Last updated: [DATE]
Version 1.0 — DRAFT, not yet reviewed by a solicitor
The rest of this policy is the detail behind those five points.
Glazed Ltd ("Umber", "we", "us") is the data controller for the personal data described in this policy.
If you are unhappy with how we handle your data you can complain to the Information Commissioner's Office at ico.org.uk — but we would rather you told us first.
| Data | Why | Legal basis |
|---|---|---|
| Email address | To create your account, sign you in, and send password resets | Performance of a contract |
| Password | Stored only as a cryptographic hash — we cannot read it | Performance of a contract |
| Display name (optional) | To personalise the app | Performance of a contract |
| Profile picture (optional) | Shown on your profile. Only if you choose to add one | Consent — you add it deliberately and can remove it |
| Sign-in provider identifiers | If you use Sign in with Apple or Google | Performance of a contract |
What we do not collect: the photograph of your face.
The analysis runs entirely on your device. The image is held in your phone's memory while it is processed and is then discarded. It is never uploaded to us, and there is no field anywhere in our systems capable of storing it.
What we do save, when you choose to save a result:
| Data | What it is |
|---|---|
| Season | e.g. "Deep Winter" |
| Confidence score and band | How certain the analysis was |
| Runner-up season | The next closest match |
| Axis values | Three numbers describing warmth, depth and clarity |
| Measured region colours | Numeric colour values (CIELAB) derived from your skin, hair and eyes |
| White balance method | Which correction the analysis applied |
| Date of the analysis |
Legal basis: performance of a contract — this is the service you signed up for.
Please read section 3 regarding the measured region colours. They are numbers, not images, but they warrant their own explanation.
| Data | Why |
|---|---|
| Photographs of clothing and accessories | So you can recognise your items. Uploaded to our storage |
| Item name, category, colour | To score items against your palette |
| Match scores | Calculated results |
Legal basis: performance of a contract.
Wardrobe photographs are stored in a private bucket. Each user's files sit in their own folder, and our database rules prevent any account reading another account's folder. Images are served through short-lived links that expire after one hour.
If you photograph a garment you are wearing, your face may appear in that image. That image is uploaded. If you would rather it were not, photograph the item flat.
| Data | Why | Legal basis |
|---|---|---|
| Which products you tap through to retailers, the retailer, your season, and the match score | To understand which recommendations are useful, and to improve matching. This is also the basis of the aggregate statistics described in section 5 | Legitimate interests — improving and funding a service you use, in a way we consider you would reasonably expect |
| Premium purchase status and history | To give you what you paid for and to handle refunds | Performance of a contract; legal obligation for records |
| Basic technical data (app version, device model, operating system, crash reports) | To fix faults | Legitimate interests |
If you use Dress together to find colours you and someone else can both wear, we store
only their first name and their colour season.
| Data | Why |
|---|---|
| Name | So you can tell them apart in the app |
| Season | The only thing needed to work out shared colours |
We deliberately store nothing else about them — no photograph, no email, no account, no
contact details. Someone you add has not agreed to anything with us, so the least we can hold
about them is the right amount. You can delete them at any time, and doing so removes the
record entirely.
Legal basis: legitimate interests — a first name and a colour category, held at your
request, to provide a feature you asked for.
Your handle, display name, biography, social media usernames, self-reported audience size, and your season. Legal basis: performance of a contract. Once approved, your creator profile is visible to other users — that is the point of it.
The analysis produces numeric measurements of your skin, hair and eye colour. These are numbers, not images, and they cannot be turned back into a photograph of you.
We want to be straightforward about something: it is arguable that measurements of skin colour could be said to reveal information about racial or ethnic origin, which is a special category of personal data under UK data protection law and attracts stronger protection.
Our position is that these measurements exist solely to place you into one of twelve colour seasons, are not used to identify you as an individual, and are not used to infer your ethnicity, nor shared for any such purpose. But we would rather state the question openly than pretend it does not exist.
Because of this, we ask for your explicit consent before saving these measurements, and you can withdraw that consent at any time by deleting your analysis or your account. Withdrawing consent does not affect anything done beforehand.
We do not use these measurements, or any inference from them, to make automated decisions that produce legal or similarly significant effects about you.
We do not sell your personal data. We never have and we do not intend to. (Section 5 covers anonymous statistics, which are a different thing entirely.)
We use the following service providers, who process data on our instructions:
| Provider | What they handle | Where |
|---|---|---|
| Supabase | Database, accounts, wardrobe image storage | [CONFIRM YOUR PROJECT REGION] |
| Apple | Payment processing for the premium unlock. Apple is the merchant of record and we never see your card details | Ireland / USA |
| RevenueCat | Verifies your purchase receipt so we know what you are entitled to | USA |
| [ANALYTICS PROVIDER, IF ANY] | Crash reporting and usage statistics | [REGION] |
| Affiliate networks (e.g. Sovrn, Awin) | When you tap through to a retailer, the network records the referral so we can be paid commission | UK / EU / USA |
When you tap a product link you leave Umber and enter the retailer's own website, which is governed by their privacy policy, not ours.
Where data is transferred outside the UK, we rely on the UK International Data Transfer Addendum or an adequacy decision.
We may also disclose data where we are legally required to, or to establish or defend legal claims.
This section explains something we may do commercially, and we would rather you read it than find out later.
What we may do. We may create statistics from patterns across all our users, and publish, share or license those statistics to third parties — for example fashion retailers, beauty brands, research firms and trend forecasters. Examples of the kind of statistic we mean:
What that data is not. It never contains your name, email, account identifier, or any photograph. It is not pseudonymised or coded data that could be matched back to you — it is genuinely aggregate.
How we protect this. We commit to the following, and these are not merely internal policy:
1. We only ever report groups, never individuals.
2. We never publish or license a figure derived from fewer than 50 people, so no group is small enough to single anyone out.
3. We never include any photograph in any dataset that leaves our systems. Selfies are not stored at all, and wardrobe images are never shared.
4. Once aggregated, the statistics cannot be reversed to identify any individual. At that point the information is no longer personal data.
Your rights here. Because these statistics are anonymous, data protection law no longer applies to them once created — which is precisely why we set the safeguards above ourselves. You can opt out of your data contributing to them at any time in Profile → Your data → Aggregate statistics, and we will exclude you going forward.
Legal basis for the underlying processing: legitimate interests — specifically, funding and improving a service in a manner that cannot identify or affect any individual user. You may object to this at any time.
| Data | Retention |
|---|---|
| Account and analyses | Until you delete your account |
| Wardrobe items and photographs | Until you delete them, or your account |
| Click history | 24 months, then deleted |
| Purchase records | 7 years — required by UK tax law |
| Anonymous aggregate statistics | Indefinitely, as they are no longer personal data |
| Backups | Deleted data disappears from backups within 30 days |
Under UK GDPR you have the right to:
You can do the first four yourself, immediately, in the app: Profile → Your data → Export everything, or Delete my account data.
For anything else, email hello@getglazed.app. We will respond within one month.
Passwords are hashed and we cannot read them. Data is encrypted in transit and at rest. Access rules are enforced by the database itself rather than by application code, so a bug in the app cannot expose another user's data. Wardrobe images sit in private storage behind expiring links.
No system is perfectly secure. If a breach occurs that is likely to result in a risk to your rights, we will tell you and the ICO without undue delay.
Umber is not intended for anyone under 16. We do not knowingly collect data from children. If you believe a child has created an account, contact us and we will delete it.
If we make a material change — particularly to section 5 — we will notify you in the app before it takes effect. We will not retrospectively apply a new use to data collected under an older policy.
Glazed Ltd, 282 Leigh Road, Leigh-on-Sea, England, SS9 1BW