Biometric Privacy Notice

This notice explains, on its own and in plain terms, how Stiled handles a photo of your face for color analysis and the color information we get from it. It is part of our Privacy Policy. It is written to meet the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act, Washington's biometric identifier law, and similar laws.

1. The short version

• We analyze the colors in your photo to recommend colors. That is all.
• It does not identify you. We do not create face geometry or faceprints, compare your face to other faces, or run facial recognition. We hold no database of faces.
• It is not used to infer sensitive traits such as race, ethnicity or health.
• It is optional and runs only after you agree to it specifically.
• We never sell, lease, trade or profit from your face photo or the color information we get from it.
• You can withdraw consent and have it deleted at any time.

2. What we collect and why

If you choose color analysis, you send us a photo of your face. On our own servers, software reads the color of the skin in that photo and works out:

• a skin tone color value (a hex code) and skin depth;
• your undertone (for example warm, cool or neutral);
• a position on two standard skin tone color scales, the Monk Skin Tone Scale and the Fitzpatrick scale; and
• a color season (for example "warm autumn") and a color palette.

These are color measurements. They cannot be used to recognize you or tell you apart from other people with similar coloring, and we do not use a third-party biometric service to make them. Some laws treat any information taken from a face photo as sensitive, so we give it the protections in this notice everywhere, whether or not a particular law requires them.

Other photos. Body photos you send for try-ons are not used for color analysis, and we do not take face geometry, measurements or any identifier from them.

3. Consent

We ask before we analyze, never after.

• By text or iMessage: before we download or analyze a face photo, we send you a message explaining what we will do. We analyze the photo only if you reply YES. Any other reply means we do not use it.
• On our website: we analyze a face photo only after you tick a separate consent box, and our servers check that your consent is recorded before any analysis runs. The box is not pre-ticked and it is not part of agreeing to our Terms.

We keep a record that you consented. The rest of Stiled works without color analysis.

4. How we use it

We use your color information only to:

• tell you your color season and palette;
• recommend colors and products that suit you; and
• help try-on previews show your coloring accurately.

We never use it to identify you, verify who you are, infer sensitive traits, or for security, surveillance or advertising. We do not use it to train AI models.

5. Who receives it

We do not sell, lease, trade or otherwise profit from it. We disclose it only to service providers that help us provide color analysis, under contracts that limit their use to that purpose:

We do not send your Fitzpatrick scale position to anyone. We also disclose this information if the law requires it, for example in response to a valid subpoena, and only to the extent required.

6. How long we keep it, and when we destroy it

We keep your face photo and color information only until the first of these happens:

1. You withdraw consent. We delete the face photo and color information from our systems within 30 days.
2. You delete your data. We delete it from our systems within 30 days.
3. 24 months pass without you using Stiled. We then delete the face photo and color information.

Copies in our database backups roll over within 7 days, and copies held by the providers above expire on their own schedules.

"Delete" means removed from our systems, not just unlinked from your profile.

If you changed phone numbers. A photo you texted us from an earlier number may be stored under that number. Tell us at privacy@stiled.app and we will find and delete it.

7. Security

We keep face photos in private storage that is not publicly accessible, encrypted in transit and at rest, with access limited to the systems that provide color analysis and to staff who need it. We protect this information with at least the same care we use for our other most sensitive information, and to the standard of care reasonable in our industry.

8. Your rights

• Decline: you never have to use color analysis.
• Withdraw consent or delete: email privacy@stiled.app. We stop analyzing new photos and delete the face photo and color information we hold within 30 days.
• See what we hold: make a request the same way. We respond within 30 days.

9. The same rules for everyone

This notice applies to every Stiled user, wherever you live. Illinois residents also have a private right of action under BIPA, and nothing in our Terms of Service limits it.

10. Contact

Stiled Labs Inc.
5227 North 7th Street, STE 65972
Phoenix, AZ 85014
privacy@stiled.app