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Privacy Policy

Last updated:

This Privacy Policy explains how Undertone ("we", "us", or "our") collects, uses, discloses, and protects information when you use our mobile application (the "App") and related services. By using the App, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

Depending on how you use the App, we may collect the following categories of information:

2. How We Use Information

We may use collected information to:

3. Face Data and Photo Analysis

Undertone processes user-selected photos solely to perform seasonal color analysis and palette recommendations. Facial information is used only to detect facial regions and analyze visual color characteristics such as undertone, contrast, brightness, and color harmony.

Undertone does not perform facial recognition, identity verification, biometric authentication, or user identification. The App does not generate or store biometric templates, faceprints, or facial geometry maps.

Face data is not used for advertising, tracking, resale, unrelated profiling, authentication, or marketing purposes.

Photo analysis is performed on-device. User photos and facial information are not shared with third parties for facial analysis, facial recognition, biometric processing, or identity verification.

4. Analytics and Diagnostics

We may use analytics and diagnostic tools to understand how the App is used, improve performance, measure feature engagement, and detect errors or crashes. These tools may collect limited device, usage, and technical information.

5. How We Share Information

We do not sell your personal data. We may share limited information only in the following circumstances:

We do not share face data, facial information, uploaded photos, or saved analysis images with third parties for facial analysis, facial recognition, biometric processing, identity verification, advertising, tracking, or resale.

6. Data Storage and Retention

Face data is processed temporarily during analysis. Undertone does not retain face data on external servers.

Photos and analysis results are stored only if the user explicitly saves a result inside the App. Saved results remain locally on the user's device and may be deleted by the user at any time.

Other information is retained only for as long as reasonably necessary to provide the App, maintain saved features, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods may vary depending on the type of data and how it is used.

7. Your Choices and Rights

Depending on your location, you may have rights to:

You may also control certain information through your device settings, app settings, and App Store subscription settings.

8. International Users

If you access the App from outside the country in which it is operated, your information may be processed in jurisdictions where data protection laws may differ from those in your location.

9. Children’s Privacy

The App is not intended for children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information through the App, please contact us so we can take appropriate action.

10. Security

We use reasonable administrative, technical, and organizational measures to protect information against unauthorized access, loss, misuse, or alteration. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Third-Party Services

The App may rely on third-party tools or services, such as Apple, analytics providers, subscription platforms, crash reporting tools, or cloud infrastructure providers. Your use of those services may also be subject to their own privacy policies and terms.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date above. Your continued use of the App after changes become effective means you accept the revised Privacy Policy.

13. Contact Us

If you have any questions, requests, or concerns about this Privacy Policy or our data practices, contact us at: support@undertones.app