Privacy Policy

1. Information we collect

Face photographs

To produce a colour analysis you upload a front-facing photograph of yourself. It is stored securely in our private cloud storage (Supabase Storage) so the analysis can run and so virtual draping can show your photo back to you. Our analysis service measures the colouring of your skin, hair and eyes to work out your undertone, depth, contrast and season. We do not use the photograph to identify you, run facial recognition or face-matching, or build a biometric identifier.

See Retention and deletion for how long we keep it and how to have it erased.

Onboarding answers (iOS app)

The iOS app asks a short set of styling questions — your goals, occasions, style vibe, colour directions and jewellery metal — and we store the answers to tailor your recommendations. They are preference data only: no name, age, address or government identifier.

Purchases, subscriptions and email

Purchases in the iOS app go through Apple in-app purchase, mediated by Adapty, our subscription provider. From Adapty and Apple we receive only what is needed to know whether you are entitled to paid features: product identifier, purchase, renewal and expiry dates, trial and cancellation state, and an opaque transaction identifier. Website purchases are processed by Stripe, which gives us the payment confirmation, order identifier, amount, currency and your checkout email. We never receive your card details or Apple ID password.

If you ask us to email your results, join the waitlist or buy on the website, we store that email address to deliver results and answer support requests.

No accounts

The CAPSI iOS app has no account creation and no login. Your data is linked to an anonymous identifier rather than to your name, email or Apple ID. Because there is no account, we cannot recover your data if you delete the app.

Diagnostics, analytics and advertising (iOS app)

We use a small number of service providers in the app:

Adapty — subscriptions and paywalls.
Mixpanel — product analytics, to see where people drop out of the flow. We never send photographs or email addresses to Mixpanel.
Meta (Facebook) — advertising measurement, to see which campaigns lead to installs and subscriptions.
Firebase Crashlytics — crash and stability reporting.

App Tracking Transparency. Advertising attribution using your device advertising identifier runs only if you allow it when the iOS prompt asks. If you decline, the app works in full. You can change your choice any time in iOS Settings → Privacy & Security → Tracking.

Website logs, cookies and analytics

Our website and API record standard technical information — IP address, user agent, timestamp and endpoint — for security, abuse prevention and rate limiting. Two analytics tools run on the live production website only:

Google Analytics 4 — page views and navigation. It sets cookies (_ga and _ga_ followed by a property identifier) holding a randomly generated visitor identifier. This is a tracking technology and the data is processed by Google.
Vercel Analytics — page views and site performance. Cookieless; it stores no identifier in your browser.

You can block or delete these cookies in your browser settings, or install Google’s opt-out add-on; the site still works. We use no advertising or retargeting cookies.

2. How we use your information

To run your colour analysis, show your photograph back to you for virtual draping, and store and re-open your saved results.
To determine your subscription or purchase entitlement, email your results and answer support requests.
To measure product usage and improve the analysis and the app.
To measure advertising performance and attribute installs, subject to your App Tracking Transparency choice.
To detect abuse, apply rate limits, keep the service secure and comply with law.

We do not sell your personal information and we do not share your photograph with advertisers.

Your photograph is never used to build or improve our analysis. It is processed only to produce your own result. We do not use it to train, test, tune or evaluate the CAPSI model or any other model, we do not add it to a training or benchmark dataset, and we do not use it to train third-party models. There is no opt-in because we do not do it at all. “Improve the analysis and the app” above means usage measurements and error reports, not your photograph.

3. Sharing and service providers

We share personal information only with the processors needed to run CAPSI, each bound to use it only on our instructions:

Supabase — database and object storage, including uploaded photographs; Render — the analysis backend; Vercel — website hosting; Cloudflare — bot protection (Turnstile) and the authentication proxy in front of the analysis service.
Apple and Adapty — in-app purchases and entitlement; Stripe — website payments; Resend — transactional email.
Mixpanel, Meta and Google (Firebase Crashlytics) — analytics, advertising measurement and crash reporting.

We may also disclose information where required by law, or to protect the rights, safety or property of CAPSI or our users.

Where your data is processed. Your database records and stored photographs sit with our database and storage provider in the United States (region us-east-2), and the analysis service that processes your photograph runs in Singapore. Wherever you live, your information is transferred to and processed in both locations, so it may be processed outside your country of residence.

For users in the EU and the UK we rely on the European Commission’s Standard Contractual Clauses (and the UK Addendum where applicable) for those transfers, together with the safeguards in our provider agreements. Neither the United States nor Singapore is covered by an EU adequacy decision for these purposes, so the Clauses are the mechanism we rely on for both.

4. Security

Photographs and analysis data are encrypted in transit and stored in private, non-public storage. Your photo is only ever shown back to you through a temporary link that expires, access to the analysis service is authenticated, and your device identifier is stored in a form that cannot be reversed.

No system is perfectly secure. We cannot guarantee absolute security, but we will notify affected users and regulators of a personal data breach where the law requires it.

5. Retention and deletion

How long we keep your photograph

We keep your photograph while you are using CAPSI, so features like virtual draping, re-running an analysis and re-opening a saved result keep working. It does not expire on a timer, and we do not delete it because it has become old.

You can have it erased at any time by deleting your account in the app, or by emailing us. Deleting your account erases your photographs straight away.

How you delete your photograph and data

In the iOS app, on the Profile tab, Delete your account and all data erases your stored photograph files and deletes your orders, analyses, saved results and entitlement records — everything.

If you used CAPSI on the website, or want us to erase your data manually, email capsi@iterelle.tech and we will action it within 30 days.

We may keep a minimal transaction record (order identifier, amount, date) where tax, accounting or fraud-prevention rules require it, and backups may persist briefly after deletion before they cycle out.

Other data

Onboarding answers and analysis results are kept until you delete them or delete your account. Email addresses are kept until you ask us to remove them.

6. Children

You must be at least 16 years of age to use CAPSI. It is not directed to children and we do not knowingly collect personal information, including face photographs, from anyone under 16. If you believe a child has uploaded a photograph, email capsi@iterelle.tech and we will delete it.

7. Your rights

Depending on where you live, you may have the right to access the personal information we hold about you, obtain a copy, correct it, delete it, restrict or object to certain processing, and withdraw consent you previously gave.

California (CCPA/CPRA). You may ask what we collect and how we use it, request deletion or correction, and opt out of the sale or sharing of personal information. We do not sell personal information and will not discriminate against you for exercising these rights.

EU/UK (GDPR). Our lawful bases are performance of a contract (running the analysis you requested or paid for), consent (uploading a photograph, and tracking for advertising), and legitimate interests (security, abuse prevention, product improvement). You may withdraw consent at any time and complain to your local supervisory authority.

The fastest route to deletion is the in-app Profile controls above. For anything else, email capsi@iterelle.tech. Because CAPSI has no accounts, we may need your order identifier or the email you used to locate your data before we can act.

8. Changes to this policy

We may update this policy as CAPSI changes. We will update the “last updated” date above, and for material changes give more prominent notice in the app or by email where we have one.

9. Contact us

Questions, requests or complaints about this policy or your data: capsi@iterelle.tech.

The data controller is Iterelle, Inc., 391 Las Colinas Blvd E, Ste 130 #2045, Irving, TX 75039, United States.