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Privacy Policy

Effective date: March 27, 2026

Welcome to Color Analysis - Epoca (“Color Analysis - Epoca”, “we”, “us”, or “our”). We are committed to protecting your privacy. This Privacy Policy explains how we process, use, disclose, and protect your information when you use our app and related services.

1. Information Processed on Your Device

To provide core features, Color Analysis - Epoca processes and stores the following data locally on your device:

  • Photos captured with the camera, imported images, and generated looks. This content stays on-device and is not uploaded to our servers.
  • Face data, including facial landmark coordinates (geometric points representing facial features such as eyes, nose, mouth, and jawline) and segmentation masks (hair and portrait regions), detected and generated from your photos using on-device machine learning. Face data is processed and stored entirely on your device and is never uploaded to any server.
  • Analysis outputs derived from face data, such as sampled skin and hair colors, color profiles, and seasonal color analysis results. These outputs are stored locally for continuous usage.
  • Support contact data when you email us (such as your email address and message content).
  • App usage and device data, such as app version, language, crash diagnostics, interaction events, and pseudonymous app or device identifiers used by analytics and subscription infrastructure providers.
  • Subscription and purchase-related data provided by Apple and RevenueCat.
  • Color Analysis - Epoca does not require account registration for core features at this time.

2. How We Use Information

We use information to:

  • Provide core app features on-device, including color analysis, studio rendering, export, and history.
  • Detect facial landmarks and generate segmentation masks on-device to locate skin, hair, and facial regions in your photos, solely for the purpose of determining your personal color profile (e.g., seasonal color type). Face data is not used for facial recognition, identity verification, or any purpose other than color analysis.
  • Store your analysis results (including face data) and history locally on your device to support continuous usage.
  • Improve app performance, stability, and user experience, including through analytics and diagnostics providers such as Firebase Analytics, Firebase Crashlytics, and PostHog.
  • Operate subscriptions, verify entitlements, and process restore/refund workflows through Apple and RevenueCat.
  • Respond to support requests and communicate important service updates.
  • We do not use your photos or face data for marketing communications, ad targeting, or training machine learning models.

3. Sharing of Information

We do not sell your personal information. Your photos, face data (facial landmarks and segmentation masks), and analysis outputs are never shared with any third party — they remain entirely on your device. We may share limited non-face, non-photo data (such as subscription identifiers, app usage analytics, crash diagnostics, pseudonymous app or device identifiers, and device metadata) with trusted service providers that support app delivery, infrastructure, analytics, diagnostics, customer support, legal compliance, billing, and auditing. These providers may include Apple, RevenueCat, Firebase Analytics, Firebase Crashlytics, and PostHog. If you request a refund through Apple, we may share limited usage-related information with Apple to support refund review.

4. Data Security

We use reasonable technical and organizational safeguards to protect personal information from unauthorized access, loss, misuse, or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

5. Data Retention

On-device photos, face data (facial landmarks and segmentation masks), analysis outputs, and history are retained locally until you delete them within the app, clear app data, or uninstall the app. Face data is not retained on any server or external system at any time. Support communications and subscription-related records may be retained for as long as needed to comply with legal, accounting, and operational obligations.

6. Analytics and Tracking

We may analyze app usage data to understand performance and improve features. Analytics and diagnostics tools may include Firebase Analytics, Firebase Crashlytics, and PostHog. Where possible, analytics data is processed in aggregate or pseudonymized form.

7. Face Data and Special Categories of Data

Color Analysis - Epoca collects face data consisting of facial landmark coordinates (geometric points representing the positions of facial features such as eyes, nose, mouth, and jawline) and segmentation masks (pixel-level regions identifying hair and portrait areas), detected and generated from your selfie or imported photo using on-device machine learning. This face data is used exclusively to locate skin and hair regions for personal color analysis (determining your seasonal color type). Face data is processed entirely on your device and is never transmitted to our servers or any third party. Face data is stored locally on your device as part of your analysis results and is retained until you delete your analysis history, clear app data, or uninstall the app. We do not use face data for facial recognition, identity verification, advertising, or any purpose beyond color analysis.

We do not intentionally collect other sensitive data such as health records, political opinions, religious beliefs, trade union membership, genetic data, or sexual orientation information.

8. International Transfers

Your photos, face data, and analysis outputs never leave your device and are not subject to international transfer. To support subscriptions, billing, refunds, analytics, diagnostics, and customer support, limited non-face, non-photo data (such as subscription identifiers, crash diagnostics, pseudonymous app or device identifiers, and device metadata) may be processed by third-party providers such as Apple, RevenueCat, Firebase, and PostHog in jurisdictions outside your country. Where applicable, we apply safeguards required by law for international data transfers.

9. Your Privacy Rights

Subject to local law, you may have rights to access, correct, delete, or restrict processing of personal information that we control (for example, support records). For on-device content, you can directly delete data in the app or by removing the app and local data. You may also withdraw permissions (such as camera or photo access) in your device settings.

10. Changes to This Policy

We may update this Privacy Policy from time to time. If material changes are made, we will provide notice through the app, website, or other appropriate channels.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at support@epochworks.ai.

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