- Contact us about the Services
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@color-wallet.com.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process sensitive personal information? Photos and answers you choose to provide may reveal characteristics protected under applicable law. We use them for the app features described below.
Do we receive information from third parties? Yes. Apple and Google send us mobile purchase and subscription status. Our email provider sends delivery-status events. A separate Stripe web checkout is not currently offered. Historical test checkout activity may have involved Stripe.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? Email us at info@color-wallet.com. We will review requests under applicable law. See Section 14 for account deletion requests.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
Information you provide. When you register, we receive your email address, password and any name you provide. The service stores a protected password hash. We assign an account ID. Your questionnaire answers, color and fashion profile choices, palette, saved colors and combinations, and camera analysis results are associated with that account.
Photos and camera use. If you choose to add a profile photo or use the Color Camera, the selected image is sent to our service. Profile images, thumbnails and camera images can be stored in our cloud storage with your account or analysis records. A camera image can be uploaded during analysis even if you do not save the result. You can decline camera or photo-library access, but the related feature will be unavailable.
Photos and answers you choose to provide may reveal characteristics protected under applicable law. We use them for the requested app features.
App and purchase records. We use an app installation identifier and account-linked session records to manage access. For mobile subscriptions, Apple App Store and Google Play provide transaction or purchase identifiers, product and subscription status, and related purchase history. When an Android purchase starts, we send a hashed account identifier to Google Play Billing to link the purchase to the correct account. We use purchase records to grant, restore and support Premium access. The mobile app does not give us your card number or card security code.
Other service communications. We use an email delivery provider for account and service messages and receive delivery-status events. Tapping expert contact in the Color Wallet mobile app opens your device's email app. If you choose to send a message, the recipient receives the address, message and attachments you send.
Historical test checkout. A separate Stripe web checkout is not currently offered for Color Wallet. Historical test activity may have created customer or checkout identifiers held by Stripe. This activity is separate from mobile subscriptions. See Stripe's privacy notice for its own processing.
The Color Wallet mobile app does not use personal information for cross-app tracking, targeted advertising or advertising analytics.
2. HOW DO WE PROCESS YOUR INFORMATION?
We use account and email information for registration, authentication, recovery and service communication. We use your choices, saved colors, photos and color results to provide and personalize the palette and camera features.
We use store purchase and subscription information to activate Premium, restore purchases, prevent entitlement misuse and provide purchase support. We use account and app activity needed to operate, protect and troubleshoot these features. We do not use account email from the Color Wallet mobile app for advertising analytics or targeted advertising.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
Where applicable law requires a legal basis, we process account, profile, photo and purchase information to provide the Color Wallet features you request and perform our agreement with you. We may rely on consent where required for an optional use. We may rely on legitimate interests to secure and troubleshoot the service and answer support requests, subject to your rights. We process information to meet a legal obligation when one applies.
You can ask us about the basis for a particular use, or withdraw consent where consent is the basis, by emailing info@color-wallet.com. Withdrawing consent does not undo earlier lawful processing or affect a different lawful basis that applies.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Our hosting and cloud storage providers process account records and uploaded images on our behalf. Our email delivery provider processes account and service messages and delivery events. Apple and Google process mobile purchases and provide us transaction and subscription status. We send a hashed account identifier to Google Play Billing when an Android purchase starts. Stripe may hold records from historical test checkout activity, but a Stripe checkout is not currently offered. If you choose to email an expert, the recipient receives what you send.
We may also share or transfer information in connection with a merger, sale of company assets, financing or acquisition of all or part of the business. We do not sell mobile-app personal information or use it for cross-app advertising in the Color Wallet mobile app.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
We keep account information while it is needed to provide Color Wallet. A deletion confirmation or receipt records a request. It does not mean the account or associated data has been erased. An immediate request can begin processing after confirmation. A seven-day option, including the one used by some earlier app versions, can be cancelled before processing begins. A date shown on a receipt is a processing date, not a guaranteed completion date.
Historical account review. Accounts that existed when we introduced the historical review hold are held for review of older records and uploads before deletion can finish. While this review remains open, a request can stay in processing, sign-in can be unavailable, and the account and its associated records and images remain. We do not mark these requests completed while the review hold applies. If a request is still pending after its processing date, email info@color-wallet.com with the request ID to ask about its status. We cannot promise a fixed completion date while historical review is outstanding.
Completed status. A completed status means the service removed the active account and the linked records and images it identified for that account. It does not establish that every older upload without a reliable ownership link was found, that records held by other companies were removed, or that backup copies expired. If you believe an older image is associated with your account, email us so its ownership can be reviewed.
Request and provider records. A limited deletion-request record remains after account erasure. It includes a request ID, status dates and a digest of any private tracking code. The current service does not automatically remove this record after a fixed period. A contact email for the completion notice is held temporarily and cleared when our email provider accepts the message or its sending window expires. If we give you a private tracking code, it works for up to 90 days. Historical Stripe test checkout records, if any, may remain with Stripe and need separate review. Apple and Google keep their own store records. We may retain payment records where the law requires.
Backups. Database backups follow our existing rotation schedule. A copy made before erasure can contain earlier account data until that copy expires through rotation. Backups are used for recovery, not ordinary app features. Contact us for information about the current rotation schedule.
Subscriptions. Deleting a Color Wallet account does not cancel an App Store or Google Play subscription. Cancel it with Apple or Google to stop future renewals. You may request account deletion before cancelling a subscription.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
The Color Wallet mobile app does not ask for a date of birth. If you are a parent or guardian and believe a child has provided personal information without consent required by applicable law, contact us at info@color-wallet.com. We will review the request and handle the information as required by applicable law.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Promotional communications. If we offer optional promotional messages in the future, you can contact us to object or use an unsubscribe link in the message. Service messages needed to manage an account may continue.
Account Information
You can contact us to review or change your account information or request deletion. The process and limits of erasure are described in Section 5.
- Contact us using the contact information provided.
Account deletion follows Section 5. A recorded request can remain pending during historical review, with the account and associated data still present. A completed status covers the active account and linked records identified by the service, subject to the limits on older uploads, request records, external providers and backups. Store subscriptions must be cancelled separately with Apple or Google.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
We do not use Color Wallet mobile-app data for cross-app tracking or cross-context behavioral advertising. Our website does not currently respond to browser Do Not Track signals. You can send a privacy request using the contact details in Section 13.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.Categories of Personal Information We Collect
The table below identifies categories of personal information we have collected in the past twelve months. The examples describe the Color Wallet information in each category. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"
| Category | Examples | Collected |
|---|
A. Identifiers | Account name, email address, account ID and app installation identifier |
YES
|
B. Personal information as defined in the California Customer Records statute | Name and email address used for your account and service communications |
YES
|
C. Protected classification characteristics under state or federal law | Characteristics that may be visible in photos you choose to upload |
YES
|
D. Commercial information | App Store and Google Play purchase and subscription status, and historical Stripe test checkout records if any |
YES
|
E. Biometric information | Fingerprints and voiceprints |
NO
|
F. Internet or other similar network activity | Use of Color Wallet features, including onboarding, saved selections and camera analysis records |
YES
|
G. Geolocation data | Device location |
NO
|
H. Audio, electronic, sensory, or similar information | Profile and camera images you choose to upload through the app |
YES
|
I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us |
NO
|
J. Education Information | Student records and directory information |
NO
|
K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics |
YES
|
| L. Sensitive personal Information | Photos or answers you choose to provide may reveal characteristics treated as sensitive under applicable law |
YES
|
We may also receive information when you contact support or ask about your account, purchases or deletion request.
For categories A, B, C, D, F, H, K and L, see Section 5 for account use, deletion status, historical records that may remain, payment records and backup rotation.
Will your information be shared with anyone else?
We share information with service providers and transaction partners for the purposes described in Section 4. We do not sell Color Wallet mobile-app personal information or share it for cross-context behavioral advertising.
We use personal information for the app and support purposes described in Sections 1 and 2. This does not include mobile-app advertising analytics.
We disclose information to the service providers and transaction partners described in Section 4. We do not sell personal information or share Color Wallet mobile-app data for cross-context behavioral advertising.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
- Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
- Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
- Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
- Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)
How to Exercise Your Rights
To exercise an applicable privacy right, email info@color-wallet.com. We may need to verify your identity before acting on a request.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@color-wallet.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
If you live in Australia or New Zealand, you can use the contact details below to ask about access, correction or another applicable privacy right.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
- offer you the products or services that you want
- respond to or help with your requests
- manage your account with us
- confirm your identity and protect your account
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
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United States
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Email info@color-wallet.com to ask to review, correct or delete personal information. We may verify that you own the account before acting. If you can sign in to the mobile app, use Delete Account in My Profile to request account deletion. If you cannot access the app or your account email, contact us at the same address to ask for help with ownership verification. Section 5 explains pending review, completed status and data that may remain.