Privacy Notice

The data controller is [PLACEHOLDER — registered legal name of the SZNZ operator], of [PLACEHOLDER — registered / trading address], company number [PLACEHOLDER — company registration number, if incorporated]. Our ICO registration number is [PLACEHOLDER — ICO registration number]. For any privacy question, or to exercise your rights, contact [PLACEHOLDER — privacy contact email address].

To be completed before launch: controller legal name, address, company number, ICO registration number and a monitored privacy contact address. SZNZ must be registered with the ICO before processing begins.

We collect only what the service actually needs. In practice that is:

• Account details — your email address and, if you set one, a display name. Your password is held by our authentication provider as a secure hash; we never see it. If you sign in with Google we receive your email address and basic profile details, not your Google password.
• Consultation answers — age range, natural hair status and depth, eye colour, brow status, whether you wear coloured contact lenses, whether fake tan or make-up is present, and what you want from your analysis. These are used to interpret your photographs correctly.
• Photographs — the images you submit for analysis, and photographs of items you scan.
• Colour measurements and results — the numeric colour values measured from your photographs, your season result, confidence values, your personalised palette and your reports.
• Purchase and membership information — what you bought, when, the amount, and your membership status and entitlements. Card details are handled by our payment provider and never reach SZNZ.
• Consent records — which consents you gave or withdrew, the exact wording shown, the policy version and the time.
• Support messages — anything you send us when you ask for help.
• Security and administrative logs — records of significant administrative actions, kept to protect the service.

We do not run analytics or advertising tools, we do not build advertising profiles, and we do not buy or sell personal data.

Why we ask for them. Your colouring cannot be measured from a description. Photographs let us measure the actual colour of your skin, eyes, hair, brows and lips, and the contrast between them.

How they are analysed. Facial landmark detection runs inside your own browser or phone — the software that locates features such as the eyes, brows and lips does not send your image anywhere to do so. The image is then assessed for usability (focus, exposure, colour cast, glare) and small colour samples are taken from defined facial regions and converted to numeric colour values. Those numbers, not the photograph, drive your result.

What is assessed. Colour characteristics only: skin, iris, hair, brow and lip colour, and the contrast between them.

Whether they are stored. Yes. Original photographs are stored in a private storage area on our infrastructure, access-controlled so that only your account can retrieve them. They are not publicly accessible and are served only through short-lived signed links to you. Derived colour measurements are stored alongside them.

How long. Photographs from an analysis you do not complete are cleared 30 days after upload. Where an analysis is completed, we keep the photographs while your account is open so your report and draping images can be re-rendered — and no longer. You can delete your photographs at any time from your settings, and we delete them within 30 days of your account closing.

Model training. No. Your photographs are not used to train or improve any model, and are not used to develop our methodology, unless you separately opt in. That consent is off by default.

Sharing. Your photographs are not shared with other users, advertisers or data brokers. They are held by our hosting and storage provider acting on our instructions, and are not sent to any AI provider.

Deletion. Delete individual photographs or all of them from your settings, or email [PLACEHOLDER — privacy contact email address] and we will do it for you.

SZNZ does not use your photographs for facial recognition, identity verification, face matching, surveillance, advertising profiles, or race or ethnicity classification, and no such functionality exists in the product. The software locates facial features in order to sample colour; it does not create a face template capable of identifying you, and we do not attempt to identify anyone from a photograph.

Under UK GDPR we must have a lawful basis for each purpose. Here is ours, in full, rather than a blanket claim of legitimate interests.

We do not use analytics or advertising cookies, so there is no analytics processing to declare. See our Cookie Notice.

We have assessed whether SZNZ processes special category data. Our conclusion, stated honestly rather than conveniently:

• SZNZ's purpose is colour analysis. We do not seek to infer, classify, record or display racial or ethnic origin, health, or any other special category, and no such classification exists in the product.
• However, a photograph of a face, and measurements of skin, hair and eye colour, are capable of being connected with racial or ethnic origin. Because that risk cannot be dismissed outright, we do not rely on the argument that no special category data can ever be involved.
• We therefore take the cautious route: we ask for your explicit consent to process your photographs for colour analysis (UK GDPR Article 9(2)(a)), separately from our Terms and separately from marketing.
• We apply safeguards proportionate to that: private access-controlled storage, per-account access rules, in-browser feature detection, no transfer of photographs to AI providers, no training use without separate opt-in, and short retention.

Flagged for legal and privacy review before launch: confirmation of this special-category assessment and of the Article 9 condition relied upon, and a documented DPIA covering facial photograph processing. The consent mechanism and records required to support it are already implemented in the product.

Your colour result is produced by automated analysis. In outline: usable photographs are identified, colour values are measured from defined facial regions across all of your images, those measurements are combined so that no single photograph is decisive, and the combined profile is compared against the twelve seasons in the SZNZ framework. Your report shows the confidence attached to your result and, where relevant, the runner-up season and why it was not chosen. We do not publish the underlying source code or commercially sensitive detail.

This is a personal styling recommendation. It has no bearing on employment, credit, insurance, housing, healthcare, education, legal rights or access to essential services, and so it does not produce legal or similarly significant effects. If you believe your result is wrong, email [PLACEHOLDER — privacy contact email address] or our support address — we will look at your evidence, and you can submit new photographs.

These are the providers actually used by SZNZ. There are no others.

Stripe is not currently a payment processor for SZNZ. If that changes, this notice will be updated before Stripe processes any live payment.

We may also disclose information where the law requires it, or to establish or defend legal claims. We do not sell personal data.

To be completed before launch: written processor terms (Article 28) with each provider above, and the published sub-processor list for each, recorded in your data-processing records.

Because our providers operate global infrastructure, your information — including your photographs — may be processed outside the United Kingdom. We do not claim that all data stays in the UK, because it does not. Where personal data is transferred outside the UK, it must be protected by an approved safeguard: UK adequacy regulations, or the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with a transfer risk assessment.

To be completed before launch: confirm and record the transfer mechanism relied on for each provider, and complete a transfer risk assessment. Then state the specific mechanism here.

We use technical and organisational measures appropriate to the sensitivity of what we hold: encryption in transit, access controls that scope every record and every photograph to the account that owns it, private storage with short-lived signed links, hashed passwords held by our authentication provider, administrative audit logging, and role-based access for staff functions. Facial feature detection runs on your own device, so less leaves it in the first place.

No system that transmits or stores information over the internet can be guaranteed completely secure, and we will not pretend otherwise. We maintain an internal process for detecting, investigating and reporting security incidents, including notifying the ICO and affected users where the law requires it.

Under UK data protection law you have the right to:

• access the personal data we hold about you
• have inaccurate data corrected
• have data erased in certain circumstances
• restrict how we use your data in certain circumstances
• object to processing based on legitimate interests
• receive certain data in a portable format, or have it transmitted to another provider
• withdraw consent at any time where we rely on it — including photo-analysis consent and marketing consent
• ask us about the automated analysis behind your result, and challenge it

These rights are not absolute. Where the law requires us to keep something — payment and tax records are the clearest example — we will keep it and tell you why, rather than promise a deletion we cannot make. We respond within one month and will not charge you unless a request is manifestly unfounded or excessive.

You can request deletion from your account settings. Before you confirm, we show you exactly what will be deleted — your photographs, colour measurements, results, palettes, reports and profile — and what must be retained, namely payment records for 7 years and consent records for 6 years. Any active membership is cancelled. Deletion is irreversible: downloaded reports remain yours, but we cannot restore your analysis.

Please contact [PLACEHOLDER — privacy contact email address] first and give us a chance to put things right. You also have the right to complain to the Information Commissioner's Office at any time, and you do not need our permission to do so: ico.org.uk, or 0303 123 1113.

We version this notice and show its effective date at the top. If we make a material change to how we use your information, we will tell you by email or in the app before it takes effect, and ask again for consent where consent is the basis we rely on.