect, store, process, and use such data for the purposes described in these Terms and the Privacy Policy.

You may request deletion of uploaded images and associated data at any time by contacting support@pearl28.com. Additional details regarding how User Content is processed, stored, and protected are described in the Privacy Policy.

10. Acceptable Use

You agree to use the Service only for lawful purposes and in accordance with these Terms.

You agree that you will not:

• upload images of another person without that person's knowledge and consent;
• upload images that you do not have the legal right to use or share;
• use the Service for any unlawful, fraudulent, or misleading purpose;
• attempt to interfere with, disrupt, or compromise the operation or security of the Service;
• attempt to reverse engineer, decompile, or otherwise attempt to extract the source code, algorithms, or underlying technology of the Service;
• use automated tools, bots, scraping technologies, or similar methods to access or extract data from the Service without authorization;
• upload content that is illegal, abusive, defamatory, obscene, or otherwise objectionable; or
• attempt to gain unauthorized access to any portion of the Service, systems, or networks connected to the platform.

We reserve the right to suspend or terminate your access to the Service if we determine that you have violated these Terms or engaged in conduct that could harm the Service, other users, or the Company.

11. Intellectual Property

The Service, including the website, platform, software, artificial intelligence systems, algorithms, analysis methods, visual interfaces, graphics, text, and other content made available through the Service (collectively, the "Platform Content"), is owned by or licensed by KloudStep LLC and is protected by intellectual property and other applicable laws.

Except as expressly permitted under these Terms, no portion of the Service or Platform Content may be copied, reproduced, distributed, modified, publicly displayed, or otherwise used without the prior written permission of the Company.

Subject to your compliance with these Terms, the Company grants you a limited, non-exclusive, non-transferable, and revocable license to access and use the Service for your personal, non-commercial use.

This license does not grant you any right to reproduce or distribute Platform Content, use the Company's trademarks, logos, or branding without permission, access or use the Service to build a competing product or service, or copy, replicate, or attempt to replicate the functionality or analysis methods of the Service.

All rights not expressly granted in these Terms are reserved by the Company.

12. Subscriptions and Billing

Certain features of the Service may be available through paid subscription plans. By purchasing a subscription, you agree to pay the applicable fees associated with the subscription plan you select.

Subscription pricing and plan details are displayed on the platform at the time of purchase. Subscription plans may include different billing terms, such as monthly charges billed over a fixed subscription period (for example, six-month or twelve-month plans).

Unless otherwise stated at the time of purchase, subscriptions automatically renew at the end of the applicable subscription term unless you cancel your subscription before the renewal date. If you do not cancel your subscription before the end of the current billing period, the subscription will automatically renew, and the applicable subscription fee will be charged to your payment method.

You authorize the Company or its payment processor to charge your selected payment method for the subscription fees associated with your plan, including any applicable renewal charges.

You may cancel your subscription at any time through your account settings or through the method provided on the platform. Cancellation will take effect at the end of the current billing period unless otherwise specified.

Payments made for subscriptions are subject to the terms described in the Refund Policy, which governs eligibility and procedures for requesting refunds.

The Company reserves the right to modify subscription pricing or billing terms. If pricing changes affect your existing subscription, we will provide notice as required by applicable law before the changes take effect.

13. Platform Availability

The Company strives to provide a reliable and accessible platform. However, the Service is provided on an "as available" basis and may not be uninterrupted or error-free.

From time to time, the Service may be unavailable due to maintenance, updates, technical issues, or other circumstances beyond the Company's control. The Company does not guarantee continuous availability of the Service or any specific feature of the platform.

The Company reserves the right to modify, update, suspend, or discontinue any part of the Service at any time, including features, tools, analysis methods, or subscription offerings, without prior notice.

14. Third-Party Services

The Service may rely on third-party technologies and service providers to operate and improve the platform. These may include analytics providers, cloud infrastructure providers, customer communication platforms, artificial intelligence service providers, and other technology partners.

These services may collect limited technical or usage information necessary to operate the Service, analyze platform performance, or improve product functionality. Additional information regarding the use of third-party services and tracking technologies is described in the Privacy Policy.

15. Disclaimer of Warranties

The Service and all content, analysis results, insights, and recommendations provided through the platform are made available on an "as is" and "as available" basis.

To the fullest extent permitted by applicable law, the Company disclaims all warranties of any kind, whether express, implied, statutory, or otherwise, including but not limited to any implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement.

Without limiting the foregoing, the Company does not warrant that:

• the Service will be uninterrupted, secure, or error-free;
• the analysis results, insights, or recommendations generated by the Service will be accurate, reliable, or complete;
• any particular results or improvements will occur from using the Service or following recommendations provided through the platform; or
• any errors or defects in the Service will be corrected.

Your use of the Service and reliance on any information provided through the platform are at your own risk.

16. Limitation of Liability

To the fullest extent permitted by applicable law, KloudStep LLC, its affiliates, officers, directors, employees, agents, and licensors will not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages arising out of or related to your use of or inability to use the Service.

This limitation applies to damages related to, among other things:

• reliance on analysis results, insights, or recommendations generated by the Service;
• skincare product use, lifestyle changes, or other actions taken based on information provided through the platform;
• errors or inaccuracies in automated analysis results;
• service interruptions, delays, or technical failures; or
• unauthorized access to or use of the Service.

To the maximum extent permitted by law, the total aggregate liability of the Company for any claim arising out of or relating to the Service or these Terms will not exceed the greater of one hundred dollars ($100), or the total amount you paid to the Company for the Service during the twelve (12) months preceding the event giving rise to the claim.

Some jurisdictions do not allow certain limitations of liability. In such cases, the Company's liability will be limited to the maximum extent permitted by applicable law.

17. Indemnification

You agree to indemnify, defend, and hold harmless KloudStep LLC, its affiliates, officers, directors, employees, agents, and licensors from and against any claims, liabilities, damages, losses, and expenses, including reasonable attorneys' fees, arising out of or related to your use of the Service, your violation of these Terms, any User Content you submit through the Service, including uploaded images, your violation of any law or the rights of any third party, or your misuse of the Service or reliance on analysis results generated by the platform.

The Company reserves the right, at its own expense, to assume the exclusive defense and control of any matter subject to indemnification by you. In such cases, you agree to cooperate with the Company in asserting any available defenses.

18. Termination of Access

The Company may suspend, restrict, or terminate your access to the Service at any time if we believe you have violated these Terms, engaged in misuse of the Service, or otherwise acted in a manner that could harm the Service, other users, or the Company.

Termination or suspension of access may occur without prior notice when reasonably necessary to protect the platform's integrity or security.

You may stop using the Service at any time. If you have an active subscription, cancellation will take effect at the end of the current billing period unless otherwise specified in the Refund Policy.

Termination of access to the Service does not relieve you of any obligations incurred prior to termination, including payment obligations or responsibilities arising under these Terms.

19. Governing Law and Dispute Resolution

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS.

These Terms and any dispute arising out of or relating to the Service or these Terms will be governed by and construed in accordance with the laws of the State of Wyoming, without regard to its conflict of law principles.

Except as otherwise provided in this Section, any dispute, claim, or controversy arising out of or relating to the Service or these Terms will be resolved exclusively through binding arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules.

The arbitration will be conducted by a single arbitrator. The arbitrator will have the authority to grant any remedy available under applicable law. Arbitration proceedings will take place in the State of Wyoming, unless the parties agree otherwise or the applicable arbitration rules permit remote proceedings.

To the fullest extent permitted by law, you agree that any dispute will be resolved on an individual basis only and not as part of a class, collective, or representative action. You waive any right to participate in a class action lawsuit or class-wide arbitration against the Company.

To the fullest extent permitted by law, you and the Company each waive any right to a trial by jury in connection with any dispute arising out of or relating to the Service or these Terms.

Nothing in this Section prevents either party from seeking temporary or preliminary injunctive relief in a court of competent jurisdiction where necessary to protect intellectual property rights or prevent irreparable harm.

20. Changes to the Terms

The Company may update or modify these Terms from time to time to reflect changes to the Service, legal requirements, or business practices. If material changes are made, the Company will provide notice by updating the "Last Updated" date at the top of these Terms and, where appropriate, by providing additional notice through the Service or by email to registered users.

Your continued use of the Service after the updated Terms become effective constitutes your acceptance of the revised Terms.

If you do not agree to the updated Terms, you must stop using the Service and may cancel your subscription in accordance with the applicable cancellation procedures.

21. Contact Information

If you have any questions about these Terms or the Service, you may contact the Company at:

The Company will make reasonable efforts to respond to inquiries submitted via the contact methods above.