1. Introduction

• TrueHue respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and protect information when you use the TrueHue app.
• TrueHue is operated by DBML Tech Solutions Private Limited.
• For any privacy-related questions or concerns, you may contact us at: support@truehue.ai

2. Information We Collect

We collect only the information necessary to provide the TrueHue service.

a) Account Information

To create and access your account, we collect:

• Phone number (used for one-time password (OTP) login)
• Name (used to personalize your experience)
• We do not collect user email addresses for account creation or login.

b) User Photo (Required for Service)

• We collect and store the photo you upload or capture within the app.
• This photo is required to provide core features, including AI-based skin tone analysis, undertone detection, lip pigmentation analysis, skin-tone twin matching, and virtual makeup application.
• During processing, we may also derive non-biometric facial landmark points (face mesh) to identify facial regions such as lips and skin areas.
• We do not perform facial recognition and do not collect biometric identifiers.

c) Derived Information

• From the uploaded photo, we generate derived information using trained AI models, including:
• Skin tone
• Undertone
• Lip pigmentation levels
• Non-biometric facial landmark data (used only to apply virtual makeup accurately)
• This derived information is used only to provide personalized results within the app and is not used for identification purposes.

d) Usage & Device Information

• We collect limited technical information, including:
• App interactions
• Device type
• Operating system information
• Diagnostic and crash data
• This information is used only to maintain app performance and stability.

3. How We Use Your Information

We use your information to:

• Authenticate users and manage accounts
• Provide core app functionality and personalized recommendations
• Store your photo and results so you can continue using the service
• Maintain, secure, and improve app performance
• Respond to support requests

4. Photo Storage & Usage

• Your photo is securely stored to provide the TrueHue service, including AI-based skin analysis, skin-tone twin matching, and virtual makeup application.
• Your photo is never shared with third parties.
• Your photo is never used to train or improve AI or machine learning models.
• Your photo is not used for facial recognition or identity verification.
• Photos are stored securely on cloud servers under your account and are processed only to generate results for your use within the app.

5. Consent & Control

• By selecting "Use My Photo", you consent to uploading and storing your photo for the purposes described in this policy.
• You may replace your photo at any time.
• If you delete your account, your photo and related data are deleted.

6. Children's Privacy

• TrueHue is intended for users 18 years of age and older.
• We do not knowingly collect personal data from individuals under 18. If such data is identified, it will be deleted.

7. Data Sharing

• We do not sell, rent, or trade personal data.
• We do not share user photos with third parties.
• We may share limited data with trusted service providers only when necessary to operate the app (for example, secure cloud storage). These providers are required to protect your data and use it only for authorized purposes.
• We may disclose information if required by law.

8. Cookies & Tracking Technologies

• TrueHue uses only necessary cookies required for basic app functionality.
• No analytics cookies are used
• No advertising or tracking cookies are used

9. Data Storage & Security

• We use reasonable technical and organizational measures to protect your information, including encryption in transit and access controls.
• No system is completely secure. Please keep your login credentials confidential.

10. Data Retention

• Account information and photos are retained while your account is active
• Photos, derived skin analysis data, and facial landmark data are permanently deleted when your account is deleted
• Technical logs are retained only as long as necessary for security and diagnostics

11. Your Rights Under Indian Law (DPDP Act, 2023)

In accordance with India's Digital Personal Data Protection Act, 2023, you have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request deletion of your personal data, as permitted by law
• You may exercise these rights by contacting us at support@truehue.ai.

12. Automated Processing

• TrueHue uses automated processing to analyze images and generate cosmetic previews and recommendations.
• This processing may include detecting non-biometric facial landmarks solely to apply virtual makeup accurately and does not involve facial recognition or biometric identification.
• We do not use automated decision-making that produces legal or similarly significant effects on users.

13. Customer Communication & CRM (With Consent)

If you provide explicit consent, we may use your name and phone number to send you:

• Service-related updates
• Feature announcements
• Promotional or informational messages related to TrueHue

These communications are:

• Sent only by TrueHue
• Not shared with advertisers or data brokers
• Optional, and you may opt out at any time

14. Changes to This Policy

• We may update this Privacy Policy from time to time.
• Any updates will be posted with a revised “Last Updated” date. Continued use of the app indicates acceptance of the updated policy.

15. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

• support@truehue.ai