Privacy Policy
Effective July 26, 2026 · Last updated August 5, 2026 · Color Glow is operated by X Tracker LLC ("we", "us") — the data controller for the processing described here; our contact details are in Section 13.
1. What we collect, and why
Your selfie (processed, never stored). When you take a selfie in the app, it is sent to our server over an encrypted connection and processed transiently to measure the colors of your skin, hair and eyes. The photo exists only for the duration of that analysis request and is deleted immediately when processing completes — whether the analysis succeeds or fails. We do not store your photo and we do not build a face-recognition database; the face data involved is described — with its retention and destruction schedule — in Section 2. What we keep is derived, non-visual data only: your color season, undertone classification, confidence score, and the numeric color measurements behind them.
Your results and imagery on your device. Your analysis results, your rendered previews (such as the portrait cutout used in the reveal), and your selfie as displayed in the app are stored on your phone only. Deleting the app, or using "Delete my data" inside it, removes them.
Account information. If you sign in with Apple or Google, we receive an account identifier and — where you or the provider share them — your email address and name. We use this to link your membership and referrals to you, including restoring them on a new device. If you use Apple's "Hide My Email", we only ever see the private relay address.
Purchases. Subscriptions are processed by Apple (and, on Android, by Google Play). We never see your payment card details. We receive subscription status (for example: active, expired) from Apple, Google Play, and our subscription-management provider, so the app knows what you've unlocked.
Referrals. If you share an invite code, we store the code, and a count of completed referrals, linked to your account and an app-installation identifier — this is how "3 friends = free" is counted.
Usage information. We collect basic app-interaction events (for example: which screens are used, whether an analysis completed) to fix problems and improve the product. Like every internet service, our servers also receive standard technical data with each request — your IP address and device type — kept only in short-lived server logs. On iOS we ask for tracking permission (the App Tracking Transparency prompt): if you allow it, we may use your device's advertising identifier to measure and attribute the performance of our advertising campaigns; if you decline, we do not track you across other companies' apps or websites — and nothing else changes about the app.
Push notifications. If you allow notifications, we store a device push token so we can send you app notifications, such as updates about your palette and features. You can turn notifications off any time in the app or in your device settings.
2. Face Data (biometric information)
To measure your coloring, our analysis transiently processes a scan of your face geometry — facial landmark positions and image regions (skin, hair, eyes) detected in your selfie. This section is our written policy for that data:
- Purpose limitation. Face data is processed for exactly one purpose: measuring the colors of your skin, hair and eyes to determine your color season. It is never used to identify you or anyone else, never used for face recognition, and never used to train AI or machine-learning models of any kind — not identification systems, and not our own analysis models. Because it is never used to identify anyone, it is processed as measurement data, not as identifying biometric data.
- Retention and destruction schedule. Face geometry data and your photo exist only in the course of processing a single analysis request and are permanently destroyed when that request completes — within seconds, and never later than the request itself. No facial landmarks, templates, or images are written to any database. What survives is exclusively non-biometric, derived color data (numeric color measurements and your season result).
- No sale, no profit. We never sell, lease, trade, or profit from face data or any biometric information.
- No disclosure. Face data is not disclosed to any third party, except that it transits our own analysis server, operated by our cloud hosting provider solely on our instructions — and nowhere else.
- Consent. Nothing is ever captured passively: the app shows you a face-data notice before the camera opens, and you agree by choosing to continue and take your selfie. Declining is simple — don't take the selfie; no other feature collects face data.
3. What we don't do
- We don't sell your personal data, and we don't share it with data brokers or advertisers.
- We don't show ads.
- We don't store your photos, and we don't use face recognition.
4. Who we share data with
Only the service providers needed to run Color Glow, and only what they need: Apple and Google (sign-in and payments), our subscription-management and purchase-screen providers, our push-notification provider, and our cloud hosting provider, where our analysis server runs. If we introduce AI-written styling text, that provider would receive derived color data only — never your photo or face data. We may disclose information in response to valid legal process (a subpoena or court order), or where necessary to protect the rights and safety of our users or others; where the law allows, we'll tell you first. If Color Glow is ever part of a merger, acquisition, or sale of assets, data may transfer with it — bound by every promise in this policy, including the no-photo-storage commitments.
5. Deleting your data
Email privacy@colorglow.app for any deletion request; we answer within 30 days. Your photo never needs a request — it is deleted from our servers automatically when the analysis completes. Deleting the app removes everything stored on your phone.
In app versions that support accounts, Profile → Account → Delete my data permanently deletes your account and its server-side data — derived results, account record, and referral history — and removes everything from your phone.
6. Data retention
Photos: not retained (deleted at analysis time). Derived results and account data: retained while your account exists, deleted on request. Subscription records: retained as required for accounting and by the app stores' and our subscription provider's own policies.
7. Children
Color Glow is not directed at children under 13, and the app does not allow use by anyone under 13 — or under the minimum age in your country for consenting to data processing, where that age is higher (parental consent is required below it). We do not knowingly collect personal information from children under 13; if we learn that we have, we will delete it promptly — contact privacy@colorglow.app.
8. Security
All traffic between the app and our servers is encrypted (HTTPS). Server access is restricted, and we deliberately minimize what exists to be breached: no stored photos, no payment details, no advertising profiles. No system is perfectly secure; if a breach ever affects your personal information, we will notify you and the relevant authorities as applicable law requires.
9. Your rights
Depending on where you live (for example the EU/EEA, UK, or California), you may have rights to access, correct, delete, or receive a copy of your personal data, to object to or request restriction of certain processing, and to withdraw any consent at any time (without affecting the lawfulness of processing before the withdrawal). EU/EEA and UK users may also lodge a complaint with their local data protection (supervisory) authority. Email privacy@colorglow.app and we'll honor them — we verify requests using the account or device you contact us from, and respond within the time the applicable law requires. An authorized agent may submit a request on your behalf. Deletion is also available directly in the app (Profile → Account → Delete my data) — the two designated request methods.
California residents: in the preceding 12 months we have collected these categories: identifiers (account ID, email, device ID, IP address), commercial information (subscription status), internet activity (app usage events), user content (your selfie, transiently), and sensitive personal information (transient face-geometry data). Sensitive personal information is used solely to perform the service you request — never to infer characteristics or for any secondary purpose — so no "Limit the Use of My Sensitive Personal Information" link is required. We do not sell your personal information and do not share it for cross-context behavioral advertising, so there is nothing to opt out of — but you retain the rights to know, delete, and correct, and to be free from discrimination for exercising them. We honor Global Privacy Control signals: because we sell and share nothing, the opted-out state is simply our default for everyone.
10. Legal bases and international transfers
Where GDPR or similar laws apply, our legal basis per purpose is: running your analysis, account, membership and referrals — performance of our contract with you; notifications and any iOS tracking permission — your consent; security, fraud prevention and product improvement — our legitimate interests. Your season result is computed automatically from color measurements; it is a styling suggestion with no legal or similarly significant effect, and you can always re-run it.
Our servers are located in the United States. Where personal data is transferred from the EU/EEA, UK or Switzerland, we rely on our providers' certification under the EU–US Data Privacy Framework and on Standard Contractual Clauses in our agreements with processors, alongside the safeguards described in this policy.
11. This website
colorglow.app itself sets no cookies, runs no analytics, and — because even our fonts are self-hosted — makes no third-party requests at all. Visiting this site shares nothing with anyone but us (our hosting provider necessarily sees standard web-server logs).
12. Changes
If we change this policy, we'll update it here and, for meaningful changes, tell you in the app. The date at the top is always current.
13. Contact
X Tracker LLC (d/b/a Color Glow)
407 Lincoln Rd Ste 6H
Miami Beach, FL 33139, USA
privacy@colorglow.app