Privacy Policy
Effective Date: October 16, 2025
Last Updated: October 16, 2025
Welcome to TrueHue, an AI-powered personal style discovery application. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our application ("App") or services. By using TrueHue, you agree to the terms of this Privacy Policy.
1. Information We Collect
We may collect the following types of information:
1.1 Information You Provide
- Facial Photos: Selfies and photos you upload for AI analysis of face shape, skin tone, and features.
- Personal Profile: Age, style preferences, lifestyle information, and beauty goals.
- Account Information: Name, email address, and subscription details.
- Feedback: Details you share when contacting our support team or rating recommendations.
1.2 Automatically Collected Information
- Device Information: IP address, operating system, device type, and App version.
- Usage Data: Actions performed within the App (e.g., feature usage, recommendation interactions).
- AI Analysis Results: Computed data about your face shape, skin tone, color season, and style profile.
1.3 Third-Party Services
We share data with the following third-party services to provide our features:
- OpenAI: Facial photos and style data are processed through OpenAI's GPT-4 Vision API for AI-powered facial analysis, face shape determination, and personalized style recommendations. Images submitted via API are not used for model training per OpenAI's API terms.
- Google Gemini: Facial photos may be processed through Google Gemini for AI-powered image generation, styling visualizations, and personalized recommendations.
- Analytics: Mixpanel for understanding user behavior and app improvements (does not receive facial photos or biometric data).
- Payments: Stripe for subscription processing and RevenueCat for subscription management (does not receive facial photos or biometric data).
2. How We Use Your Information
- Analyze your facial features to determine face shape, skin tone, and color season.
- Provide personalized style recommendations for makeup, hairstyles, and fashion.
- Generate color palettes and style suggestions tailored to your features.
- Improve our AI algorithms and recommendation accuracy.
- Manage your subscription and premium features access.
- Send you relevant style tips and app updates (with your consent).
- Comply with legal obligations and enforce our Terms of Service.
3. Photo and Biometric Data Processing
3.1 Facial Analysis
When you upload photos, our AI analyzes:
- Face shape and proportions
- Skin undertones and color characteristics
- Eye color and shape
- Hair color and texture (if visible)
3.2 Data Protection for Photos
- Photos are encrypted during transmission to third-party AI services
- We do not store original photos on our servers
- Photos are immediately deleted after AI processing is complete
- Only computed features and analysis results are retained on our servers
- Original photos and generated images are stored locally on your device only
- No photos are shared with third parties for marketing purposes
3.3 Biometric Data Rights
In jurisdictions with biometric privacy laws:
- We obtain explicit consent before collecting biometric data
- You can request deletion of biometric identifiers at any time
- Biometric data is not sold or shared for commercial purposes
3.4 Detailed Face Data Collection and Use
What Face Data We Collect:
- Facial measurements and proportions (forehead width, cheekbone width, jawline width, face length)
- Face shape determination (oval, round, square, heart, diamond, or rectangle)
- Skin undertones and color characteristics
- Eye color, shape, and iris characteristics
- Hair color and texture (when visible in uploaded photos)
- Facial structure analysis (cheekbone prominence, jawline definition)
How We Use Face Data:
- Determine your face shape for personalized hairstyle and makeup recommendations
- Analyze skin undertones to identify your optimal color palette and season
- Suggest eyewear frames that complement your facial structure
- Generate AI-powered styling visualizations (virtual try-on features)
- Provide fashion and accessory recommendations that harmonize with your coloring
- Improve our AI algorithms and recommendation accuracy
Third-Party Face Data Sharing:
- OpenAI (GPT-4 Vision): Photos are temporarily transmitted for facial analysis. Images are not used for model training per OpenAI's API terms and are not retained by OpenAI.
- Google Gemini: Photos are temporarily transmitted for AI-powered image generation and styling visualizations. Images are processed and not permanently stored.
- Face data is NEVER shared with marketing companies, advertisers, or data brokers.
- We do not store original photos on our servers; all images are stored locally on your device.
Face Data Storage and Retention:
- Original Photos: NOT stored on our servers. All photos and generated images are stored locally on your device only.
- Analysis Results: Only computed facial characteristics (not photos) are stored in our encrypted database to provide personalized recommendations. These include face shape, skin undertone, and feature measurements.
- User Control: You can delete photos from your device at any time. Analysis results can be deleted by requesting data deletion through in-app settings or contacting support.
- Account Deletion: All facial analysis results are permanently deleted from our servers when you delete your account.
Your Rights Regarding Face Data:
- Request a copy of your facial analysis results at any time
- Delete your face data and analysis results through in-app settings
- Withdraw consent for facial analysis processing
- Contact our privacy team for immediate deletion: technologies.alpine@gmail.com
4. Data Retention
- Original Photos: NOT stored on our servers. Photos are stored locally on your device only and are never retained on our servers.
- Analysis Results: Computed facial characteristics (not photos) are retained to provide personalized recommendations; deleted upon account deletion.
- Usage Data: Retained for analytics and improvements; anonymized after 24 months.
- Account Data: Retained for the duration of your account's activity and deleted upon request.
5. Security Measures
5.1 Data Protection
We implement comprehensive security measures including:
- End-to-end encryption for photo transmission
- Secure cloud storage with encryption at rest
- Regular security audits and penetration testing
- Access controls and multi-factor authentication
- SOC 2 compliant infrastructure
5.2 AI Model Security
- AI processing occurs in secure, isolated environments
- Models are regularly updated to prevent bias and improve accuracy
- No training data includes personally identifiable information
6. Children's Privacy (COPPA Compliance)
TrueHue is intended for users 18 years and older. We comply with the Children's Online Privacy Protection Act (COPPA).
6.1 Age Verification
We do not knowingly collect information from children under 13. If we discover we have collected such information, we will:
- Immediately delete all associated data and photos
- Terminate the associated account
- Notify parents/guardians if possible
7. Your Privacy Rights
You have the following rights regarding your personal data:
- Access: Request a copy of your personal data
- Correction: Update or correct inaccurate information
- Deletion: Request deletion of your data and analysis results
- Portability: Receive your data in a machine-readable format
- Withdrawal: Withdraw consent for data processing at any time
- Objection: Object to processing based on legitimate interests
To exercise these rights, contact us using the information in Section 9.
8. International Users
8.1 GDPR Compliance (EU Users)
For EU users, we ensure compliance with GDPR through:
- Explicit consent for facial analysis processing
- Data minimization and purpose limitation
- Right to be forgotten implementation
- Data Protection Officer appointment
8.2 Data Transfers
Data may be transferred to the United States for processing. We ensure adequate protection through Standard Contractual Clauses and other approved mechanisms.
9. Contact Information
For questions or concerns regarding this Privacy Policy, please contact:
TrueHue Privacy Team