Privacy Policy

1. About This Policy

This Privacy Policy explains how Emma Color ("Emma Color," "we," "us," or "our") handles information when you use the Emma Color iOS application, our website, or contact support. Emma Color provides AI-assisted personal color analysis based on the 12-season color system, style recommendations, and, with an eligible subscription, an AI chat experience.

Emma Color is the operator responsible for the processing described in this Policy. For privacy questions or requests, contact [email protected].

2. Information We Handle

Depending on how you use Emma Color, we handle the following categories of information:

• Analysis content: photographs you take or select for color analysis, the resulting season, palette, measurements, and recommendations.
• Chat content: messages, questions, images, and AI-generated responses in the subscriber chat.
• Purchase information: product and entitlement status, subscription status, transaction or purchase identifiers, and related App Store receipt information. We do not receive your full payment-card details.
• Technical and usage information: app events, feature interactions, approximate technical location derived from network information, device and operating-system information, app version, language, timestamps, installation or vendor identifiers, diagnostics, and crash logs.
• Support information: your email address, the contents of your request, and a pseudonymous Support ID. When you contact us through the in-app support flow, the app automatically includes the Support ID so we can investigate your request.

Please do not submit information that is not needed for color analysis or styling assistance. Images may reveal sensitive details incidentally, so review the background and remove other people from an image before uploading it.

3. How We Use Information

We use information to:

• provide, personalize, and maintain color analysis, recommendations, purchases, subscription access, and AI chat;
• process photographs and prompts, generate responses, and preserve your on-device history;
• verify entitlements, prevent duplicate consumption of purchases, and restore eligible subscription access;
• understand feature usage, diagnose crashes, improve reliability, and develop the service;
• protect Emma Color, our providers, and users from fraud, abuse, security threats, or unlawful activity;
• respond to support and privacy requests and comply with applicable legal obligations.

4. Where Information Is Processed

Emma Color does not maintain its own persistent server database of your analysis photographs, chat history, or analysis results. Processing still involves the following service providers:

• Apple processes App Store purchases, subscriptions, and platform diagnostics that you choose to share with Apple.
• RevenueCat receives purchase, entitlement, subscription, and pseudonymous app-user information to manage access to paid features.
• Cloudflare provides Cloudflare R2 storage. Cloudflare R2 temporarily hosts photographs used for analysis and images attached to chat so they can be delivered securely for processing. Analysis photographs stored by Emma Color in Cloudflare R2 are subject to a 24-hour lifecycle/TTL and are automatically deleted through lifecycle expiration.
• OpenAI is a third-party AI service provider used as part of Emma Color's analysis and chat processes. For analysis, Emma Color provides OpenAI temporary access to the analysis photograph through a Cloudflare R2 URL so OpenAI can process it as part of Emma Color's analysis. OpenAI also receives text prompts, chat images made available through temporary Cloudflare URLs, and relevant conversation context. Emma Color uses OpenAI's Conversations API to store and retrieve conversation state across response-generation requests.
• Amplitude receives pseudonymous product-usage events and technical identifiers for analytics.
• Google Firebase Analytics receives product-usage and technical information, and Firebase Crashlytics receives crash reports, diagnostic logs, and device or app information.

Third-party service providers that process personal information on Emma Color's behalf are permitted to process that information only as necessary to provide their services and are subject to applicable contractual, privacy, and data-protection obligations. These providers also process information under their own terms and privacy commitments. You can learn more from Apple, RevenueCat, Cloudflare, OpenAI, Amplitude, and Google.

5. Storage and Retention

Different information is retained in different places:

According to OpenAI's API data controls documentation, data submitted through the API is not used to train OpenAI models unless the API customer affirmatively opts in. Provider practices can change, and we may update this Policy when they do.

6. Legal Bases

Where applicable law requires a legal basis, we process information as necessary to perform our agreement with you, including providing purchased analyses and subscription features; for our legitimate interests in operating, securing, supporting, and improving Emma Color; with your consent, including access to the camera, photo library, or optional platform diagnostics; and to comply with legal obligations. You may withdraw consent through iOS settings where the processing depends on consent, without affecting earlier lawful processing.

7. Facial Images and Face Data

During color analysis, Emma Color automatically captures photographs containing your face through the in-app camera. These photographs are used to provide your personal color analysis, results, and related recommendations by analyzing visible appearance and color characteristics.

Emma Color does not perform facial recognition. It does not use facial images to identify, authenticate, or verify a person, and it does not create faceprints, facial-recognition embeddings, biometric templates, or biometric identifiers. The analysis is a styling assessment, not a medical or biometric identity service.

Emma Color temporarily uploads the photographs to Cloudflare R2. The temporary copy stored by Emma Color in Cloudflare R2 is subject to a 24-hour lifecycle/TTL and is automatically deleted through lifecycle expiration. Emma Color does not otherwise store or use the photographs after the analysis.

OpenAI is a third-party AI service provider used as part of Emma Color's analysis process. Emma Color provides OpenAI temporary access to the photograph through a Cloudflare R2 URL so OpenAI can process it as part of the analysis. Emma Color's 24-hour Cloudflare R2 lifecycle applies to the temporary copy stored by Emma Color; information processed or retained by OpenAI is governed separately by OpenAI's applicable data controls, terms, policies, and legal obligations, as described in Section 5.

Before an analysis photograph is made available to OpenAI, Emma Color displays an in-app disclosure explaining that photographs of your face will be processed with OpenAI. The photograph is not made available to OpenAI for that analysis until you choose to continue.

Emma Color does not sell facial photographs or face data and does not share them for advertising or marketing purposes.

8. Advertising, Tracking, and Sale of Data

The current version of Emma Color does not display third-party advertising, use your information for cross-app tracking, or sell personal information. We do not share personal information for cross-context behavioral advertising as those terms are defined by applicable U.S. privacy laws.

If we introduce advertising attribution, Apple App Tracking Transparency permission, or new advertising SDKs, we will update this Policy and the App Store privacy disclosures before that functionality is released and request consent when required.

9. International Processing

Emma Color is available globally, and our providers may process information in countries other than the country where you live. Those countries may have different data-protection laws. Where required, we and our providers rely on appropriate transfer mechanisms, contractual safeguards, consent, or other lawful bases for international transfers.

10. Your Privacy Rights

Depending on where you live, you may have rights to request access, correction, deletion, restriction, portability, or objection; withdraw consent; opt out of certain uses; and appeal a decision or complain to a data-protection authority. We will not discriminate against you for exercising a privacy right.

To make a request, email [email protected]. Using the in-app support flow automatically includes your Support ID, which helps us locate pseudonymous provider records. We may ask for additional information to verify the request. Because Emma Color has no user accounts and much of the data is stored only on your device, we may be unable to identify or retrieve records that cannot reasonably be linked to your Support ID. We will explain any limitation and respond as required by applicable law.

Deleting Emma Color from your device removes the app's locally stored chat history and analysis results. It does not necessarily delete information already retained by Apple or the service providers described above, which remains subject to their applicable retention rules and your legal rights.

11. Children

Emma Color is not intended for children under 13, and we do not knowingly collect personal information from children under 13. If local law requires a higher age for a person to consent to data processing or enter into these Terms, a parent or legal guardian must authorize the use. If you believe a child has provided information without appropriate permission, contact us so we can take appropriate action.

12. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect information, including encrypted network transmission and time-limited image storage. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Protect your device with a passcode and avoid submitting information you do not want processed by the providers identified in this Policy.

13. Changes and Contact

We may update this Policy to reflect changes to Emma Color, our providers, or applicable law. We will revise the "Last updated" date and provide additional notice when required. Your continued use after an update is subject to the revised Policy, except where consent is required.

Questions or privacy requests: [email protected].