Effective Date: July 2, 2026
Last Updated: October 15, 2026

Welcome to TrueToned ("TrueToned," "we," "our," or "us").

Your privacy is important to us. This Privacy Policy explains how we collect, use, process, store, share, and protect personal information when you use our website, Chrome browser extension, iOS application, and related services (collectively, the "Services").

TrueToned provides personal seasonal colour analysis and colour-matching tools. Certain features differ between our Chrome extension and iOS application, as explained below.

For privacy questions or requests, contact us at hello@truetoned.ca.

Who We Are

TrueToned is a Canadian personal colour analysis platform designed to help individuals discover the colours that complement their natural features.

Our Services include:

• Personal Colour Analysis: Seasonal colour analysis using a questionnaire and optional photographs.

• Chrome Extension: Personalised colour-compatibility ratings on supported retailer websites.

• iOS Application: Standalone seasonal colour analysis, personalised colour palettes, and an on-device colour scanner.

• User Accounts: Secure access to saved colour profiles and analysis results.

Our Chrome extension and iOS application provide different features. The iOS application does not include retailer integrations, in-app shopping, or retailer checkout.

TrueToned is operated as an independent Canadian business.

Independent Service

TrueToned is an independent software service and browser extension. Unless expressly stated, TrueToned is not affiliated with, endorsed by, sponsored by, or operated by any retailer, brand, marketplace, or manufacturer.

Information We Collect

We collect personal information necessary to provide, maintain, and improve TrueToned's Services. The information collected depends on the features you choose to use.

A. Account Information

• Password, stored securely as a one-way hash

• Name and email address

• Account verification and authentication information

• Customer support communications

Providing this information is optional; however, some features may not function without it.

B. Images and Color Analysis

When you upload a photograph or selfie, TrueToned processes the image to perform a personalized color analysis.

The analysis may identify characteristics such as:

• Hair and eye colour

• Skin undertone and natural contrast

• Jewellery preferences, vein colour, and tanning characteristics

• Relevant appearance details, including makeup, self-tanner, and contact lenses

• Seasonal colour analysis results, personalised palettes, and related recommendations

Your uploaded images are processed solely for the purpose of providing our Services.

We do not claim ownership of any images you upload.

Unless you explicitly consent, your uploaded photographs will not be used to train artificial intelligence or machine learning models.

Photograph Processing and Retention

You may voluntarily submit photographs for seasonal colour analysis. Photo analysis requires your consent, and questionnaire-only analysis is available without uploading photographs.

When you consent, photographs are transmitted securely to TrueToned's servers and processed through OpenAI to help determine your seasonal colour characteristics.

Submitted photographs are not saved to your TrueToned account or active production database. We retain your resulting colour analysis and questionnaire information instead.

Photographs may be processed temporarily by our service providers and may remain in limited operational backups or third-party security logs, as explained in the Data Retention section.

C. Account Information

If you create an account, we may collect:

• Username

• Email address

• Password (stored using industry-standard encryption or hashing)

• Profile settings

• Saved analyses

• Saved retailers

• Saved favorites

• Saved wardrobes (when available)

D. Shopping Information

To provide personalized recommendations while you use the Services, TrueToned may process limited information relating to products displayed on supported retailer webpages that you actively choose to visit while using the browser extension. This may include information such as:

• Product titles

• Product colors

• Product categories

• Product identifiers

• Product page URLs

This information is processed solely to provide the requested functionality of the Services. TrueToned does not use this information to build or maintain retailer product catalogs.

E. Device Information

We may automatically collect technical information such as:

• Browser type

• Operating system

• Device type

• Language settings

• IP address

• Time zone

• Crash reports

• Performance diagnostics

• Extension version

• Mobile application version

F. Browser Extension Permissions

If you install the TrueToned browser extension, it may request permission to:

• Detect supported retailer websites

• Analyze limited product information displayed on supported retailer webpages in order to generate personalized color recommendations and shopping insights.

• Display personalized color recommendations

• Store user preferences

• Synchronize settings across devices

On supported retailer websites you choose to visit, the Chrome extension may read product titles, colour names, categories, and other relevant product details to provide colour-compatibility ratings.

Product matching is performed locally within the extension. Optional AI-generated product explanations may transmit limited colour-related information to our servers and OpenAI, but not your photographs or the full retailer webpage.

G. IOS Application

The iOS application processes questionnaire answers, optional photographs, saved colour profiles, and subscription status.

Its colour-scanning feature samples colours on your device without uploading scan photographs for seasonal analysis.

H. Subscriptions

Chrome subscriptions are processed through Stripe. iOS subscriptions are processed through Apple In-App Purchases, with RevenueCat managing subscription entitlements.

TrueToned stores limited subscription identifiers and status information but does not store complete payment-card details.

I. Technical information

Our hosting and security providers may process IP addresses, request timestamps, and related technical information for service operation, security, and abuse prevention.

We do not currently use separate advertising, product-analytics, or crash-reporting SDKs in the Chrome extension or iOS application.

How We Use Your Information

We use the personal information we collect to operate TrueToned and provide the features you choose to use.

Specifically, we use your information to:

• Create and update your seasonal colour analysis and personalised colour palette.

• Provide colour-compatibility ratings on supported retailer websites through our Chrome extension.

• Generate optional AI-assisted explanations of colour recommendations.

• Create, authenticate, and secure your TrueToned account.

• Synchronise your saved colour profile and analysis across supported TrueToned services.

• Manage subscriptions, free trials, and access to paid features.

• Send essential account communications, including email verification and password resets.

• Respond to customer support inquiries and privacy requests.

• Prevent fraud, unauthorised access, misuse, and repeated free-trial claims.

• Maintain the security, reliability, and functionality of our Services.

• Comply with applicable legal obligations.

We do not sell your personal information.

We do not use customer photographs to train TrueToned's own artificial intelligence models.

OpenAI processes photographs submitted for optional photo analysis. Our OpenAI organisation's model-training data-sharing settings are disabled, meaning we have not opted to share API inputs and outputs for model training. OpenAI may still retain certain information temporarily for security and abuse-monitoring purposes, as explained in this Privacy Policy.

Artificial Intelligence and Third-Party Processing

TrueToned uses artificial intelligence and third-party service providers to deliver certain features.

AI-Powered Colour Analysis

Our seasonal colour analysis combines questionnaire responses, established colour-matching rules, and optional AI-assisted photograph analysis.

When you consent to photograph analysis, your submitted images and relevant questionnaire information are securely transmitted through TrueToned's servers to OpenAI for processing.

If you choose questionnaire-only analysis, no photograph is sent to OpenAI.

OpenAI Data Privacy

TrueToned uses OpenAI's API to process submitted photographs and generate certain optional colour-related explanations.

Our OpenAI organisation has disabled data sharing for model training. Under OpenAI's standard API practices, API inputs and outputs are not used to train its models unless the customer explicitly opts in.

OpenAI may retain submitted information, including photographs, in security and abuse-monitoring logs for up to 30 days, or longer where required for legal or safety reasons. We do not currently have Zero Data Retention enabled.

We have also disabled optional API call logging within our OpenAI organisation.

Other Service Providers

TrueToned uses the following providers to operate its Services:

• Railway: Application hosting and database infrastructure.

• OpenAI: Optional photograph analysis and AI-assisted colour explanations.

• Stripe: Chrome extension subscription payments.

• Apple: iOS In-App Purchase processing.

• RevenueCat: iOS subscription entitlement management.

• Email delivery providers: Account verification, password resets, and essential communications.

These providers may process information in countries outside Canada, including the United States, subject to their respective privacy and security practices.

We may also disclose information when required by applicable law, to protect our Services and users, or in connection with a legitimate business transfer.

Limitations of AI Analysis

Seasonal colour results are estimates and may be affected by lighting, camera quality, makeup, hair colouring, self-tanner, screen calibration, and other factors.

TrueToned does not guarantee that every colour recommendation will be accurate. Users should exercise their own judgment when interpreting results or making purchases.

Cookies, Chrome Extension Permissions, and Retailer Websites

Cookies and Local Storage

TrueToned's Chrome extension uses local browser storage to maintain authentication sessions, saved colour-profile information, preferences, and certain temporary feature data.

The iOS application uses device storage and secure authentication storage for account sessions and application preferences.

Neither application relies on traditional browser cookies to maintain its authentication sessions.

Our website may use cookies or similar technologies necessary for its operation. Additional information is available in our Cookie Policy at https://www.truetoned.co/cookie-policy.

Chrome Extension Permissions

The TrueToned Chrome extension operates on supported retailer websites to provide personalised colour-compatibility ratings.

To perform these functions, it may access product information displayed on supported pages, including product titles, colour names, categories, and relevant product identifiers.

Product colour matching is performed locally within the extension. TrueToned does not use this information to build a centralised catalogue of your browsing activity.

The extension does not intentionally monitor unrelated websites or access retailer payment information.

Third-Party Retailers

TrueToned is independent of the retailers and brands supported by its Chrome extension.

When you visit a retailer's website or make a purchase, that retailer's own privacy policy, terms, and payment practices apply.

TrueToned does not process purchases made on third-party retailer websites.

Affiliate Links

TrueToned does not currently insert affiliate tracking links into retailer websites through its Chrome extension. If this practice changes, we will update our disclosures as appropriate.

Third-Party Services

We may use trusted third-party service providers, including providers for:

• Cloud hosting

• Authentication

• Artificial intelligence processing

• Subscription and payment processing

• Email delivery

• Error monitoring

• Security

• Customer support

These providers are only given access to information necessary to perform services on our behalf and are expected to protect that information appropriately.

7. Browser Extension Processing

While using supported retailer websites, the TrueToned browser extension processes limited webpage information necessary to provide personalized recommendations and related features.

This processing occurs only while you actively use the extension on supported websites and is limited to the functionality requested by you.

TrueToned does not access retailer customer accounts, payment information, or unrelated browsing activity.

Retail Partners

TrueToned may display recommendations for products available from third-party retailers.

Purchases made through third-party retailers are governed by those retailers' own privacy policies and terms.

TrueToned is not responsible for the privacy practices of third-party retailers.

How We Share Information

We do not sell your personal information.

We may share information only when necessary:

• With service providers supporting our Services

• When required by law

• During a merger, acquisition, or sale of business assets

• To protect the rights, safety, or security of TrueToned, our users, or others

• With your explicit consent

Data Retention and Account Deletion

TrueToned retains personal information only as necessary to provide our Services, maintain account security, prevent misuse, and meet applicable legal obligations.

Account and Colour Profile Information

We retain your account details, questionnaire responses, seasonal colour results, and personalised palettes while your account remains active, or for as long as reasonably necessary for the purposes described in this Policy.

Photograph Storage and Retention

Photographs submitted for optional seasonal colour analysis are processed temporarily through TrueToned's servers and OpenAI.

TrueToned does not store submitted photographs in your active account profile or production database. On October 15, 2026, we completed a cleanup of previously stored selfie data from our active production database.

Historical photographs may still exist in restricted operational backups or rollback snapshots, and may be temporarily retained by third-party providers under their applicable security and retention policies.

OpenAI's standard API abuse-monitoring practices may involve retaining submitted information for up to 30 days, or longer in certain legal or safety circumstances.

Account Deletion

You may request deletion of your TrueToned account through available account-deletion features or by contacting hello@truetoned.ca.

When an account is deleted, TrueToned removes the associated user record, saved colour profile, colour analysis, and refresh authentication tokens from its active application database.

Certain limited information may remain where necessary or permitted, including:

• Records of previously claimed free trials to prevent repeated trial abuse.

• Subscription transaction and entitlement records needed for billing integrity.

• Information retained by Stripe, Apple, RevenueCat, or other providers under their respective policies.

• Information contained in restricted backups until those backups are deleted or expire.

• Records required for legal compliance, security, or dispute resolution.

Deleting your TrueToned account does not automatically delete information held independently by payment providers or immediately remove information from OpenAI's security logs.

Your Privacy Choices

You can choose questionnaire-only colour analysis without submitting photographs.

You may also contact hello@truetoned.ca to request access to, correction of, or deletion of personal information, subject to applicable legal requirements and permitted retention exceptions.

We may need to verify your identity before processing certain privacy requests.

Data Security and international processing

How We Protect Your Information

TrueToned uses reasonable technical and organisational safeguards designed to protect personal information against unauthorised access, disclosure, alteration, and loss.

These safeguards include:

• HTTPS encryption for information transmitted between your device and our servers.

• Secure password hashing and account authentication.

• Access controls for application infrastructure and stored information.

• Measures that prevent submitted photographs from being saved to active account profiles and analysis records.

• Restricted access to operational backups and sensitive administrative information.

Although we take reasonable precautions, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security.

International Data Processing

TrueToned operates from Canada, but some of our service providers maintain infrastructure or process information in other countries, including the United States.

Personal information may be processed by providers such as Railway, OpenAI, Stripe, Apple, RevenueCat, and our email delivery providers.

Information processed outside Canada may be subject to the laws of the country where it is processed, including lawful access requests by public authorities.

We use service providers and technical safeguards appropriate to the nature of the information being processed.

Your Account Security

You are responsible for maintaining the confidentiality of your account credentials and protecting access to your devices.

If you believe your account has been accessed without authorisation, please contact hello@truetoned.ca.

Children's Privacy

TrueToned's Services are not intended for children under the age of 13, or under a higher minimum age where required by applicable law.

We do not knowingly collect personal information from children who are below the applicable minimum age. If we become aware that such information has been collected, we will take appropriate steps to delete it, subject to legal requirements.

Parents or guardians with concerns may contact hello@truetoned.ca.

Your Privacy Rights

Depending on your location and applicable privacy laws, you may have the right to:

• Request access to personal information we hold about you.

• Request corrections to inaccurate or incomplete information.

• Request deletion of your personal information.

• Withdraw consent for optional photograph processing.

• Request information about how your personal information is used, stored, or shared.

• Raise concerns or complaints regarding our privacy practices.

You may exercise applicable privacy rights by contacting hello@truetoned.ca.

We may request reasonable information to verify your identity before responding. Certain requests may be subject to lawful exceptions, including requirements relating to billing, fraud prevention, security, or record retention.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our Services, privacy practices, or applicable legal requirements.

When we make changes, we will update the "Last Updated" date. Where required by law, we will provide additional notice of material changes.

Contact Us

For questions, concerns, or requests relating to this Privacy Policy, please contact:

TrueToned
Email: hello@truetoned.ca
Website: https://www.truetoned.co