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ComposeRx believes consumers should know when and how artificial intelligence is involved in the products and experiences we deliver. This AI Disclosure & Responsible-Use Policy ("AI Policy") describes the categories of AI we use, what we do and do not use AI to do, how we mitigate AI-specific risks, and the choices available to you. This AI Policy supplements (and does not replace) our Privacy Policy and Medical Disclaimer.
We will tell you when you are interacting with AI rather than a human.
We will not use AI to make medical, healthcare, or other consequential decisions about you.
We will not pretend that AI-generated content was created by a real person.
We will label AI-generated imagery and AI-generated text used in marketing where the law requires it and, in most other cases, where a reasonable consumer would want to know.
We will keep a human in the loop for any decision that meaningfully affects you (e.g., an order refusal, a refund decision).
We will not train third-party AI models on the contents of your personal customer-support conversations, your skin-quiz responses, or your uploaded photographs without your separate, affirmative opt-in consent.
Customer-support drafting.We use large language models (including OpenAI's GPT family and Anthropic's Claude) to help our human agents draft replies to customer-support inquiries. A human ComposeRx agent reviews every AI-assisted reply before it is sent to you. If we ever deploy a fully automated chatbot that can respond without a human in the loop, we will clearly label it as a bot at the start of the conversation, in accordance with California's Bolstering Online Transparency Act (Cal. Bus. & Prof. Code §§17940–17943, the "Bot Act").
Product recommendations and skin-quiz personalization.We may use AI to convert your skin-quiz answers into product recommendations. These recommendations are advisory only. They are not medical recommendations, diagnoses, or treatment plans. You can ignore them at any time and contact our team or your dermatologist with questions.
Marketing content.We may use generative AI to assist with drafting blog posts, social-media captions, product descriptions, and email copy. All AI-generated marketing copy is reviewed by a human ComposeRx team member for accuracy and brand voice before publication. We do not publish AI-generated text as if it were written by a real, named person (including a dermatologist or influencer) unless the person identified is in fact the author or has co-authored and approved the text.
AI-generated imagery.Where we publish AI-generated or AI-modified imagery in advertising or on product pages, we label it conspicuously (for example, "AI-generated illustration" or "AI-modified image — for illustration only"). We do not use AI to generate or alter before-and-after photographs of real customers, ever. Before-and-after photographs depict the authentic results of real users, with only the formatting adjustments described in our Testimonials Disclaimer.
Analytics, fraud prevention, and operations.We use machine-learning systems built into our ecommerce, fraud, and analytics platforms (e.g., Shopify, Klaviyo, Yotpo) for routine business operations such as detecting suspected payment fraud, predicting product demand, and segmenting marketing audiences. These uses do not produce legal or similarly significant effects on you.
Medical, healthcare, or dermatological decisions.We do not use AI to diagnose, treat, cure, or prevent any disease, to make any healthcare treatment decision, or to substitute for the advice of a licensed dermatologist or other healthcare professional. See our Medical Disclaimer.
Solely automated decisions with legal or similarly significant effects.We do not engage in profiling in furtherance of decisions made solely by automated processing that produce legal or similarly significant effects on you (for example, an automated denial of service or an automated price determination without human review). Any consequential decision affecting a consumer — for example, the refusal of an order on fraud-prevention grounds, or the denial of a refund — is reviewed by a human ComposeRx team member before it becomes final.
Biometric identification of customers.We do not use facial recognition or other biometric identification on photographs you upload. We do not extract face-geometry data from before-and-after photographs.
Hidden chatbots.We do not represent AI-generated communications as human-authored in a way that would mislead a reasonable consumer.
We do not provide your personal customer-support transcripts, skin-quiz responses, uploaded photographs, account data, or order history to third-party AI providers for use in training their general-purpose models. Our use of OpenAI's and Anthropic's APIs is configured so that submitted content is not used for model training in accordance with the applicable enterprise-grade data-processing agreement. We also do not train any ComposeRx-proprietary AI model on your personal information without your separate, affirmative opt-in consent.
Where we use aggregated, de-identified data (e.g., to evaluate which broad product categories are most often recommended for which broad skin-concern categories), we follow industry-standard de-identification practices and do not attempt to re-identify the underlying consumers.
We disclose AI involvement in our content in three ways:
In-line label on synthetic media. AI-generated images, video, and audio in our marketing or on product pages carry a visible label such as "AI-generated" or "AI-modified — for illustration only."
Conversational disclosure. If we deploy a fully automated customer-service chatbot, the chatbot will identify itself as automated at the start of every conversation, in compliance with the California Bot Act.
Policy disclosure. This AI Policy itself, together with the AI section of our Privacy Policy, summarizes where and how we use AI.
We will also include any provenance signals (such as the Coalition for Content Provenance and Authenticity, or "C2PA," Content Credentials) on AI-generated marketing imagery, where the tools used to generate the imagery support those signals.
Opt out of AI-personalized recommendations.Email hello@composerx.com with the subject "Opt out of AI personalization" to receive non-personalized site experiences. You may also adjust your communication preferences in your account settings.
Opt out of marketing profiling.Use the "Your Privacy Choices" link in our website footer or transmit a Global Privacy Control signal. We will treat this as a request to opt out of targeted advertising, behavioral profiling, and the use of your information to train AI systems for marketing purposes.
Human review of any automated decision.If you believe that an automated or AI-assisted decision has affected you (for example, your order was canceled, your account was suspended, or your refund was denied), you may request human review by emailing hello@composerx.com. We will respond within 15 business days.
Access, correction, deletion.Your rights under the Privacy Policy and the Consumer Health Data Privacy Policy apply to any data we hold that has been processed by AI systems on our behalf.
AI systems make mistakes. Generative AI in particular can produce content that is factually inaccurate, outdated, or that reflects bias present in training data. We mitigate these risks by:
Requiring human review of AI-assisted customer-support replies and AI-assisted marketing copy before publication or sending.
Not relying on AI for medical, healthcare, or dermatological recommendations.
Testing our recommendation logic and personalization features for unfair, biased, or otherwise undesirable outputs across skin tones, age groups, and skin concerns.
Retaining the right to disable any AI feature that we find to be producing inaccurate or biased outputs.
If you encounter an AI-generated output from a ComposeRx service that appears incorrect, biased, or harmful, please report it to hello@composerx.com. We take such reports seriously and use them to improve our systems.
We use third-party AI providers including OpenAI and Anthropic for the use cases described in §2. Our agreements with these providers prohibit their use of our submitted content for general model training, require reasonable security measures, and require compliance with applicable U.S. state privacy laws. We periodically review our AI vendors against these obligations.
We monitor and seek to comply with emerging AI laws as they take effect, including:
California Bot Act (Cal. Bus. & Prof. Code §§17940–17943) — chatbot disclosure.
California SB 942, the California AI Transparency Act (effective January 1, 2026) — disclosure obligations for generative AI providers (we are primarily a downstream user, but we apply the same labeling spirit to our own AI-generated content).
California AB 2013 — generative-AI training-data transparency.
California SB 1001 — bot disclosure (online influence).
Colorado AI Act (SB 24-205, effective February 1, 2026) — disclosure and risk-management duties for "high-risk" AI systems involved in consequential decisions. We do not currently use AI for consequential decisions; if we ever do, we will provide the required pre-decision disclosure, allow correction, and allow human review.
Texas Responsible AI Governance Act (HB 149, effective January 1, 2026) — disclosure of AI use to consumers and prohibition on discriminatory algorithmic decisions.
Utah AI Policy Act (SB 149, effective May 1, 2024) — disclosure and consumer-protection obligations for generative AI in consumer interactions.
FTC Section 5 of the FTC Act — prohibits unfair or deceptive practices including "AI-washing," undisclosed AI use that misleads consumers, and unsubstantiated AI-related performance claims.
EU AI Act Article 50 transparency obligations — to the extent any ComposeRx content is accessed by EU consumers, we apply Article 50-style labeling for AI-generated content, even though our Services are directed primarily to U.S. consumers.
ComposeRx maintains internal policies governing how AI features are evaluated, approved for use, monitored, and retired. We review this AI Policy at least annually and update it as our use of AI evolves.
We may update this AI Policy from time to time. For material changes affecting how we use AI in ways that meaningfully affect consumers, we will provide reasonable advance notice (at least 30 days) on our website or by email before the changes take effect, and update the Effective Date above.
Questions, concerns, or reports of AI-generated content that appears inaccurate, biased, or harmful can be sent to hello@composerx.com.
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