Glowtone Biometric Information Policy
Effective date: October 27, 2026 Version: 1.0
1. Scope
This policy applies to face-related data that Glowtone ("we", "us") collects or processes when you use color analysis, the draping preview and virtual try-on. It supplements our Privacy Policy. It is intended to meet the written policy and notice requirements of the Illinois Biometric Information Privacy Act (740 ILCS 14, "BIPA"), the Texas Capture or Use of Biometric Identifier Act (Tex. Bus. & Com. Code 503.001, "CUBI"), and Washington law on biometric identifiers (RCW 19.375 and the Washington My Health My Data Act), and similar laws.
2. What data is involved
| Data | Description |
|---|---|
| Face photo (selfie) | The image you take for color analysis |
| Face landmarks | Numeric coordinates from face detection (MediaPipe) used only to locate cheek, eye and hair regions to measure color |
| Face crop | A cropped face image that may be sent to an AI provider for a second opinion on color season |
| Draping preview | Your face composited on colored backgrounds |
| Full-body photo | Photo of you used for virtual try-on (stored on your device) |
| Try-on result | AI-generated image of you in an outfit |
We do not create or store a face template, faceprint, or any data used to identify or recognize you, and we do not match your face against any other face or database.
3. Purpose
Only to (a) measure the color of your skin, eyes and hair, (b) determine and display your color season and palette, (c) show a draping preview, and (d) generate a virtual try-on preview you request. We do not use this data for advertising, profiling, identification, authentication, surveillance or training AI models.
4. Consent before collection
We do not collect, capture or process your face data unless you have first read the notice and given your written (electronic) consent in the app. We record the time and version of your consent. You may withdraw consent at any time in Settings > Privacy or at privacy@glowtone.app. If you withdraw, we stop processing and delete related data as described below.
5. Disclosure to others
We do not sell, lease, trade or otherwise profit from your biometric data. We disclose face data only: 1. to our service providers who process it on our behalf and under contract: our hosting provider, and AI providers (OpenRouter and Google, for the face crop second opinion and for try-on); 2. with your consent; or 3. if required by law, subpoena or valid legal process.
6. Written retention schedule and destruction
| Data | Retention | Destruction method |
|---|---|---|
| Face photo (selfie), face landmarks, face crop | Deleted immediately after the analysis completes (target: within seconds; also if processing fails) | Secure deletion of temporary files / release from memory; automated cleanup job |
| Draping preview | Maximum 1 hour after creation | Automated deletion job |
| Try-on result image | Maximum 1 hour after creation | Automated deletion job |
| Full-body photo | Only on your device; not kept on our server. Deleted from the app when you delete it, withdraw consent or uninstall. | By you; in-app delete button |
| Copies at AI providers | Not retained after the request: every request is sent with zero data retention and with training denied | Provider deletion; contractual obligation |
| Color values (Lab numbers) and season result | Until you delete your account or reset your profile. These are not used to identify you. | Deletion from database |
| Consent record | For the period needed to prove consent, 3 years after your last interaction | Deletion from database |
Outer limits: we permanently destroy any biometric identifier or biometric information in our possession when the initial purpose for collecting it has been satisfied, when you withdraw consent, or within 3 years of your last interaction with us, whichever occurs first (BIPA), and in any event within the time required by Texas law (no later than one year after the purpose expires) and Washington law. In practice, the schedule above is much shorter.
If we receive a valid warrant or subpoena, or if a court orders otherwise, we may be required to retain specific data; we will tell you unless the law forbids it.
7. Storage and protection
We store and transmit face data with a reasonable standard of care for our industry and at least as protective as how we handle other confidential information: encrypted transmission (HTTPS), restricted server access, API keys only on the server, unguessable and expiring file locations, no face images in logs, analytics or backups.
8. Your rights
You can: ask what face data we hold; withdraw consent; request deletion; and, where laws give you more rights, use them. Contact privacy@glowtone.app. We respond within 45 days or sooner where required.
9. Minors
Glowtone is for users aged 13 and older. We do not knowingly collect face data from children under 13.
10. Changes
We will update this policy when our practices change and will ask for your consent again before applying material changes to face data processing.
11. Contact
Luis Javier Ferrero Calle (Glowtone), Hessenring 35, 67593 Westhofen, Germany, privacy@glowtone.app