Privacy Policy

1. Who We Are

This Privacy Policy applies to the Tonely mobile app and the tonely.studio website (together, the "Service"). Tonely provides AI-powered personal color season analysis based on a single selfie. For any question about your personal data, contact us at support@tonely.studio.

2. What Data We Process

• Your selfie: the face photo you upload for color analysis.
• Account data: if you create an account with email and password, your email address and (optional) name; for guest use, only a random user identifier.
• Analysis results: your season type and color palette (color/type data only — no photo).
• Purchase status: whether you have unlocked Premium. Payments are processed by Apple; we never receive your card details.
• Minimal technical data: basic device/session information needed for debugging and operating the Service.
• Device quota record: to ensure the free analysis can be used once per device (fraud prevention), an irreversible hash of a random identifier generated by the app. It is not linked to your identity and is never used for advertising or tracking.

3. Your Selfie: Purpose and Sensitivity

A face photo is sensitive, biometric-adjacent data, and we treat it accordingly. We process your photo only to determine your skin undertone, eye and hair color and to place you into one of the 12 color seasons. Your photo is:

• never used for identification or facial recognition,
• never used to derive or store any biometric template, facial geometry map, or "faceprint" — no such identifier is ever created,
• never used for advertising and never sold to third parties,
• never used to train AI models,
• processed only after your explicit consent given in the app.

4. Processing via an AI Provider

The analysis is performed via the Claude API operated by our third-party AI provider, Anthropic PBC (USA). Your photo is transmitted to Anthropic over an encrypted (TLS) connection solely for the purpose of the analysis. Under Anthropic's API terms, data submitted via the API is not used to train AI models and is retained only on a limited basis for abuse monitoring for a maximum of 30 days before deletion. This international transfer is based on the explicit consent you give in the app.

5. Storage Location, Retention and Automatic Deletion

• Photos: automatically deleted from our servers immediately after the analysis completes; if that immediate deletion ever fails due to a technical error, a daily scheduled cleanup removes any remaining photo within at most 7 days.
• Analysis results: (season type and palette — not the photo) are stored with your account until you delete it.
• Account data: stored until you delete your account, then permanently removed.
• Where your data is stored: your photo (until the moment of analysis) and your analysis results are stored on our own servers hosted on DigitalOcean infrastructure in Frankfurt, Germany (EU).

6. Analytics

We use only minimal, aggregated usage analytics to improve the Service. We do not share data with advertising networks, and your photos are never sent to any analytics system.

7. Sharing of Data

We do not sell your personal data. Data is shared only with the service providers required to operate the Service: our hosting/infrastructure provider, the AI analysis provider (photo only, at the moment of analysis only), and Apple for verifying purchases. We may disclose data to competent authorities where legally required.

8. Security

Your data is encrypted in transit (TLS), and access is restricted to what is strictly necessary. No system is 100% secure; in the event of a data breach we will notify you in accordance with applicable law.

9. Your Rights

Under applicable data protection law (KVKK in Türkiye, GDPR in the European Union), you have the right to access, rectify and delete your data, to object to processing, and to withdraw your consent at any time. Users in Türkiye can find the detailed statutory disclosure on our KVKK page.

10. Account Deletion

You can permanently delete your account and all associated data in the app via Settings → Delete Account. You may also send a deletion request to support@tonely.studio. For abuse prevention, only the device quota record (a hash that contains no personal data and is not linked to your identity) is retained after account deletion.

11. Children's Privacy

Tonely is not directed at children under 13, and we do not knowingly collect data from this age group.

12. Changes

We will publish material changes to this policy on this page and, where appropriate, notify you in the app.

13. Contact

Questions: support@tonely.studio