Johnson & Johnson’s (J&J) consumer division, which is now known as Kenvue, has agreed a US$4.7m settlement related to claims that Neutrogena’s Skin360 service violated privacy laws in the US.
Neutrogena Skin360 offers consumers a personalised skin analysis by taking a selfie with their mobile phone camera.
It then recommends a skin care regimen of Neutrogena products.
Between 2020 and 2022, the Illinois-based plaintiffs in the case – Helene Melzer, Christine Borovoy, Andy Sajnani and Patricia Biewald – each used the Skin360 application on their mobile devices.
They alleged that, in creating this assessment, the technology scanned, collected, captured, used and stored digital copies of their unique facial geometries in an electronic database.
They further claimed that J&J did not inform them that their biometric data was being captured, collected, stored, used, or disseminated.
The plaintiffs say this biometric data was tied to individuals’ names, birth dates and other personally identifying information.
In their class action lawsuit, first filed in a New Jersey federal court in 2022, they alleged this violated the state of Illinois’ Biometric Information Privacy Act (BIPA).
J&J Consumer had moved to dismiss the case, arguing that the alleged conduct fell within a healthcare exemption under BIPA.
However, a federal judge last year said that the court found it “a reach to consider these services ‘medical care’ under BIPA's healthcare exemption”.
J&J Consumer later agreed to settle the lawsuit in August 2025.
Now, the company has agreed to a settlement amount of $4.7m, according to court documents seen by Cosmetics Business filed on 17 February.
Around 11,000 consumers who performed a Skin360 skin assessment using any version of Skin360, via mobile app or website, while in Illinois between 9 December 2019 and 5 May 5 2023 are expected to share in the payout.
The agreement also says that J&J Consumer must delete images obtained during a 360 assessment in this period.
Plus, the company must maintain a user notice and written consent mechanism for Skin360 and a written policy regarding the retention and destruction of information collected through the service.
Cosmetics Business has contacted J&J and Kenvue for comment.
J&J spun off its consumer division, which includes Neutrogena, into standalone company Kenvue in 2023.
Kenvue has since been acquired by personal care company Kimberly-Clark in a US$48.7bn deal agreed in November 2025.