Privacy Policy

Last updated August 28, 2026

Last updated: August 28, 2026

This Privacy Notice for ToneMate ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (ToneMate), or any other application of ours that links to this Privacy Notice
• Use ToneMate. ToneMate is a mobile app that analyzes a photo of your face to determine your skin tone, undertone, and seasonal color palette, and then recommends clothing colors and generates outfit suggestions from photos of clothes you add to a personal wardrobe. The face photo is deleted as soon as the analysis finishes; only the resulting color profile is stored. Analysis, clothing tagging, and outfit generation are performed by third-party AI services. Photos are never used to train AI models and are never sold. ToneMate can be used as a guest without an account, on a free tier with an account, or with an optional paid subscription.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@tonemate.co.

Summary of key points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using the table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information from third parties? Yes, but only what is needed to sign you in and to keep your subscription in sync. If you sign in with Google or Apple, we receive the profile details those services return. Our subscription provider tells us when your subscription starts, renews, or ends.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by emailing us at support@tonemate.co. We will consider and act upon any request in accordance with applicable data protection laws.

Table of contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. Do we offer artificial intelligence-based products?
6. How do we handle your sign-in providers?
7. Is your information transferred internationally?
8. How long do we keep your information?
9. How do we keep your information safe?
10. What are your privacy rights?
11. Controls for Do-Not-Track features
12. Do United States residents have specific privacy rights?
13. Do other regions have specific privacy rights?
14. Your face photo and your biometric data
15. If you are in Turkiye: your rights under KVKK
16. How old you have to be to use ToneMate
17. Do we make updates to this notice?
18. How can you contact us about this notice?
19. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• contact or authentication data
• photographs of your face, used to analyze your skin tone and deleted as soon as the analysis finishes
• photographs of your clothing, stored in your wardrobe until you delete them
• age range, collected as a bracket such as 25-34 rather than an exact date of birth
• gender, which is optional and can be skipped

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• biometric data
• skin tone and undertone derived from your face photo; we do not infer or record your race or ethnic origin

Sign-in provider data. We offer you the option to register with us using your existing Google or Apple account. If you choose to register in this way, we will collect certain profile information about you from that provider, as described in the section called "How do we handle your sign-in providers?" below.

Consent records. When you accept or decline this notice, our terms, the biometric consent, or analytics, we record which decision you made, which version of the document it applied to, and when. We keep this as a legal record that your consent was given.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, storage, photo library, so you can choose an existing photo instead of taking a new one, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

Notifications. If you allow notifications, ToneMate schedules a daily reminder to build your outfit. These reminders are scheduled on your device by your operating system — we do not send push notifications, we do not create or store a push token, and no personal data (your location, your photos, or the contents of your wardrobe) is transmitted or included in a reminder. You can turn reminders off at any time in Settings → Notifications inside the app, or in your device's own notification settings.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. If you allow it, we read your device's location when you set up or change your location, and we use it for one purpose only: to look up the name of your city and today's weather, so outfit suggestions match the conditions outside. Those coordinates are sent to the weather and city-lookup providers named in section 4 in order to answer that request. We do not store your coordinates on our servers. Your city and the location your device uses for later weather updates are kept on your device, and are erased when you uninstall the app. Location is optional: you can decline it and type a city name instead, and you can withdraw access at any time in your device settings.
• Guest device identifier. If you use ToneMate as a guest, we store a one-way hash of a device identifier. It lets us apply the guest usage limit to a device and stops a device that has already created an account from returning to guest mode. The hash cannot be reversed to identify your device, and we never store the identifier itself.

Google API

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. (Retention period: For as long as your account exists. Deleting your account deletes it and its contents outright rather than deactivating it.)
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. (Retention period: Your face photo is deleted the moment the analysis finishes. Your color palette, clothing photos, wardrobe details, and outfits are kept until you delete them or delete your account.)
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. (Retention period: For as long as it takes to deal with your request, and a reasonable period afterwards in case you get back in touch about the same matter.)
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services. (Retention period: For as long as your account exists. Records of subscription events are kept afterwards with your user ID removed. Apple and Google hold the purchase receipts themselves.)
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. (Retention period: Hashed IP records are kept for a short rolling window. Usage counters and the hashed guest device record are kept for as long as they are needed to enforce the limits they exist for.)
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• To analyze your face photo and determine your color palette. With your explicit consent, we send your face photo to a third-party AI service to work out your skin tone, undertone, and seasonal color palette. We keep the result, not the photo. (Retention period: The photo is deleted the moment the analysis finishes, whether it succeeded or failed. The resulting color palette is kept until you delete your account.)
• To generate outfit suggestions from your wardrobe. We send photos and details of the clothes you add, your color palette, and the local weather to a third-party AI service, which suggests outfits and explains its reasoning. (Retention period: Clothing photos and outfits are kept until you delete the item, delete the outfit, or delete your account.)
• To apply usage limits fairly. We count how many analyses and wardrobe items each account and each guest device has used, and we store a hashed device identifier and a hashed IP address. (Retention period: Hashed IP records are kept for a short rolling window. The guest device record is kept for as long as the device may return to the app.)

3. What legal bases do we rely on to process your personal information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Diagnose problems and/or prevent fraudulent activities
  • stop one person from creating unlimited free accounts, keep the free and guest tiers sustainable, and control the cost of the AI services we pay for per use
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The third parties we may share personal information with are as follows:

• AI Service Providers — Google Gemini API
• Cloud Computing Services — Supabase and Modal Labs
• Invoice and Billing — Apple App Store in-app purchases, RevenueCat and Google Play Billing
• User Account Registration and Authentication — Google Sign-In and Sign in with Apple
• Web and Mobile Analytics — PostHog
• Website Performance Monitoring — Sentry
• Local weather and city lookup for outfit suggestions — Open-Meteo and OpenStreetMap Nominatim

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do we offer artificial intelligence-based products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including Google Gemini. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "What legal bases do we rely on to process your personal information?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• Image analysis
• Personal color analysis and outfit recommendations

How we process your data using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

How to opt out

We believe in giving you the power to decide how your data is used. To opt out, you can:

• Contact us using the contact information provided
• Decline the biometric consent, or simply do not start a skin analysis. We never send a photo to the AI service unless you start an analysis or add a wardrobe item.

6. How do we handle your sign-in providers?

In Short: If you choose to register or log in to our Services using your Google or Apple account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using Sign in with Apple or Google Sign-In. Where you choose to do this, we will receive certain profile information about you from that provider, which is typically your name and your email address. Apple lets you hide your real email address and forward mail through a private relay instead; if you choose that, the relay address is all we ever see. We do not receive contact lists, friend lists, posts, or anything else from your account with that provider.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your sign-in provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences.

7. Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Germany and the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "When and with whom do we share your personal information?" above), including facilities in the United States, Germany, Turkey, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). If you are located in the EU or UK, see section "How do we process your information?" for our retention periods by purpose.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. What are your privacy rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.
• Open Profile and choose Delete account in the app. Deleting your account permanently removes your photos, wardrobe, outfits, and skin analysis results.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. Specifically, three things outlive a deleted account, none of which can identify you afterwards: a dated record that our documents were accepted, a record that a subscription started, renewed, or ended, and the hashed device marker that counts the free guest allowance. Deleting your ToneMate account explains each of them, and what deletion does and does not cover.

If you have questions or comments about your privacy rights, you may email us at support@tonemate.co.

11. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. Do United States residents have specific privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "What information do we collect?"

We only collect sensitive personal information, as defined by applicable privacy laws, for the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A — As long as the user has an account with us
• Category B — As long as the user has an account with us
• Category C — As long as the user has an account with us
• Category D — As long as the user has an account with us
• Category E — The face photo is deleted the moment the analysis finishes, whether it succeeded or failed. We keep only the resulting color palette, until you delete your account.
• Category F — Only collected if you turn analytics on in the app. Events are held by our analytics provider on its own retention schedule; we do not keep a separate copy.
• Category G — Only collected if you grant location permission. We keep one current location per account, overwritten each time it updates, until you delete your account. We keep no location history.
• Category H — This is the photographs you take. Your face photo is deleted the moment the analysis finishes. Clothing photos are kept until you delete the item or your account. We collect no audio, video, or thermal data.
• Category K — As long as the user has an account with us
• Category L — The face photo is deleted the moment the analysis finishes. Your location is a single current value that is overwritten each time it updates, and is deleted with your account.

Sources of personal information

Learn more about the sources of personal information we collect in "What information do we collect?"

How we use and share personal information

Learn more about how we use your personal information in the section "How do we process your information?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section "When and with whom do we share your personal information?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal information as defined in the California Customer Records law
• Category C. Characteristics of protected classifications under state or federal law
• Category D. Commercial information
• Category E. Biometric information
• Category F. Internet or other electronic network activity information
• Category G. Geolocation data
• Category H. Audio, electronic, visual, and similar information
• Category K. Inferences drawn from collected personal information
• Category L. Sensitive personal information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "When and with whom do we share your personal information?"

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to exercise your rights

To exercise these rights, you can contact us by emailing us at support@tonemate.co, or in the app: open Profile, where you can delete your account and everything in it, and turn analytics off, without contacting us at all. You may also refer to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@tonemate.co. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "How can you contact us about this notice?"

13. Do other regions have specific privacy rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How can you review, update, or delete the data we collect from you?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How can you review, update, or delete the data we collect from you?"

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa) General enquiries: enquiries@inforegulator.org.za Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za

14. Your face photo and your biometric data

This section is the notice we ask you to consent to before your first skin analysis. It is the whole of what we do with your face photo — there is no separate document.

What we collect, and why it counts as special-category data

When you run a skin analysis we collect the photograph of your face that you take or choose, and we derive from it a seasonal colour palette (for example "Deep Winter"), an undertone (warm, cool, or neutral), and a set of recommended colours. Under Article 9 of the GDPR and Article 6 of the KVKK this is special-category — sensitive — personal data, which is why we ask for your explicit consent before any analysis and record which version of this notice you agreed to, and when.

We use it for one thing: working out your colour palette and, from that, recommending clothing colours and building outfit suggestions. We do not use it to infer health conditions, race, ethnic origin, nationality, or anything else. We do not sell it, license it, or hand it to anyone for their own purposes.

Who processes it

Your photograph is sent from our servers to Google Gemini, our AI provider, for the length of the analysis and no longer. Our own backend runs on Supabase in Frankfurt.

How long we keep it

The photograph is deleted the moment the analysis finishes — whether it succeeded or failed. It is not held for a fixed period, it is not kept "for a while", and it is never moved to long-term storage. What remains afterwards is the derived result: your palette, undertone, and season. That stays in your account until you delete it or delete your account.

Saying no, and changing your mind

Consent is yours to give and to take back.

• You can decline the biometric consent and still use the rest of the app. You will not be able to run a skin analysis, and everything else keeps working.
• You can withdraw your consent at any time by writing to support@tonemate.co, or by deleting your account from inside the app, which removes the results with it. Withdrawing does not make an analysis we already ran unlawful.
• We never start an analysis on our own. A photograph goes nowhere unless you begin one.

How the analysis works, and why we are telling you

ToneMate runs an automated system that looks at a photograph of your face and places you into one of twelve seasonal color categories, based on physical characteristics such as your skin tone, your undertone, and the contrast between your features. Under Article 50(3) of the EU Artificial Intelligence Act, we are telling you plainly that this system exists and that you are interacting with it whenever you run a skin analysis. The system sorts by physical appearance only. It does not identify you as a person, it does not attempt to determine your race or your ethnic origin, and its output is a styling suggestion, not a decision that has any legal effect on you or that similarly significantly affects you. Nothing about your account, your access, or your price depends on what it returns. Using it is entirely your choice: we never send a photograph to it unless you start an analysis yourself, you can decline the biometric consent and still use the rest of the app, and you can delete the result at any time from inside the app.

15. If you are in Turkiye: your rights under KVKK

ToneMate is operated from Turkiye, so Turkish data protection law (KVKK, Law No. 6698) applies to us as the data controller. Your face photo and the color result derived from it are special categories of personal data under Article 6 of the KVKK, which is why we ask for your explicit consent before any analysis and record that consent with a version and a timestamp. Article 11 of the KVKK gives you a defined set of rights over your personal data, and every one of them applies to you. That article states them in full and is the authoritative list. In day-to-day terms they let you ask whether we process your data, ask what we hold and why, have anything incomplete or wrong corrected, have it erased, have any third party we shared it with told about a correction or an erasure, and object to a result produced solely by automated analysis. Write to support@tonemate.co to exercise any of them and we will answer within the time the law allows.

Article 10 of the KVKK also asks us to tell you how we collect your data and on what legal ground. We collect all of it directly from you, inside the app: when you create an account, when you take or choose a photo, when you tell us your age range, and when you allow access to your location. We rely on your explicit consent under Article 6 for your face photo and the colour result derived from it. For everything else we rely on Article 5: that the processing is directly related to and necessary for performing the agreement between us, and on our legitimate interests where those do not override your fundamental rights and freedoms — for example, keeping usage limits fair. Who we transfer your data to, and why, is listed in "When and with whom do we share your personal information?" above.

16. How old you have to be to use ToneMate

ToneMate is for people aged 16 and over. We ask for your age range during setup, before an account is created, and if you tell us you are under 16 you cannot continue and we never collect an email address from you. We do not knowingly collect personal information from anyone under 16. If you believe a person under 16 has given us personal information, write to support@tonemate.co and we will delete the account and its contents. We collect your age as a range, such as 25 to 34, rather than a date of birth, because a range is all we need and it tells us less about you.

17. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

18. How can you contact us about this notice?

If you have questions or comments about this notice, email us at support@tonemate.co. This is the address for every request in this notice, and we answer it ourselves.

19. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, email us at support@tonemate.co. You can also delete your account and everything in it from inside the app: open Profile and choose Delete account.