Privacy Policy

This policy explains what the Nuanza app and this website do with personal data. Nuanza is published by Claes Consultants BV, Belgium ("we", "us").

At a glance

The short version

• There is no account. We do not ask for your name, email address or phone number.
• For a color scan, one photo of your face is sent to our server and from there to Google Cloud, where it is analyzed automatically. This happens only after you have agreed in the app. The photo is not kept afterwards: not on our server and not on your phone. Our server does not store the result either.
• Your scans and your favorites are stored on your phone. A scan holds your season, your readings and your colors, not your photo.
• Our server keeps one anonymous technical record per app installation: a device key, scan counters, an anonymous purchase ID and whether Nuanza Complete is unlocked. It is deleted when you choose "Delete everything" in the app, and automatically when it has not been used for 12 months.
• Nuanza Complete is a one-time purchase handled by Apple or Google. RevenueCat validates the purchase for us under a random anonymous ID. We do not receive your name, your email address or your payment details.
• The app records usage data: which screens are opened and which buttons are used, without any photo or result and without an identifier stored on your phone. It goes to our own server and helps us improve the app. You can turn it off in the app: open You, go to Privacy and turn off "Share usage data".
• The app shows no advertising and does not track you across apps or websites. This website sets no cookies.

1. Who is responsible for your data

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Claes Consultants BV
Boskant 32
3945 Tessenderlo-Ham
Belgium
Company and VAT number: BE 0685.540.174
hello@easystreet.be

2. What we process and why

The photo for a color scan

What: one photo of your face. The app crops it around your face and reduces its size on your phone before sending it. Why: to read your coloring (undertone, depth, clarity, contrast and the colors of your skin, eyes, hair and lips) and place you in one of 12 color seasons. Where: sent over an encrypted connection to our server in the European Union (Ireland), held in memory while the request is handled, and passed to Google Cloud, where it is analyzed automatically. Our server does not write the photo to a database, a file or a log. We send the photo to Google solely to produce your result. The app does not save the photo on your phone and does not show it in your result or your scan history.

The language of the app

Why: so that the description of your coloring comes back in your language. Where: sent with the photo and included in the technical log line of the request.

The scan result

What: your season, the four readings, the colors read from your skin, eyes, hair and lips with a short name, a one or two sentence summary, and notes on the quality of the photo (lighting, makeup detected). Where: returned to the app and stored on your phone. Our server does not store it.

Favorites and app settings

What: the palettes you saved, the date on which you gave your consent, and whether you have seen the introduction and the scanning tips. Where: stored in the app's storage on your phone. On Android, backups are switched off for the app. On iPhone, your results and favorites are not included in your phone's own iCloud or computer backup. Earlier versions of the app saved a small copy of the scan photo on your phone. This version deletes those copies when it starts. On iPhone, a copy that an earlier version had already placed in your phone's own iCloud or computer backup stays in that backup until the backup is next overwritten or you delete it.

The camera and face detection on your phone

What: while the camera screen is open, the app detects where your face is in the picture, to guide you and to crop the photo. This is done by Google's on-device face detection library (ML Kit), which may send Google technical usage and diagnostic data but no images. The camera images are not stored; only the one photo you take for the scan is sent to our server.

The device record

What: one record per app installation with the platform (iOS or Android), a device key identifier (on iOS created by Apple's App Attest, on Android a random identifier created by the app), on iOS the public key and the attestation receipt, a request counter, the total number of scans, the number of scans today with its date, the number of free results and free attempts used, the anonymous purchase ID described under "Purchases", whether Nuanza Complete is unlocked, and the dates of registration and of the last verification. It contains no name, no photo and no result. Why: to check that a request comes from the genuine app on a genuine phone, to apply the limit on free results and the daily scan limit, and to check on the server whether Nuanza Complete is unlocked. Where: in our database at Supabase in the European Union (Ireland).

Purchases (Nuanza Complete)

What: Nuanza Complete is a one-time purchase that you make through the Apple App Store or Google Play. Apple or Google takes the payment; we do not receive your name, your email address or your payment details. The app contains software from RevenueCat, which validates the purchase with Apple or Google for us. RevenueCat gives each app installation a random anonymous ID and receives the purchase information (the product, the transaction identifiers, the store, the country, the price and currency, and the purchase dates) and technical data (the type of device, the version of the operating system and of the app, and the time the app last contacted RevenueCat). RevenueCat uses your IP address to derive a country when the transaction does not contain one, and states that it does not store the IP address. The app sends the anonymous ID to our server with each scan request, and our server stores it in the device record together with the unlock status. Why: to deliver what you bought, to restore the purchase after a reinstall or on a new phone, and to see how many purchases were made. Where: at RevenueCat in the United States (section 6) and in our database in the European Union (Ireland).

Usage data

What: the app records which screens you open and which buttons you use. Examples: the app was opened, a step of the introduction was shown, you agreed on the consent screen, camera access was granted or refused, a scan was started, a result, a palette or a tab was opened, a favorite was saved, a locked part was pressed, the Nuanza Complete screen was shown or closed, a purchase was started, completed (with its price and currency), canceled or restored, scans or all data were deleted. For a scan the app also records how long the analysis took, how reliable the reading was (low, medium or high), the lighting rating, the number of issues found in the photo or the reason the scan failed. Some events carry a count or a yes or no value, such as the number of favorites, whether a scan exists and whether Nuanza Complete is unlocked. Each event carries its time, the app version, the platform (iOS or Android), the language and the country set on your phone, whether the app is a test version, and a session ID. The session ID is a random value that the app creates in memory each time it starts. It is not saved on your phone and is replaced the next time the app starts, so events from different sessions cannot be connected with each other or with your phone. Within one session it does group the events together. It is not the device key, not the purchase ID and not an advertising identifier. The app saves no usage events on your phone; it only saves whether "Share usage data" is on or off. The events contain no photo, no color, no season, no reading of your coloring, no summary text, no name, no email address and nothing you type. We do not store your IP address with the events. Why: to see how the app is used and where it fails, so that we can improve it. We do not use this data for advertising and do not combine it with data from other apps or websites. Where: sent to our own server and stored in our database at Supabase in the European Union (Ireland). We read it in our own dashboard and use no third-party analytics service. Your choice: "Share usage data" is on by default. You can turn it off at any time in the app: open You and go to Privacy. From then on nothing is recorded or sent.

Integrity checks

What: with each scan the app sends a proof of integrity: on iOS a signature made with the App Attest key, on Android a Play Integrity token, which our server has verified by Google. Why: to protect the service against automated and abusive use.

Technical logs

What: for each request our server logs the status, how long each step took, the language, the size of the photo and technical identifiers of the request. The logs never contain the photo, the result or the device key, and error messages are cleaned of such content before they are logged. Supabase, which hosts our server, also processes your IP address and the time of the request in its own infrastructure logs.

Email

If you write to us, we process your email address and the content of your message to answer you.

This website

This website sets no cookies, has no analytics and loads no content from other domains. Vercel, which hosts it, processes your IP address and the requested page in its server logs to deliver and protect the site.

3. What we do not do

• We do not ask for or collect your name, email address, phone number or advertising identifier, and the app does not use your phone's location. The usage data contains the country set on your phone.
• The app shows no advertising and does not track you across apps or websites. The usage data described in section 2 stays on our own server; we use no third-party analytics service.
• We do not sell your data and do not share it for advertising.
• We do not use your photo for anything other than producing your result.
• We do not identify you from your photo and do not compare your face with other faces.

4. Photos of your face and biometric data

A photo of your face is personal data and we treat it with care. Nuanza uses it only to describe colors. It does not create a face template, does not recognize or verify who you are and does not match your face against any database. The face detection on your phone only locates the face in the picture.

Because the photo is not processed to uniquely identify a person, we do not consider this to be processing of biometric data as a special category under Article 9 GDPR. The result describes the color of skin, eyes, hair and lips. It contains no statement about ethnic origin, health or age. We nevertheless ask for your explicit consent before any photo is sent (section 5).

The analysis is automated. It produces a makeup color suggestion and has no legal or similarly significant effect on you (Article 22 GDPR).

5. Legal basis and your consent

• Your consent (Article 6(1)(a) GDPR): processing your photo, the app language and the result to carry out a color scan. Before the first photo is sent, the app shows a consent screen that explains where the photo goes. No photo is sent without your agreement.
• Performance of a contract (Article 6(1)(b) GDPR): processing the purchase information, the anonymous purchase ID and the unlock status, to deliver Nuanza Complete after you buy it and to restore it later. Counting purchases and revenue rests on our legitimate interest in knowing how the app performs commercially (Article 6(1)(f) GDPR).
• Legitimate interests (Article 6(1)(f) GDPR): the device record, the integrity checks, the limit on free results, the daily scan limit and the technical logs. Our interest is to protect the service against abuse and automated use, to keep its costs under control and to keep it working. The same basis applies to the server logs of this website and to answering your emails.
• Legitimate interests (Article 6(1)(f) GDPR), usage data: the usage data. Our interest is to understand how the app is used so that we can improve it. The events contain no name, no photo and no result, stay on our own server and are not used for advertising. You can object at any time by turning off "Share usage data" in the app (You, then Privacy).

Withdrawing consent. You can withdraw your consent at any time in the app: open You, go to Privacy and choose "Withdraw consent". "Delete everything" also withdraws it. After that, no photo is sent until you agree again. Withdrawal does not affect scans made before it, and the results on your phone stay until you delete them.

The camera only works after you have given permission on your phone. You can withdraw that permission in the settings of your phone at any time.

6. Who receives your data, and where

We use the following service providers. They process data on our behalf under their data processing terms.

• Supabase (Supabase, Inc., United States): runs our server functions and our database, which also holds the usage data. The database is located in the European Union (Ireland), and the app asks for the server function to run in that same region.
• Google Cloud (Google Cloud EMEA Limited, Ireland, and Google LLC, United States): analyzes the photo automatically, as our processor under Google's data processing terms. The analysis service we use is not offered to us in a location limited to the European Union, so Google can process the photo in a data center outside the European Economic Area (EEA), including in the United States. We send the photo solely to produce your result. Google may keep request data briefly in memory for the technical operation of the service.
• RevenueCat (RevenueCat, Inc., United States): validates purchases of Nuanza Complete with Apple and Google and keeps the purchase status, as our processor under RevenueCat's data processing addendum. RevenueCat processes the data described under "Purchases" in section 2 in the United States.
• Google Play Integrity (Android) and Apple App Attest (iOS): confirm that the app and the phone are genuine. Apple and Google provide these services as part of your phone's operating system, under their own privacy policies.
• Google's on-device face detection library (ML Kit): the face detection described in section 2.
• Vercel (Vercel Inc., United States): hosts this website.

Transfers outside the EEA. Where these providers process personal data in the United States or another country outside the EEA, the transfer is covered by the European Commission's Standard Contractual Clauses in the provider's data processing terms and, where applicable, by the adequacy decision for the EU-U.S. Data Privacy Framework. You can ask us for more information about these safeguards.

Apple and Google distribute the app through their stores and handle the payment for Nuanza Complete. They are responsible, under their own privacy policies, for the data they process when you download the app or buy something in it, including your account and payment details. We do not pass your data to anyone else, unless the law obliges us to.

7. How long data is kept

• Photo: on our server only for the duration of the request, which is normally a few seconds. It is not stored there, and the app does not keep it on your phone. For Google, see section 6.
• Scans and favorites: on your phone until you delete them or uninstall the app.
• Device record: until you choose "Delete everything" in the app. A record that has not been used for 12 months is deleted automatically.
• Purchase data: the anonymous purchase ID and the unlock status in our device record are kept as long as that record. RevenueCat keeps the purchase record for as long as we use RevenueCat for the app, so that the purchase can be validated and restored; we delete it earlier if you ask us to (section 9). Apple and Google keep their own data about your purchase under their terms.
• Technical logs: for the limited period that Supabase and Vercel retain logs.
• Usage data: the individual events are deleted after 24 months. Totals without the session ID may be kept longer.
• Emails: for as long as needed to handle your question, and no longer than 24 months after the last message.

8. How to delete your data

• In the app, open You and scroll to Data. "Delete all scans" removes your scans from the phone.
• "Delete everything" removes your scans and your favorites from the phone, deletes the device record on our server and withdraws your consent. If the phone is offline at that moment, the app tries once more to delete the server record the next time it starts.
• "Delete everything" does not change the usage data. The app stores no identifier for it on your phone, so there is nothing to remove, and events recorded earlier could never be connected to your phone. To stop the usage data, turn off "Share usage data" under Privacy in the You tab.
• "Delete everything" does not cancel or refund a purchase. Your purchase of Nuanza Complete stays registered with your Apple or Google account, and you can restore it in the app. The purchase record at RevenueCat is not deleted by "Delete everything"; write to us if you want it deleted.
• You can also delete a single scan from your scan history.
• Uninstalling the app removes everything it stored on your phone. The device record on our server is then deleted automatically after 12 months without use.
• On iPhone, a small copy of a scan photo that an earlier version of the app placed in a backup of your phone stays there until that backup is next overwritten or deleted. You manage that backup yourself.

9. Your rights

Under the GDPR you have the right to:

• obtain access to the personal data we hold about you and receive a copy;
• have inaccurate data corrected;
• have your data erased;
• have the processing restricted;
• receive the data you provided in a structured, machine-readable format (portability);
• object to processing that is based on our legitimate interests;
• withdraw your consent at any time (section 5).

To exercise a right, write to hello@easystreet.be. It is free of charge and we answer within one month. Most of your data is on your own phone, where you can view and delete it yourself. The device record on our server is not linked to your name or email address; you delete it yourself with "Delete everything". To find purchase data at RevenueCat we need the order number on your receipt from Apple or Google, because we cannot look you up by name. The usage data contains no identifier that is stored on your phone or linked to you, so we cannot find the events of one person or one phone, and cannot provide or delete them on request. You stop it yourself by turning off "Share usage data".

You also have the right to lodge a complaint with a supervisory authority. In Belgium this is the Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données), Rue de la Presse 35, 1000 Brussels, contact@apd-gba.be, www.dataprotectionauthority.be. You can also turn to the authority of the country where you live.

10. Children

Nuanza is not directed at children under the age of 16, and we do not knowingly process personal data of children under 16. If you believe a child has used the app, contact us.

11. Security

All data is sent over encrypted connections. The database can only be reached by our own server functions. The server accepts scan requests only from app installations that pass the integrity check. Photos and results are not stored on the server.

12. Changes to this policy

When the app or the way we process data changes, we update this page and its effective date. Earlier versions are available on request.

13. Contact

Questions about this policy or about your data: hello@easystreet.be.