Effective Date: [19/01/2026]
This Privacy Policy applies to users worldwide and is designed to comply with global privacy standards, including the UK GDPR, EU GDPR, and applicable U.S. privacy laws.
1. Information We Collect
1.1 Information You Provide
- Hair photos uploaded for colour matching
- Hair colour selections or preferences
- Information you provide when contacting support
We do not require account registration unless explicitly stated.
1.2 Automatically Collected Information
- Device type, operating system, and app version
- App usage data (screens viewed, interactions)
- Crash logs and performance data
- Aggregated and anonymised analytics
2. How We Use Your Information
We use personal data to:
- Perform hair colour analysis and matching
- Display suitable hair extension shade results
- Operate and improve the Services
- Monitor performance and prevent misuse
- Comply with legal obligations
3. Hair Photos and Image Processing
- Uploaded photos are used solely for hair colour analysis.
- Photos are not sold, not used for advertising, and not shared with merchants or advertisers.
- Photos are processed securely and retained only for as long as necessary to complete matching or until deleted by you.
You may delete uploaded photos at any time within the app.
4. Advertising and Sponsored Content
Some brands displayed in the app are paid partners.
- Sponsored placements are clearly labelled (e.g. “Sponsored”, “Ad”).
- Sponsorship affects visibility only, not matching accuracy.
- Advertisers and merchants do not receive:
- Hair photos
- Matching results
- Personal user data
5. Data Sharing
We may share limited data with:
- Cloud hosting providers
- Analytics and performance service providers
Such providers process data only on our instructions and are bound by confidentiality obligations.
We do not sell personal data.
6. Legal Bases for Processing (GDPR)
Where applicable, we process personal data based on:
- Consent (e.g. photo uploads)
- Legitimate interests (app functionality, analytics)
- Legal obligations
7. Data Retention
We retain personal data only for as long as necessary:
- Photos: until analysis is completed or deleted
- Analytics: retained in anonymised, aggregated form
8. Your Rights (Global)
Depending on your location, you may have the right to:
- Access your personal data
- Correct inaccurate data
- Request deletion of your data
- Withdraw consent at any time
- Object to or restrict processing
8.1 UK & EU Users (GDPR Rights)
You also have the right to:
- Data portability
- Lodge a complaint with your local data protection authority
(UK: Information Commissioner’s Office (ICO))
8.2 United States (California) Users
If you are a California resident, you have the right to:
- Know what personal data we collect
- Request deletion of personal data
- Opt out of the sale of personal data
We do not sell personal data.
9. Data Security
We implement appropriate technical and organisational safeguards to protect personal data against unauthorised access, loss, or misuse.
10. International Data Transfers
Your data may be processed outside your country of residence. Where required, we use appropriate safeguards to protect your information in accordance with applicable laws.
11. Children’s Privacy
The Services are not intended for users under the age of 16. We do not knowingly collect personal data from children.
12. How We Use Your Information
If you subscribe to paid features, we process subscription status and transaction identifiers provided by app store platforms. We do not receive or store full payment card details.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Continued use of the Services after updates constitutes acceptance of the revised policy.
14. Contact Us
For privacy questions or data requests, contact:
Email: support@haircolourmatch.com
Country: United Kingdom
This Privacy Policy explains how Qin Dynasty Ltd (“we”, “us”, or “our”) collects, uses, and protects personal data when users (“you”) use the [HTR Hair Colour Match] mobile application, website, and related services (collectively, the “Services”).
