Privacy Policy

Last updated: [DATE]

This policy explains what [COMPANY NAME] ("we," "us") collects when you use 12TONE, why we collect it, and the choices you have. The short version: your photos are used only to produce your analyses, never used to train any models, stored encrypted if your package includes future re-analyses, and permanently deleted at your request.

1. What we collect

  • Photos. The three photos you upload for your analysis (face in daylight, face indoors, inner wrist).
  • Contact details. Your email address, and your name if you provide it.
  • Location. The city you provide (or confirm from an approximate IP-based suggestion) — used only to generate weather-matched Seasonal Drops. We never collect precise GPS location.
  • Purchase data. Order details from our payment processor. We never see or store your full card number — payment is handled by [PAYMENT PROCESSOR], whose privacy policy applies to payment data.
  • Usage data. Standard technical data (browser type, pages viewed, approximate region) via cookies and similar technologies, for analytics and advertising measurement as described in Section 6.

2. How we use it

  • To generate your color analysis and deliver it to your palette page;
  • To generate monthly Seasonal Drops using local weather data for your city (if subscribed);
  • To send transactional emails: your results link, billing receipts, renewal reminders, and cancellation confirmations;
  • To send marketing emails if you opted in — every one includes a working unsubscribe link;
  • To process payments, prevent fraud, provide support, and comply with law.

3. Your photos, specifically

  • Photos are processed by automated systems solely to produce your analysis.
  • Photos are not used to train or improve any models and not shared with advertisers or any third party beyond the service providers listed below.
  • Depending on your package, photos may be securely retained (encrypted at rest) so future analyses don't require re-uploading. You can request permanent deletion of your photos at any time via the contact page, and we will delete them promptly. Your palette page displays your results — never your photos.
  • Our analysis technology provider processes photos under contractual terms that prohibit retention beyond processing and prohibit training on your data. Current provider: [ANALYSIS PROVIDER NAME].
  • If your jurisdiction treats facial images as biometric or sensitive data, we process them only with your explicit consent, given at the upload step, and only for the purpose above.

4. What we share (and don't)

We do not sell your personal information. We share data only with service providers who help us run 12TONE, bound by contracts limiting their use of it:

  • [ANALYSIS PROVIDER] — automated analysis of photos;
  • [HOSTING PROVIDER] — application hosting and storage;
  • [PAYMENT PROCESSOR] — payments and subscription billing;
  • [EMAIL PROVIDER] — transactional and (if opted in) marketing email;
  • Weather data providers — receive only city-level coordinates, never your identity;
  • Authorities, where required by law.

5. Retention

  • Photos: retained securely while your account or package is active (where your package includes future analyses), and permanently deleted promptly upon your request.
  • Analysis results & palette page: kept while your page is active, or until you request deletion.
  • Account, order & billing records: kept as required for tax, accounting, and legal purposes.

6. Cookies & advertising

We use cookies and similar technologies for essential site functions, analytics, and measuring advertising (e.g., knowing an ad led to a purchase). Where required by law, we ask for consent before setting non-essential cookies, and you can withdraw consent at any time via [COOKIE SETTINGS LINK]. You can also control cookies in your browser settings.

7. Your rights

Depending on where you live (including under GDPR and CCPA/CPRA), you may have the right to access, correct, delete, or receive a copy of your personal information, object to or restrict certain processing, and opt out of targeted advertising. We honor these rights regardless of residency where feasible. To exercise them, use the contact page or email [SUPPORT EMAIL]. We will verify your request via the email associated with your purchase and respond within the legally required timeframe. We never discriminate against you for exercising your rights.

8. Security

Photos and personal data are encrypted in transit and at rest. Access to production systems is restricted and logged. No system is perfectly secure, which is why photos are encrypted at rest, access is tightly restricted, and deletion requests are honored promptly and permanently.

9. Children

The Service is for adults 18+. We do not knowingly collect data from anyone under 18, and we delete it if we learn we have.

10. International transfers

We operate from [COUNTRY] and use providers that may process data in other countries, including the United States. Where required, transfers are protected by appropriate safeguards such as Standard Contractual Clauses.

11. Changes

We will post any changes here with an updated date, and notify subscribers by email of material changes before they take effect.

12. Contact

[COMPANY NAME] · [COMPANY ADDRESS] · [SUPPORT EMAIL] · Contact page