Glowtone Privacy Policy
Effective date: October 27, 2026 Last updated: October 27, 2026 Version: 1.0
1. Who we are
Glowtone ("Glowtone", "we", "us", "our") is a mobile app and web app that helps you find the colors that suit you, suggests outfits, and shows AI-generated previews of outfits on a photo of you.
Business responsible for your data: Luis Javier Ferrero Calle (sole proprietor, trading as Glowtone), Hessenring 35, 67593 Westhofen, Germany. Contact for privacy questions: privacy@glowtone.app (see Section 14).
This Policy explains what personal information we collect, why, who receives it, how long we keep it, and what choices you have. Our separate Biometric Information Policy (in the app and at https://glowtone.app/biometric) gives extra detail about face-related data and forms part of this Policy.
2. Short version
- Your selfie is analyzed on our server and deleted right after the analysis. We keep only color numbers (CIELAB values) and your color season result.
- Face landmarks (points that locate your cheeks, eyes and hair) are used only to find where to measure color. They are deleted together with the selfie. We do not keep face templates or faceprints and we do not identify you from your face.
- A cropped part of your selfie may be sent to an AI model provider (Google Gemini, through the routing service OpenRouter) to get a second opinion on your color season. We send these requests with zero data retention and no training (see Section 7).
- A preview image of your face on colored backgrounds ("draping preview") is stored on our server for up to 1 hour, then deleted.
- Your full-body photo for virtual try-on stays on your device. It is sent to an image model (Google, through OpenRouter) only when you start a try-on. The result image is stored on our server for up to 1 hour, then deleted.
- We do not sell your personal information and we do not share it for cross-context behavioral advertising. We do not use advertising or analytics SDKs.
- You must be at least 13 to use Glowtone.
3. Information we collect
3.1 Information you give us
| Category | Examples | When |
|---|---|---|
| Onboarding answers | Age or birth year (age gate), goals, budget, favorite stores, occasions, style swipes (style profile) | Onboarding |
| Selfie(s) | 2 to 3 photos of your face, optionally with a white sheet of paper for white balance | Color analysis |
| Full-body photo | Photo of you for virtual try-on | Try-on |
| Outfit photos and screenshots | Photos for "Rate my Fit"; screenshots or photos of items for "Shop-Check" | When you use those features |
| Account data (optional) | Your email address, used only to sign in with a one-time link | Only if you create an account |
| Saved content | Saved looks and items, style diary entries, scores, streaks | When you use the app |
| Closet photos | Photos of your own clothes for "My closet" (please photograph clothes, not people) | When you add pieces to your closet |
| Price alerts | The products you watch and your optional target price | When you turn on a price alert |
| Invites and Color Twins | Your invite or twin link, an optional first name you choose to show your friend, and your season result shown to the friend who joins | When you invite a friend |
| Votes from friends (web page) | Which look a friend picked. We do not store the voter's IP address, only a salted one-way code to stop double votes; polls close after 7 days | When friends vote on your poll |
| Waitlist sign-up (website) | Email address, which beta you want (iOS, Android), where you came from on our site | When you join the waitlist |
| Communications | Messages you send to support | When you contact us |
Please do not upload photos of other people without their permission, and do not upload photos of children.
3.2 Information we create from your photos
| Category | Description | Kept? |
|---|---|---|
| Color values | Lab (CIELAB) numbers measured on skin, eyes and hair; warmth, value and clarity scores | Yes, tied to your profile |
| Color season result | One of 12 seasons, confidence value, neighbor season, palette | Yes |
| Face landmarks | Coordinates used only to locate cheeks, eyes, hair | No, deleted with the selfie |
| Face crop sent to AI provider | Cropped face image used for a second opinion | Not kept by us; see Section 7 for provider handling |
| Draping preview image | Your face on colored backgrounds | Up to 1 hour, then deleted |
| Try-on result image | AI-generated image of you in an outfit | Up to 1 hour, then deleted |
| Reveal video | A short video of your season result; includes your draping image only if you choose to add it. Made on our own server, no AI provider | Up to 1 hour, then deleted. Save it to your device to keep it. |
| Rate my Fit / Shop-Check results | Scores, tips, detected item color | The uploaded photo is processed in memory and not stored on our server. Results stay in your diary on your device until you delete them. |
| Closet cut-outs | A cut-out image and a small thumbnail of each piece, its category, colors and pattern. Created on our own server, no AI provider is involved. Location and camera data (EXIF/GPS) are removed on upload. | Yes, until you delete the piece or your closet. The original photo is deleted right after the cut-out is made. |
| Game progress | Glow points, level, stickers, daily challenges, streak, palette bingo, monthly recap | Yes, tied to the random installation ID (or your account) until you reset the app or delete it |
3.3 Information collected automatically
| Category | Examples |
|---|---|
| Device and app data | App version, platform, language and time zone, as needed to run the app |
| Identifiers | A random installation ID created by the app. We do not use an advertising identifier. |
| Purchase data | Subscription status and transaction identifiers from Apple, Google and RevenueCat. We do not receive your card number. |
| Link clicks | When you tap a product link, we may record that click. The retailer may set cookies on its own site. |
| Usage counts | Daily totals per feature (for example "42 outfit lists loaded today"). These counts contain no installation ID, IP address or content and cannot be linked to you. |
| Abuse protection | Your IP address is used in memory only to limit how often the AI features can be called (rate limiting); it is not stored with your profile. |
| Server logs | Technical access logs of our web server (time, address called, status, IP address, installation ID, app version). No photos and no face data. |
We do not collect your location. The app does not use GPS and does not ask for location permission.
3.4 Information we do not intentionally collect
We do not ask for your body measurements, weight, or health information, and the app does not rate bodies or weight. We do not collect Social Security numbers, financial account numbers, or government IDs.
4. How we use information (purposes)
| Purpose | Data used |
|---|---|
| Analyze your coloring and give your color season, palette and explanation | Selfie (temporarily), color values |
| Show proof of the result (draping preview) | Selfie-derived image (up to 1 hour) |
| Generate virtual try-on previews | Full-body photo, selected outfit |
| Rate my Fit and Shop-Check | Uploaded photo or screenshot, your season |
| Recommend outfits, "Outfit of the Day", weekly edit | Season, style profile, budget, occasions |
| Run subscriptions and restore purchases | Purchase data |
| Optional account: sign in and keep your data across devices | Email address, account ID, linked installation IDs |
| Provide support, prevent fraud and abuse, enforce our Terms | Account data, device data, logs |
| Keep the service running and fix errors | Server logs, usage counts (no photos) |
| My closet: cut-outs, outfits from your own clothes, "complete the look" suggestions | Closet photos (briefly), cut-outs, colors |
| Glow points, stickers, challenges and bonus try-ons | Game progress, the actions that earn points |
| Price alerts and Best Deals | Watched products, target prices, public shop prices |
| Waitlist and launch emails | Email address, beta preference |
| Comply with law | As required |
| Affiliate attribution | Link click data |
We do not use your selfies, landmarks, body photos or generated images to train AI models. Our requests to AI providers are sent with zero data retention and with data collection for training turned off (see Section 7).
5. Legal bases (EU/UK users only)
See Section 12.
6. Biometric and face-related information
Analyzing the color of your face involves processing face landmarks, which some laws treat as biometric information. We ask for your separate, explicit consent before we capture or analyze your face, we keep nothing that could identify you from your face, and we publish a written retention and destruction schedule. Details are in the Biometric Information Policy. You can withdraw consent in the app (Settings > Privacy) or by emailing us. If you withdraw consent, color analysis and the draping preview will no longer be available.
7. Who we share information with (service providers)
We share information only as needed to run the app.
| Recipient | Role | What they receive | Purpose |
|---|---|---|---|
| OpenRouter (USA) | AI routing service (processor) | Face crop (color season second opinion); full-body photo and outfit images (try-on); outfit photos or screenshots (Rate my Fit, Shop-Check); text prompts | Forward requests to AI models |
| Google (Gemini models) | AI model provider (sub-processor through OpenRouter) | Same as above, as routed | Generate color second opinion and try-on images |
| Hetzner Online GmbH (Germany, servers in Falkenstein) | Hosting (processor) | All data we hold on our server | Run the service |
| Supabase (USA) | Login service (processor) | Email address and account ID, only if you create an account | Sign in with a one-time link |
| Resend (USA, sending from the EU) | Email delivery (processor) | Your email address and the sign-in email | Deliver sign-in emails |
| RevenueCat (USA) | Subscription management (processor) | Installation ID, purchase data | Unlock Glow Pass and restore purchases |
| Apple App Store / Google Play | Independent business | Purchase and subscription data | Billing (see their policies) |
| Local notifications (on your device) | None: reminders are scheduled on your phone; no push token is sent to us, Apple, Google or Expo | Nothing leaves your device | Reminders you turn on: weekly edit, outfit of the day, occasion plans, free trial ending |
| Professional advisers, authorities | Independent | As required | Legal compliance, claims |
| Business transfer | Successor | Data transferred with the business | Merger, sale or similar, with notice to you where required |
Every request we send to AI models through OpenRouter is sent with zero data retention and with data collection for training denied, so it is only routed to model endpoints that do not store your content or use it for training.
Third-party shops and affiliate links. Outfit and product links lead to third-party retailer websites. When you leave Glowtone, the retailer's own privacy policy applies. We may earn a commission on purchases made through links (see Terms). We do not send your photos or color results to retailers.
8. "Sale" and "sharing" (California)
We do not sell personal information and we do not "share" it for cross-context behavioral advertising, as those terms are defined in the CCPA/CPRA. We have not sold or shared personal information of consumers, including consumers under 16, in the past 12 months.
9. Retention
| Data | Retention |
|---|---|
| Selfie(s), face crop, face landmarks | Deleted immediately after the analysis completes, also if processing fails. Never written to long-term storage or backups. |
| Draping preview image | Up to 1 hour, then deleted automatically |
| Full-body photo | Stored on your device only until you delete it in the app or uninstall. We do not keep a copy on our server. |
| Photo sent for try-on (in transit and processing) | Held only for the request and deleted when it ends |
| Try-on result image | Up to 1 hour, then deleted automatically. Save it to your device if you want to keep it. |
| Rate my Fit / Shop-Check uploaded photo | Processed in memory, not stored |
| Color values and season result | Until you delete your data or your account, and no longer than 24 months after your last use |
| Style profile, saved items, diary | Until you delete them or your account, and no longer than 24 months after last use |
| Closet cut-outs and thumbnails | Until you delete the piece, use "Delete my closet" or reset the app; original closet photos are deleted right after the cut-out (or kept until you retry if the cut-out service was busy) |
| Game progress, price alerts | Until you reset the app or delete your data |
| Account data | Until you delete your account |
| Consent records | Proof that you agreed to the biometric notice (time, text version, app version, installation ID): kept for 3 years, also after you delete your data, so we can show that we asked for consent |
| Waitlist email | Until 6 months after launch, or earlier if you unsubscribe or ask us to delete it |
| Daily usage counts (no personal data) | 14 months |
| Purchase records | As required by tax and accounting law (in Germany generally up to 10 years) |
| Support messages | 24 months |
| Server logs (no images, no face data) | 30 days |
| Biometric-related data | See Biometric Information Policy. We destroy it as described there, and in any event no later than the earlier of (a) when the purpose for collecting it is satisfied or (b) 3 years after your last interaction with us. In practice our schedule is much shorter. |
Our server backups do not contain photos or face data.
10. Your choices and rights (US)
10.1 For everyone
- Delete all your data in the app: Settings > Privacy > "Reset app and erase my data". If you are signed in, this also deletes your account and login.
- Withdraw biometric consent (Settings > Privacy).
- Turn off notifications in your device settings.
- Manage or cancel subscriptions in your Apple ID or Google Play settings.
- Email us at privacy@glowtone.app.
10.2 California (CCPA/CPRA) and other US state privacy laws
Residents of California and certain other states (for example Colorado, Connecticut, Virginia, Texas, Oregon and others, depending on thresholds) may have these rights, subject to exceptions: - Know and access the categories and specific pieces of personal information we hold about you. - Delete personal information we collected from you. - Correct inaccurate personal information. - Opt out of sale or sharing and of targeted advertising (we do neither; see Section 8). - Limit use of sensitive personal information. We use sensitive personal information (face-related data) only to provide the features you request, so we do not offer a separate "limit" link. - Non-discrimination: we will not deny service or charge different prices because you exercise your rights. - Portability where applicable. - Appeal a refusal (some states). Email us with "Appeal" in the subject line.
How to make a request: use the delete function in the app, email privacy@glowtone.app, or follow the steps at https://glowtone.app/delete-account. We will verify your request by matching information you provide against our records (for example your installation ID shown in the app, or your account email) and respond within 45 days (we may extend once by a further 45 days and will tell you). An authorized agent may submit a request on your behalf with written permission.
Categories (CCPA table, last 12 months).
| CCPA category | Collected? | Source | Disclosed for a business purpose to |
|---|---|---|---|
| Identifiers (installation ID, account ID, email) | Yes | You, your device | Hosting, login, email and subscription providers |
| Commercial information (purchase status) | Yes | App stores | Subscription providers |
| Biometric information (face-related, as defined by CCPA) | Temporarily | You | AI providers (face crop), hosting |
| Internet or app activity | Yes (server logs, link clicks) | Your device | Hosting |
| Geolocation | No | ||
| Sensory data (photos) | Yes, temporarily | You | AI providers, hosting |
| Inferences (color season, style profile) | Yes | Derived | Hosting |
| Sensitive personal information (face-related data; no precise geolocation) | Yes, as above | You | As above |
10.3 Biometric-specific notices
See the Biometric Information Policy for notices under the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act, and Washington law.
10.4 Do Not Track and Global Privacy Control
The app and our website do not track you across other companies' apps and websites. Our website sets no cookies and loads no third-party trackers, so there is nothing a Global Privacy Control signal would need to switch off.
11. Children
Glowtone is not for children under 13. We ask for your age in onboarding and block access if you are under 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has used the app, email privacy@glowtone.app and we will delete the data. We do not knowingly sell or share data of anyone under 16. Glowtone has no social feed and no public profiles.
12. EU / UK users
Glowtone is currently offered in the United States only. This section applies if you use Glowtone from the EU or UK.
Controller: see Section 1.
Legal bases (Art. 6 and Art. 9 GDPR):
| Purpose | Basis |
|---|---|
| Face analysis for color season (face images and landmarks; we do not use them to uniquely identify you, but we treat them cautiously as possible special category data) | Explicit consent, Art. 6(1)(a) and, to the extent Art. 9 applies, Art. 9(2)(a). You can withdraw at any time. |
| Virtual try-on, Rate my Fit, Shop-Check (processing your photo at your request) | Contract performance, Art. 6(1)(b); consent for face content |
| Outfit recommendations, subscriptions, account, support | Contract, Art. 6(1)(b) |
| Security, fraud prevention, server logs, legal claims | Legitimate interests, Art. 6(1)(f) |
| Tax and accounting | Legal obligation, Art. 6(1)(c) |
Your rights: access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and the right to complain to a supervisory authority (in Germany, for example the Landesbeauftragter für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz; in the UK, the ICO).
International transfers: Some of our providers are located in the USA (see Section 7). Where required we rely on the EU-US Data Privacy Framework for certified recipients or on Standard Contractual Clauses.
Automated decisions: The color season is an automated estimate for your information and does not produce legal or similarly significant effects on you.
Age: Where the minimum age for consent in your country is above 13 (for example 14 to 16), the higher age applies.
13. Security
We use reasonable technical and organizational measures such as encryption in transit (HTTPS), access controls, automatic deletion of temporary files, and keeping API keys on the server and out of the app. No system is perfectly secure. If a breach affects you, we will notify you and authorities as required by law.
14. Contact
Luis Javier Ferrero Calle (Glowtone) Hessenring 35 67593 Westhofen Germany Email: privacy@glowtone.app
15. International users and data location
Glowtone is operated from Germany. Our server is located in Germany (Hetzner, Falkenstein). Some of your information may be processed in the United States and other countries where our providers operate (see Section 7).
16. Changes to this Policy
We may update this Policy. If changes are material, we will notify you in the app before they take effect and, where the law requires, ask for your consent again (in particular for any change to biometric processing). The "Last updated" date shows the latest version.